Report on Comments — Copyright, NFPA NFPA 101 · Oystein (Sam) F. Husoe, National Fire Sprinkler Association, CA [M] (Alt. to Kenneth E. Isman) Cindy Mahan, Friendship Community

101-1

Report on Comments — Copyright, NFPA NFPA 101 Report of the Committee on

Safety to Life (SAF-AAC)

Technical Correlating Committee

James R. Quiter, ChairArup, CA [SE]

Ron Coté, Nonvoting SecretaryNational Fire Protection Association, MA

James B. Brown, Honeywell, Incorporated, IL [M] Rep. National Electrical Manufacturers Association Richard W. Bukowski, US National Institute of Standards & Technology, MD [RT] Rep. Signaling Systems Correlating Committee Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Lee J. Dosedlo, Underwriters Laboratories Incorporated, IL [RT] Jackie T. Gibbs, Marietta Fire Department, GA [U] Rep. International Association of Fire Chiefs Kenneth E. Isman, National Fire Sprinkler Association, NY [M] J. Edmund Kalie, Jr., Prince George’s County Government, MD [E]William E. Koffel, Koffel Associates, Incorporated, MD [SE]Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association Kirby W. Perry, Kirby W. Perry Architects & Associates Incorporated, TX [SE] Rep. American Institute of Architects Lawrence G. Perry, Building Owners & Managers Association International, MD [U]

Alternates

Robert E. Burke, Muse & Associates, DC [C] (Alt. to Jake Pauls)Kevin J. Kelly, National Fire Sprinkler Association, NY [M] (Alt. to Kenneth E. Isman)Martin H. Reiss, The RJA Group, Incorporated, MA [SE] (Alt. to James R. Quiter)Todd C. Shearer, Wheelock, Incorporated, NJ [M] (Alt. to James B. Brown)Michael S. Shulman, Underwriters Laboratories Incorporated, CA [RT] (Alt. to Lee J. Dosedlo)Michael D. Tomy, Heery International Incorporated, GA [SE] (Alt. to Kirby W. Perry)

Nonvoting

John L. Bryan, Frederick, MD [SE] (Member Emeritus)David A. de Vries, Firetech Engineering Incorporated, IL [SE] Rep. TC on Means of Egress William E. Fitch, Omega Point Laboratories Incorporated, TX [RT] Rep. TC on Furnishings & Contents Ralph Gerdes, Ralph Gerdes Consultants, LLC, IN [SE] Rep. TC on Assembly Occupancies & Membrane Structures Wayne D. Holmes, HSB Professional Loss Control, CT [I] Rep. TC on Industrial, Storage, & Miscellaneous Occupancies Morgan J. Hurley, Society of Fire Protection Engineers, MD [U] Rep. TC on Fundamentals Thomas W. Jaeger, Gage-Babcock & Associates, Incorporated, VA [SE] Rep. TC on Detention & Correctional Occupancies Philip R. Jose, Guilderland, NY [SE] Rep. TC on Board & Care Facilities Richard L. Klinker, Klinker & Associates, Incorporated, MD [SE] Rep. TC on Building Service & Fire Protection Equipment James K. Lathrop, Koffel Associates, Incorporated, CT [SE] Rep. TC on Residential Occupancies Harold E. Nelson, Hughes Associates, Incorporated, VA [SE] (Member Emeritus)Daniel J. O’Connor, Schirmer Engineering Corporation, IL [I] Rep. TC on Health Care Occupancies Eric R. Rosenbaum, Hughes Associates, Incorporated, MD [SE] Rep. TC on Fire Protection Features Ed Schultz, Code Consultants, Incorporated, MO [SE] Rep. TC on Mercantile & Business Occupancies Catherine L. Stashak, Des Plaines, IL [E] Rep. TC on Educational & Day-Care Occupancies David W. Stroup, US National Institute of Standards & Technology, MD [RT] Rep. TC on Alternative Approaches to Life Safety Staff Liaison: Ron Coté

Committee Scope: This Committee shall have primary responsibility for documents on the protection of human life from fire and other circumstances capable of producing similar consequences and for the nonemergency and emergency movement of people.

Report of the Committee on Assembly Occupancies and Membrane Structures (SAF-AXM)

Ralph Gerdes, ChairRalph Gerdes Consultants, LLC, IN [SE]


Scott W. Adams, Park City Fire Service District, UT [E] Rep. International Fire Marshals Association Stanton M. Alexander, North American Testing Company, FL [M] Weston E. Bacon, Jr., Bacon Hedland Management, Incorporated, IL [U] Rep. International Association of Exposition Management Scott R. Bartlett, Tyco/SimplexGrinnell, MA [M] Rep. National Electrical Manufacturers Association George D. Bushey, Rosser International, GA [SE] William Conner, Schuler & Shook, Incorporated, IL [SE] Rep. American Society of Theater Consultants Bhola Dhume, City of New Orleans, LA [E] Ronald R. Farr, Kalamazoo Township Fire Department, MI [E] Rep. Michigan Fire Inspectors Society Robert D. Fiedler, City of Lincoln, NE [E] William E. Fitch, Omega Point Laboratories Incorporated, TX [RT] Wesley W. Hayes, Polk County Fire Services Division, FL [E] Rep. International Fire Marshals Association Roland J. Huggins, American Fire Sprinkler Association, Incorporated, TX [IM]Jonathan Humble, American Iron and Steel Institute, CT [M]Kevin J. Kelly, National Fire Sprinkler Association, NY [M]John Lake, Marion County Fire Rescue, FL [E] Rep. NE Florida Fire Prevention Association Vern L. Martindale, Church of Jesus Christ of Latter-day Saints, UT [U] Joseph J. Messersmith, Jr., Portland Cement Association, VA [M]Gregory R. Miller, Code Consultants, Incorporated, MO [U] Rep. National Association of Theatre Owners Keith C. Nagelski, Soft Play, L.L.C., NC [M] Rep. International Play Equipment Manufacturers Association Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [SE] Steven W. Peavey, Altamonte Springs Fire Department, FL [E] Rep. Florida Fire Marshals & Inspectors Association Larry B. Perkins, RBC Center/Carolina Hurricanes, NC [U] Rep. International Association of Assembly Managers, Incorporated John William Pritchett, Athens-Clarke County Fire Department, GA [E] Ed Roether, HOK SVE, MO [U] Karl G. Ruling, Entertainment Services & Technology Association, NY [U] Rep. US Institute for Theatre Technology Philip R. Sherman, Philip R. Sherman, PE, NH [SE] Jeffrey S. Tubbs, Arup Fire, MA [SE] Daniel R. Victor, Interkal, LLC, MI [M] Rep. National School Supply & Equipment Association Paul L. Wertheimer, Crowd Management Strategies, IL [SE]

Alternates

Gene Boecker, Code Consultants, Incorporated, MO [U] (Alt. to Gregory R. Miller)David Cook, Ralph Gerdes Consultants, LLC, IN [SE] (Alt. to Ralph Gerdes)Jerrold S. Gorrell, City of Phoenix, AZ [U] (Alt. to Karl G. Ruling)Mike Hayward, Little Tikes Commercial Play Systems Incorporated, MO [M] (Alt. to Keith C. Nagelski)Eugene Leitermann, Theatre Projects Consultants, Incorporated, CT [SE] (Alt. to William Conner)Vern T. Lewis, Church of Jesus Christ of Latter-day Saints, UT [U] (Alt. to Vern L. Martindale)Steven J. Scandaliato, Scandaliato Design Group, Incorporated, CO [IM] (Alt. to Roland J. Huggins)Stephen V. Skalko, Portland Cement Association, GA [M] (Alt. to Joseph J. Messersmith)Mark V. Smith, Gainesville Fire Rescue Department, FL [E] (Alt. to John Lake)Robert B. Treiber, National Fire Sprinkler Association, Incorporated, OH [M] (Alt. to Kevin J. Kelly)Robert J. Wills, American Iron and Steel Institute, AL [M] (Alt. to Jonathan Humble)

Staff Liaison: Ron Coté

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the nonemergency and emergency movement of people in assembly occupancies, tents, and membrane structures.

101-2


Board and Care Facilities (SAF-BCF)

Philip R. Jose, ChairGuilderland, NY [SE]

Gregory E. Harrington, Nonvoting SecretaryNational Fire Protection Association, MA

Gregory J. Austin, Gentex Corporation, MI [M] Rep. National Electrical Manufacturers Association Warren D. Bonisch, Schirmer Engineering Corporation, TX [I] Harry L. Bradley, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Philip C. Favro, Philip C. Favro & Associates, CA [SE] Laura A. Hoffman, Volunteer State Community College, TN [SE] Kenneth E. Isman, National Fire Sprinkler Association, NY [M]David Ray Kiely, The Charles Lea Center, SC [U] Rep. American Network of Community Options & Resources James K. Lathrop, Koffel Associates, Incorporated, CT [SE] John E. Mahoney, Gage Babcock & Associates, Incorporated, VA [U] Rep. American Health Care Association Paul E. Patty, Underwriters Laboratories Incorporated, IL [RT] Francis G. Reuer, US Department of Health & Human Services, CO [E] James W. Rice, US Department of Veterans Affairs, MI [U]

Alternates

Kerry M. Bell, Underwriters Laboratories Incorporated, IL [RT] (Alt. to Paul E. Patty)Margaret R. Engwer, US Department of Veterans Affairs, PA [U] (Alt. to James W. Rice)Oystein (Sam) F. Husoe, National Fire Sprinkler Association, CA [M] (Alt. to Kenneth E. Isman)Cindy Mahan, Friendship Community Care, Incorporated, AR [U] (Alt. to David Ray Kiely)James F. Woodford, Tyco/SimplexGrinnell, MA [M] (Alt. to Gregory J. Austin)Mayer D. Zimmerman, US Department of Health & Human Services, MD [E] (Alt. to Francis G. Reuer)

Nonvoting

Harold E. Nelson, Hughes Associates, Incorporated, VA [SE} (Member Emeritus)

Staff Liaison: Gregory E. Harrington

Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in residential board and care facilities.

Report of the Committee on Building Service and Fire Protection Equipment (SAF-BSF)

Richard L. Klinker, ChairKlinker & Associates, Incorporated, MD [SE]


Keith A. Ball, Tyco/SimplexGrinnell, FL [M] Rep. National Electrical Manufacturers Association Harry L. Bradley, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Pat D. Brock, Oklahoma State University, OK [SE] Phillip A. Brown, American Fire Sprinkler Association, Incorporated, TX [IM]Paul M. Donga, Boston Fire Department, MA [E] Edward A. Donoghue, Edward A. Donoghue Associates, Incorporated, NY [M] Rep. National Elevator Industry IncorporatedKenneth E. Isman, National Fire Sprinkler Association, NY [M]Joseph M. Jardin, New York City Fire Department, NY [C] Rep. NFPA Fire Service Section Ignatius Kapalczynski, Connecticut Department of Public Safety, CT [E] Roy C. (Chuck) Kimball, Brooks Equipment Company, Incorporated, NC [M] Rep. Fire Equipment Manufacturers’ Association David P. Klein, US Department of Veterans Affairs, MD [U]Dennis A. Lockard, Newport Beach Fire Department, CA [E] Rep. Western Fire Chiefs Association Roger L. McDaniel, Florida Department of Corrections, FL [U] Richard R. Osman, Schirmer Engineering Corporation, IL [I] Dinesh K. Patel, US Department of the Navy, CA [U] Martin H. Reiss, The RJA Group, Incorporated, MA [SE] Lawrence J. Shudak, Underwriters Laboratories Incorporated, IL [RT] Carl Dewayne Wren, Austin Fire Department, TX [E]

Alternates

Lisa Marie Bossert, Schirmer Engineering Corporation, NC [I] (Alt. to Richard R. Osman)James D. Brown, Oklahoma State Universtiy, OK [SE] (Alt. to Pat D. Brock)Greg Gottlieb, Hauppauge Fire District, NY [C] (Alt. to Joseph M. Jardin)Claudia Hagood, Klinker and Associates, Incorporated, MD [SE] (Alt. to Richard L. Klinker)Thomas P. Hammerberg, Automatic Fire Alarm Association, Incorporated, FL [M] (Voting Alt. to AFAA Rep.) Kevin J. Kelly, National Fire Sprinkler Association, NY [M] (Alt. to Kenneth E. Isman)Peter A. Larrimer, US Department of Veterans Affairs, PA [U] (Alt. to David P. Klein)Stephen M. Leyton, Protection Design and Consulting, CA [IM] (Alt. to Phillip A. Brown)John J. McSheffrey, Jr., MIJA, Incorporated, MA [M] (Alt. to Roy C. (Chuck) Kimball)Gary L. Nuschler, Otis Elevator Company, CT [M] (Alt. to Edward A. Donoghue)Andrew M. Schneider, Maryland State Fire Marshals Office, MD [E] (Alt. to Harry L. Bradley)Randolph W. Tucker, The RJA Group, Incorporated, TX [SE] (Alt. to Martin H. Reiss)


Committee Scope: This Committee shall have primary responsibility for documents on the application of fire protection systems including detection, alarm, and suppression, and the life safety impact of various building systems.

Report of the Committee on Detention and Correctional Occupancies (SAF-DET)

Thomas W. Jaeger, ChairGage-Babcock & Associates, Incorporated, VA [SE]


James R. Ambrose, Code Consultants, Incorporated, MO [SE] David L. Bondor, St. Paul Fire and Marine, TX [I] Rep. American Society of Safety Engineers Peter J. Collins, US Department of Justice, DC [U] Randy Gaw, Correctional Service of Canada, Canada [E] Patrick G. Gordon, Philadelphia Prison System, PA [U] Timothy (T.J.) Gottwalt, ESSEX Industries, Incorporated, CT [M] Rep. Builders Hardware Manufacturers Association Kenneth E. Isman, National Fire Sprinkler Association, NY [M] William E. Koffel, Koffel Associates, Incorporated, MD [SE] Roger L. McDaniel, Florida Department of Corrections, FL [U] Jack McNamara, Bosch Security Systems, NY [M] Rep. National Electrical Manufacturers Association E. Eugene Miller, Washington, DC [SE] Jerry Nealy, Cumulus Fibres, Incorporated, NC [M] Rep. Institutional Bedding Manufacturers Association Brian C. Pavey, Folger Adam Security Incorporated, IL [M] Robert R. Perry, Robert Perry Associates Incorporated, IL [M] Rep. Door & Hardware Institute Kenneth J. Schwartz, Schirmer Engineering Corporation, IL [I] Wayne S. Smith, Texas State Fire Marshal, TX [E] Rep. International Fire Marshals Association David W. Spence, Corrections Corporation of America, TN [U]

Alternates

A. Larry Iseminger, Jr., Maryland State Fire Marshals Office, MD [E] (Alt. to Wayne S. Smith)Kevin J. Kelly, National Fire Sprinkler Association, NY [M] (Alt. to Kenneth E. Isman)Kurt A. Roeper, Ingersoll Rand Security and Safety, OH [M] (Alt. to Timothy (T.J.) Gottwalt)Ralph R. Winter, Code Consultants, Incorporated, MO [SE] (Alt. to James R. Ambrose)John Younghusband, Schirmer Engineering Corporation, CA [I] (Alt. to Kenneth J. Schwartz)


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in detention and correctional occupancies.

101-3


Educational and Day-Care Occupancies (SAF-END)

Catherine L. Stashak, ChairDes Plaines, IL [E]

Rep. Illinois Fire Inspectors Association


Scott R. Bartlett, Tyco/SimplexGrinnell, MA [M]Samuel S. Dannaway, S. S. Dannaway Associates, Incorporated, HI [SE]Victor L. Dubrowski, Code Consultants, Incorporated, MO [SE]Douglas R. Freels, Performance Design Technologies, TN [SE]Dominick G. Kass, National Fire Sprinkler Association, NY [M]Vern L. Martindale, Church of Jesus Christ of Latter-day Saints, UT [U] Erin A. M. Oneisom, US Air Force, AE [U] Michael L. Sinsigalli, Windsor Locks Fire Department, CT [E] Aleksy L. Szachnowicz, Anne Arundel County Public Schools, MD [U] Ralph J. Warburton, University of Miami, FL [SE] Kenneth Wood, Office of the Illinois State Fire Marshal, IL [E]

Alternates

Kevin J. Kelly, National Fire Sprinkler Association, NY [M] (Alt. to Dominick G. Kass)Amy J. Murdock, Code Consultants, Incorporated, MO [SE] (Alt. to Victor L. Dubrowski)Roger B. Rudy, Performance Design Technologies, LLC, TN [SE] (Alt. to Douglas R. Freels)Fred K. Walker, US Department of the Air Force, FL [U] (Alt. to Erin A. M. Oneisom)


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in educational occupancies and day-care occupancies.

Report of the Committee on Fire Protection Features (SAF-FIR)

Eric R. Rosenbaum, ChairHughes Associates, Incorporated, MD [SE]

Milosh T. Puchovsky, Nonvoting SecretaryNational Fire Protection Association, MA

Carl F. Baldassarra, Schirmer Engineering Corporation, IL [I] John F. Bender, Maryland Office of State Fire Marshal, MD [E] Rep. International Fire Marshals Association Robert M. Berhinig, Underwriters Laboratories I Incorporated, IL [RT] Gregory J. Cahanin, St. Petersburg, FL [U] Rep. Louisiana State Firemen’s Association Brian L. Eklow, Aon Risk Consultants, IL [I] Sam W. Francis, American Forest & Paper Association, PA [M]Ralph Gerdes, Ralph Gerdes Consultants, LLC, IN [SE] Wayne D. Holmes, HSB Professional Loss Control, CT [I] Jonathan Humble, American Iron and Steel Institute, CT [M]Ignatius Kapalczynski, Connecticut Department of Public Safety, CT [E] Marshall A. Klein, Marshall A. Klein & Associates, Incorporated, MD [SE] William E. Koffel, Koffel Associates, Incorporated, MD [M] Rep. Glazing Industry Code Committee Vickie J. Lovell, InterCode Incorporated, FL [M] Rep. Air Movement & Control Association Jeffrey A. Maddox, The RJA Group, Incorporated, CA [SE] John W. McCormick, Code Consultants, Incorporated, MO [SE] Joseph J. Messersmith, Jr., Portland Cement Association, VA [M]Jon W. Pasqualone, Martin County Board of County Commissioners, FL [E] Rep. Florida Fire Marshals & Inspectors Association Kurt A. Roeper, Ingersoll Rand Security and Safety, OH [M] Rep. Steel Door Institute Kathleen Taraba, Rolling Plains Construction, Incorporated, CO [IM] Rep. Firestop Contractors International Association Kenneth Wood, Office of the Illinois State Fire Marshal, IL [E]

Alternates

Donald W. Belles, Koffel Associates, Incorporated, TN [M] (Alt. to William E. Koffel)Joseph A. Brooks, Air Movement & Control Association International, IL [M] (Alt. to Vickie J. Lovell)Edward K. Budnick, Hughes Associates, Incorporated, MD [SE] (Alt. to Eric R. Rosenbaum)Joseph A. Castellano, The RJA Group, Incorporated, GA [SE] (Alt. to Jeffrey A. Maddox)

Charles B. Clark, Jr., Brick Industry Association, VA [M] (Voting Alt. to BIA Rep.) David Cook, Ralph Gerdes Consultants, LLC, IN [SE] (Alt. to Ralph Gerdes)John F. Devlin, Schirmer Engineering Corporation, MD [I] (Alt. to Carl F. Baldassarra)Jack Gump, HSB Professional Loss Control, TN [I] (Alt. to Wayne D. Holmes)David M. Hammerman, Marshall A. Klein and Associates, Incorporated, MD [SE] (Alt. to Marshall A. Klein)Thomas R. Janicak, Ceco Door Products, TN [M] (Alt. to Kurt A. Roeper)Mark Kluver, Portland Cement Association, CA [M] (Alt. to Joseph J. Messersmith)David A. Lewis, Code Consultants, Incorporated, MO [SE] (Alt. to John W. McCormick)William J. McHugh, Jr., Firestop Contractors International Association, IL [IM] (Alt. to Kathleen Taraba)Andrew M. Schneider, Maryland State Fire Marshals Office, MD [E] (Alt. to John F. Bender)David P. Tyree, American Forest & Paper Association, CO [M] (Alt. to Sam W. Francis)Robert J. Wills, American Iron and Steel Institute, AL [M] (Alt. to Jonathan Humble)

Nonvoting

Michael Earl Dillon, Dillon Consulting Engineers, Incorporated, CA [SE} Rep. TC on Air Conditioning

Staff Liaison: Milosh T. Puchovsky

Committee Scope: This Committee shall have primary responsibility for documents on construction compartmentation, including the performance of assemblies, openings, and penetrations, as related to the protection of life and property from fire and other circumstances capable of producing similar consequences.

Report of the Committee on Fundamentals (SAF-FUN)

Morgan J. Hurley, ChairSociety of Fire Protection Engineers, MD [U]


Thomas H. Allen, Smoke Guard Corporation, ID [U] Rep. American Institute of Architects Robert E. Bachman, Robert E. Bachman, Consulting Structural Engineer, CA [SE] Rep. National Council of Structural Engineers Associations Wayne G. Carson, Carson Associates, Incorporated, VA [SE] Amy Y. Cheng, Clark County Department of Development Services, NV [E] James E. Churchill, Schirmer Engineering Corporation, CA [I] Salvatore DiCristina, Rutgers, The State University of New Jersey, NJ [E] Barbara Ebstein, Vinick Associates, Incorporated, CT [U] Rep. American Society of Interior Designers Robert J. Eugene, Underwriters Laboratories Incorporated, WA [RT] Ben Greene, City of Englewood, CO [E] Norman E. Groner, John Jay College of Criminal Justice, NY [SE] David J. Jacoby, Arup Fire, NY [SE] David P. Klein, US Department of Veterans Affairs, MD [U]James A. Landmesser, US Department of Energy, TN [E] James K. Lathrop, Koffel Associates, Incorporated, CT [SE] Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association Stephen V. Skalko, Portland Cement Association, GA [M]Jeffrey B. Stone, American Forest & Paper Association, FL [M]Victoria B. Valentine, National Fire Sprinkler Association, NY [M]John M. Watts, Jr., Fire Safety Institute, VT [SE] Robert J. Wills, American Iron and Steel Institute, AL [M]Steven F. Wydeveld, Will County Land Use, IL [E]

Alternates

Eugene A. Cable, US Department of Veterans Affairs, NY [U] (Alt. to David P. Klein)Robert M. Carasitti, Schirmer Engineering Corporation, MA [I] (Alt. to James E. Churchill)Jonathan Humble, American Iron and Steel Institute, CT [M] (Alt. to Robert J. Wills)Mark Kluver, Portland Cement Association, CA [M] (Alt. to Stephen V. Skalko)John V. Loscheider, Loscheider Engineering Company, WA [SE] (Alt. to Robert E. Bachman)Kimberly A. Marks, The Marks Design Group, Incorporated, TX [U] (Alt. to Barbara Ebstein)

101-4

Report on Comments — Copyright, NFPA NFPA 101 Eric N. Mayl, Koffel Associates, Incorporated, MD [SE] (Alt. to James K. Lathrop)Rodney A. McPhee, Canadian Wood Council, Canada [M] (Alt. to Jeffrey B. Stone)Rick Thornberry, The Code Consortium, Incorporated, CA [M] (Voting Alt. to W.R. Grace Rep.) John R. Wiggins, Underwriters Laboratories Incorporated, NC [RT] (Alt. to Robert J. Eugene)

Nonvoting

Pichaya Chantranuwat, Fusion Consultants Company Limited/Thailand, Thailand [SE}


Committee Scope: This Committee shall have primary responsibility for documents on the basic goals, objectives, performance requirements, and definitions for protection of human life and property from fire, earthquake, flood, wind, and other circumstances capable of producing similar consequences, and on the nonemergency and emergency movement of people.

Report of the Committee on Furnishings and Contents (SAF-FUR)

William E. Fitch, ChairOmega Point Laboratories Incorporated, TX [RT]


Vytenis Babrauskas, Fire Science and Technology Incorporated, WA [SE] Lisa Bonneville, Bonneville Design, MA [U] Rep. American Society of Interior Designers Eugene A. Cable, US Department of Veterans Affairs, NY [U] Frederic B. Clarke, Benjamin Clarke Associates, Incorporated, VA [SE] Paul Dillon, Southern Polytechnic State University, GA [M] Rep. Sleep Products Safety Council Pravinray D. Gandhi, Underwriters Laboratories Incorporated, IL [RT] Marcelo M. Hirschler, GBH International, CA [SE] E. Ken McIntosh, Carpet and Rug Institute, GA [M] Henry Paszczuk, City of New Britain Fire Department, CT [E] T. Hugh Talley, Hugh Talley Company, TN [M] Rep. American Furniture Manufacturers Association

Alternates

James K. Lathrop, Koffel Associates, Incorporated, CT [M] (Alt. to E. Ken McIntosh)James V. Ryan, Potomac, MD [SE] (Alt. to Frederic B. Clarke)Shelley Siegel, Accessible Interiors’ Network, Incorporated, FL [U] (Alt. to Lisa Bonneville)


Committee Scope: This Committee shall have primary responsibility for documents on limiting the impact of furnishings and building contents effect on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people.

Report of the Committee on Health Care Occupancies (SAF-HEA)

Daniel J. O’Connor, ChairSchirmer Engineering Corporation, IL [I]


James R. Ambrose, Code Consultants, Incorporated, MO [SE]William N. Brooks, Eichleay Engineers, Incorporated, PA [SE]Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Wayne G. Carson, Carson Associates, Incorporated, VA [SE] Robert J. Carubia, Jr., West Virginia University Hospitals, WV [U] Michael A. Crowley, The RJA Group, Incorporated, TX [SE] Samuel S. Dannaway, S. S. Dannaway Associates, Incorporated, HI [SE] Rep. American Society of Safety Engineers Buddy Dewar, National Fire Sprinkler Association, FL [M]Douglas S. Erickson, American Society for Healthcare Engineering, VI [U]Kenneth S. Faulstich, US Department of Veterans Affairs, DC [U]John E. Fishbeck, Joint Commission on Accreditation of Healthcare Organizations, IL [E] Antonio Freire, Axa Courtage, France [I] Donald W. Harris, California Office of Health Planning & Development, CA [E] Thomas W. Jaeger, Gage-Babcock & Associates, Incorporated, VA [U] Rep. American Health Care Association

John I. Mills, Beery, Rio & Associates, VA [SE] Kirby W. Perry, Kirby W. Perry Architects & Associates Incorporated, TX [SE] Rep. American Institute of Architects Peter P. Petresky, Pennsylvania Department of Health, PA [E] Rep. Association of Health Facility Survey Agencies Brian Prediger, US Department of the Army, MD [U] George F. Stevens, US Department of Health & Human Services, AZ [E] John S. Taylor, Health South Rehabilitation Hospital of Southern Arizona, AZ [U] Rep. NFPA Health Care Section Mayer D. Zimmerman, US Department of Health & Human Services, MD [E]

Alternates

James H. Antell, The RJA Group, Incorporated, IL [SE] (Alt. to Michael A. Crowley)Lori B. Dinney, Code Consultants, Incorporated, MO [SE] (Alt. to James R. Ambrose)Michael R. Durst, National Fire Sprinkler Association, CO [M] (Alt. to Buddy Dewar)Joshua W. Elvove, US Department of Veterans Affairs, CO [U] (Alt. to Kenneth S. Faulstich)J. Richard Fruth, Hayes Large Architects, PA [SE] (Alt. to Kirby W. Perry)Thomas W. Gardner, Schirmer Engineering Corporation, GA [I] (Alt. to Daniel J. O’Connor)William E. Koffel, Koffel Associates, Incorporated, MD [U] (Alt. to Douglas S. Erickson)

Nonvoting

Pichaya Chantranuwat, Fusion Consultants Company Limited/Thailand, Thailand [SE}


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in health care occupancies.

Report of the Committee on Industrial, Storage, and Miscellaneous Occupancies (SAF-IND)

Wayne D. Holmes, ChairHSB Professional Loss Control, CT [I]


John A. Alderman, RRS Engineering, TX [SE] Rep. American Society of Safety Engineers Thomas L. Allison, Westinghouse Savannah River Co., SC [U] Raymond E. Arntson, Rayden Research LLC, WI [SE] Donald C. Birchler, FP&C Consultants Incorporated, MO [SE] Howard M. Bucci, US Department of Energy, WA [U] Charles E. Doody, Canton Fire Department, MA [E] John F. Farney, Jr., Sargent & Lundy Engineers, IL [SE] Larry L. Fluer, Fluer, Incorporated, CA [M] Rep. Compressed Gas Association Larry N. Garrett, Delphi Corporation, IN [U] Rep. NFPA Industrial Fire Protection Section James E. Golinveaux, Tyco Fire & Building Products, RI [M] Rep. American Fire Sprinkler Association Jonathan Humble, American Iron and Steel Institute, CT [M]Ronald Keefer, Menlo Park Fire Protection District, CA [E] Marshall A. Klein, Marshall A. Klein & Associates, Incorporated, MD [U] Rep. Automotive Oil Change Association Neal W. Krantz, LVC Technologies, Incorporated, MI [IM] Rep. Automatic Fire Alarm Association, Incorporated Richard S. Kraus, PSC Petroleum Safety Consultants, VA [U] Rep. American Petroleum Institute Raymond W. Lonabaugh, National Fire Sprinkler Association, PA [M]Patrick A. McLaughlin, McLaughlin & Associates, RI [U] Rep. Semiconductor Industry Association Milton L. Norsworthy, Arch Chemicals, Incorporated, TN [M] Anthony M. Ordile, Loss Control Associates, Incorporated, PA [SE] Rep. TC on Storage and Warehousing of Containers and Portable Tanks Phani K. Raj, Technology & Management Systems, Incorporated, MA [SE] Rep. TC on Liquefied Petroleum Gases William J. Satterfield, III, Hydrogen Safety, LLC/Rode & Associates, LLC, RI [SE] Jeffrey M. Shapiro, International Code Consultants, TX [M] Rep. The Chlorine Institute, Incorporated Stephen V. Skalko, Portland Cement Association, GA [M]Cleveland B. Skinker, Bechtel Power Corporation, MD [SE] Bruce J. Swiecicki, National Propane Gas Association, IL [IM]David C. Tabar, The Sherwin-Williams Company, OH [U]

101-5

Report on Comments — Copyright, NFPA NFPA 101 Samuel Vanover, Jefferson Parish Fire Department, LA [E] Rep. TC on Hazardous Chemicals Carl Dewayne Wren, Austin Fire Department, TX [E]

Alternates

Clarence D. (Dale) Eggen, US Department of Energy, WA [U] (Alt. to Howard M. Bucci)Daniel J. Gengler, National Fire Sprinkler Association, WI [M] (Alt. to Raymond W. Lonabaugh)Jack Gump, HSB Professional Loss Control, TN [I] (Alt. to Wayne D. Holmes)David M. Hammerman, Marshall A. Klein and Associates, Incorporated, MD [U] (Alt. to Marshall A. Klein)Roland J. Huggins, American Fire Sprinkler Association, Incorporated, TX [M] (Alt. to James E. Golinveaux)Mark Kluver, Portland Cement Association, CA [M] (Alt. to Stephen V. Skalko)William E. Koffel, Koffel Associates, Incorporated, MD [U] (Alt. to Patrick A. McLaughlin)Todd D. Matteson, Westinghouse Savannah River Company, SC [U] (Alt. to Thomas L. Allison)David J. Repasky, The Sherwin-Williams Company, OH [U] (Alt. to David C. Tabar)Roberto Lozano Rosales, Delphi Corporation, TX [U] (Alt. to Larry N. Garrett)Roger A. Smith, Compressed Gas Association, Incorporated, VA [M] (Alt. to Larry L. Fluer)Gary F. Trojak, The Chlorine Institute, Incorporated, VA [M] (Alt. to Jeffrey M. Shapiro)Robert J. Wills, American Iron and Steel Institute, AL [M] (Alt. to Jonathan Humble)

Nonvoting

Virginia M. Gilman, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration (Alt. to Terence P. Smith) Terence P. Smith, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in industrial and storage occupancies, special structures, windowless and underground buildings, and high-rise buildings.

Report of the Committee on Means of Egress (SAF-MEA)

David A. de Vries, ChairFiretech Engineering Incorporated, IL [SE]


Lawrence Brown, National Association of Home Builders, DC [U]John L. Bryan, Frederick, MD [SE] Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Steven Di Pilla, ACE USA/ESIS Risk Control Services, NJ [I] Rep. American Society of Safety Engineers Joshua W. Elvove, US Department of Veterans Affairs, CO [U]Philip C. Favro, Philip C. Favro & Associates, CA [SE] Edward L. Fixen, Schirmer Engineering Corporation, CA [I] David Frable, US General Services Administration, IL [U] Rita C. Guest, Carson Guest, Incorporated, GA [U] Rep. American Society of Interior Designers Billy G. Helton, Lithonia Emergency Systems, GA [M] Rep. National Electrical Manufacturers Association William E. Koffel, Koffel Associates, Incorporated, MD [SE] Erica D. Kuligowski, US National Institute of Standards & Technology, MD [RT] Lawrence J. McGinty, US Central Intelligence Agency, DC [U] Gary L. Nuschler, Otis Elevator Company, CT [M] Rep. National Elevator Industry Incorporated Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association Robert R. Perry, Robert Perry Associates Incorporated, IL [M] Rep. Door & Hardware Institute Eric R. Rosenbaum, Hughes Associates, Incorporated, MD [SE] Michael S. Shulman, Underwriters Laboratories Incorporated, CA [RT] Leslie Strull, The RJA Group, Incorporated, IL [SE] Andrew L. Stuffler, City of Ventura Fire Department, CA [E] Michael Tierney, Builders Hardware Manufacturers Association, CT [M]

Michael D. Tomy, Heery International Incorporated, GA [SE] Rep. American Institute of Architects Joseph H. Versteeg, Versteeg Associates, CT [E] Rep. Fairfield CT Fire Marshal’s Office

Alternates

Warren D. Bonisch, Schirmer Engineering Corporation, TX [I] (Alt. to Edward L. Fixen)Michael A. Crowley, The RJA Group, Incorporated, TX [SE] (Alt. to Leslie Strull)Joseph M. DeRosier, US Department of Veteran Affairs, MI [U] (Alt. to Joshua W. Elvove)Edward A. Donoghue, Edward A. Donoghue Associates, Incorporated, NY [M] (Alt. to Gary L. Nuschler)Barbara Ebstein, Vinick Associates, Incorporated, CT [U] (Alt. to Rita C. Guest)Steven D. Holmes, Underwriters Laboratories Incorporated, CA [RT] (Alt. to Michael S. Shulman)James K. Lathrop, Koffel Associates, Incorporated, CT [SE] (Alt. to William E. Koffel)R. T. Leicht, State of Delaware, DE [E] (Alt. to Kenneth E. Bush)James A. Milke, University of Maryland, MD [SE] (Alt. to John L. Bryan)Brian T. Rhodes, Hughes Associates, Incorporated, MD [SE] (Alt. to Eric R. Rosenbaum)Roy W. Schwarzenberg, US Central Intelligence Agency, DC [U] (Alt. to Lawrence J. McGinty)Gregory J. Steinman, Thomas & Betts Corporation, TN [M] (Alt. to Billy G. Helton)

Nonvoting

Pichaya Chantranuwat, Fusion Consultants Company Limited/Thailand, Thailand [E]Matthew I. Chibbaro, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration Virginia M. Gilman, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration (Alt. to Matthew I. Chibbaro)


Committee Scope: This Committee shall have primary responsibility for documents on the general requirements for safe egress for protection of human life from fire and other circumstances capable of producing similar consequences, and on the nonemergency and emergency movement of people.

Report of the Committee on Mercantile and Business Occupancies (SAF-MER)

Ed Schultz, ChairCode Consultants, Incorporated, MO [SE]


David M. Banwarth, David M. Banwarth Associates, LLC, MD [SE] E. Joseph Bocci, US Department of the Treasury, DC [U] Kenneth E. Bush, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association David A. Dodge, Safety and Forensic Consulting, ME [SE] Rep. American Society of Safety Engineers Sam W. Francis, American Forest & Paper Association, PA [M] Douglas R. Freels, Performance Design Technologies, TN [SE] Daniel J. Gauvin, Tyco/SimplexGrinnell, MA [M] Rep. National Electrical Manufacturers Association William Hiotaky, The Taubman Company, MI [U] Wayne D. Holmes, HSB Professional Loss Control, CT [I] Jonathan Humble, American Iron and Steel Institute, CT [M] Michael J. Laderoute, MJL Associates, Incorporated, VA [M] Rep. Fire Equipment Manufacturers’ Association Brian L. Marburger, St. Paul Travelers, IL [I] Jeff Martin, Elite Fire Protection, Canada [IM] Rep. National Association of Fire Equipment Distributors Richard V. Moon, Insurance Services Office, Incorporated, NJ [I] Lawrence G. Perry, Building Owners & Managers Association International, MD [U] Steven E. Randall, National Fire Sprinkler Association, FL [M] Sheldon S. Rucinski, Schirmer Engineering Corporation, IL [I] David C. Tabar, The Sherwin-Williams Company, OH [U] Rick Thornberry, The Code Consortium, Incorporated, CA [SE] William J. Tomes, TVA Fire and Life Safety, Incorporated, GA [U] Rep. The Home Depot

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Report on Comments — Copyright, NFPA NFPA 101 Alternates

Tracey D. Bellamy, TVA Fire and Life Safety, Incorporated, GA [U] (Alt. to William J. Tomes)Darryl Thomas Brown, Performance Design Technologies, TN [SE] (Alt. to Douglas R. Freels)Jack Gump, HSB Professional Loss Control, TN [I] (Alt. to Wayne D. Holmes)Raymond W. Lonabaugh, National Fire Sprinkler Association, PA [M] (Alt. to Steven E. Randall)Patrick A. McLaughlin, McLaughlin & Associates, RI [U] (Alt. to David C. Tabar)Richard R. Osman, Schirmer Engineering Corporation, IL [I] (Alt. to Sheldon S. Rucinski)Dennis L. Pitts, American Forest & Paper Association, TX [M] (Alt. to Sam W. Francis)Terry Schultz, Code Consultants, Incorporated, MO [SE] (Alt. to Ed Schultz)Robert J. Wills, American Iron and Steel Institute, AL [M] (Alt. to Jonathan Humble)


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and for the emergency movement of people in mercantile and business occupancies.

Report of the Committee on Residential Occupancies (SAF-RES)

James K. Lathrop, ChairKoffel Associates, Incorporated, CT [SE]


James R. Bell, Marriott International, Incorporated, DC [U] Rep. American Hotel & Lodging Association Warren D. Bonisch, Schirmer Engineering Corporation, TX [I] H. Wayne Boyd, US Safety & Engineering Corporation, CA [M] Harry L. Bradley, Maryland State Fire Marshals Office, MD [E] Rep. International Fire Marshals Association Byron L. Briese, The RJA Group, Incorporated, VA [U] Rep. NFPA Lodging Industry Section Lawrence Brown, National Association of Home Builders, DC [U]Phillip A. Brown, American Fire Sprinkler Association, Incorporated, TX [IM] James J. Convery, Arup Fire, NJ [SE] Sam W. Francis, American Forest & Paper Association, PA [M] Ralph Gerdes, Ralph Gerdes Consultants, LLC, IN [SE] Wendy B. Gifford, Invensys Climate Controls America, IL [M] Rep. National Electrical Manufacturers Association Robert Howe, Vermont Department of Labor & Industry, VT [E] Rep. National Association of State Fire Marshals Kenneth E. Isman, National Fire Sprinkler Association, NY [M] Marshall A. Klein, Marshall A. Klein & Associates, Incorporated, MD [SE] Joseph J. Messersmith, Jr., Portland Cement Association, VA [M] Ronald G. Nickson, National Multi Housing Council, DC [U]Erin A. M. Oneisom, US Air Force, AE [U] Henry Paszczuk, City of New Britain Fire Department, CT [E] Jake Pauls, Jake Pauls Consulting Services in Building Use & Safety, MD [C] Rep. American Public Health Association Peter Puhlick, University of Connecticut, CT [U] Alan Robinson, Tuan and Robinson, Structural Engineers, Incorporated, CA [E] Rep. Building Seismic Safety Council/Code Resource Support Committee John A. Sharry, Beakmann Properties, CA [U] T. Hugh Talley, Hugh Talley Company, TN [M] Rep. American Furniture Manufacturers Association Joseph H. Versteeg, Versteeg Associates, CT [SE]

Alternates

Carl F. Baldassarra, Schirmer Engineering Corporation, IL [I] (Alt. to Warren D. Bonisch)David Cook, Ralph Gerdes Consultants, LLC, IN [SE] (Alt. to Ralph Gerdes)Thomas G. Daly, Hilton Hotels Corporation, CA [U] (Alt. to James R. Bell)David M. Hammerman, Marshall A. Klein and Associates, Incorporated, MD [SE] (Alt. to Marshall A. Klein)Stanley C. Harbuck, School of Building Inspection, UT [C] (Alt. to Jake Pauls)Mark Kluver, Portland Cement Association, CA [M] (Alt. to Joseph J. Messersmith)Michael F. Meehan, Virginia Sprinkler Company, Incorporated, VA [IM] (Alt. to Phillip A. Brown)

Donald J. Pamplin, National Fire Sprinkler Association, WA [M] (Alt. to Kenneth E. Isman)Dennis L. Pitts, American Forest & Paper Association, TX [M] (Alt. to Sam W. Francis)Jeffrey L. Shearman, Zurich Services Corporation, PA [U] (Alt. to Byron L. Briese)Fred K. Walker, US Department of the Air Force, FL [U] (Alt. to Erin A. M. Oneisom)


Committee Scope: This Committee shall have primary responsibility for documents on protection of human life and property from fire and other circumstances capable of producing similar consequences, and on the emergency movement of people in hotels, dormitories, apartments, lodging and rooming houses, and one- and two-family dwellings.

These lists represent the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book.

The Report of the Committee on Safety to Life is presented for adoption, as follows:

The Reports were prepared by the:

• Technical Correlating Committee on Safety to Life (SAF-AAC)• Technical Committee on Assembly Occupancies and Membrane

Structures (SAF-AXM)• Technical Committee on Board and Care Facilities (SAF-BCF)• Technical Committee on Building Service and Fire Protection Equipment

(SAF-BSF)• Technical Committee on Detention and Correctional Occupancies (SAF-

DET)• Technical Committee on Educational and Day-Care Occupancies (SAF-

END)• Technical Committee on Fire Protection Features (SAF-FIR)• Technical Committee on Fundamentals (SAF-FUN)• Technical Committee on Furnishings and Contents (SAF-FUR)• Technical Committee on Health Care Occupancies (SAF-HEA)• Technical Committee on Industrial, Storage, and Miscellaneous

Occupancies (SAF-IND)• Technical Committee on Means of Egress (SAF-MEA)• Technical Committee on Mercantile and Business Occupancies (SAF-

MER)• Technical Committee on Residential Occupancies (SAF-RES)

This Report on Comments was prepared by the Technical Committee on Safety to Life, and documents its action on the comments received on its Report on Proposals on NFPA 101®, Life Safety Code®, 2006 edition, as published in the Report on Proposals for the 2005 June Meeting.

This Report on Comments has been submitted to letter ballot of the applicable Technical Committee’s on Safety to Life. The results of the balloting, after circulation of any negative votes, can be found in the report.

This Report on Comments has also been submitted to letter ballot of the Technical Correlating Committee on Safety to Life which consists of 12 voting members; of whom 11 voted affirmatively. Members voting negatively after recirculation of negative ballots, and members abstaining are recorded below by comment number. 1 ballot was not returned (Gibbs).

101-45 Affirmative Comment: Pauls101-46 Negative: Perry101-56a Negative: Perry101-67 Negative: Perry101-222 Negative: Perry101-353 Negative: Perry101-354 Negative: Perry

101-45 Affirmative with CommentMr. Pauls: Comment 101-45 was submitted by me on the wider minimum

exit stair issue and was accepted in part by the Means of Egress (MEA) Technical Committee when it accepted related Comment 101-46. After involvement of several occupancy Technical Committees, the finally accepted comment was 101-56a. The process, especially within the MER TC and IND TC, was instructive, as were discussions within the Technical Correlating Committees for NFPA 101 and NFPA 5000. With so much discussion occurring after the MEA TC ballots, it is appropriate to comment with some hindsight at the TCC ROC release ballot stage, if only to provide some additional guidance to NFPA members who will vote in June 2005.

Overall, it is clear to me (after all these TC and TCC deliberations) that more of Comment 101-45 should have been accepted, especially its broadened basis or rationale for requiring an increased minimum exit stair width. Once Comment 101-56 became the basis for increasing minimum stair width, the stated rationale for wider stairs became solely the issue of counter flow of evacuees and emergency responders. This was a strategic error in my opinion. The reasons for wider exit stairs are multifaceted and include effectiveness of occupant evacuation even in the absence of counter flow by emergency responders. (For full details on the increased rationale, which includes larger

101-7

Report on Comments — Copyright, NFPA NFPA 101 people and reduced fitness of those people, see Comment 101-45.) Moreover, as recommended in Comment 101-45, the threshold for wider exit stairs should be lowered significantly below the currently accepted 2000-person occupant load per stair.

Clearly, according to the overall consensus achieved thus far, wider exit stairs are needed. However, the change proposal accepted thus far is a very small change when a larger change is warranted, both to correct errors made decades ago in choosing 44 inches as a standard minimum width and to account for physiological changes in occupants in recent decades.

101-46 NegativeMr. Perry: As noted by multiple members of both the SAF-IND and the

SAF-MER committees (see comments 101-56c and 101-353), there remains a lack of adequate substantiation for the increase in stair width based on the total number of occupants serving the stair. Based on the substantive negative ballot comments (see comment 101-56c) raised by SAF-IND, the Technical committee responsible for high-rise requirements, and the overwhelming vote by SAF-MER to not apply the wider stair provisions to business and mercantile occupancies, this comment and the original proposal to increase stair width should be rejected.

101-56a NegativeMr. Perry: It is unclear why the SAF-AXM committee is given the ‘last

word’ on the subject of wider stairs, when this change will likely never affect assembly occupancies. In continuing to reject the application of the increased stair width in business and mercantile occupancies, the SAF-MER committee (see comment 101-353) noted that the proposal, even with revisions proposed in the comment period, “the defend in place concept, i.e. use of horizontal exits….has not been properly considered”. In the changes included in this comment by SAF-AXM, the ‘consideration’ of horizontal exits is eliminated from the code for purposes of calculating whether the wider stairs are required. This is a substantive change that SAF-AXM has no business making. Also note the significant negative ballot comments by SAF-IND on this issue at comment 101-56c.

101-67 NegativeMr. Perry: During the technical committee discussions, the proponent of

the wider stair proposal numerous times indicated that increasing the stair width was not a capacity issue. The SAF-MER substantiation for accepting the increased stair width confirms this, as it notes only that wider stairs are needed for counterflow.

If a designer chooses to allocate a larger occupant load per floor into the wider stair, the ‘problem’ is self-correcting, as current code requirements will increase the width of the exit discharge door as needed. If there aren’t more occupants allocated to the stair because of the increased width, there is no additional occupant load, and there is no justification for increasing door width.

This is a substantive technical change that is being proposed by the Technical Correlating Committee with inadequate justification, and is inappropriate at this point in the process.

101-222 NegativeMr. Perry: After reviewing the extensive negative ballot comments

by SAF-AXM members and reviewing the technical substantiation provided by the original submitter and commenter, I am convinced that no technical justification has been provided for this change. Without technical substantiation, this change should be rejected. The original proposal gave as substantiation several irrelevant examples (areas used for childcare, areas used for religious instruction) as ‘justification’ for the change. The comment simply states that the submitter ‘supports the original substantiation’, and that ‘many other activities’ take place in churches. No substantiation has been provided to eliminate the sprinkler exception for ‘assembly occupancies used primarily for worship with fixed seating’. This change has significant cost impact, and should not be accepted without demanding some real technical documentation.

101-353 NegativeMr. Perry: Business occupancies are likely to be the most common

building type impacted by the increased stair width change. The SAF-IND committee, responsible for high-rise provisions, (see comment 101-56c) has noted extensive misgivings with the increased stair width change. It is inappropriate to override a strong majority position of this TC, particularly with final wording developed by a committee (SAF-AXM) that is unaffected by the change. SAF-MER included in their substantiation a note that the proposal for wider stairs didn’t adequately address horizontal exits. Subsequent action by SAF-AXM ‘addressed’ horizontal exits by eliminating them for purposes of calculating where wider stairs are needed. This is a substantive change without justification, and one which SAF-MER never had an opportunity to address.

101-354 NegativeMr. Perry: See comments to comment 101-353. This item should be

changed to ‘reject’.

101-8

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________ 101-1 Log #3a SAF-AXM FINAL ACTION: Accept in Principle (Entire Document) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be supplemented so 12.4.5.7.2(D) shows UL 263 as equivalent to NFPA 251 and ASTM E 119 as follows: 12.4.5.7.2 (D) Fire Test. A sample curtain with not less than two vertical seams shall be subjected to the standard fire test specified in NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, or UL 263, Standard for Fire Tests of Building Construction and Materials, as applicable to nonbearing walls and partitions for a period of 30 minutes, as follows: ... Add UL 263 to Chapter 2 references, showing the edition date as 2003.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Identify locations, within NFPA 101 chapters of responsibility, of references to NFPA fire test standards that have ASTM and/or UL counterparts. Indicate what changes, if any, need to be made as part of ROC. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise as follows: 12.4.5.7.2 (D) Fire Test. A sample curtain with not less than two vertical seams shall be subjected to the standard fire test specified in NFPA 251, Standard Methods of Tests of Fire Endurance of Building Construction and Materials, or ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials, as applicable to nonbearing walls and partitions for a period of 30 minutes, as follows: 12.4.5.7.2 (E) Smoke Test. Curtain fabrics shall have a smoke density not to exceed 25 where tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Materials, or UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, and the curtain fabric shall be tested in the condition in which it is to be used. Add ASTM E 119 to Chapter 2 references, showing the edition date as 2000a. Add ASTM E 84 to Chapter 2 references, showing the edition date as 2004. Add UL 723 to Chapter 2 references, showing the edition date as 2003. COMMITTEE STATEMENT: The action accomplishes what the submitter requested. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-2 Log #3b SAF-FIR FINAL ACTION: Accept in Principle (Entire Document) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified per Berhinig’s comment to revise Chapter 8 to add UL 10C so that the combination of UL 10B and UL 10C are offered in the list of alternatives to NFPA 252. Also, add UL 10B and UL 10C to the UL referenced publications in 2.3.6. SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Identify locations, within NFPA 101 chapters of responsibility, of references to NFPA fire test standards that have ASTM and/or UL counterparts. Indicate what changes, if any, need to be made as part of ROC. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Where the following NFPA fire test standards are referenced in Chapter 8, also make reference to the corresponding ASTM and UL fire test standards as follows: NFPA 251: ASTM E 119, UL 263 NFPA 252: ASTM E 2074, UL 10B NFPA 257: ASTM E 2010, UL 9 COMMITTEE STATEMENT: This action meets the intent of the submitter. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH COMMENT ON AFFIRMATIVE BERHINIG: In the table include reference to ANSI Standard UL 10C, Positive Pressure Fire Tests of Door Assemblies as follows: NFPA 251: ASTM E 119, UL 263 NFPA 252: ASTM E 2074, UL 10B, UL 10C NFPA 257: ASTM E 2010, UL 9.

_______________________________________________________________ 101-3 Log #3c SAF-FUR FINAL ACTION: Accept in Principle (Entire Document) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified per Gandhi’s comment to revise Chapter 10 to add UL 723 as an alternative to NFPA 255. See also Comments 101-14, 101-15, and 101-162SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Identify locations, within NFPA 101 chapters of responsibility, of references to NFPA fire test standards that have ASTM and/or UL counterparts. Indicate what changes, if any, need to be made as part of ROC. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific changes proposed. COMMITTEE STATEMENT: The committee reviewed references to NFPA fire test standards in chapter 10 as proposed by the submitter. UL 723 is similar to NFPA 255 and ASTM E 84. UL 1895 was similar to ASTM E 1590 but is no longer published. UL 1056 is similar to ASTM 1537. While the identified UL fire test standards are similar to certain ASTM and NFPA fire test standards, the committee does not believe that the UL standards are necessarily equivalent. The committee is of the opinion that UL 723 and UL 1056 have not kept current with the corresponding NFPA and ASTM counterparts in terms of technical content. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Negative: 1 EXPLANATION OF NEGATIVE: GANDHI: I voted negative on this ballot since UL 723 is technically equivalent to NFPA 255 with respect to calibration, test procedures (including mounting methods), and calculations. The technical correlating committee has not given any examples where UL 723 technically differs from NFPA 255. Please note that UL 723 was last revised in August 2003, when it was reissued as an ANSI document.

_______________________________________________________________101-4 Log #3e SAF-IND FINAL ACTION: Accept in Principle (Entire Document) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Identify locations, within NFPA 101 chapters of responsibility, of references to NFPA fire test standards that have ASTM and/or UL counterparts. Indicate what changes, if any, need to be made as part of ROC. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle In 11.9.1.5 and 11.10.1.4 add the following test standards as being equivalent to NFPA 256: ASTM E 108, Standard Test Methods for Fire Tests of Roof Coverings UL 790, tests for Fire resistance of Roof Covering Materials. COMMITTEE STATEMENT: Meets the intent of the submitter. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-5 Log #3f SAF-MER FINAL ACTION: Accept in Principle (Entire Document) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified so as NOT to add UL 214 as an equivalent to NFPA 701 because UL 214 has been withdrawn.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-5 RECOMMENDATION: Identify locations, within NFPA 101 chapters of responsibility, of references to NFPA fire test standards that have ASTM and/or UL counterparts. Indicate what changes, if any, need to be made as part of ROC. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Throughout chapters 36, 37, 38 and 39 add the following as equivalent to NFPA test standards as appropriate: NFPA 255 - ASTM E 84, Standard Test Method for Surface Burning characteristics of Building Materials - UL 723, Standard for Safety Test for Surface Burning Characteristics of Building Materials. NFPA 701 - UL 214, Standard For Safety Tests for Flame-Propagation of Fabrics and Films. COMMITTEE STATEMENT: Meets intent of the submitter. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES

101-9

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-5a Log #CC55 SAF-MEA FINAL ACTION: Accept (2.3.2) _______________________________________________________________ SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-9 RECOMMENDATION: In 2.3.2, update the BHMA A156.19 reference from 1997 to 2002. SUBSTANTIATION: Correlation with action on Comment 5000-85. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-6 Log #100 SAF-FUN FINAL ACTION: Accept (2.3.4) _______________________________________________________________ SUBMITTER: Edward A. Donoghue, Edward A. Donoghue Associates, Inc. / Rep. National Elevator Industry, Inc. (NEII) COMMENT ON PROPOSAL NO: 101-10 RECOMMENDATION: Revise text to read: ASME A17.1, Safety Code for Elevators and Escalators, 2000 2004, including Addenda ASME A17.1a-2005 and Supplement ASME A17.1S-2005. SUBSTANTIATION: To reference current code. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-6a Log #CC402 SAF-DET FINAL ACTION: Accept (2.3.5) _______________________________________________________________ SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-13 RECOMMENDATION: To the list of ASTM standards in 2.3.5, add: ASTM F 1577, Standard Test Methods for Detention Locks for Swinging Doors, 2001. SUBSTANTIATION: Mandatory reference to ASTM F 1577 was added to the 2003 edition of the Code in 22.1.2.2.2 applicable to new detention and correctional occupancies. The addtion to 2.3.5 corrects an oversight. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-7 Log #206 SAF-FUN FINAL ACTION: Accept (2.3.6) _______________________________________________________________ SUBMITTER: Bob Eugene, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 101-13 RECOMMENDATION: Revise as follows: 2.3.6 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062. UL 555, Standard for Fire Dampers, 1999, Revised 2002. UL 555S, Standard for Smoke Dampers, 1999, Revised 2003. UL 924, Emergency Lighting and Power Equipment, 1995, Revised 2001. UL 1784, Standard for Air-Leakage Tests of Door Assemblies, 2001. UL 1975, Standard for Fire Tests for Foamed Plastics Used for Decorative Purposes, 1996. B.1.2.10 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062. UL Fire Resistance Directory. UL 1975, Standard for Fire Tests for foamed Plastics Used for Decorative Purposes, 1996. UL 2079, Standard for Test s for Fire Resistance of Building Joint Systems, 1st Edition, 1998. SUBSTANTIATION: Update to most current editions and titles of referenced standards in accordance with NFPA Manual of Style 3.6.3.1.1 and 1.6.2.3. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-7a Log #CC54 SAF-MEA FINAL ACTION: Accept (2.3.6) _______________________________________________________________ SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-13 RECOMMENDATION: In 2.3.6, update the UL 924 reference from “1995” to “1995, Revised 2001”. SUBSTANTIATION: Correlation with action on Comments 5000-85 and 5000-120. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

_______________________________________________________________101-8 Log #4 SAF-FIR FINAL ACTION: Accept in Principle (Chapter 3 Membrane) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-23 RECOMMENDATION: Revise the new definition of Membrane so as not to refer to a chapter of the Code. The Manual of Style would permit, for example, listing the term as “Membrane (Fire Protection Feature)” so as to differentiate it from the current defined term Membrane. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the definition of membrane and add annex material for the term to read as indicated below: 3.3.138 Membrane. A thin layer of construction material. A.3.3.138 For the purpose of fire protection features, a membrane can consist of materials such as gypsum board, plywood, glass, fabric, etc. For the purpose of membrane structures, a membrane consists of thin, flexible, water-impervious material capable of being supported by an air pressure of 1-1/2 inch (38 mm) water column. COMMITTEE STATEMENT: This revision meets the intent of the submitter by providing explanatory information in the annex. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH _______________________________________________________________101-9 Log #193a SAF-FUN FINAL ACTION: Reject (3.3.xx Children’s Playground Structure) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-56 RECOMMENDATION: Accept the proposal in part in principle with the following language in a new section in Chapter 3 on definitions: 3.3.xx Children’s Playground Structure. a play structure made up of one or more components intended for the entertainment of children where the user enters an enclosed play environment. SUBSTANTIATION: This proposal is consistent with the proposals made to Chapter 27 of NFPA 5000 and Chapters 36 and 37 of NFPA 101, on mercantile occupancies, to incorporate requirements for children’s playgrounds in malls. The definition is added to clarify the type of structure involved. This was requested at the last cycle by the technical committees on Assembly Occupancies and Educational and Day-Care Occupancies. I will not repeat all the information provided in the proposal or in the comments to proposals 101-608, 101-624 and 5000-797. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Note that the term “multilevel play structure” is already defined in 3.3.217.5. At the time SAF-FUN met to prepare its ROC action, the ROP rejection of special requirements for children’s playground structures was still in effect. Thus, the term is not used in the Code. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-10 Log #193b SAF-MER FINAL ACTION: Reject (3.3.xx Children’s Playground Structure) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-56 RECOMMENDATION: Accept the proposal in part in principle with the following language in a new section in Chapter 3 on definitions: 3.3.xx Children’s Playground Structure. a play structure made up of one or more components intended for the entertainment of children where the user enters an enclosed play environment. SUBSTANTIATION: This proposal is consistent with the proposals made to Chapter 27 of NFPA 5000 and Chapters 36 and 37 of NFPA 101, on mercantile occupancies, to incorporate requirements for children’s playgrounds in malls. The definition is added to clarify the type of structure involved. This was requested at the last cycle by the technical committees on Assembly Occupancies and Educational and Day-Care Occupancies. I will not repeat all the information provided in the proposal or in the comments to proposals 101-608, 101-624 and 5000-797. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The proposed term is not used in the code. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-11 Log #169 SAF-MEA FINAL ACTION: Accept (3.3.xx Electrically-Locked Egress Doors (New) ) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-29 RECOMMENDATION: Reject the Proposal.

101-10

Report on Comments — Copyright, NFPA NFPA 101 SUBSTANTIATION: The entire subject of locking has been totally confused and mixed up by a series of proposals including this one. This is a totally different concept from access controlled egress doors. If it is to be in the Code it should be separate material. There are many electrically-locked egress doors that do restrict free egress at ANY time. Let’s stop, go back to square one and approach this more logically. For now return to the 2003 Code. COMMITTEE MEETING ACTION: Accept Delete the proposed definition of Electrically-Locked Egress Doors. COMMITTEE STATEMENT: The committee action accomplishes what the submitter requested, but explicitly states the action to be taken. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE ELVOVE: If the proposed language for this new definition is suspect, the technical committee did well to accept this comment. However, this subject needs to be addressed as there are many instances where electronic locks are being used without access control and criteria (definitions and requirements) addressing these installations is needed. Also see my comment on 101-51 (Log #162). _______________________________________________________________101-12 Log #171 SAF-MEA FINAL ACTION: Reject (3.3.xx Escape Device or System (New)) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-32 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: This material is not appropriate for the Life Safety Code. At best it could be used in one- and two-family dwellings and that chapter does not use the term. All of the occupancy committees except one have rejected the concept and there is a comment to reject it in that occupancy. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action on Comment 101-78 which retains the subject of escape devices and systems, but relocates it to a new Section 7.13 on supplemental evacuation equipment. Such evacuation equipment will not receive credit for satisfying any means of egress requirements. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 20 Negative: 2 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: I’m voting against the action of the Committee to reject 101-12 for the following reasons: ASTM Committee E06 on Performance of Buildings has appointed a new subcommittee, E.06-77 on High-Rise Building External Evacuation Devices. This subcommittee had their initial meeting in Washington, D.C. on October 3 and 4, 2004. It appears to be premature to accept these devices in NFPA 101 prior to the results from the initiated study by the ASTM subcommittee. SHULMAN: In regard to 101-12 and -13, please see Shulman comments submitted with the ROP ballot under 101-32. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me.COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). GUEST: I am voting to support this proposal to define an escape device or system. Based on documented disasters such as the one on 9/11, we know that the current codes in place cannot cover every possible disaster that could lead to loss of lives. The use of additional systems cannot anticipate every type of problem either, however, optional means of egress that do not interfere with systems required by the code may allow additional options for people to escape when regular means of egress are blocked. The support of the development of such secondary systems by NFPA will encourage development and add the experienced voice of NFPA to help define standards that will work with the codes in place now. KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78.

_______________________________________________________________101-13 Log #277 SAF-MEA FINAL ACTION: Accept in Principle (3.3.xx Escape Device or System (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-32 RECOMMENDATION: Revise text to read as follows: 3.3.xx* Escape Device or System. Dedicated equipment that provides an alternate means of egress or escape, typically on the exterior of the building or structure. A.3.3.xx Escape devices and systems include a variety of products on the market, some of which are not recognized by the Life Safety Code, as indicated in Section A.7.2.14. Devices such as but are not limited to cables, ropes, chain ladders, controlled descent devices, parachutes, slides, chutes, powered platforms, vertical take off and landing craft, and helicopter-suspended platforms typically do not meet the criteria of 7.2.14., the Life Safety Code recommends not recognizing some of these devices or systems. SUBSTANTIATION: As approved by the Assembly Occupancies Technical Committee, there are uses for escape devices from catwalks and platforms within such buildings. So although escape devices and systems are typically used for external evacuation, they are not exclusively so. In the balloting of some of the proposals on this subject, there was apparently some confusion as to what devices were considered to meet the criteria of 7.2.14. By the above changes to the Annex note, the confusion should be substantially alleviated. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Accept in Principle Revise text to read as follows: 3.3.xx* Escape Device or System. Dedicated equipment that provides a supplemental means of evacuation an alternate means of egress or escape, on the exterior of the building or structure. A.3.3.xx Escape devices and systems include a variety of products on the market, some of which are not recognized by the Code, as indicated in A.7.13.1. Devices such as but are not limited to cables, ropes, chain ladders, controlled descent devices, parachutes, slides, chutes, powered platforms, vertical take off and landing craft, and helicopter-suspended platforms typically do not meet the criteria of 7.2.13.1., As indicated in 7.2.14, the Code recommends not recognizing some of these devices or systems. COMMITTEE STATEMENT: The committee action is consistent with the action on Comment 101-78 which retains the subject of escape devices and systems, but relocates it to a new Section 7.13 on supplemental evacuation equipment. Such evacuation equipment will not receive credit for satisfying any means of egress requirements. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 20 Negative: 2 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: See my Explanation of Negative on Comment 101-12. SHULMAN: In regard to 101-12 and -13, please see Shulman comments submitted with the ROP ballot under 101-32. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78

101-11

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-13a Log #CC52 SAF-MEA FINAL ACTION: Accept (3.3 Fire Retardant-Treated Wood) _______________________________________________________________ SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-90 RECOMMENDATION: Add definition as follows: 3.3.xx Fire Retardant-Treated Wood. A wood product impregnated with chemical by a pressure process or other means during manufacture, which is tested in accordance with NFPA 255, has a listed flame spread of 25 or less, and shows no evidence of significant progressive combustion when the test is continued for an additional 20-minute period; nor does the flame front progress more than 10.5 ft (3200 mm) beyond the centerline of the burners at any time during the test. SUBSTANTIATION: See Comment 101-43a (Log #CC51) on 7.1.3.2.1(3) which recognizes the use of fire retardant-treated wood (FRTW). The definition is needed. It is copied from NFPA 5000. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE DE VRIES: For current purposes of correlation with NFPA 5000, the committee action is appropriate. It would be preferable to remove the performance requirements and relocate to another section, rather than incorporate those criteria into a definition. ELVOVE: Proposed text exceeds that of a definition and should therefore be truncated. And if NFPA 5000 reads similarly, then its definition needs to change as well. Note: use term consistently through the code where used (e.g., “fire retardant-treated wood”). KOFFEL: It is recognized that the submitter has proposed the same definition as currently exists in NFPA 5000™. However, the proposed definition is not consistent with the Manual of Style for NFPA Technical Committee Documents dated July 2004 in that the proposed definition contains requirements (Paragraph 2.3.2.3). I do not recommend that the TCC modify the action of SAF-MEA unless the definition in NFPA 5000™ can also be modified. A possible revised definition could be as follows: 3.3.xx* Fire Retardant Treated Wood. A wood product impregnated with chemical by a pressure process or other means during manufacture. A.3.3.xx Fire retardant treated wood is tested in accordance with NFPA 255, has a listed flame spread index of 25 or less, and shows no evidence of significant progressive combustion when the test is continued for an additional 20-minute period; nor does the flame front progress more than 10.5 ft (3200 mm) beyond the centerline of the burners at any time during the test. See also NFPA 703. _______________________________________________________________101-14 Log #5a SAF-FUN FINAL ACTION: Accept in Principle (3.3.xx Flame Spread Index (New) and 3.3.xx Smoke Developed Index (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-33 RECOMMENDATION: Add text to show UL 723 as an equivalent of NFPA 255 and ASTM E 84. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise as follows: 3.3.xx Flame Spread Index. A comparative measure, expressed as a dimensionless number, derived from visual measurements of the spread of flame versus time for a material tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, or ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Materials, or UL 723, Standard for Test for Surface Burning Characteristics of Building Materials. 3.3.xx Smoke Developed Index. A comparative measure, expressed as a dimensionless number, derived from measurements of smoke obscuration versus time for a material tested in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, or ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Materials, or UL 723, Standard for Test for Surface Burning Characteristics of Building Materials. Add UL 723 to Chapter 2 references, showing the edition date as 2003. COMMITTEE STATEMENT: The committee action accomplishes what the submitter requested. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: LATHROP: The Committee on Furnishings and Contents believes that UL 723 has not kept up with NFPA 255 and ASTM E-84. Therefore, at this time, it is not equivalent.

_______________________________________________________________101-15 Log #5b SAF-FUR FINAL ACTION: Accept in Principle (3.3.xx Flame Spread Index (New) and 3.3.xx Smoke Developed Index (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-14. The TCC also notes that in the Committee Statement prepared by SAF-FUR, the reference to NFPA 703 should instead be a reference to UL 723.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-33 RECOMMENDATION: Add text to show UL 723 as an equivalent of NFPA 255 and ASTM E 84. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is of the opinion that the NFPA 703 has not kept current with NFPA 255 and ASTM E84. Technical changes regarding mounting methods and calibration of equipment that have been incorporated into NFPA 255 and ASTM E84 have not been made to UL 723. Also see committee action and statement on Comment 101-3. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Negative: 1 EXPLANATION OF NEGATIVE: GANDHI: I voted negative on this ballot since UL 723 is technically equivalent to NFPA 255 with respect to calibration, test procedures (including mounting methods), and calculations. The technical correlating committee has not given any examples where UL 723 technically differs from NFPA 255. Please note that UL 723 was last revised in August 2003, when it was reissued as an ANSI document. _______________________________________________________________101-16 Log #6 SAF-FUN FINAL ACTION: Accept in Principle (3.3.xx Kitchen (New)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-35 RECOMMENDATION: Give consideration to Hurley’s Explanation of Negative and Lathrop’s Comment on Affirmative so as to make any needed changes. HURLEY: The proposed definition of kitchen is much too narrow. Paragraph 7.5.2.1 prohibits exit access through a kitchen. The reason for defining a “kitchen” was because the Fundamentals committee became aware of situations where exit access was being prohibited through spaces that contained only food warming equipment or microwave ovens. The intent of the Fundamentals committee was to define “kitchen” such that exit access could be permitted through these types of spaces. However, kitchens could contain hazards other than stoves or cooktops. Consider, for example, a food preparation area in a fast food restaurant that only serves fried chicken. Such a food preparation area might contain only deep fat fryers, with no stoves or cooktops. If this new definition for “kitchen” were added to the code, the code could reasonably be interpreted as permitting exit access through this type of space, since it would not meet the definition of a “kitchen”. Adding this definition to the code in its present form would create a very dangerous loophole. It should not be added in its present form, because if it were to be accepted as part of the ROP, changing it would require a 2/3 majority of the committee. If a more all-encompassing definition cannot achieve the 2/3 majority as part of the ROC, the 2006 edition of the code would be published with this seriously flawed definition. I would invite those that are concerned with the misapplication of the code to create a more comprehensive definition during the ROC period. LATHROP: This definition still needs work. Fryers must be added as they are one of the biggest hazards in the definition. Also broilers and ovens need to be addressed. To prevent microwave ovens from making a room a kitchen, maybe a minimum size needs to be added such as over 4 cu ft. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-35 so as to NOT add a definition of kitchen. COMMITTEE STATEMENT: The definition of Kitchen proposed at the ROP stage creates confusion, rather than clarity. See Comment 101-434a (Log #CC10) which adds advisory annex text A.7.5.1 to help clarify the subject. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-17 Log #235 SAF-FUN FINAL ACTION: Reject (3.3.xx Kitchen (New) ) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-35 RECOMMENDATION: Revise text to read as follows: 3.3.xx Kitchen. A room ... food utilizing a stove or cooktop high hazard appliances. 3.3.xy Kitchenette. A room or area for warming or preparing food with low hazard appliances. SUBSTANTIATION: I agree with TC member Hurley, but should consider differences between commercial and residential and also kitchenettes. COMMITTEE MEETING ACTION: Reject

101-12

Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE STATEMENT: See committee action on Comment 101-16 which rejects Proposal 101-35 so as to NOT add a definition of kitchen. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

_______________________________________________________________101-18 Log #216 SAF-DET FINAL ACTION: Reject (3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Kevin J. Kelly, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Revise the definition of lockup as follows: An area incidental to an occupancy that is not detention and correctional where occupants are restrained and such occupants are mostly incapable of self preservation because of security measures not under the occupant’s control. SUBSTANTIATION: To close a loophole that would allow the lockup concept to be utilized to avoid other detention and correctional requirements where the lock-up is the predominant occupancy. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: If the words “incidental to the occupancy” were added, a free-standing building used to hold persons (for example, a border-crossing building used exclusively to detain illegal immigrants) would not get defined as a lock-up and, thus, would not be subject to the new requirements for lock-ups. The SAF-DET committee intends for the lock-up provisions to apply to non-detention occupancies regardless of whether the function of detaining persons is incidental. See also the action on Comment 101-295a which clarifies that the lock-ups (1) where an individual stays more than 24 hours or (2) with more than 50 persons, constitute a detention and correctional facility that must meet all the provisions for a detention and correctional occupancy, not the provisions for lock-ups. The language in ROP Proposal 101-476, referring to following “the requirements of Chapter 22/23 for detention and correctional occupancies,” could be misread so as to require following only the provisions of the new subsection on lock-ups. NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-19 Log #7 SAF-MER FINAL ACTION: Accept in Principle (3.3.27.2 Anchor Building) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-43 RECOMMENDATION: Review and take any action needed on the subject given that the definition of Anchor Building shown in the Recommendation represents a revision that was distributed to the SAF-MER technical committee part of the way through the letter balloting process. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle The committee reaffirms its action of Accept on proposal 101-43 and recommends that the definition of read as follows: Anchor Building. A building housing any occupancy having low or ordinary hazard contents and having direct access to a mall building, but having all required means of egress independent of the mall. COMMITTEE STATEMENT: The committee reaffirms its statement in the ROP. It is not the committee’s intent to prohibit anchor buildings housing occupancies such as hotels from being part of a mall complex. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA recognizes the concerns raised by Mr. Thornberry regarding the potential fire and life safety impacts (e.g., occupant loading and means of egress) resulting from the inclusion of transportation facilities in mall buildings. NEMA is in favor of accepting Comment 101-21 and supports Mr. Thornberry’s recommendation for egress studies to be conducted to address these concerns in accordance with this substantiation for comments 101-425 and 101-426. EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment, I would vote negative to reject the action taken. See my comment son Comment 101-21.

_______________________________________________________________101-20 Log #223 SAF-AXM FINAL ACTION: Reject (3.3.10.3 Arena Stage) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-58 RECOMMENDATION: No revision proposed. Reconsider proposal as submitted. SUBSTANTIATION: The material and substantiation submitted with the original proposal was substantial and definitive in the consideration of defining types of stages that require fire curtains at a lower level and types of stages that would not be included in a fire curtain requirement. The definitions in this original proposal would be used with the acceptance of 101-325. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Inadequate substantiation for the change requested. See Committee Statement for the rejection of ROP Proposals 101-325 and 101-326. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-21 Log #264 SAF-MER FINAL ACTION: Reject (3.3.27.2 Anchor Building) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-43 RECOMMENDATION: Delete the proposed text for Anchor Building and substitute the following: Anchor Building. A building housing assembly, business, and mercantile occupancies, other than bulk merchandise retail, having low or ordinary hazard contents and having direct access to a mall building, but having all required means of egress independent of the mall. SUBSTANTIATION: This revised definition which we have proposed is identical to the current definition in NFPA 5000, Section 3.3.58.3. The Committee has not provided any technical justification for the revisions to the definition shown in the original proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-19. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA recognizes the concerns raised by Mr. Thornberry regarding the potential fire and life safety impacts (e.g., occupant loading and means of egress) resulting from the inclusion of transportation facilities in mall buildings. NEMA is in favor of accepting Comment 101-21 and supports Mr. Thornberry’s recommendation for egress studies to be conducted to address these concerns in accordance with this substantiation for comments 101-425 and 101-426. EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment, I would vote negative on the Committee Action to reject this Public Comment which I submitted on behalf of one of my clients, the Alliance for Fire and Smoke Containment and Control (AFSCC), regarding the definition for “Anchor Building.” As indicated in the Substantiation for the Public Comment, the proposed definition is identical to that contained in 3.3.58.3 of NFPA 5000. Thus, this would provide consistency between the two codes. Furthermore, it is much more specific than the definition proposed in Proposal 101-43 which is very open ended and virtually allows any occupancy having low or ordinary hazard contents to be an anchor building. That definition goes way beyond the original concept for anchor buildings that were incorporated into the original covered mall building provisions and upon which all the regulations for covered mall buildings were based after a significant evaluation of existing covered mall buildings at the time. If this definition is to be expanded, then the regulations regarding covered mall buildings and anchor buildings should be completely reevaluated to determine how the expanded allowable use of occupancies in anchor buildings would impact the overall level of life safety provided.

101-13

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-22 Log #8 SAF-RES FINAL ACTION: Accept in Principle (3.3.50 Dwelling Unit) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-49A RECOMMENDATION: Give consideration to the proposal so as to make any needed changes. The TCC learned at its ROP meeting [which occurred after the Technical Committee on Residential Occupancies (SAF-RES) held its ROP meeting] of the formation of a task group by the NEC project to address the definition of Dwelling Unit. As no new wording has yet been recommended for the definition, this proposal is shown as “Rejected.” This proposal was submitted by the TCC to permit the SAF-RES committee to make any needed changes to the definition of Dwelling Unit during ROC preparation. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-23. COMMITTEE STATEMENT: The action on Comment 101-23 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-22a Log #CC12 SAF-FUN FINAL ACTION: Accept (3.3 Dwelling Unit) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-49A RECOMMENDATION: Revise 3.3.50 as follows: Dwelling Unit. One or more rooms arranged for the use of one or more individuals living together, providing complete, independent housekeeping purposes, with space for living facilities, including permanent provisions for living, eating, living, and sleeping, eating,; facilities for cooking,; and provisions for sanitation. SUBSTANTIATION: The NEC TCC requested that Panels 1 and 2 and SAF/BLD-RES form a task group to revise and correlate the definition of Dwelling Unit. The task group met twice via teleconference calls along with numerous e-mails to resolve the issue. It is the task group’s opinion that this one definition will meet the needs of the NEC, NFPA 1, NFPA 101, and NFPA 5000 with regard to dwelling units. It believes that this definition does not change the intent of any of the codes, while at the same time simplifies and clarifies what a dwelling unit is and correlates the four documents. Members of the task group include David Hittinger and Lanny McMahill from NEC CMP-1, Donald King and Susan Porter from NEC CMP-2, and James Lathrop and Harry Bradley from the SAF/BLD-RES committee. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-23 Log #114 SAF-RES FINAL ACTION: Accept (3.3.50 Dwelling Unit) _______________________________________________________________ SUBMITTER: John D. Minick, National Electrical Manufacturers Association COMMENT ON PROPOSAL NO: 101-49A RECOMMENDATION: Revise 3.3.50 as follows: 3.3.50 Dwelling Unit. One or more rooms arranged for the use of one or more individuals living together, providing complete, independent housekeeping purposes, with space for living facilities, including permanent provisions for living, eating, living, and sleeping, eating,; facilities for cooking. and provisions for sanitation. SUBSTANTIATION: The NEC TCC requested that Panels 1 and 2 and SAF/BLD-RES form a task group to revise and correlate the definition of Dwelling Unit. The task group met twice via teleconference calls along with numerous e-mails to resolve the issue. It is the task group’s opinion that this one definition will meet the needs of the NEC, NFPA 1, NFPA 101, and NFPA 5000 with regard to dwelling units. It believes that this definition does not change the intent of any of the codes, while at the same time simplifies and clarifies what a dwelling unit is and correlates the four documents. Members of the task group include David Hittinger and Lanny McMahill from NEC CMP-1, Donald King and Susan Porter from NEC CMP-2, and James Lathrop and Harry Bradley from the SAF/BLD-RES committee COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM

_______________________________________________________________101-24 Log #116 SAF-RES FINAL ACTION: Accept in Principle (3.3.50 Dwelling Unit) _______________________________________________________________ SUBMITTER: Lanny G. McMahill Phoenix, AZ COMMENT ON PROPOSAL NO: 101-49A RECOMMENDATION: Revise 3.3.50 as follows: 3.3.50 Dwelling Unit. One or more rooms arranged for the use of one or more individuals living together, providing complete, independent housekeeping purposes, with space for living facilities, including permanent provisions for living, eating, living, and sleeping, eating,; facilities for cooking,; and provisions for sanitation. SUBSTANTIATION: The NEC TCC requested that Panels 1 and 3 and SAF/BLD-RES form a task group to revise and correlate the definition of “Dwelling Unit.” The task group met twice via teleconference calls along with exchanging several e-mails. The group discussed and debated many variations of the definition and eventually came to a reasonable compromise to resolve the issue. It is the task group’s opinion that this one definition will meet the needs of the NEC, NFPA 1, NFPA 101, and NFPA 5000 with regard to dwelling units. The task group believes that this definition does not change the intent of any of the codes, while at the same time simplifies and clarifies what a dwelling unit is and correlates the four documents. A few words have been deleted from the original definition, as they were considered unnecessary. Words added to the definition that provide clarification include “housekeeping” and “facilities.” “Housekeeping” meaning “to perform the routine duties (as cooking and cleaning) of managing a house,” and “facilities” meaning “services and space and equipment provided for a particular purpose. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-23. COMMITTEE STATEMENT: The action on Comment 101-23 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-24a Log #CC9 SAF-FUN FINAL ACTION: Accept (3.3.134.3 Business Occupancy, and 6.1.11.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that the action by SAF-FUN was not “information balloted” by SAF-MER because SAF-MER earlier approved the same change to the definition of Business Occupancy for NFPA 5000.SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-14 RECOMMENDATION: Revise as follows: 3.3.152.3* Business Occupancy. An occupancy used for account and record keeping or the transaction of business other than mercantile. 6.1.11.1* Definition - Business Occupancy. An occupancy used for account and record keeping or the transaction of business other than mercantile. SUBSTANTIATION: In Proposal 101-14, SAF-FUN revised definitions by adopting the some preferred definitions from the Glossary of Terms which in many cases involved adopting the NFPA 5000 version of a definition. In the NFPA 5000 ROP being processed in the same revision cycle as NFPA 101, the BLD-MER committee revised the definition of Business Occupancy but did not propose a similar change for NFPA 101. This comment recommends changes that will make the NFPA 101 definition of Business Occupancy read the same as that proposed for NFPA 5000. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

_______________________________________________________________101-25 Log #9a SAF-AXM FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposals 101-51 and 101-476.COMMITTEE STATEMENT: The SAF-AXM committee understands the need for special provisions for lock-ups to supplement the requirements for assembly occupancies. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

101-14

Report on Comments — Copyright, NFPA NFPA 101

_______________________________________________________________101-26 Log #9b SAF-BCF FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reviewed the proposed lock-up provisions and determined they do not affect board and care facililties. Therefore, no action is necessary. The committee notes it has no objection to the proposed lock-up provisions. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-27 Log #9c SAF-END FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of Proposal 101-51 and Proposal 101-476. COMMITTEE STATEMENT: The BLD/SAF-END committee does not take exception to the proposed provisions for Lock-ups. The committee is aware that BLD/SAF-DET will hold its ROC meeting after all the other occupancy chapter committees have met. The committee has requested that BLD/SAF-DET add mandatory references (that is, “pointers” to the provisions for Lock-ups) in each of the occupancy chapters via a committee comment. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-28 Log #9d SAF-HEA FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-292. COMMITTEE STATEMENT: The action on the referenced comment responds adequately to the issue from the perspective of health care occupancies. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-29 Log #9e SAF-IND FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 3.3.xx Lock-up and 6.1.7.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: BLD-IND takes no issue with the provisions introduced by proposals 101-51 and 101-476, and notes that the provisions do not apply to industrial and storage occupancies. Also see committee action on comment 101-293. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-30 Log #9f SAF-MER FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: SAF-MER is in support of the action taken by SAF-DET on proposals 101-51 and 101-476. Also see Committee Action on Comment 101-294. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-31 Log #9g SAF-RES FINAL ACTION: Accept in Principle (3.3.152.5 Detention and Correctional Occupancy, 6.1.7.1 and 3.3.xx Lock-up) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-51 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reviewed the proposed lock-up provisions and determined they do not affect the residential occupancy chapters. Therefore, no action is necessary. The committee notes it has no objection to the proposed lock-up provisions. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-32 Log #352 SAF-FUN FINAL ACTION: Reject (3.3.152.13 Residential Board and Care Occupancy) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-52 RECOMMENDATION: Reconsider. SUBSTANTIATION: Actual experience shows that patients with profound mental, physical and developmental disabilities are being placed in Board and Care facilities. Custodial care occurs in both impractical Board and Care and in Limited Care Health Care, with and without licensed medical care. As stated by the BCF committee, occupancy classification should always be based on the use of a building or not on what it is called. The self-preservation capabilities of occupants in impractical Board and Care are indistinguishable from those in Limited Care Health Care. Either impractical B&C is limited care, or the threshold between the two needs to be made distinct. The committee’s characterization of the proposal as not true was defensive, rather than objectively evaluated and substantiated. The language of the proposed definition was documented as having been taken from the International Building Code. The IBC definition makes the distinction of occupancy by self-preservation capability clearly apparent and simplifies code application. Facilities constructed in accordance with the national building codes classify impractical Board & Care equivalent facilities as institutional by use. This clarity of definition also simplifies the criteria for assessing when diminishing occupant capabilities render a facility inappropriate for that level of care. Prior committee actions eliminating evacuation capability evaluations from new Board and Care indicates the committees’ intent to clean up the extremely variable, evacuation capability concept. This proposed revised definition completes this effort by standardizing the same occupant self-preservation capability to existing facilities. The Board and Care occupancy fundamentally contradicts its own intentions by identifying occupants as impractical to evacuate; yet requires their movement to a point of safety, while Health Care takes similarly incapable occupants and defends them in place. This proposal corrects the definition of Board and Care on the basis of the occupants’ capability for self-preservation. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: A definition is not the appropriate place to equalize the requirements for new board and care (Chapter 32) and existing board and care (Chapter 33). It is better to let the Code requirements, not the definitions, address the subject. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-33 Log #353 SAF-BCF FINAL ACTION: Reject (3.3.152.13 Residential Board and Care Occupancy) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-53 RECOMMENDATION: Reconsider. SUBSTANTIATION: Actual experience shows that patients with profound mental, physical and developmental disabilities are being placed in Board and Care facilities. Custodial care occurs in both impractical Board and Care and in Limited Care Health Care, with and without licensed medical care. As stated by the committee, occupancy classification should always be based on the use of a building or not on what it is called. The self-preservation capabilities of occupants in impractical Board and Care are indistinguishable from those in Limited Care Health Care. Either impractical B&C is limited care, or the threshold between the two needs to be made distinct. The proposed definition was based on the International Building Code approach. The IBC definition makes the distinction of occupancy by self-preservation capability clearly apparent and simplifies code application. Facilities constructed in accordance with the national building codes classify impractical Board & Care equivalent facilities as institutional by use. This clarity of definition also simplifies the criteria for assessing when diminishing occupant capabilities render a facility inappropriate for that level of care. Prior committee actions eliminating evacuation capability evaluations from new Board and Care indicates the committees’ intent to clean up the extremely variable, evacuation capability concept. This proposed revised definition completes this effort by standardizing the same occupant self-preservation capability to existing facilities. The Board and Care occupancy fundamentally contradicts its own intentions by identifying occupants as impractical to evacuate; yet requires their movement to a point of safety, while Health Care takes similarly incapable occupants and defends them in place. Impractical residents should not be afforded different levels of safety because of occupancy. That is contrary to occupancy based fire protection. This proposal corrects the definition of Board and Care on the basis of the occupants’ capability for self-preservation. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment is rejected for the following reasons: 1. As submitted, the definition would force many board and care facilities to be classified as health care occupancies. In some cases, this can decrease the level of protection (e.g. fewer requirements for smoke detection). 2. The Code allows the authority having jurisdiction to make the final determination of occupancy classification. If the AHJ determines a facility meets the definition of a limited care facility, it should be classified as health care. 3. The Code has always assumed board and care facility occupants might require staff assistance to relocate to a point of safety. The committee notes that like board and care occupants, health care occupants might be required to relocate to a point of safety depending on the fire location and severity. The Code does not assume all health care occupants will be protected in place without moving, or being moved, to an adjoining smoke compartment. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-34 Log #224 SAF-AXM FINAL ACTION: Reject (3.3.210 Stage) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-57 RECOMMENDATION: No revision proposed. Reconsider proposal as submitted. SUBSTANTIATION: The material and substantiation submitted with the original proposal was substantial and definitive in the consideration of defining types of stages that require fire curtains at a lower level and types of stages that would not be included in a fire curtain requirement. The definitions in this original proposal would be used with the acceptance of 101-325. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Inadequate substantiation for the change requested. See Committee Statement for the rejection of ROP Proposals 101-325 and 101-326. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-35 Log #314 SAF-FUN FINAL ACTION: Accept in Principle (3.3.217.8 Temporary) _______________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-59 RECOMMENDATION: Revise to read: Temporary. A building or structure that is in place for a period of 180 days or less in a 12 month period. SUBSTANTIATION: The proposed change is consistent with the current definition of Permanent. The proposed wording better clarifies the terms of when a building is temporary. It also provides guidance on when to consider a building as permanent. COMMITTEE MEETING ACTION: Accept in Principle Revise the 3.3.217.8 definition of Permanent Structure as follows: Permanent Structure. A building or structure that is intended to remain in place for a period of more than 180 consecutive days in any consecutive 12 month period. COMMITTEE STATEMENT: The committee action should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: THORNBERRY: The current definition for “Permanent Structure” is adequate. The proponent of the Comment on Proposal 101-59 did not provide any substantiation that justified the Committee making the revisions proposed to the definition for “Permanent Structure”. Certainly, a permanent structure is one that is going to remain in place for consecutive days and not a random number of days within any consecutive 12 month period. How can one consider a structure that is in place for a period of 90, days then is removed and is set in place for another 91 days at the same location a few months later but still within a consecutive 12 month period, to be a permanent structure? As the revisions are proposed to the definition for “Permanent Structure”, it becomes a potential record keeping nightmare to keep track of the structure that may be removed and relocated, then moved back over a period of many months but which is only occupied for a few days at a given time. In summary, without any overwhelming supporting documentation provided to indicate the need to change the definition for “Permanent Structure”, I can’t see the why the Committee should do it. Therefore, I urge that this Public Comment be rejected. Furthermore, the proponent for the original Proposal 101-59 was attempting to resolve differences between the definitions for “permanent” and “temporary” which were contained in NFPA 102-1995 rather than what is currently shown in NFPA 101-2003. As NFPA 101 deals with the definition for “Temporary Structure”, it simply indicates that such a structure does not meet the definition for “Permanent Structure.” Certainly this resolves any conflict that could result where both definitions are defined independently of the other. _______________________________________________________________101-36 Log #10 SAF-BSF FINAL ACTION: Accept in Principle (3.3.218 System, Elevator Evacuation System, Standpipe System) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-60 RECOMMENDATION: Review and take any action needed on the subject of the proposed deletion by SAF-FUN of the definition of Standpipe System, given that the SAF-BSF has primary responsibility for the provisions of 9.7.4.2. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete the definition of ‘standpipe system’ in 3.3.218.2. COMMITTEE STATEMENT: The Technical Committee on Building Service and Fire Protection Equipment concurs with the action taken by the Technical Committee on Fundamentals to delete the definition of the term ‘standpipe system.’ NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-37 Log #290 SAF-FUN FINAL ACTION: Reject (4.2.1) _______________________________________________________________ SUBMITTER: Tony Crimi, A.C. Consulting Solutions, Inc. / Rep. International Firestop Council COMMENT ON PROPOSAL NO: 101-61 RECOMMENDATION: Revise text to read as follows: 4.2.1 Occupant Protection. A structure shall be designe d, and constructed, and maintained to reasonably prevent the spread of fire and smoke and to protect occupants who are not intimate with the initial fire development for the time needed to evacuate, relocate, or defend in place. SUBSTANTIATION: The Committee raised concerns that the proposed language was too specific in regard to the “high level” objective. The proponents wording did capture some additional concepts which are consistent with other sections of NFPA 101, namely the concept of “maintaining”

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Report on Comments — Copyright, NFPA NFPA 101 building components, whether passive or active, in order to provide a barrier to the free movement and growth of fire and smoke. This should be captured in Chapter 4. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The high level objective of 4.2.1 needs to remain clearly focussed without additional detail. The submitter’s language is too vague to be useful. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-38 Log #354 SAF-FUN FINAL ACTION: Reject (4.5.1.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-63 RECOMMENDATION: Revise: Multiple safeguards should be both passive fire protection features as identified in Chapter 8 and active fire protection systems features as identified in Chapter 9 used in combination, without placing total reliance on either one. SUBSTANTIATION: Acknowledging Mr Wills ROP comment, the terminology is expanded for clarity. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Proposal 101-63 is being rejected so as NOT to add A.4.5.1. See Comment 101-38a (Log #CC11). NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: THORNBERRY: It is my opinion that the proponent of this Public Comment has provided additional clarification to the original proposal which was accepted by the Committee by a vote of 17 to 1. The reason the Committee has rejected the proposed revisions suggested by the proponent is that the Committee generated a Committee Comment 101-38a to reject the original Proposal 101-63. No other substantiation was given. It is my opinion that the clarification greatly improves this Annex note which is only provided as guidance as to how to look at multiple safeguards when providing a fire protection solution to a life safety problem in a building. Since the proposed revisions reflect the terminology used in Section 5.5.3.8, it can be assumed that persons using this code section would be familiar with the terminology related to both active and passive fire protection features. _______________________________________________________________101-38a Log #CC11 SAF-FUN FINAL ACTION: Accept (A.4.5.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-63 RECOMMENDATION: Reject Proposal 101-63 so as NOT to add A.4.5.1. SUBSTANTIATION: Chapters 8 and 9 do not use the terms “active” and “passive” to define the systems they address. It is possible to achieve the intended level of safety, and not rely on a single safeguard, without using features/systems from both Chapters 8 and 9. The proposed annex guidance is too restrictive. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: THORNBERRY: I do not agree with the Committee Action to reverse its previous action of Accept in Principle on Proposal 101-63. The original Committee Action was successful by a vote of 17 to 1. Furthermore, it should be noted that this is only an Annex note which is intended to provide additional guidance as to how one might interpret and apply the provisions of the code. This Annex note does not mandate anything but simply provides an indication that when evaluating multiple safeguards to provide a solution to a fire protection problem, that both active and passive fire protection features be considered and be used in combination so that total alliance does not occur on either one. This provides a balanced approach to providing a fire protection solution which greatly enhances the probabilities that in the event of a fire problem, the level of safety will still be provided. This approach is further elaborated on in Section 5.5.3.8 Design Fire Scenario 8 which also contains an Annex note discussing the possible failure of any one passive or active fire protection system or feature needing to be considered when a performance based design is being implemented. Thus, the Annex note in Proposal 101-63 actually provides continuity as well as a link between the general goals and objectives in Chapter 4 and the goals and objectives in Chapter 5 for performance based design.

_______________________________________________________________101-39 Log #185 SAF-FUN FINAL ACTION: Reject (4.5.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Salvatore DiCristina, Rutgers, The State University of New Jersey / Rep. NFPA Building Code Development COMMENT ON PROPOSAL NO: 101-64 RECOMMENDATION: Reverse the action taken by the committee. SUBSTANTIATION: The capabilities of fire department services are dynamic and difficult to quantify. We concur with the dissenting committee members. COMMITTEE MEETING ACTION: Accept In 4.5.2, do NOT add the new item (5) Capabilities of response personnel. COMMITTEE STATEMENT: The committee action does what the submitter requested, and shows the text that is to be deleted. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 13 Negative: 8 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: CARSON: Response personnel can be a significant part of the response to a fire or other emergency. Response personnel do not just include fire department but also include in-house personnel. NFPA 5101 includes reference to staff actions in several locations including: 3.3.57* Evacuation Capability. “The ability of occupants, residents, and staff as a group either to evacuate a building or to relocate from the point of occupancy to a point of safety.” 4.5.3.2 Unobstructed Egress. “No lock or fastening shall be permitted that prevents free escape from the inside of any building other than in health care occupancies and detention and correctional occupancies where staff are continually on duty and effective provisions are made to remove occupants in case of fire or other emergency.” 5.4.5.5* Staff Assistance. “The inclusion of trained employees as part of the fire safety system shall be identified and documented.” 7.2.13.1 “(6) An evacuation plan that specifically includes the elevator shall be implemented and staff personnel shall be trained in operations and procedures for elevator emergency use in normal operating mode prior to fire fighter recall.” 9.6.3.3 “Where permitted by Chapter 11 through Chapter 42, a presignal system shall be permitted where the initial fire alarm signal is automatically transmitted without delay to a municipal fire department, to a fire brigade (if provided), and to an on-site staff person trained to respond to a fire emergency.” There are many other sections of NFPA 101 that specifically reference the intervention of humans in providing some fire safety function. (All of these references are not listed here for the sake of brevity, but NFPA 101 includes references to staff performing some emergency function in well over 50 separate locations.) Deleting the reference to response personnel is in direct conflict with requirements presently in the Code. CHENG: It is my opinion that “capability of response personnel” contributes to the level of safety for an individual building or structure and its occupants. Therefore due regards should be given to the “capability of response personnel”. GREENE: The capabilities of response personnel are a dynamic variable. This variable will change over time. It is influenced by budgets, growth and other demands on the fire service. It is unreasonable to assume you can predict what the capabilities will be in 5 year or 10 years. The building safeguards should be intrinsic to the building not based upon outside factors that will change with time. GRONER: The requirements in Chapter 4 are “general,” that is, intended to provide perspective and orientation for the entire code. As such, code language should NOT preserve the fiction that human response capabilities are beyond the scope of code provisions and that codes should only cover the physical components of the buildings. More specifically, in many settings, the “appropriateness of safeguards” inextricably depends on the “capabilities of response personnel.” Judgments about appropriateness necessarily take into account response capabilities. The commenter claims that a problem with “response personnel” is that they are “dynamic,” but aren’t all active systems “dynamic”? If “dynamic” means changeable, then the number of occupants and their capabilities should also be deleted from the list. Valid judgments about the appropriateness of safeguards simply depend on being sufficiently conservative. LATHROP: First, the commentors only refer to fire dept. personnel. In both health care and in detention and correctional occupancies, there are in-house personnel that the Code does rely on. In addition, the Code does recognize responding fire dept personnel to some degree, especially in NFPA 5000, in that exposure distances would have to be significantly larger if we assumed there was no fire dept response. The fact that we allow a Class 1 standpipe without a fire pump for low-rise buildings implies that we are relying on the fire dept. The fact that we allow Class 1 standpipes at all implies we are relying on the fire dept. I am not an advocate of deleting basic fire protection, because “there is a fire house across the street,” but we must acknowledge that the Code does, in fact, recognize fire dept. response to some extent. PAULS: I am opposed to FUN TC action at the ROC stage that reverses its earlier action at ROP stage. First, “response personnel” includes more than only the fire services. Those coming from outside the building also include EMS and

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Report on Comments — Copyright, NFPA NFPA 101 police personnel. On site, there may also be fire safety directors. Second, those opposed have complained about fluctuations over time; this is true of other items in the list. Third, those opposed have not attacked the last item, “Other factors necessary to provide occupants with a reasonable degree of safety,” which covers a broad array of factors that can also fluctuate over time. Finally, the requirement refers to “due regard” which, among other things, could mean “appropriate consideration,” so one is not realistically expected to predict the future, but it is reasonable to consider what is known at a given time. Incidentally, one possible partial fix is to replace the word, “capabilities” (which is also used in item 2), with a broader term such as “role” or “roles.” Response personnel role(s) can be more readily identified than can capabilities. SKALKO: The explanation for the negative ballots by Lathrop and Thornberry present good reasons why the provisions of 4.5.2 should include the capabilities of response personnel in the consideration of appropriate safeguards for fire and life safety in buildings. The Committee proposal should be accepted as previously approved. THORNBERRY: I believe the Committee has missed the point of Proposal 101-64 which was originally generated by the Committee and accepted on a vote of 17 to 1 to include the capabilities of response personnel when assessing the appropriateness of safeguards being provided as required by the code. There is a basic assumption underlining the provisions incorporated into the Life Safety Code for providing a reasonable level of fire and life safety that there will be response provided by emergency personnel. On that basis any life safety design must consider the capabilities of the responding personnel when assessing the implementation of the code, especially as it relates to achieving the goals and objectives specified in Chapter 4 and, more importantly, in a performance based design approach in Chapter 5. The proponent of this Public Comment indicates that the capabilities of fire department services are dynamic and difficult to quantify. The same can certainly be said of Item (2) Capabilities of the Occupants which is currently enumerated in Section 4.5.2 Appropriateness of Safeguards. Section 4.5 Fundamental Requirements is basically provided for assessing the intent of the code when there becomes an interpretive issue as to how the code should apply to a specific condition. Incorporating capabilities of response personnel in Section 4.5.2 makes sense since throughout the code there are requirements provided that recognize emergency response. For example, standpipes may be required in specific occupancies under specific conditions which are provided assuming there is a certain emergency response being provided by a local fire department. In many cases when automatic sprinkler systems are required, they are mandated to be electrically supervised with the water flow alarm being monitored to notify the local fire department when it is activated, again acknowledging that there will be a fire department response. In summary, retaining Proposed new Item (5) Capabilities of Response Personnel does not put any unrealistic burden on the users of the code or the enforcers of the code but simply delineates another consideration that should be undertaken when assessing the appropriateness of safeguards being provided by a design to meet the intent of the Life Safety Code for a specific project. _______________________________________________________________101-40 Log #355 SAF-FUN FINAL ACTION: Reject (4.5.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-64 RECOMMENDATION: Delete: (5) Capabilities of response personnel SUBSTANTIATION: This item should be deleted unless response personnel are physically present at all times that the building is occupied. All of the safeguards of this document refer to features physically inherent and internal to the building. As stated by Mr Wills, external resources are too variable to depend upon equally over time. Accepted proposal 101-75 #335 “Continuous maintenance of requirements developed as part of a performance based design would be virtually impossible to enforce when applied to municipal response capabilities. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 13 Negative: 8 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: CARSON: See my Explanation of Negative on Comment 101-39. CHENG: See my Explanation of Negative on Comment 101-39. GREENE: The capabilities of response personnel are a dynamic variable. This variable will change over time. It is influenced by budgets, growth and other demands on the fire service. It is unreasonable to assume you can predict what the capabilities will be in 5 year or 10 years. The building safeguards should be intrinsic to the building not based upon outside factors that will change with time.

GRONER: The commenter seems to confuse the list of factors in 4.5.2 with the safeguards. However, the safeguards are not listed. The list is factors that should be taken into consideration when judging the appropriateness of various safeguards. Further, the commenter seems to equate “response personnel” with “fire department services,” but the term “response personnel” should be defined more broadly. In health care, board and care many residential, assembly occupancies, etc. life safety strategies cannot be accomplished without the actions of trained onsite staff. The code should acknowledge the appropriateness of safeguards on their response capabilities. The committee was originally correct in including “response personnel” in the list of factors that need to be considered when judging the appropriateness of safeguards. LATHROP: First, the commentors only refer to fire dept. personnel. In both health care and in detention and correctional occupancies, there are in-house personnel that the Code does rely on. In addition, the Code does recognize responding fire dept personnel to some degree, especially in NFPA 5000, in that exposure distances would have to be significantly larger if we assumed there was no fire dept response. The fact that we allow a Class 1 standpipe without a fire pump for low-rise buildings implies that we are relying on the fire dept. The fact that we allow Class 1 standpipes at all implies we are relying on the fire dept. I am not an advocate of deleting basic fire protection, because “there is a fire house across the street,” but we must acknowledge that the Code does, in fact, recognize fire dept. response to some extent. PAULS: I am opposed to FUN TC action at the ROC stage that reverses its earlier action at ROP stage. First, “response personnel” includes more than only the fire services. Those coming from outside the building also include EMS and police personnel. On site, there may also be fire safety directors. Second, those opposed have complained about fluctuations over time; this is true of other items in the list. Third, those opposed have not attacked the last item, “Other factors necessary to provide occupants with a reasonable degree of safety,” which covers a broad array of factors that can also fluctuate over time. Finally, the requirement refers to “due regard” which, among other things, could mean “appropriate consideration,” so one is not realistically expected to predict the future, but it is reasonable to consider what is known at a given time. Incidentally, one possible partial fix is to replace the word, “capabilities” (which is also used in item 2), with a broader term such as “role” or “roles.” Response personnel role(s) can be more readily identified than can capabilities. SKALKO: The explanation for the negative ballots by Lathrop and Thornberry present good reasons why the provisions of 4.5.2 should include the capabilities of response personnel in the consideration of appropriate safeguards for fire and life safety in buildings. The comment should be rejected and the original Committee language for 4.5.2 retained. THORNBERRY: See my Explanation of Negative on Comment 101-39. _______________________________________________________________101-41 Log #11 SAF-FUN FINAL ACTION: Accept in Principle (4.5.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-68 RECOMMENDATION: Review and take any action needed on the subject of the proposed change by SAF-FIR to 4.5.5, given that SAF-FUN has primary responsibility for the text. Give consideration to Holmes’, Kapalczynski’s, and Roeper’s Explanation of Negative so as to make any needed changes. HOLMES: The use of the word, “limit”, implies a prescribed maximum amount, quantity, or number. As noted in the Committee Substantiation, limit means to bound or set a boundary. The Life Safety Code does not presently, nor does it intend to, establish a maximum amount or numerical boundary for smoke movement. KAPALCZYNSKI: The proposal offers a choice of words connected by “or.” This invites multiple interpretations, which results in greater difficulty in enforcement. One word is preferable and that word is “resist.” The committee has reviewed numerous proposals for requiring specific air leakage requirements in smoke barriers and smoke partitions. Each of these proposals has been rejected on the basis that existing smoke barriers and smoke partitions already perform adequately with respect to the intent of the code and that the necessity for additional technical requirements are not substantiated. Consequently, proposals to more finely calibrate the wording alone, when additional technical requirements have already been rejected, should be rejected, too. Applying “resist” to smoke partitions and “limit” to smoke barriers confuses the clarity of the code intent and will coerce the committee into reconsidering proposals for unenforceable technical specifications that have been presently determined to be unnecessary. The Technical Correlating Committee should consider that 4.5.5 and 8.6.8.2 are in fundamental conflict with each other. Section 4.5.5 cannot be required if 8.6.8.2 is used and 8.6.8.2 cannot be permitted if 4.5.5 is enforced. Note my comments on 101-191 (Log #355). ROEPER: I am returning my ballot with negatives for each of the above referenced logs. My reasons for doing so follow: (1) The definitions to the terms retard, resist, restrict and limit, as determined by the committee, provide no discernible difference to the user of the standard.

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Report on Comments — Copyright, NFPA NFPA 101 (2) 101-179 (Log #CP609) strikes the term “restrict” and seeks to replace it with “limit”. Unfortunately, the definitions to these two terms each reference the other term, i.e., restrict is to limit, and limit is to restrict. I realize that the debate over these terms has gone on for some time, however, I do not feel that the committee’s current position on the use of the terms provides clear and actionable language for the user of the standard. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-68 so as to retain the word “prevent” as it appears in 4.5.5 of the current edition: 4.5.5 Vertical Openings. 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 limit or resist the spread of fire, smoke, or fumes through vertical openings from floor to floor before occupants have entered exits. COMMITTEE STATEMENT: The words “limit or resist” do not clarify, but further confuse, as raised by the explanation of negative votes from the ROP. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-42 Log #200 SAF-FUN FINAL ACTION: Reject (5.2) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-80 RECOMMENDATION: Accept this proposal in part in principle but use the following language for Section 5.2: 5.2 Performance Criteria. 5.2.1 General. A design shall meet the objectives specified in Section 4.2 if, for each design fire scenario, assumption, and design specification, the performance criterion in 5.2.2 is criteria in 5.2.2 and 5.2.3 are met. 5.2.2* Performance Criterion. Any occupant who is not intimate with ignition shall not be exposed to instantaneous or cumulative untenable conditions. 5.2.3* Performance Criterion. Buildings shall be designed and constructed to reasonably prevent the spread of fire beyond the compartment of fire origin (room flashover). A.5.2.3 NFPA 555, Guide on Methods for Evaluating Potential for Room Flashover, contains appropriate strategies to prevent room flashover. SUBSTANTIATION: I understand the committee’s concern. This comment adds a performance criterion for prevention of flashover, which I believe is fairly critical. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The performance criterion of 5.2.2 clearly captures the intended performance. If a performance-based design can assure immediate evacuation, for example, there might not be any need to prevent fire spread or flashover. The submitter’s proposed criterion is too prescriptive for the performance-based option. Also, preventing fire spread beyond the room of fire origin does not assure there will not be flashover in the room of fire origin. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-43 Log #12 SAF-FUN FINAL ACTION: Accept in Principle (Table 6.1.14.4.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-86 RECOMMENDATION: Revise the text so as to refer to 9.7.1.1(1) rather than directly referencing NFPA 13, for consistency and ease of reference within the Code, as addressed in Lathrop’s Comment on Affirmative. LATHROP: Although I agree with the technical content, I disagree with the direct reference to NFPA 13. The reference to Section 9.7 should remain. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle At the end of Table 6.1.14.4.1 note “a,” change the reference to the sprinkler installation standard, and revise the wording with respect to supervision, as follows: a The fire resistance rating is permitted to be reduced by 1 hour, but in no case to less than 1 hour, where the building is protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1) NFPA 13, and supervised in accordance with 9.7.2. COMMITTEE STATEMENT: The reference to 9.7.1.1(1) is specific to NFPA 13. A general reference to Section 9.7 would permit use of NFPA 13D or NFPA 13R for certain residential occupancies. The committee intends that the reduction in fire resistance rating offered by note “a” be applicable only where sprinkler protection is provided per NFPA 13. The wording with respect to supervision needed revision to prevent permitting supervsion per NFPA 13 (that is, valves locked or sealed in open position) because supervision needs to be electrical per 9.7.2.

NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-43a Log #CC51 SAF-MEA FINAL ACTION: Accept (7.1.3.2.1(3)) _______________________________________________________________ SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-90 RECOMMENDATION: Revise 7.1.3.2.1(3) as follows: (3) The 2-hour fire resistance-rated separation required by 7.1.3.2.1(2) above shall be constructed of an assembly of noncombustible or limited-combustible materials and shall be supported by construction having not less than a 2-hour fire resistance rating. In Type III, IV, and V construction, fire retardant-treated wood enclosed in noncombustible or limited combustible materials shall be permitted. SUBSTANTIATION: NFPA 5000 allows buildings four or more stories in height to be of combustible construction. Fire-retardant-treated wood (FRTW) should be allowed in these buildings. See Comment 101-13a (Log #CC52) which adds to 3.3.xx a definition of Fire Retardant-Treated Wood. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-43b Log #CC478 SAF-IND FINAL ACTION: Reject (7.1.6.3, 7.2.5.2 and 42.8.2.2.6.1(2)) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT. SAF-MEA which has primary responsibility for Chapter 7 was information balloted on the action by SAF-IND with 18 in agreement and 3 in disagreement. The dissenting comments were technically convincing that the proposed text should not go forward. The TCC also notes that the proposed text is not enforceable, especially the words “appropriate provisions.”SUBMITTER: Technical Committee on Industrial, Storage, and Miscellaneous Occupancies COMMENT ON PROPOSAL NO: 101-92 RECOMMENDATION: 1. Accept SAF-MEA action on proposal 101-92 and further revise to read as follows: 7.1.6.3.1 Level. 11.1.6.3.1 Walking surfaces, other than as provided in 11.1.6.3.2, shall comply with the following: (1) Walking surfaces shall be nominally level. (2) The slope of a walking surface in the direction of travel shall not exceed 1 in 20 unless the ramp requirements of 11.2.5 are met. (3) The slope perpendicular to the direction of travel shall not exceed 1 in 48. 7.1.6.3.2 Vehicle ramps in parking structures, as permitted in 42.8.2.2.6, and not an accessible means of egress or other accessible element shall be exempt from the provisions of 7.1.6.3.1. 2. Add the following as new section 7.2.5.2, and renumber remaining sections of 7.2.5 and associated sections as follows: 7.2.5 Ramps. 7.2.5.1 General. Every ramp used as a component in a means of egress shall conform to the general requirements of Section 7.1 and to the requirements of 7.2.5. 7.2.5.2 Vehicle ramps in parking structures, as permitted in 42.8.2.2.6, and not an accessible means of egress or other accessible element, shall be exempt from the provisions of 7.2.5. 3. Add new language to Section 42.8.2.2.6.1(2) to read as follows: 42.8.2.2.6 Ramps. 42.8.2.2.6.1 Ramps shall be permitted in accordance with any of the following conditions: (1) Ramps complying with 7.2.5 and not subject to normal vehicular traffic where used as an exit. (2) In a ramp-type open parking structure with open vehicle ramps not subject to closure, the ramp shall be permitted to serve in lieu of the second means of egress from floors above the level of exit discharge, provided that the ramp discharges directly outside at the street level. The open vehicle ramps shall be exempt from appropriate provisions of Sections 7.1.6 and 7.2.5. (3) For parking structures extending only one floor level below the level of exit discharge, a vehicle ramp leading directly to the outside shall be permitted to serve in lieu of the second means of egress, provided that no door or shutter is installed therein. SUBSTANTIATION: SAF-IND is in support of the action by SAF-MEA on proposal 101-92. SAF-IND also determined that the provisions concerning ramped portions of parking structures that serve as a second means of egress required recognition with further exemptions to the ramp provisions within NFPA 101 due to the unique nature of parking structures. In this case, recognition that the ramped areas of parking structures are shared by both pedestrians and vehicles, therefore those specific attributes normally associated only with pedestrian

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Report on Comments — Copyright, NFPA NFPA 101 only ramps and walking surfaces could not be strictly applied. NFPA 88A, Section 4.4.2, has recognized this aspect through its exemptions from NFPA 101 Section 7.5.2 ramp provisions. Therefore, the intent of SAF-IND was to recognize that the exemptions from specific ramp provisions were necessary to address in NFPA 101. The SAF-IND also recognized that the provisions so cited in proposal 101-92, and the additional proposed language by SAF-IND in this comment should apply to NFPA 5000 Building Construction and Safety Code since similar provisions exist within that document. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-44 Log #400 SAF-MEA FINAL ACTION: Reject (7.2 (New) ) _______________________________________________________________ SUBMITTER: Dave Frable, U.S. General Services Administration COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Delete entire new text. This proposal should be rejected. SUBSTANTIATION: We concur with the negative ballot comments submitted by Mr. Fixen that the fundamental driver for this proposal is proponent’s belief that the only reasonable evacuation strategy to consider for any building is for a complete and total evacuation as opposed to other evacuation strategies (e.g., selective evacuation strategies, horizontal exiting, additional exit stairs, etc.) currently recognized by the Code. In addition, the proponent has failed to realize that in some cases, an egress system that relies strictly on total evacuation to the exterior of a building is not practical. For example, health care occupancy, total building evacuation might expose patients to conditions more dangerous than those encountered in relocating the patients from a fire compartment to a safe smoke compartment on the same floor. It is also the proponent’s belief that increasing the widths of exit stairs is the only viable solution to address the need to totally evacuate multi-story buildings as well as addressing counter-flow problems on exit stairs encountered by first responders and evacuees in multi-storied buildings. However, the proponent has failed to acknowledge the use of elevators as a viable alternative strategy to be utilized for occupant evacuation and/or relocation in a multi-storied building, other then to state “the prospects for this are not good”. There is an ongoing research initiative for the development of performance requirements for the use of elevators for occupant egress and fire department access is currently being conducted by the National Institute of Standards and Technology (NIST). NIST has received positive feedback on this initiative from many organizations across the world. Organizations such as the American Society of Mechanical Engineers, KONE Elevators, OTIS Canada Elevators, United Technologies Research Center, International Association of Fire Fighters, just to name a few. Should this research initiative be successful, the use of elevators by occupants in an emergency situation would provide the option to both increase the speed of the evacuation and also provide a means of evacuation for individuals unable to negotiate the stairs. Last but not least, the proponent has not provided any calculations to quantitatively access the impact of widening the exit stairs on evacuation movement nor has the proponent provided any comparison to the current exit stair width or the impact of providing more exit stairs meeting the current stair width requirements. We do however feel that it may be prudent to re-examine the current minimum exit stair width criteria, however, more importantly and more critically, prior to revising minimum exit stair widths with arbitrary dimensions, we should re-examine the entire concept of occupant evacuation in multi-storied buildings (e.g., all evacuation strategies currently recognized by the Codes for all individuals). Based on the above concerns, we feel the proposal is just too premature and has not been fully thought out by the proponent to be considered at this time. Therefore, the only prudent action to take is to retain the current minimum stair width criteria. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s request is in direct conflict with the action taken on Comment 101-46. The extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions. See also, in the action on Comment 101-46, the revised langauge clarifying how the cumulative loads are to be calculated, and criteria explaining what portion of the stairway needs to provide the increased width. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 20 Negative: 4 EXPLANATION OF NEGATIVE: ELVOVE: First of all, the modifications made by the occupancy technical committees to comment 101-46 et al subsequent to the MEA ROC meeting seem to have improved upon the text of the proposed new requirements for

wider stairs in high-rise (or extremely high occupancy) buildings. Therefore, if wider stairs will be required to allow for sufficient (downward) egress capacity and (upward) counterflow, then the egress (ingress) doors really need to be increased in size to accommodate bidirectional flow. Should this comment not be accepted, then I would change by affirmative vote on Comments 101-44, 45, 46 and 59 to negative as I would not widen stairs without adequately sized doors. FIXEN: The issue of stair counterflow involving building occupants and emergency responders is a very important issue that should be carefully addressed by the committee and fire safety community. However, the proponent and committee continue to try to work from an arbitrary benchmark (e.g., 2,000 persons) that may seem reasonable but is nonetheless an arbitrary benchmark for a substantial code change. A substantial code change of this nature must be substantiated and supported by more rigorous research or data that directly demonstrates the need for the change and can quantify the improvement resulting from the change. The issue of counter flow can occur in low or tall buildings with stairs serving less than 2,000 occupants. To my knowledge, the threshold of 2,000 occupants and the corresponding stair width has no relationship to any performance or evacuation goal. The change implies a solution that in fact has not been shown to solve counterflow in tall buildings whether 10, 20, or 50 stories. Finally, the issue of counterflow in tall buildings is not an isolated issue where the safe evacuation of tall buildings is involved. It is a part of a much larger discussion that should include all aspects involved in the full and complete evacuation of tall buildings such as fire-resistive construction, other potential means for emergency responder access, structural design considerations, etc. To merely widen a stair to an arbitrarily chosen width because the occupant load exceeds 2,000, does not in and of itself fully address if complete and safe evacuation will be achieved. Stair width should be one part of a complete building evaluation and even then the solution should have a direct relationship to a stated goal. Based on this, I believe the committee’s action should have been to reject. FRABLE: See my reasons stated in my negative comment on NFPA 101-46. Based on these concerns, the appropriate action on this comment should have been “Accept”. KULIGOWSKI: As a personal vote, I am certainly in favor of wider stairs; however, I am not convinced that the numbers of occupants and the corresponding stair width are appropriate. First, I am still unclear as to what these numbers are based on. There does not seem to be enough substantial evidence to support the increments of stair widths associated with the number of occupants served by the stairway, as listed in the original proposal by Pauls and the amended version by Lathrop. I question how the occupant number and the corresponding stair width were decided upon. Pauls includes data on obesity of the U.S. population from 1960 to the recent year of 2000, however refers to people movement data on stairs only as recent as the mid 1980s. So, my concern reflects the fact that we do not have recent people movement data (especially on counterflow) to point to that clearly compares movement in many different sized staircases, so that the most appropriate stair size can be chosen to be included in the code. Second, in the absence of appropriate research to support the increased width, it is not clear that the additional width is providing significant additional capacity. For example, since the committee chose not to increase door width commensurate with the added stair width, discharge capacity at the bottom of these wider stairs may become the controlling factor rather than stair width. Finally, the presentation of the data in the final proposed new section in Comment 101-46 is inconsistent. For new stairs serving less than 50 occupants, the minimum clear width excludes handrails while for wider stairs, the minimum clear width is measured between handrails. This can only lead to confusion. Regardless of width, the measurement should be consistent. The table at the right provides a set of consistent values for either approach. Unfortunately, the proposed standard does not Cumulative Between Full Width < 50 27 36 – 36 50 – 1999 36 43 – 45 > 1999 48 55 – 57 _______________________________________________________________101-45 Log #209 SAF-MEA FINAL ACTION: Accept in Part (7.2.x) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be revised to add: See Comment 101-56a.SUBMITTER: Jake Pauls, Jake Pauls Consulting Services COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Suggest revised text as shown below: 7.2.x* Minimum New Stair way Width. 7.2.x.1 Where total occupant load of all stories served by the stairway is fewer than 50, the minimum width clear of all obstructions, except projections not more than 4 1⁄2 in. (11.4 cm) at or below handrail height on each side, shall be 36 in. (91 cm). 7.2.x.2 Where the total occupant load of all stories served by the stairway is 50 or more, the minimum clear width measured as the horizontal distance between two handrails shall be as shown in Table 7.2.x.2 with the total occupant load being, for downward egress travel, the total number of occupants from stories above the level where the width is measured and, in the case of upward egress travel, the total number of occupants from stories below the

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Report on Comments — Copyright, NFPA NFPA 101 level where the width is measured. Where multiple stairways serve the total occupant load, the “Total Occupant Load Served by the Stairway” shall be that stairway’s prorated share of the total occupant load, calculated in proportion to the stairway width as measured clear between handrails.

Table 7.2.x.2

Total Occupant Load Stairway width clear Served by the Stairway between handrails 50 to 149 36 in. (91 cm) 150 to 999 and more 48 in. (122 cm) 1000 to 1999 44 in. (112 cm) 2000 and more 48 in. (122 cm)

SUBSTANTIATION: Note: this comment addresses factors going beyond those presented in proposal 101-107 as well as the lengthy Technical Correlating Committee negative ballot comment from Pauls in relation to the MER Technical Committee’s counter proposal, 101-591 (found, respectively on pages 101-7 to 101-8 and 101-207 of the Report on Proposals). They should be read in conjunction with this comment. In particular it should be noted that GSA’s representative, Mr. Frable, in his negative ballot comment, stated, “it appears the proponent has not taken into consideration when determining these arbitrary thresholds that 40% of the population in North America is seriously overweight.” This is addressed at length below. An editorial change is suggested for the heading, changing “Stair” to “Stairway” for consistency with the requirement (which addresses the minimum width of both the stair flight and the landings serving the stair). Two problems are addressed by this comment, with the first possibly being addressed in a new annex note based on the following (or similar discussion). First, clarification is provided regarding where a stairway, serving a number of stories, needs to have the specified width. This change, to the text of 7.2.x.2 could be adopted without the more-substantial change suggested to the table. The clarification addresses some people’s criticism that the entire height of stairway of a high-rise building, for example, would need to be sized at the width applicable to the total occupant load of all stories rather than only that portion of the stairway height actually subjected to the occupant load during a total evacuation. A complementary change is clarification of how the occupant load would be apportioned between or among multiple stairways. For example, if three equal-width stairways were provided to serve a total occupant load of 3x above some level of the building, then each of the three stairways below that level would be assumed to serve a total occupant load of x. If one of the three stairways had a width, clear between handrails, of 60 inches and the other two had a width, clear between handrails, of 48 inches, the apportioned total occupant load per stairway would be, respectively, 1.154x, 0.923x and 0.923x. There is a potential confusion here in relation to use of horizontal exits and the reduction permitted by 7.2.4. to stairway egress capacity. The cleanest way of handling horizontal exits, in relation to the minimum width issue addressed here, is simply to ignore them. This is because, in case of total evacuation of the building, the benefit of the horizontal exits is relatively localized and thus moot; the performance of the exit stairways will largely determine the speed and duration of the evacuation. This clarification about where the width is specified would be largely unnecessary if the more-substantial change (in this comment) were adopted. This substantial change addresses the changed—and changing—demographics of building occupants in two respects. First relative to the research studies described by the proponent of proposal 101-107, these were performed decades ago at a time and in mostly in a country (Canada) when and where people were both thinner and more physically fit than are typical US residents today. Being overweight or obese has become a national health problem in the US among adults and children—the very people who will occupy, and might need to evacuate, buildings for decades to come. Irrefutable evidence for this is in the statistics from the US Centers for Disease Control (CDC), which along with other health organizations, has documented the major increases in overall body mass index (BMI) for US residents with these data being presented on a state-by-state, year-to-year basis on the web site http://www.cdc.gov/nccdphp/dnpa/obesity/resources.htm. The occurrence of obesity (BMI greater than or equal to 30) has approximately doubled from about 15 percent to 31 percent between the early 1970s to 2000 among adults aged 20 to 74 in the US. (See appended two-page tables of data from CDC, downloaded in pdf format from http://www.cdc.gov/nchs/products/pubs/pubd/hestats/obese/obse99.htm.) The Surgeon General for the US (at http://www.surgeongeneral.gov/topics/obesity/calltoaction/fact_glance.htm) notes that: 61% of adults in the United States were overweight or obese (BMI> 25) in 1999. 13% of children aged 6 to 11 years and 14% of adolescents aged 12 to 19 years were overweight in 1999. This prevalence has nearly tripled for adolescents in the past 2 decades. The increases in overweight and obesity cut across all ages, racial and ethnic groups, and both genders. Notably, most of the Canadian office building evacuation studies—a major input for current US means of egress formulas on egress width and capacity—were already completed by the early 1970s. The same is true for the landmark studies of John Fruin whose book, Pedestrian Planning and Design, was based on field studies (for his PhD) in the New York area before 1970. People,

today—and even more so in the coming decades—are larger than those studied for these studies of a few decades ago in Canada and the US. Moreover, it is likely that the differences between today’s (tomorrow’s) building populations and those of several decades ago, when building code requirements for means of egress were formulated in North America and the UK, are even more pronounced. (These earlier deliberations, resulting for example in the once-standard 22-inch unit of exit width— which is still the basis of the current 44-inch nominal, minimum egress stairway width, have been described in critical reviews by Pauls, published in the journal Fire Technology, in 1984 and referenced at the end of proposal 101-107.) In addition to people getting larger, they are becoming so because of reduced fitness generally. This affects people’s ability to cope with the physical demands of evacuation on stairs. One indication of this trend is the estimate of how many people would (or did) have difficulty evacuating down multiple stories of stairs in evacuation of office buildings. Pauls’ estimate of 3 percent of typical Canadian office workers, at about 1970, not being good candidates for using stairs for evacuation with a crowd of other descending persons, can be compared with more-recent US estimates about twice as large. Appendix O of the preliminary report issued by NIST in June 2004, on the World Trade Center evacuation, included the following finding, “Some 6 percent (n=52) reported having a limitation which impacted their ability to evacuate. These limitations included obesity, heart condition, needing assistance to walk, pregnancy, asthma, elderly, chronic condition, recent surgery or injury, and other.” This is also reflected in lower-than expected speeds of movement down the WTC exit stairs, and longer than expected evacuation times, estimated in both US and UK studies so far of the WTC evacuation (as described, for example, in Proceedings of the 3rd International Symposium on Human Behaviour in Fires, 1994). Generally, there are multiple indications that people are not able to evacuate as quickly and efficiently as assumed in drawing up the current means of egress requirements. Finally, we have an aging population generally. Increasingly, people are going to have to work longer than has been the case. Thus we must begin now to design for an older population generally. This means providing more-generous, easier-to-use egress facilities. All of the above factors point to wider minimum width for egress stairways. This comment is based on these considerations as well as the benefit of simplifying the formula for successively wider minimum widths suggested in proposal 101-107. The most extensive simplification of the formula was explicitly noted, in the last paragraph of proposal 101-107, as being acceptable to the proponent. The main difference between what was noted in that last paragraph of the proposal and what is in this comment is the retention of the traditional nominal 44-inch minimum stairway width (36 inches clear between handrails) for a small number of cases with total occupant load served being between 50 and 150. All of the suggestions—the originally proposed, 4-part table; a halving of the table’s occupant load limits shown near the end of the proposal; the major simplification suggested in the last paragraph of the proposal; and the partial simplification suggested in this comment—would be responsive to the demographics changes and evolving life safety capabilities described in this comment. Note that there is a separate comment addressing a possible need to address the minimum width of exit discharge doorways from the wider stairways resulting from proposal 101-107. Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Accept in Part See committee action on Comment 101-46 re: how the cumulative loads are to be calculated, and criteria explaining what portion of the stairway needs to provide the increased width. Do not change the threshold so as to require extra width at a total occupant load of 150 persons. COMMITTEE STATEMENT: The submitter’s criteria for how the cumulative loads are to be calculated, and explanation of what portion of the stairway needs to provide the increased width has been worked into the committee action on Comment 101-46. The submitter has not substantiatied the need to require extra stair width at total occupant load of 150 persons. The extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 20 Negative: 4 EXPLANATION OF NEGATIVE: ELVOVE: First of all, the modifications made by the occupancy technical committees to comment 101-46 et al subsequent to the MEA ROC meeting seem to have improved upon the text of the proposed new requirements for wider stairs in high-rise (or extremely high occupancy) buildings. Therefore, if wider stairs will be required to allow for sufficient (downward) egress capacity and (upward) counterflow, then the egress (ingress) doors really need to be increased in size to accommodate bidirectional flow. Should this comment not be accepted, then I would change by affirmative vote on Comments 101-44, 45, 46 and 59 to negative as I would not widen stairs without adequately sized doors.

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Report on Comments — Copyright, NFPA NFPA 101 FIXEN: See my Explanation of Negative on Comment 101-44. FRABLE: See my reasons stated in my negative comment on NFPA 101-46. Based on these concerns, the appropriate action on this comment should have been “Reject”. KULIGOWSKI: As a personal vote, I am certainly in favor of wider stairs; however, I am not convinced that the numbers of occupants and the corresponding stair width are appropriate. First, I am still unclear as to what these numbers are based on. There does not seem to be enough substantial evidence to support the increments of stair widths associated with the number of occupants served by the stairway, as listed in the original proposal by Pauls and the amended version by Lathrop. I question how the occupant number and the corresponding stair width were decided upon. Pauls includes data on obesity of the U.S. population from 1960 to the recent year of 2000, however refers to people movement data on stairs only as recent as the mid 1980s. So, my concern reflects the fact that we do not have recent people movement data (especially on counterflow) to point to that clearly compares movement in many different sized staircases, so that the most appropriate stair size can be chosen to be included in the code. Second, in the absence of appropriate research to support the increased width, it is not clear that the additional width is providing significant additional capacity. For example, since the committee chose not to increase door width commensurate with the added stair width, discharge capacity at the bottom of these wider stairs may become the controlling factor rather than stair width. Finally, the presentation of the data in the final proposed new section in Comment 101-46 is inconsistent. For new stairs serving less than 50 occupants, the minimum clear width excludes handrails while for wider stairs, the minimum clear width is measured between handrails. This can only lead to confusion. Regardless of width, the measurement should be consistent. The table at the right provides a set of consistent values for either approach. Unfortunately, the proposed standard does not Cumulative Between Full Width < 50 27 36 – 36 50 – 1999 36 43 – 45 > 1999 48 55 – 57 _______________________________________________________________101-46 Log #166 SAF-MEA FINAL ACTION: Accept in Principle (7.2.X.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-56a.SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Revise 7.2.X.2 Where the cumulative total occupant load of all stories served by the stairway required capacity of a stair is 50 or more,... Revise Table 7.2.X.2 left column heading to read: Cumulative Required Capacity of the Stair Delete the entries for 50 to 149 and 150 to 999 in Table 7.2.X.2. Add a new annex note to read: A.7.2.X.2 This is based on accumulating the required capacity of the stair on each story the stair serves. For example, a stair in a two story building that has 2000 people on the second story but has 10 stairs that serve the second story, would be considered to have 200 for the purposes of Table 7.2.X.2. A 41 story building with 200 people on each story with two stairs would be considered to have 4000 people for the purposes of Table 7.2.X.2. A typical 44 in. stair would not be required to have 48 in. between handrails until it serves (2000/147=14) approximately 14 stories. This accumulating of capacity is done for the purposes of this requirement only. Egress capacity requirements of Section 7.3 are NOT cumulative on a story by story basis. SUBSTANTIATION: This is an attempt to resolve some of the criticisms of the proposal while maintaining some of the important parts of this proposal. This will address the problem of moving large numbers of people down several stories of a building. COMMITTEE MEETING ACTION: Accept in Principle Revise as follows: 7.2.2.2 Dimensional Criteria. 7.2.2.2.1 Standard Stairs. 7.2.2.2.1.1 Stairs shall meet the following criteria: (1) New stairs shall be in accordance with Table 7.2.2.2.1(a) 7.2.2.2.1.1(a) and 7.2.2.2.1.2. (2)* Existing stairs shall be permitted to remain in use, provided that they meet the requirements for existing stairs shown in Table 7.2.2.2.1(b) 7.2.2.2.1.1(b). (3) Approved existing stairs shall be permitted to be rebuilt in accordance with the following: (a) Dimensional criteria of Table 7.2.2.2.1(b) 7.2.2.2.1.1(b) (b) Other stair requirements of 7.2.2 (4) The requirements for new and existing stairs shall not apply to stairs located in industrial equipment access areas where otherwise provided in 40.2.5.2.

Table 7.2.2.2.1.1(a) 7.2.2.2.1(a) New StairsFeature Dimensional Criteria

Minimum width clear of all obstructions, except projec-tions not more than 4½ in. (114 mm) at or below hand-rail height on each side

See 7.2.2.2.1.2 44 in. (1120 mm); 36 in. (915 mm) where total occu-pant load of all stories served by stairways is fewer than 50

Maximum height of risers 7 in. (180 mm)

Minimum height of risers 4 in. (100 mm)

Minimum tread depth 11 in. (280 mm)Minimum headroom 6 ft 8 in. (2030 mm)Maximum height between landings

12 ft (3660 mm)

Landing See 7.2.1.3 and 7.2.1.4.4

Table 7.2.2.2.1.1(b) 7.2.2.2.1(b) Existing Stairs [No change to table] 7.2.2.2.1.2 Minimum New Stair Width. (A) Where total occupant load of all stories served by the stairway is fewer than 50, the minimum width clear of all obstructions, except projections not more than 4 1/2 in. (114 mm) at or below handrail height on each side, shall be 36 in. (915 mm). (B)* Where the cumulative required capacity of a stairway is 50 persons or more, the minimum clear width measured as the horizontal distance between two handrails shall be in accordance with Table 7.2.2.2.1.2(B) and the requirements of 7.2.2.2.1.2(C), (D) and (E).

Table 7.2.2.2.1.2(B) New Stair WidthCumulative Required

Capacityof the Stairway

Stairway Width,Clear between Handrails

50 – 1999 persons 36 in. (910 mm)2000 persons and more 48 in. (1220 mm)

(C) For downward egress travel, stairway width shall be based on the total number of occupants from stories above the level where the width is measured. (D) For upward egress travel, stairway width shall be based on the total number of occupants from stories below the level where the width is measured. (E) The total cumulative load assigned to a particular stairway shall be that stairway’s prorated share of the total occupant load, calculated in proportion to the stairway width as measured between handrails.

A.7.2.2.2.1.2(B) The stairway width requirement of 7.2.2.2.1.2(B) is based on accumulating the required capacity of the stair on each story the stairway serves. For example, a stair in a 2-story building that has 2000 persons on the second story but has 10 equally-sized stairs that serve the second story, would be considered to have 200 persons for the purposes of applying Table 7.2.2.2.1.2(B). For a 41-story building with 200 persons on each story with two equally-sized stairs, each stair would be considered to have 4000 persons for the purposes of applying Table 7.2.2.2.1.2(B). A typical 44-in. (1120-mm) stair would not be required to be increased in width so as to provide 48 in. (1220 mm) between handrails until it serves approximately 14 stories, calculated as follows:

[2000 persons] / [147 persons per floor for a 44-in. (1120-mm) width stair] ≈ 14 stories.

The accumulating of capacity is done for the purposes of the requirement of 7.2.2.2.1.2 only. The egress capacity requirements of Section 7.3 are NOT cumulative on a story-by-story basis.COMMITTEE STATEMENT: The committee action is based on recognition that the extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions The submitter’s language has been supplemented with criteria for how the cumulative loads are to be calculated, and explanation of what portion of the stairway needs to provide the increased width. This was done in response to comments received from others. See recommendation in Comment 101-45, and substantiation in Comment 101-59. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 5 EXPLANATION OF NEGATIVE: BROWN: It may be premature for the TC to set the standard on combination egress/ingress dimensions until the Federal Government and other sanctioned studies on this subject are finalized.

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Report on Comments — Copyright, NFPA NFPA 101 ELVOVE: First of all, the modifications made by the occupancy technical committees to comment 101-46 et al subsequent to the MEA ROC meeting seem to have improved upon the text of the proposed new requirements for wider stairs in high-rise (or extremely high occupancy) buildings. Therefore, if wider stairs will be required to allow for sufficient (downward) egress capacity and (upward) counterflow, then the egress (ingress) doors really need to be increased in size to accommodate bidirectional flow. Should this comment not be accepted, then I would change by affirmative vote on Comments 101-44, 45, 46 and 59 to negative as I would not widen stairs without adequately sized doors. FIXEN: See my Explanation of Negative on Comment 101-44. FRABLE: For the record, GSA is not opposed to technically sound Code proposals that attempt to improve overall building safety. This would include proposals to increase the width of exit stairways in buildings. However GSA is not convinced that this proposal and the substantiation provided is technically sound. Currently, as written, proposal 101-46 is not technically sound for the following reasons: 1. Horizontal Exits. The proposal has not taken into consideration the use of horizontal exits. In 7.2.4.1.2, horizontal exits are permitted to be a substituted for other exits where the total egress capacity of the other exits ( stairs, ramps, doors leading outside the building) is not less than half that required for the entire area of the building or connected buildings and provided that none of the other exits, is a horizontal exit, unless provided in 7.2.4.1.3. However, proposal 101-46 appears to have discounted the use of horizontal exits. In addition, the proposal has not addressed how the calculated total occupant load of each floor that uses horizontal exits is to be addressed or how horizontal exits will affect the requirements proposed for determining the minimum stair widths. 2. Stair Width Thresholds. The proposal has gaps in the thresholds for when the requirements for the new minimum stair widths are to be applied. The proposed new 7.2.2.2.1.2(A) states where ”total occupant load of all stories served by the stairway” is fewer than 50, the minimum clear width of all obstructions, except projections not more than 4 1/2 in. at or below handrail height on each side shall be 36 in. and the proposed new 7.2.2.2.1.2(B) states where the “cumulative required capacity of a stairway” is 50 persons or more, the minimum clear width measured as the horizontal distance between two handrails shall be in accordance with Table 7.2.2.2.1.2(B) and the requirements of 7.2.2.2.1.2(C), (D), and (E). However, as currently written a gap exists where the total occupant load of all stories served by the stairway is between 50 and 100 persons. No minimum stair width requirement has been provided for when the total occupant load of all stories served by the stairway falls between these thresholds. 3. Cumulative Required Capacity. The proposal leads to confusion related to capacity issues addressed in 7.2.4 and Section 7.3. 4. Additional Stairs. The proposal does not address high-rise buildings that may have additional stairways on lower floors for determining the total occupant loads of all stairways. 5. Size of Stairs. No guidance has been provided to determine how one pro-rates the total cumulative occupant load for each floor when each stair is equally sized or when each stair is not equally sized. For example, no criterion has been provided to determine how many occupants are assigned to each stair. 6. 2000 Cumulative Person Criterion. The Committee statement states that the basis for the trigger of 2000 cumulative person criterion was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on the site before all occupants have evacuated the building. However, no documentation has ever been provided to substantiate this claim. What makes the trigger of 2000 cumulative person criterion better than a trigger of 1500 cumulative person criterion or a trigger of 2500 cumulative person criterion. Based on the above concerns, the appropriate action on this comment should have been “Reject”. KULIGOWSKI: As a personal vote, I am certainly in favor of wider stairs; however, I am not convinced that the numbers of occupants and the corresponding stair width are appropriate. First, I am still unclear as to what these numbers are based on. There does not seem to be enough substantial evidence to support the increments of stair widths associated with the number of occupants served by the stairway, as listed in the original proposal by Pauls and the amended version by Lathrop. I question how the occupant number and the corresponding stair width were decided upon. Pauls includes data on obesity of the U.S. population from 1960 to the recent year of 2000, however refers to people movement data on stairs only as recent as the mid 1980s. So, my concern reflects the fact that we do not have recent people movement data (especially on counterflow) to point to that clearly compares movement in many different sized staircases, so that the most appropriate stair size can be chosen to be included in the code. Second, in the absence of appropriate research to support the increased width, it is not clear that the additional width is providing significant additional capacity. For example, since the committee chose not to increase door width commensurate with the added stair width, discharge capacity at the bottom of these wider stairs may become the controlling factor rather than stair width. Finally, the presentation of the data in the final proposed new section in Comment 101-46 is inconsistent. For new stairs serving less than 50 occupants, the minimum clear width excludes handrails while for wider stairs, the minimum clear width is measured between handrails. This can only lead to

confusion. Regardless of width, the measurement should be consistent. The table at the right provides a set of consistent values for either approach. Unfortunately, the proposed standard does not Cumulative Between Full Width < 50 27 36 – 36 50 – 1999 36 43 – 45 > 1999 48 55 – 57 COMMENT ON AFFIRMATIVE DE VRIES: In addition to the issue of counterflow between evacuees and emergency responders, there are other issues addressed by this comment, related comments and the related proposal, including movement of two columns of people traveling in the same direction and movement related to assisting mobility-impaired evacuees, as indicated in the substantiation submitted with Proposal 101-107. As accepted in principle, there remain some awkward provisions, such as two differing methods of measuring stair width and a mixture of terminology regarding the cumulative occupant load, which have been addressed appropriately by action of an occupancy committee. KOFFEL: I am aware that several other Technical Committees have reviewed the action on Comment 101-46 and proposed further modifications. The TCC will need to review the other proposed Committee Comments and potentially note that the Committee Action on this comment has been further revised. PAULS: Reporting Suggestions from Two Occupancy Committees on the Means of Egress TC action to Accept in Principle Comments 101-46. Comment also applies to 5000-323, substituting Chapter 11 for Chapter 7. At the recent NFPA 101 and NFPA 5000 occupancy technical committee meetings in San Diego, I participated in a meeting of the MER TC to encourage it to remove its exception to the new increased minimum stair width rule being considered by the MEA TC. While unsuccessful with this, I did come to a good understanding of the MER TC position; there seemed to be consensus in favor of the new increased minimum width but there were concerns about how the new requirement was presented. Therefore, I prepared a draft comment—addressing MER TC concerns—and presented it the next day to three other occupancy committees which accepted the draft comment with and without some minor revisions. This affirmative ballot comment provides a record of what happened as well as the end result for two of the three TC’s (with only minor editorial corrections made as well). Apparently, if sustained by Occupancy Committee letter ballots, the Comment would be sent to the MEA TC as an information ballot that would also be considered by the appropriate Technical Correlating Committee when it addresses Comments 101-46. Substantiation. This suggestion addresses three specific concerns of the MER TC (on 11/8/04): a gap in the thresholds for 36-in. minimum width and other widths; the effect of horizontal exits; and the effect of additional exits at the lower stories of a building. The elimination of language about “Cumulative Required Capacity” should eliminate possible confusion about capacity issues addressed by sections 7.2.4 and 7.3. Annex notes should further assist in clearing up confusions on this.In addition, because of possible confusion when using two different methods of specifying minimum stair width (as in the original proposal), only the conventional nominal width measurement is used (e.g., 36 in., 44 in. and 56 in. rather than using—for wider stairs—the clear handrail-to-handrail width. Secondly, by simply adding the reference to 7.2.2.3.2 to Table 7.2.2.1.1(a), the term “stair,” instead of “stairway,” can be used consistently in this section (because the width of the landings is linked to stair width in 7.2.2.3.2.).7.2.2.2 Dimensional Criteria.7.2.2.2.1 Standard Stairs.7.2.2.2.1.1 Stairs shall meet the following criteria:(1) New stairs shall be in accordance with Table 7.2.2.2.1.1(a) and 7.2.2.2.1.2.(2)* Existing stairs shall be permitted to remain in use, provided that they meet the requirements for existing stairs shown in Table 7.2.2.2.1.1(b).(3) Approved existing stairs shall be permitted to be rebuilt in accordance with the following:(a) Dimensional criteria of Table 7.2.2.2.1.1(b)(b) Other stair requirements of 7.2.2(4) The requirements for new and existing stairs shall not apply to stairs located in industrial equipment access areas where otherwise provided in 40.2.5.2.

Table 7.2.2.2.1.1(a) New StairsFeature Dimensional CriteriaMinimum width See 7.2.2.2.1.2Maximum height of risers 7 in. (180 mm)Minimum height of risers 4 in. (100 mm)Minimum tread depth 11 in. (280 mm)Minimum headroom 6 ft 8 in. (2030 mm)Maximum height between landings

12 ft (3660 mm)

Landing See 7.2.1.3, and 7.2.1.4.4 and 7.2.2.3.2

Table 7.2.2.2.1.1(b) Existing Stairs [No change to table]

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Report on Comments — Copyright, NFPA NFPA 101 7.2.2.2.1.2 Minimum New Stair Width.(A) Where total occupant load of all stories served by the stair is fewer than 50, the minimum width clear of all obstructions, except projections not more than 4 1/2 in. (114 mm) at or below handrail height on each side, shall be 36 in. (915 mm).(B)* Where stairs serve occupant loads exceeding that permitted by (A), the minimum width clear of all obstructions, except projections not more than 4 1/2 inches (114 mm) at or below handrail height on each side,

Table 7.2.2.2.1.2(B) New Stair WidthTotal Cumulative OccupantLoad Assigned to the Stair

Width,

Fewer than 2000 persons 44 in. (1120 mm)

2000 persons and more 56 in. (1422 mm)

(C) The total cumulative occupant load assigned to a particular stair shall be that stair’s prorated share of the total occupant load, as stipulated in (D) and (E), calculated in proportion to the stair width.(D) For downward egress travel, stair width shall be based on the total number of occupants from stories above the level where the width is measured.(E) For upward egress travel, stair width shall be based on the total number of occupants from stories below the level where the width is measured.A.7.2.2.2.1.2(B) The stair width requirement of 7.2.2.2.1.2(B) is based on accumulating the occupant load on each story the stair serves.The accumulating of occupant load is done for the purposes of the requirement of 7.2.2.2.1.2 only. The egress capacity requirements of Section 7.3 are NOT cumulative on a story-by-story basis.If additional exits provide egress capacity, the occupant load served by such additional exits—up to the limit permitted for the egress capacity of such additional exits, is not added to the total occupant load considered for the minimum stair width requirements of Section 7.2.2.2.1.2.If horizontal exits are provided on any of the stories, the total occupant load of all compartments on the story with the horizontal exits is used in the calculation of the minimum stair width requirements of 7.2.2.2.1.2. The number of stairs permitted through application of horizontal exit requirements, in 7.2.4, is not affected by the minimum stair width requirements of 7.2.2.2.1.2.The following examples illustrate applications of the minimum stair width requirement. (1) A stair in a 2-story building that has 2000 persons on the second story, among10 equally-sized stairs that serve the second story, would be considered to have 200 persons for the purposes of applying Table 7.2.2.2.1.2(B). The minimum width of such a stair would be 44 in. (1120 mm).(2) For a relatively large floor area building, a typical 44-in. (1120-mm) stair would not be required to be increased in width until it serves approximately 14 stories, calculated as follows:[2000 persons] / [147 persons per floor for a 44-in. (1120-mm) width stair] ≈ 14 stories. For egress in the descending direction, only the stair width below the 14 stories with the total occupant load of 2000 persons per stair, or 4000 persons if served by two equally sized stairs, would need to be increased to 56 in. (1422 mm). If the building had 20 stories, only the stairs on the lowest 7 stories would be required to have the 56-in. (1422 mm) width.(3) For a 41-story building with 200 persons on each story (or 8,000 persons overall, not including the ground floor) with two equally-sized stairs, each stair would be considered to have 4,000 persons for the purposes of applying Table 7.2.2.2.1.2(B). Only the portion of the stair serving 2,000 persons would be required to have the wider width. If each story provides the same floor area for occupancy, the upper 20 stories would have 44-in (1120 mm) stairs and the lowest 20 stories would have the 56-in (1422 mm) stairs as a minimum. _______________________________________________________________101-47 Log #236 SAF-MEA FINAL ACTION: Reject (7.2.1.6.1) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-97 RECOMMENDATION: Revise ROP action and accept original proposal. SUBSTANTIATION: 1. If sprinklers were installed to allow delayed-egress, but the sprinklers are shutdown (supervisory), the doors should unlock. 2. There should be better coordination between 72 and 101 which both have unlocking requirements. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s proposed requirement is difficult to accomplish technically and he has not substantiated the need to impose such difficulty. The provision is also difficult from an operational standpoint, like when a nursing home patient wanders away upon release of the door lock. The Code adequately requires in 9.7.6.1 that a fire watch be operational when a sprinkler system or alarm system is out of service for more than 4 hours in any 24-hr period. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

_______________________________________________________________101-48 Log #13 SAF-MEA FINAL ACTION: Accept in Principle (7.2.1.6.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-101 RECOMMENDATION: Give consideration to Koffel’s Explanation of Negative so as to make any needed changes. KOFFEL: The proposal has introduced new concepts not originally anticipated with access-controlled egress doors. The original concept involved an arrangement in which the door would normally be unlocked as an occupant approaches the door. Combining the original concept with another concept in which the doors are normally locked is not appropriate. The proposed new material, if added to the Code, should be a separate section. In addition, I would note the following: 1. The two new systems permit listed or approved hardware. What is the basis for approval? How does an AHJ determine that the touch sensitive hardware will still work if the occupant is wearing gloves, has an artificial limb, etc.? 2. Sections 7.2.1.6.2(2) and 7.2.1.6.2(5) continue to refer to an “access control system.” The terminology should be revised if all three systems are retained in a single Code section. 3. What is meant by a “supervised building fire-protective signaling system” and “supervised fire detection system?” Is this something different than what is required by NFPA 72? 4. What is meant by resetting an automatic sprinkler system? Does this mean that all control valves have been reopened or that the waterflow alarm has been reset? 5. The impact of the changes may be minimal on existing access-controlled egress doors, should the current provisions be retained for existing systems? For example, does one need to replace the sign with the proposed new language? SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-51. COMMITTEE STATEMENT: The action on the comment referenced above in the committee action field should meet the intent of the negative ballot referenced by the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-49 Log #14 SAF-MEA FINAL ACTION: Accept in Principle (7.2.1.6.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-103 RECOMMENDATION: Give consideration to Koffel’s and Versteeg’s Explanation of Negative so as to make any needed changes. KOFFEL: If a section is to be added on electrically-locked egress doors [see 101-101 (Log #397)], why is all this language required in this section? Since much of the language contained in 101-101 (Log #397) has been repeated in this action, my comments concerning the language accepted in 101-101 (Log #397) would apply for this section as well. Furthermore, there has not been a correlating change made to 7.4.1.6. VERSTEEG: This appears to be building specific and permits a “make-shift” solution to condition where compliant hardware can be purchased and installed. Refer to my opposing position as stated under 101-101 (Log #397). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-103 so as NOT to add special provisions for elevator lobby electrical door locking systems. COMMITTEE STATEMENT: The committee action should meet the intent of the negative ballots referenced by the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-50 Log #15 SAF-MEA FINAL ACTION: Accept in Principle (7.2.1.6.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified per Koffel’s comment so that in ROP Proposal 101-104 the word “protective” be substituted where the word “protection” was used.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-104 RECOMMENDATION: Give consideration to Koffel’s and Elvove’s Explanation of Negative so as to make any needed changes. KOFFEL: The proposed new sentence (7) is in direct conflict with the existing sentence (6). It should be noted that (6) does not require a building fire-protective signaling system as alluded to in the proposed new sentence (7). If retained, the language “fire protection signaling system” should be changed to be consistent with other sections of the Code. In fact, it would appear as if

101-24

Report on Comments — Copyright, NFPA NFPA 101 the phrase “fire-protective signaling system” should also be replaced with “fire alarm system.” ELVOVE: There may be some confusion regarding what a “building fire protection signaling system” is compared to an “automatic fire detection system” as proposed by new text in 101-101 (Log #397). If the former includes manual pull stations, it would appear the proposed text cause a conflict in the Code. If the Committee’s intent is only to unlock doors upon detector activation, new text proposed in 101-104 (Log #CP212) should suffice and therefore this proposal should be rejected. Regardless, the Committee should clarify when doors are required to be unlocked at the ROC meeting by revising text or adding an annex note. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain the ROP acceptance of Proposal 101-104. COMMITTEE STATEMENT: The language with respect to “building fire protection signaling system” is consistent with other provisions in 7.2.1.6.2. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE KOFFEL: Apparently the Committee missed the nuance of my ballot comment. The language accepted in Proposal 101-104 uses the phrase “fire protection signaling system.” The language in other sections of 7.2.1.6.1 uses the phrase “fire protective signaling system.” While I further noted that other sections of NFPA 101® now use fire alarm system I was really trying to exchange the word “protective” for “protection.” _______________________________________________________________101-51 Log #162 SAF-MEA FINAL ACTION: Accept in Principle (7.2.1.6.2) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-101 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: The entire subject of locking has been totally confused and mixed up by a series of proposals including this one. This is a totally different concept from access controlled egress doors. If it is to be in the Code it should be separate material. Please note the Koffel and Versteeg negatives. Let’s stop, go back to square one and approach this more logically. For now return to the 2003 Code. COMMITTEE MEETING ACTION: Accept in Principle Do not revise 7.2.1.6.2 to address electrically locked egress doors. Rather, keep 7.2.1.6.2 as applying to access controlled egress doors and revise the language from the 2003 edition as follows: 7.2.1.6.2* Access-Controlled Egress Doors. Where permitted in Chapter 11 through Chapter 42, doors in the means of egress shall be permitted to be equipped with an approved entrance and egress access control system, provided that all the following criteria are met: (1) One of the following shall be provided: (a) A sensor shall be provided on the egress side, arranged to detect an occupant approaching doors that are arranged to unlock in the direction of egress upon detection of an approaching occupant or loss of power to the sensor. (b) Listed panic hardware or fire exit hardware that, when operated, unlocks the door (2) Loss of power to the part of the access control system that locks the doors shall automatically unlock the doors in the direction of egress. (3) The doors shall be arranged to unlock in the direction of egress from a manual release device located 40 in. to 48 in. (1015 mm to 1220 mm ) vertically above the floor and within 60 in. (1525 mm) of the secured doors. (4) The manual release device specified in 7.2.1.6.2(3) shall be readily accessible and clearly identified by a sign that reads as follows: PUSH TO EXIT. (5) When operated, the manual release device shall result in direct interruption of power to the lock - independent of the access control system electronics - and the doors shall remain unlocked for not less than 30 seconds. (6) Activation of the building fire-protective signaling system, if provided, shall automatically unlock the doors in the direction of egress, and the doors shall remain unlocked until the fire-protective signaling system has been manually reset. (7) Activation of the building automatic sprinkler or fire detection system, if provided, shall automatically unlock the doors in the direction of egress, and the doors shall remain unlocked until the fire-protective signaling system has been manually reset. A.7.2.1.6.2 It is not the intent to require doors that restrict access but comply with 7.2.1.5.9 to comply with the access-controlled egress doors provisions of 7.2.1.6.2. 7.2.1.5.9* A latch or other fastening device on a door shall be provided with a releasing device that has an obvious method of operation and that is readily operated under all lighting conditions. A.7.2.1.5.9 Examples of devices that might be arranged to release latches include knobs, levers, and panic bars. This requirement is permitted to be satisfied by the use of conventional types of hardware, whereby the door is released by turning a lever, knob, or handle or by pushing against a panic bar, but not by unfamiliar methods of operation such as a blow to break glass. It is

also within the intent of this requirement that switches integral to traditional door knobs, lever handles, or bars, that interrupt the power supply to an electro-magnetic lock, be permitted if affixed to the door leaf. The operating devices should be capable of being operated with one hand and should not require tight grasping, tight pinching, or twisting of the wrist to operate. COMMITTEE STATEMENT: The addition of 7.2.1.6.2(1)(b), addressing panic hardware, to the 2003 edition created problems. AHJs have been reported to require any door with an electric lock (regardless of whether it meets the provision of 7.2.1.5.9) to comply with the provisions for access-controlled egress doors. The action taken by the committee at the ROP stage in Proposal 101-101 was an attempt to clarify the issue. The new text only further muddied the waters. The action on this comment clarifies the issue. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE ELVOVE: I agree with the technical committee’s action of revising the text for 7.2.1.6.2 (i.e., reverting back to text language from the 2000 Code) along with the two new annex notes in A.7.2.1.6.2 and A.7.2.1.5.9 as this clarifies the requirements for access control systems and limits 7.2.1.6.2’s applicability only to access control systems. However, even with the new annex note in A.7.2.1.5.9, the code still doesn’t adequately address situations (e.g., high security) where doors are not equipped with motion sensors and are locked on the egress side (e.g., where card sensors, biomechanical sensors, etc. are required to remove power to electronic or magnetic door locks). These doors would rightfully not be permitted by the Code, yet they are commonly installed. Therefore, in order to confront this reality, the Code needs a separate section on “Electronically Locked Egress Doors” that includes a definition and provisions for overriding these kinds of doors such as connecting to the fire alarm system or installing emergency manual devices to override security locking systems such as what is currently required for delayed egress and access control systems. Also see my comment on 101-11 (Log #169). _______________________________________________________________101-52 Log #165 SAF-MEA FINAL ACTION: Reject (7.2.1.6.2) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-105 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: See Comment on Proposal 101-103 and the Explanation of negatives on both Proposals 101-103, 101-104, and 101-105. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Comments 101-51 and 101-50 which address the subject. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-53 Log #356 SAF-MEA FINAL ACTION: Accept in Principle (7.2.1.6.2) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-101 RECOMMENDATION: Consider. SUBSTANTIATION: Section 7.9.1.1 does not include access controlled doors in its requirements for emergency lighting, therefore the sign identified by 7.2.1.6.2 (4) has no assurance of being visible under all lighting conditions during the time that the conditions of occupancy require that the means of egress be available for use. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-92. COMMITTEE STATEMENT: The action on the comment referenced above in the committee action field should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-54 Log #163 SAF-MEA FINAL ACTION: Accept (7.2.1.6.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-103 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: This is a very detailed provision to provide ONE way to solve the problem of locked elevator lobby doors. It has potentially made many existing situations in violation of the Code as a simpler situation may not meet all this. It could be easily argued that prior arrangements would now be non-conforming since the code has provided ONE method to resolve the situation. We were better off when the Code left it up to the owner and AHJ to work out existing situations. COMMITTEE MEETING ACTION: Accept Reject Proposal 101-103 on elevator lobby electrical locking systems. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

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Report on Comments — Copyright, NFPA NFPA 101 COMMENT ON AFFIRMATIVE ELVOVE: I agree with the technical committee’s action of rejecting the original proposal which created a separate, somewhat verbose (and apparently unnecessary) section for elevator lobby egress where such lobbies (especially existing) are locked and the only egress from the elevator lobby is through the locked (e.g., tenant) space. However, as stated in my comment on the affirmative during the ROP ballot, the intent of the original proposal was to ensure occupants can egress from locked elevator lobbies by using an existing manual pull station where located in the elevator lobby to automatically unlock elevator lobby doors via the fire alarm system instead of having to install an additional “push to exit” button. With the rejection of proposal 101-101 which attempted to create a separate section for “Electronically Locked Egress Doors,” this situation is not adequately addressed by the Code. Note: elevator lobby exit access is currently addressed by 7.4.1.6 which states: “Elevators shall have access to at least one exit. Such exit access shall not require the use of a key, tool, special knowledge or special effort.” However this paragraph wouldn’t preclude using electronically locked egress doors. See my similar comments on 101-11 and 101-51. _______________________________________________________________101-55 Log #164 SAF-MEA FINAL ACTION: Reject (7.2.1.6.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-104 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: See Comment on Proposal 101-103 and the Explanation of negatives on both Proposals 101-103 and 101-104. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See action on Comment 101-50. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-56 Log #357 SAF-MEA FINAL ACTION: Accept (7.2.1.6.3) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-103 RECOMMENDATION: Delete in entirety. SUBSTANTIATION: This proposal attempts to correct occurrences where there is a violation or inability to comply with Section 7.4.1.6. This proposal should either offer alternative compliance options to Section 7.4.1.6 or suggest a change to it. Acceptance of new Section 7.2.1.6.3.2(2) directly violates section 9.6.2.2 by contradiction. Section 7.9.1.1 does not include access controlled doors in its requirements for emergency lighting, therefore the signs identified by 7.2.1.6.3.1(3) and 7.2.1.6.3.2(3) have no assurance of being visible under all lighting conditions during the time that the conditions of occupancy require that the means of egress be available for use. COMMITTEE MEETING ACTION: Accept Reject Proposal 101-103 on elevator lobby electrical locking systems. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE ELVOVE: I agree with the technical committee’s action of rejecting the original proposal which created a separate, somewhat verbose (and apparently unnecessary) section for elevator lobby egress where such lobbies (especially existing) are locked and the only egress from the elevator lobby is through the locked (e.g., tenant) space. However, as stated in my comment on the affirmative during the ROP ballot, the intent of the original proposal was to ensure occupants can egress from locked elevator lobbies by using an existing manual pull station where located in the elevator lobby to automatically unlock elevator lobby doors via the fire alarm system instead of having to install an additional “push to exit” button. With the rejection of proposal 101-101 which attempted to create a separate section for “Electronically Locked Egress Doors,” this situation is not adequately addressed by the Code. Note: elevator lobby exit access is currently addressed by 7.4.1.6 which states: “Elevators shall have access to at least one exit. Such exit access shall not require the use of a key, tool, special knowledge or special effort.” However this paragraph wouldn’t preclude using electronically locked egress doors. See my similar comments on 101-11 and 101-51. _______________________________________________________________101-56a Log #CC278 SAF-AXM FINAL ACTION: Accept (7.2.2.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action of Accept stand and notes that correlative actions have been taken via TCC notes on Comments 101-45, 101-46, 101-56b and 101-56c. Further, the TCC notes that SAF-MEA which has primary responsibility for Chapter 7 was information balloted on the action by SAF-AXM with 19 in agreement and 3 in disagreement.SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Further revise the text that resulted from SAF-MEA committee action on Comment 101-46 as follows:

7.2.2.2 Dimensional Criteria.7.2.2.2.1 Standard Stairs. 7.2.2.2.1.1 Stairs shall meet the following criteria: (1) New stairs shall be in accordance with Table 7.2.2.2.1.1(a) and 7.2.2.2.1.2. (2)* Existing stairs shall be permitted to remain in use, provided that they meet the requirements for existing stairs shown in Table 7.2.2.2.1.1(b). (3) Approved existing stairs shall be permitted to be rebuilt in accordance with the following: (a) Dimensional criteria of Table 7.2.2.2.1.1(b) (b) Other stair requirements of 7.2.2 (4) The requirements for new and existing stairs shall not apply to stairs located in industrial equipment access areas where otherwise provided in 40.2.5.2.

Table 7.2.2.2.1.1(a) New StairsFeature Dimensional Criteria

Minimum width See 7.2.2.2.1.2



Minimum tread depth 11 in. (280 mm)Minimum headroom 6 ft 8 in. (2030 mm)Maximum height between landings

12 ft (3660 mm)

Landing See 7.2.1.3, and 7.2.1.4.4 and 7.2.2.3.2


7.2.2.2.1.2 Minimum New Stair Width. (A) Where total occupant load of all stories served by the stair stairway is fewer than 50, the minimum width clear of all obstructions, except projections not more than 4 1/2 in. (114 mm) at or below handrail height on each side, shall be 36 in. (915 mm). (B)* Where stairs serve occupant loads exceeding that permitted by (A), the minimum width clear of all obstructions, except projections not more than 4 1/2 inches (114 mm) at or below handrail height on each side, Where the cumulative required capacity of a stairway is 50 persons or more, the minimum clear width measured as the horizontal distance between two handrails shall be in accordance with Table 7.2.2.2.1.2(B) and the requirements of 7.2.2.2.1.2(C), (D) and (E).


Cumulative Required Capacityof the Stairway


50 – 1999 Fewer than 2000 persons

36 in. (910 mm) 44 in. (1120 mm)

2000 persons and more 48 in. (1220 mm) 56 in. (1420 mm)

(C) (E) The total cumulative occupant load assigned to a particular stair stairway shall be that stair’s stairway’s prorated share of the total occupant load, as stipulated in (D) and (E), calculated in proportion to the stair stairway width as measured between handrails. (D) (C) For downward egress travel, stair stairway width shall be based on the total number of occupants from stories above the level where the width is measured. (E) (D) For upward egress travel, stair stairway width shall be based on the total number of occupants from stories below the level where the width is measured.

A.7.2.2.2.1.2(B) The stair stairway width requirement of 7.2.2.2.1.2(B) is based on accumulating the required capacity of the stair occupant load on each story the stair stairway serves. The accumulating of capacity occupant load is done for the purposes of the requirement of 7.2.2.2.1.2 only. The egress capacity requirements of Section 7.3 are NOT cumulative on a story-by-story basis. If additional exits provide egress capacity, the occupant load served by such additional exits—up to the limit permitted for the egress capacity of such additional exits, is not added to the total occupant load considered for the minimum stair width requirements of 7.2.2.2.1.2. If horizontal exits are provided on any of the stories, the total occupant load of all compartments on the story with the horizontal exits is used in the calculation of the minimum stair width requirements of 7.2.2.2.1.2. The number of stairs permitted through application of horizontal exit

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Report on Comments — Copyright, NFPA NFPA 101 requirements, in 7.2.4, is not affected by the minimum stair width requirements of 7.2.2.2.1.2. The following examples illustrate applications of the minimum stair width requirement. (1) A For example, a stair in a 2-story building that has 2000 persons on the second story but has, among 10 equally-sized stairs that serve the second story, would be considered to have 200 persons for the purposes of applying Table 7.2.2.2.1.2(B). The minimum width of such a stair would be 44 in. (1120 mm). (2) For a relatively large floor area building, a A typical 44-in. (1120-mm) stair would not be required to be increased in width so as to provide 48 in. (1220 mm) between handrails until it serves approximately 14 stories, calculated as follows:


For egress in the descending direction, only the stair width below the 14 stories with the total occupant load of 2000 persons per stair, or 4000 persons if served by two equally sized stairs, would need to be increased to 56 in. (1420 mm). If the building had 20 stories, only the stairs on the lowest 7 stories would be required to have the 56-in. (1420 mm) width. (3) For a 41-story building with 200 persons on each story (or 8,000 persons overall, not including the ground floor) with two equally-sized stairs, each stair would be considered to have 4,000 persons for the purposes of applying Table 7.2.2.2.1.2(B). Only the portion of the stair serving 2,000 persons would be required to have the wider width. If each story provides the same floor area for occupancy, the upper 20 stories would have 44-in (1120 mm) stairs and the lowest 20 stories would have the 56-in (1420 mm) stairs as a minimum. SUBSTANTIATION: The SAF-MEA means of egress committee prepared its action on Comment 101-46 two weeks before the occupancy chapter committees met. The SAF-AXM assembly occupancies committee met after the SAF-MER mercantile/business occupancies committee met and had the benefit of hearing the concerns raised by SAF-MER. The changes proposed above in the Recommendation answer those concerns. In accordance with the Rules of Procedure, the SAF-MEA committee, which has primary responsibility for Chapter 7 on means of egress, will be “information balloted” on these changes. The results of the informational ballot will be presented to the Technical Correlating Committee which will decide whether the amended language goes forward for Association action. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-56b Log #CC601 SAF-RES FINAL ACTION: Accept in Principle (7.2.2.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed from Accept to Accept in Principle – See Comment 101-56a.SUBMITTER: Technical Committee on Residential Occupancies COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Further revise the text that resulted from SAF-MEA committee action on Comment 101-46 as follows: 7.2.2.2 Dimensional Criteria.7.2.2.2.1 Standard Stairs. 7.2.2.2.1.1 Stairs shall meet the following criteria: (1) New stairs shall be in accordance with Table 7.2.2.2.1.1(a) and 7.2.2.2.1.2. (2)* Existing stairs shall be permitted to remain in use, provided that they meet the requirements for existing stairs shown in Table 7.2.2.2.1.1(b). (3) Approved existing stairs shall be permitted to be rebuilt in accordance with the following: (a) Dimensional criteria of Table 7.2.2.2.1.1(b) (b) Other stair requirements of 7.2.2 (4) The requirements for new and existing stairs shall not apply to stairs located in industrial equipment access areas where otherwise provided in 40.2.5.2.

Table 7.2.2.2.1.1(a) New StairsFeature Dimensional Criteria

Minimum width See 7.2.2.2.1.2



Minimum tread depth 11 in. (280 mm)Minimum headroom 6 ft 8 in. (2030 mm)Maximum height between landings 12 ft (3660 mm)Landing See 7.2.1.3, and 7.2.1.4.4

and 7.2.2.3.2


7.2.2.2.1.2 Minimum New Stair Width. (A) Where total occupant load of all stories served by the stair stairway is fewer than 50, the minimum width clear of all obstructions, except projections not more than 4 1/2 in. (114 mm) at or below handrail height on each side, shall be 36 in. (915 mm). (B)* Where stairs serve occupant loads exceeding that permitted by (A), the minimum width clear of all obstructions, except projections not more than 4 1/2 inches (114 mm) at or below handrail height on each side, Where the cumulative required capacity of a stairway is 50 persons or more, the minimum clear width measured as the horizontal distance between two handrails shall be in accordance with Table 7.2.2.2.1.2(B) and the requirements of 7.2.2.2.1.2(C), (D) and (E).


Cumulative Required Capacityof the Stairway


50 – 1999 Fewer than 2000 persons

36 in. (910 mm) 44 in. (1120 mm)

2000 persons and more 48 in. (1220 mm) 56 in. (1420 mm)

(C) (E) The total cumulative occupant load assigned to a particular stair stairway shall be that stair’s stairway’s prorated share of the total occupant load, as stipulated in (D) and (E), calculated in proportion to the stair stairway width as measured between handrails. (D) (C) For downward egress travel, stair stairway width shall be based on the total number of occupants from stories above the level where the width is measured. (E) (D) For upward egress travel, stair stairway width shall be based on the total number of occupants from stories below the level where the width is measured.

A.7.2.2.2.1.2(B) The stair stairway width requirement of 7.2.2.2.1.2(B) is based on accumulating the required capacity of the stair occupant load on each story the stair stairway serves. The accumulating of capacity occupant load is done for the purposes of the requirement of 7.2.2.2.1.2 only. The egress capacity requirements of Section 7.3 are NOT cumulative on a story-by-story basis. If additional exits provide egress capacity, the occupant load served by such additional exits—up to the limit permitted for the egress capacity of such additional exits, is not added to the total occupant load considered for the minimum stair width requirements of 7.2.2.2.1.2. If horizontal exits are provided on any of the stories, the total occupant load of all compartments on the story with the horizontal exits is used in the calculation of the minimum stair width requirements of 7.2.2.2.1.2. The number of stairs permitted through application of horizontal exit requirements, in 7.2.4, is not affected by the minimum stair width requirements of 7.2.2.2.1.2. The following examples illustrate applications of the minimum stair width requirement. (1) A For example, a stair in a 2-story building that has 2000 persons on the second story but has, among 10 equally-sized stairs that serve the second story, would be considered to have 200 persons for the purposes of applying Table 7.2.2.2.1.2(B). The minimum width of such a stair would be 44 in. (1120 mm). (2) For a relatively large floor area building, a A typical 44-in. (1120-mm) stair would not be required to be increased in width so as to provide 48 in. (1220 mm) between handrails until it serves approximately 14 stories, calculated as follows:


For egress in the descending direction, only the stair width below the 14 stories with the total occupant load of 2000 persons per stair, or 4000 persons if served by two equally sized stairs, would need to be increased to 56 in. (1420 mm). If the building had 20 stories, only the stairs on the lowest 7 stories would be required to have the 56-in. (1420 mm) width.

(3) For a 41-story building with 200 persons on each story (or 8,000 persons overall, not including the ground floor) with two equally-sized stairs, each stair would be considered to have 4,000 persons for the purposes of applying Table 7.2.2.2.1.2(B). Only the portion of the stair serving 2,000 persons would be required to have the wider width. If each story provides the same floor area for occupancy, the upper 20 stories would have 44-in (1120 mm) stairs and the lowest 20 stories would have the 56-in (1420 mm) stairs as a minimum. SUBSTANTIATION: This committee comment represents further revisions to the action taken by the Technical Committee on Means of Egress on Comment

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Report on Comments — Copyright, NFPA NFPA 101 101-46, as presented to this committee by member Jake Pauls. The committee endorses these further revisions for the reasons presented by Mr. Pauls at the ROC meeting, as follows: “This suggestion addresses three specific concerns of the MER TC (on 11/8/04): a gap in the thresholds for 36-in. minimum width and other widths; the effect of horizontal exits; and the effect of additional exits at the lower stories of a building. The elimination of language about “Cumulative Required Capacity” should eliminate possible confusion about capacity issues addressed by sections 7.2.4 and 7.3. Annex notes should further assist in clearing up confusions on this. In addition, because of possible confusion when using two different methods of specifying minimum stair width (as in the original proposal), only the conventional nominal width measurement is used (e.g., 36 in., 44 in. and 56 in. rather than using-for wider stairs-the clear handrail-to-handrail width. Secondly, by simply adding the reference to 7.2.2.3.2 to Table 7.2.2.1.1(a), the term “stair,” instead of “stairway,” can be used consistently in this section (because the width of the landings is linked to stair width in 7.2.2.3.2.).” The committee notes this action is subject to an informational ballot to SAF-MEA since that committee is responsible for Ch. 11, and it met prior to SAF-RES. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It may be premature for the TC to set the standard on combination egress/ingress dimensions until the Federal Government and other sanctioned studies on this subject are finalized. It also seems that the different revised texts may be new material and should be held until next cycle. _______________________________________________________________101-56c Log #CC476 SAF-IND FINAL ACTION: Reject (7.2.2.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting. Also see Comment 101-56a.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Technical Committee on Industrial, Storage, and Miscellaneous Occupancies COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: The committee is in support of the SAF-MEA action of Accept in Principle on Comment 101-46. SUBSTANTIATION: See committee statement by SAF-MEA on Comment 101-46. COMMITTEE MEETING ACTION: Accept COMMITTEE STATEMENT: This committee comment is a result of proposed action by BLD-MEA on Comment 5000-323. While the committee agrees that there are perceived safety and egress concerns associated with high rise buildings and voted to support the general concept of wider stairs within the context of high rise buildings, a number of concerns as noted below were raised during committee deliberations by TC members and the committee directed that these concerns be documented in the ROC. 1. A more holistic approach is required to adequately address the perceived safety and egress concerns associated with high rise buildings. some members of BLD-IND are not convinced that the proposed revision adequately addresses the issues and that it only offers an intermediate step that will be revised in the future. 2. Wider stairs may not be the most effective means of addressing the perceived concerns and the requirement for wider stairs may be premature. Other safeguards or a combination of other safeguards with wider stairs might be more appropriate. 3. It is not clear if the wider stairs should be required for all stairs or only for certain stairs that are intended for both fire department use and egress. 4. All factors associated with obesity and an aging population may not have been given adequate consideration. 5. The TC has concerns about the technical basis associated with the 14 story height criteria and the occupant load criteria of 2000 people. 6. It is unclear if the extra stair width will achieve the desired objective of counterflow and if firefighting operations and equipment were considered in establishing the new dimensions, i.e., fire hose laid across the stairs during firefighting operations would impede or stop flow of egressing occupants and the wider stair dimensions would not compensate for such obstructions. 7. Occupant behavior, such as occupants attempting to descend wider stairs at a faster rate and attempting to pass slower moving occupants, has not been sufficiently studied and could result in more trips and falls on wider stairs during emergency movement. 8. A more important factor might be the contamination of the stair by smoke and other products of combustion rather than stair width. 9. The defend in place concept. i.e., use of horizontal exits, which is currently allowed has not been properly considered in the application of the wider stair provisions.

10. The wider stair requirement may be premature considering that the NIST study has not yet been completed and released. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 16 Negative: 9 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: FLUER: I am changing my vote from affirming the committee action to NEGATIVE. I find the reasons as stated by Mr. Klein and others compelling, and feel that the negative comments from the MEA committee members should be addressed, and that the IND committee be given adequate time to reach considered consensus. HOLMES: As noted in the Committee Statement, there are numerous technical issues that are unresolved and there is insufficient information and justification to support the increase in stair width. For the record, the Committee Meeting Action to Accept was the result of the committee’s inability to form consensus on the Comment during the TC ROC meeting. The letter ballot affords the TC the opportunity to vote rationally on the Comment after careful consideration. It is important to note that there is no clear indication that the increase in stair width will have a significant affect on safety of occupants. However, requiring increased stair width will have significant cost impact. There is no technical justification for the threshold level at which the increased stair width criteria will be applied. Stairway egress with firefighter ingress is much more than just a counter flow problem that can be resolved by wider stairs. Firefighting operations within stairways will create obstructions to egress that wider stairs will not address. Most importantly, the wider stair regulations do not take into consideration the additional safety to occupants provided by horizontal exits. While the proponent has argued that the use and recognition of horizontal exits is “playing with numbers”, that is definitely not the case. The Life Safety Code and other codes have long recognized the benefit of horizontal exits. The horizontal exit offers the ability of occupants to safely exit an area to a safe location separated by a two-hour fire rated barrier without having to enter an exit stairway. Once the occupant has traveled into a horizontal exit, the occupant is considered to have completed required exit travel distance requirements and is safely situated. Any stairway provisions in the code must continue to recognize and credit horizontal exits as a safe exit. HUMBLE: The list of technical issues cited as a result of our SAF-IND meeting on 10-11 November 2004 are of sufficient basis to not have this proposal go forward at this time. KLEIN: Please register my vote as negative on this code proposal. The code comment was created by our Committee to support Comment 101-46 that was accepted by the Means of Egress Committee dealing with wider stairs in high-rise buildings. At the ROC Meeting of our Committee, there was discussion on this issue that generated the 10 items of concern that our Committee had with the Means of Egress Committee’s decision. The 10 items of concern are listed in the Committee Statement on this Comment. I voiced my concern at our Committee meeting about our Committee generating a Committee Comment either supporting or not supporting MEA’s Comment 101-46. I believe we were not given enough time nor all the information the MEA Committee had to make its conclusions on this important issue. Based on the 10 concerns generated during our Committee meeting, I believe that our Committee should not be put on the spot to make a quick decision without reading all the information on this issue. Without review of the “entire record” on this Comment, our Committee voted to support MEA’s Comment 101-46. I chose to abstain from this hand vote. However, in order to vote on this written ballot, I made the special effort to actually review the technical justification for Comment 101-46, which I understand includes the following: 1. Substantiation for ROC Comment 5000-323 2. ROC Comment 101-45 (Log #209) 3. ROP Proposals 101-591 and 5000-781 4. ROP Proposal101-107 5. Mr. Paul’s TCC negative votes on ROP Proposal 101-591 published on pages 101-7 to 101-8, and on ROP Proposal 5000-781 published on pages 5000- to 5000-10 After reviewing all this material, I found the opponents’ comments to the widening of stairs fair and reasonable. However, the rebuttals in the TCC negative votes by Mr. Paul of these opponents’ comments were unconvincing in addressing these opponents’ comments. One major concern of mine on this issue is that the aging of the population and the increase in obesity of the population has not been adequately investigated as it relates to such persons being able to use stairs no matter how wide we make them. How does wider stairs address this major issue? Mr. Paul’s TCC response to this question was to widen stairs even further. It would not matter to my 86-year-old mother how wide such stairs are, since she would not be able to traverse them. I would expect that there are numerous other individuals with the same problems as my mother, because of age or obesity, that wider stairs are not the answer. In conclusion, I believe the concerns of our Committee, those of the Business/Mercantile Committee, and the negative comments from the MEA Committee members should be adequately addressed before any code change to widen stairs is placed in the NFPA 101/NFPA 5000 Codes

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Report on Comments — Copyright, NFPA NFPA 101 KRANTZ: I concur with Mr. Holmes, Klein, McLaughlin, and Skalko’s “Negative” vote being that I agree with their comments on this matter. KRAUS: I agree with the reasons presented by Messrs. Holmes, Klein, etc. MCLAUGHLIN: I am voting negative because the 10 concerns outlined in the substantiation need to be satisfactorily addressed before I would vote to increase stair width. I agree with the comments by Marshall Klein. Furthermore, my recollection is that the Committee took action on an amended version of MEA 5000-323 which responded to concerns express by the Mercantile and Business Committee. SHAPIRO: I agree with the negative ballot comments of other committee members. SKALKO: The Committee action accepts the proposal approved by the BLD-MEA yet in the Committee Statement there are 10 items listed specifying reasons why the proposal as written may not be thorough enough to be codified. The concerns listed need to be considered thoroughly by the BLD-MEA and the proposal modified, as necessary, to address the issues that have been raised in the TC-IND committee deliberations. _______________________________________________________________101-57 Log #285 SAF-MEA FINAL ACTION: Reject (7.2.2.2.1(5) (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Add new text as follows: 7.2.2.2.1 Standard Stairs. Stairs shall meet the following criteria: [no change to (1) through (4)] (5) Where an escape device, group of devices or system is installed in accordance with 7.2.14.2 in a building, or portion thereof, and the total occupant load of all stories served by the stairway in that building or portion thereof, is 50 or more, the minimum width of new stairs clear of all obstructions, except projections not more than 114 mm (4 1/2 in.) at or below handrail height on each side shall be 1120 mm (44 in). SUBSTANTIATION: Where an escape device, group of devices or system is installed in accordance with 7.2.14.2 (as revised by a related comment) then significant additional egress capacity has been provided for building occupants in a manner that is coordinated through an evacuation plan and that is included in the training of building staff. That additional egress capacity will reduce the loading on the stairs in the building for both evacuees and for responding emergency service workers. Recognition for this added safeguard should be provided in the form of allowing the building to be built in accordance with 2003 minimum stair width requirements. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems ltd., Moseroth ltd. (Spider Rescue System) and DoubleExit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See action on Comment 101-78. The revised material does not permit escape devices to serve as means of egress components. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 23 Abstain: 1 EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. While the Committee Action on this comment may not need to be revised based upon the ballot results on Comment 101-78. I merely want to highlight this Public Comment as part of the package of comments. Please see my ballot comment regarding Comment 101-78.

_______________________________________________________________101-58 Log #16 SAF-MEA FINAL ACTION: Accept in Principle (Table 7.2.2.2.1(a)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: (a) Determine and specify where the new minimum stair width provision is to be located within Chapter 7 as this subject is unresolved in the Recommendation. (b) Provide any needed justification for applying the new requirement to all occupancies, including consideration of Proposal 101-591. (c) Give consideration to Fixen’s Explanation of Negative so as to make any needed changes. FIXEN: While the technical substantiation merits consideration, it appears that the fundamental driver for this substantiation is the complete and uncontrolled evacuation of very tall buildings, as opposed to staged evacuation currently contemplated by Code. It is premature to make changes that are not anchored to corresponding fundamental changes in the Code such as complete evacuation of very tall buildings. To my knowledge there is no committee consensus on fundamentally changing the underlying evacuation philosophy of tall buildings from staged to complete. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-46. COMMITTEE STATEMENT: (a) The action on Comment 101-46 shows where the new provision is to be located. (b) The committee action on Comment 101-46 is based on recognition that the extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions. The subject is related to counterflow as explained in the preceding paragraph. It is not occupancy specific. See action on Comment 101-354 which rejects Proposal 101-591. The ROP action by SAF-MER to exempt mercantile and business occupancies from the stair width requirement is unjustified. (c) In response to Fixen’s ballot comment, where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-59 Log #309 SAF-MEA FINAL ACTION: Reject (Table 7.2.2.2.1(a) New 7.2) _______________________________________________________________ SUBMITTER: Lawrence G. Perry Silver Spring, MD COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Delete new text in its’ entirety. Revert to 2003 edition text. SUBSTANTIATION: The several pages of Proposal Substantiation fail to provide any explanation of the charging language added within the new section 7.2.x, which is poorly written, and appears to read vastly different from the way this change has been presented. “Where the total occupant load of all stories” ... As written, this charging language triggers increased stair width based on the total occupant load, not on the fraction of the occupant load (1/2 if 2 stairs are provided, 1/3 if three stairs are provided, etc.) on each story that is assumed to use each stair. Regardless of the intent of the proposal, this language will require wider stairs at thresholds much lower than those cited as examples in the proposal. Further, this will require wider stairs regardless of the number of exit stairs that are provided, and regardless of the presence of horizontal exits. “... occupant load of all stories served by the stairway ...” Regardless of the intent of the proposal, the words state that you must calculate the entire load of all stories, and determine the width of the stairway using that total occupant load. Nothing in the text would permit the reduction in the width ‘of the stairway’ on upper floors where the cumulative occupant load was less than the increase-width triggers. The proponents claim that the concept is used widely throughout the code already, and is readily understood. However, the phrases “occupant load of all stories served by the stairway”, “all stories served by the stairway”, or “served by the stairway”, are not used anyplace in the current code. The text added via this proposal would increase stair widths for the full height of an exit stair simply because of a high occupant load on a lower floor level, because the stairway ‘served’ the lower floor. The proponent notes in the substantiation (in the paragraph above the “more-conservative approach” table) “the fact that, for office buildings, actual occupancy has been much less — by at least 50 percent on average — than the

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Report on Comments — Copyright, NFPA NFPA 101 traditional one person occupant load per 100 square feet of space.” Somehow in the substantiation this becomes a factor in considering even more conservative triggers for increased stair width. If anything, this fact indicates that there is already a built-in safety factor in the egress capacity for office buildings. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s request is in direct conflict with the action taken on Comment 101-46. The extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire conditions. See also, in the action on Comment 101-46, the revised langauge clarifying how the cumulative loads are to be calculated, and criteria explaining what portion of the stairway needs to provide the increased width. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 21 Negative: 3 EXPLANATION OF NEGATIVE: ELVOVE: First of all, the modifications made by the occupancy technical committees to comment 101-46 et al subsequent to the MEA ROC meeting seem to have improved upon the text of the proposed new requirements for wider stairs in high-rise (or extremely high occupancy) buildings. Therefore, if wider stairs will be required to allow for sufficient (downward) egress capacity and (upward) counterflow, then the egress (ingress) doors really need to be increased in size to accommodate bidirectional flow. Should this comment not be accepted, then I would change by affirmative vote on Comments 101-44, 45, 46 and 59 to negative as I would not widen stairs without adequately sized doors. FIXEN: See my Explanation of Negative on Comment 101-44. FRABLE: See my reasons stated in my negative comment on NFPA 101-46. Based on these concerns, the appropriate action on this comment should have been “Accept”. _______________________________________________________________101-60 Log #17 SAF-END FINAL ACTION: Accept in Principle (Table 7.2.2.2.1(b)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-108 RECOMMENDATION: Make any needed correlative changes to the Educational and Day-Care Occupancies chapters’ stair provisions as raised in the Committee Statement: The ROP action makes the changes to Chapter 7 requested by the submitter. However, the SAF-END educational and day-care occupancies committee will need to make correlative changes to 15.2.2.3.2 and 17.2.2.3.2 as those paragraphs currently require existing stairs to be Class A in areas occupied by students/clients. The SAF-MEA committee asks the Technical Correlating Committee to send a comment to SAF-END so that committee can achieve the correlation at the ROC-preparation phase if SAF-END does not do it for the ROP. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete as follows: 15.2.2.3* Stairs. 15.2.2.3.1 Stairs complying with 7.2.2 shall be permitted. 15.2.2.3.2 Existing Class A stairs shall be permitted. 15.2.2.3.3 Existing Class B stairs shall be permitted where not used for student access. 17.2.2.3* Stairs. 17.2.2.3.1 Stairs complying with 7.2.2 shall be permitted. 17.2.2.3.2 Existing Class A stairs shall be permitted. 17.2.2.3.3 Existing Class B stairs shall be permitted where not used by clients. COMMITTEE STATEMENT: The existing stairs provisions of Chapter 7 are adequate for educational occupancies. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-61 Log #18 SAF-MEA FINAL ACTION: Accept in Principle (7.2.2.4.4) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-111 RECOMMENDATION: Give consideration to the subject of retroactivity for existing stairs as raised in Elvove’s Comment on Affirmative so as to make any needed changes.

ELVOVE: Suggest an exception for existing stairs be added so not to retroactively require new handrails. In addition, some annex material including a diagram might help users visually understand the intent of this proposal. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-62. COMMITTEE STATEMENT: The action on the comment referenced in the committee action field rejects Proposal 101-111. So, the subject of applicability to existing stairs is moot. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-62 Log #288 SAF-MEA FINAL ACTION: Accept (7.2.2.4.4) _______________________________________________________________ SUBMITTER: Gene Boecker, Code Consultants, Inc. COMMENT ON PROPOSAL NO: 101-111 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: The use of angled steps is common within the aisles of large assembly facilities (e.g., stadiums, arenas, theaters). These are what would be considered trapezoidal stairs according to the submitter. As is mentioned in the negative ballot, there is insufficient data to address this. Questions must be addressed to determine at what angle not perpendicular to the leading edge of the riser is movement considered a hazard greater than that where movement is perpendicular. While movement at 70 degrees to the edge may be considered extreme, it has yet to be shown that the same risk is expressed if the movement is at 15 degrees to the perpendicular or 3 degrees to the perpendicular. The proposal raises a valid concern that should be researched so that a rational position can be taken with proper substantiation other than an intuitive belief that a tripping hazard may be present. If angled movement is acceptable in circular stairs then there must be some criteria for determining when an angle is too great. For aisles in a stadium or large theater, this would require a radical reconfiguration of the egress assumption. Is an angle of 3 degrees too much? 5 degrees? 10 degrees? What are construction tolerances? These are only a few of the questions that must be answered before a convincing position can be taken. Without any technical justification for the idea, the proposal should be placed on hold (rejected for now), until the documentation is available and can be properly supported. COMMITTEE MEETING ACTION: Accept Reject Proposal 101-111 so as NOT to add a requirement for handrails to be postioned perpendicular to the stair tread. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-63 Log #258 SAF-MEA FINAL ACTION: Hold (7.2.2.5.4) _______________________________________________________________ SUBMITTER: Jake Pauls, Jake Pauls Consulting Services COMMENT ON PROPOSAL NO: 101-117 RECOMMENDATION: Revise text to read as follows: 7.2.2.5.4.8* Where new contrasting marking is applied to stairs, such marking shall comply with the following: (1) The marking shall include a continuous strip as a coating on, or a material integral with, the full widfth width of the leading edge of such tread. (2) The marking shall include a continuous strip as a coating on, or a material integral with, the full widfth width of the leading edge of each landing nosing. (3) The marking strip width, measured horizontally from the leading vertical edge of the nosing shall be consistent at all nosings. (4) The marking strip width shall be 1 in. to 2 in. (25 mm to 51 mm) 7.2.2.5.4.9* Where new contrast marking is applied for stairway handrails, it shall be applied, or be part of, at least the upper surface of the handrail, have a minimum width 1/2 in. (13 mm), and shall extend the full length of each handrail. After marking, the handrail shall comply with 7.2.2.4.4.6. A.7.2.2.5.4.8 For stair nosing marking, surface-applied material, such as adhesive-backed tape and magnetic strips, should not be used as it is not durable under the scuffing from users’ feet and, in coming loose, it creates a tripping hazard. While a carefully applied and consistently maintained coating is acceptable, contrasting color or photoluminescent material integral with the nosings is preferable because of its permanence. See also 7.1.6.4 and 7.2.2.3.3 for slip resistance uniformity requirements as well as prohibition of projections on the treads. Guidance on the use of photoluminescent marking is provided by ASTM E 2030, Guide for Recommended Uses of Photolummines c ent (Phosphorescent) Safety Markings. Additional marking, for example, at the side boundaries of the stair, should be applied in accordance with the guidance provided therein. If photoluminescent marking is also provided for handrails, it should be on at least the upper surface of the handrail and should extend the full length of each handrail. A.7.2.2.5.4.9 Guidance on the use of photoluminescent marking is provided by ASTM E 2030, Guide for Recommended Uses of Photoluminescent (Phosphorescent) Safety Markings, however, wall marking behind handrails is not recommended as it fails to highlight the handrail and might even detract

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Report on Comments — Copyright, NFPA NFPA 101 from visually detecting the presence and location of the handrail. Generally, coatings, and other applied markings, if used, should be durable for expected usage, especially at end terminations of the marking and at changes in stair direction where usage is more extensive and hand forces larger. SUBSTANTIATION: Editorially, spelling errors are corrected with the words “width” and “photoluminescent.” (Twice in each case.) More substantially, the annex note on handrail marking is too important not to include as a requirement rather than a recommendation. Handrail marking is not scoped but merely provided with requirements that need to be met if new handrail marking is used. For the safety and usability of the stairway, the marking of handrails is of similar importance to that of nosing marking and related criteria need to be imposed on minimum width, continuity and on continued graspability of handrails generally. Guidance on durability is also important, as is guidance on use of photoluminescent marking; hence the new annex note. Submission of this comment is partly based on work within a Taskforce on egress marking working on input to New York City requirements that will be applicable to existing and new high-rise buildings; however no claim is made that the comment is consistent with the recommendations of the Taskforce which are not finalized as this comment is submitted. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces a subject that has not had public review via the Report on Proposals (ROP) and in accordance with the Regulations Governing Committee Projects must be held for processing as a proposal for the next revision cycle. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-64 Log #298 SAF-MEA FINAL ACTION: Reject (7.2.2.5.4.8) _______________________________________________________________ SUBMITTER: Manny Muniz, Manny Muniz Assoc. COMMENT ON PROPOSAL NO: 101-117 RECOMMENDATION: Delete and add text as follows: A.7.2.2.5.4.8 For stair nosing marking, surface applied material, such as adhesive backed tape and magnetic strips should not be used as it is not durable under the scuffing from users feet and, in coming loose, it creates a tripping hazard. In order to avoid a tripping hazard, use marking stripes that are manufactured specifically for use on walking surfaces and insure that they are applied in accordance with the manufacturer’s installation instructions. While a carefully applied and consistently maintained coating is acceptable, contrasting color or photoluminescent material integral with the nosings is preferred because of its permanence. See also 7.1.6.4 and 7.2.2.3.3 for slip resistance uniformity requirements as well as prohibition of projections on the treads. Guidance on the use of photoluminescent marking is provided by ASTM E2030, Guide for Recommended Uses of Photoluminescent (Phosphorescent) Safety Markings. Additional marking, for example, at the side boundaries of the stair, should be applied in accordance with the guidance provided therein. If photoluminescent marking is also provided for handrails, it should be on at least the upper surface of the handrail and should extend the full length of each handrail. Remainder unchanged. SUBSTANTIATION: We wish to commend the committee for understanding the need for adequately marking stair treads for exit stairs. While we fully support the proposed regulation, we do not feel the appendix explanation is consistent with Section 2.3.8.2 of the Manual of Style for NFPA Technical Committee Documents which states: “Caution and warning statements shall only be permitted to be used within the mandatory text sections where a distinct hazard to the user, building, property, exposures, and so forth exists.” We understand the concerns of the committee and feel there is a more positive way in which to state the concern. We feel the attached new wording addresses the concern in a more positive and appropriate manner. Our industry has successfully manufactured safety tapes applied to walking surfaces for many years. We use only industrial grade adhesives specifically formulated for walking surfaces to insure that the tapes will not be displaced by foot traffic. These tapes are specifically designed and manufactured for use on walking surfaces. When installed in accordance with the manufacturer’s installation instructions, they will not cause a tripping hazard. Any safety devise not properly installed in accordance with the manufacturers installation instructions can become a hazard. We do not outlaw safety devices simply because we may have seen an improper installation. That is why the authority having jurisdiction is responsible to see that all building safety devices and components are installed in full accordance with the manufacturer’s installation instructions. We must also point out that the committee has no data to support the statement “Tape should not be used as it is not durable under the scuffing from users feet and, in coming lose, it creates a tripping hazard.” Such statements by a fire safety organization without documented substantiation should be reviewed by legal staff. We wish to speak in support of this proposal. Removal of the proposed first sentence of the appendix section will maintain the factual basis and enable us to go forward in full support of this worthwhile proposal. COMMITTEE MEETING ACTION: Reject

COMMITTEE STATEMENT: There is no consensus standard for marking stripes for use on walking surfaces. Installing one manufacturer’s product per that manufacturer’s instructions does not assure durability, wearability, or the stay-in-place features needed. Such a specification is not enforceable. Also, the submitter has misread the NFPA style manual. Caution and warning statements generally do not belong in the body of a document; they belong in the advisory annex. The style manual directs that such statements are to be placed in the body of the document ONLY where a distinct hazard exists. The technical committee is then established as the group to judge the hazard. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-65 Log #373 SAF-MEA FINAL ACTION: Hold (7.2.2.5.4.8) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: 101-117 RECOMMENDATION: Add new text: NFPA 1 UFC 14.6.4.8 A contrasting marking stripe shall be provided on each stair tread and riser in accordance with ASTM E 2030-02. NFPA 101 7.2.2.5.4.8 A contrasting marking stripe shall be provided on each stair tread and riser in accordance with ASTM E 2030-02. SUBSTANTIATION: Stairs in a building are used for both occupant evacuation and for firefighter access to the upper floors during a fire. Visibility of those stairs under normal and emergency conditions is crucial to both occupant survival and to firefighter safety. Many occupants have common visual impairments such as low vision. People’s ability to navigate the stairs in an emergency in a timely fashion can literally mean the difference between life and death as the window of time for safe evacuation is never known in advance. FEMA’s World Trade Center Building Performance Study (Chapter 2, WTC 1 and WTC 2, Section 2.2.1.3) noted that between both towers, 99% of the people below the floors of impact survived in part because important modifications had been made to the building egress system after the 1993 WTC bombing, including the placement of photoluminescent markings on the egress paths and the stair treads to facilitate emergency egress. ASTM E 2030-02 provides three approved methods of marking the stairs which will provide visible stair markings for both descent of occupants and ascent of firefighters in the event there is a loss of normal and emergency power. This last point is of a great importance in that it takes into account the potential failure of emergency power or emergency batteries. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces a subject that has not had public review via the Report on Proposals (ROP) and in accordance with the Regulations Governing Committee Projects must be held for processing as a proposal for the next revision cycle. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-66 Log #19 SAF-MEA FINAL ACTION: Accept in Principle (7.2.2.6.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-118 RECOMMENDATION: Give consideration to Koffel’s Comment on Affirmative so as to make any needed changes. KOFFEL: Language should be added to allow previously approved, existing conditions. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 7.2.2.6.2 as follows: 7.2.2.6.2* Visual Protection. Outside stairs shall be arranged to avoid any impediments to the use of the stairs by persons having a fear of high places. For Outside stairs more than three stories in height, other than previously approved existing stairs, shall be provided with an opaque visual obstruction any arrangement intended to meet this requirement shall not be less than 48. in. (1220 mm) 1220 mm (48 in.) in height. COMMITTEE STATEMENT: The performance-based first sentence needs to be retained so existing outside stairs are not completely exempted from the requirement for visual protection. Previously approved existing stairs need to be exempted from the new requirement for the opaque barrier. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 23 Negative: 1 EXPLANATION OF NEGATIVE: ELVOVE: Because there is no exception for existing occupancies. Should such one be included, I would vote affirmatively on this comment.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-67 Log #208 SAF-MEA FINAL ACTION: Reject (7.2.3 and 7.2.1.2.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, for technical correlation with the action on Comment 101-56a, to Accept in Principle – Add text as follows: 7.2.2.2.1.2(F) The clear width of door openings discharging from stairways required to comply with 7.2.2.2.1.2(B) shall be in accordance with 7.2.1.2.4(9). 7.2.1.2.4(9)* Where a single door is provided for discharge from a stairway required to comply with 7.2.2.2.1.2(B) and such door serves as the sole means of exit discharge from such stairway, the clear width of the door opening, measured in accordance with 7.2.1.2.2, shall be not less than two-thirds the nominal width of the stairway. A.7.2.1.2.4(9) The relative egress carrying capacity of door openings and stairs is based on the two-to-three ratio used in Table 7.3.3.1 to help balance the capacity of various egress elements and assure that downstream egress facilities do not form a bottleneck or constriction to flow. For example, a stairway with a nominal width of 56 in. (1420 mm) should be served by an exit discharge door with a minimum width opening of 37 in. (940 mm) if only one discharge door is provided. It might be advantageous for two discharge doors to serve such a stairway, each with a more-typical clear opening width of 32 in. (810 mm). This would facilitate access, into the exit, of firefighters and other emergency responders without causing undue interference to evacuees attempting to transition from the stair to the exit discharge door.SUBMITTER: Jake Pauls, Jake Pauls Consulting Services COMMENT ON PROPOSAL NO: 101-107 RECOMMENDATION: Suggested new text to read as shown below: 7.2.x.3 For minimum door opening width discharging from stairways in compliance with 7.2.x.2, see 7.2.1.2.4.x. 7.2.1.2.4.x* For a single door serving as the sole means of egress discharge from stairways, the clear width of the door opening (measured in accordance with 7.2.1.2.2) shall be not less than two-thirds the nominal width of the stairway, where the nominal width of the stair is the width clear between handrails plus 9 inches (228 mm). A.7.2.1.2.4.x The relative egress carrying capacity of door openings and stairs is based on the two-to-three ratio used in Table 7.3.3.1. For example, a stairway with a nominal width of 57 inches (1448 mm)—with the allowance, permitted by 7.3.2.2 for 4 1/2 in. (114 mm) of handrail projection on each side beyond a clear, handrail-to-handrail width of 48 in. (1220 mm)—would require a clear width of door opening of 38 in. (965 mm) if only one discharge door were provided. It might be advantageous for two discharge doors to serve such a stairway, each with a more-typical clear opening width of 32 in. (810 mm). This would facilitate access, into the exit, of firefighters and other emergency responders without causing undue interference to most of the evacuees attempting to transition from the stair to the exit discharge door. SUBSTANTIATION: This is a clarification and correlation change needed to address concerns expressed by some people regarding an increase in minimum stairway width (under proposal 101-107). The proposed annex note provides background on the technical issue of relative performance of stairs and doors. Note that the two-to-three ratio is the one fitting best with current practice in relation to capacity rules. A three-to-four ratio is also referred to in egress research literature (e.g. the “Movement of People” chapter in the SFPE Handbook of Fire Protection Engineering )—which would lead to a more-conservative choice of minimum door width. This is one reason that the full 4 1/2 inches of handrail projection into the capacity-credited stair width is assumed here, as opposed to a minimum 3 1/2 inches (with 1 1/4 inch handrail width and 2 1/4 clearance). In other words, a slightly conservative handrail projection assumption is made in conjunction with the less-conservative ratio of relative performance of doors and stairs. Otherwise, with the assumption of a three-to-four ratio, the discharge door opening would be 42 3/4 inches minimum with a 57-inch nominal stair width or 41 1/4 inches minimum with a 55-inch nominal stair width. Further refinement of this matter would require systematic data collection and detailed analysis going beyond that done to date on evacuation flows. To go beyond the relatively crude egress technology used in traditional and current code requirements, use should be made of the more-sophisticated “effective-width model” for evacuation flow that is discussed in the SFPE Handbook of Fire Protection Engineering. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: This comment is tied to the wider stair issue of Comment 101-46. The wider stair is to facilitate counterflow on the stair. A person entering the building through a door opening while others are exiting the building through the same door creates an impediment for just a couple seconds. The upward traveling person encroaches on stair width the whole time they are climbing the stairs. Thus, the stair needs to be made wider, but the door does not. If the greater stair width required by the action on Comment 101-46 is then used to receive credit for increased stair capacity, then the door will need to be made wider for compliance with the existing requirements related to capacity of means of egress. Thus, the issue raised by the submitter is self-correcting. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 5 EXPLANATION OF NEGATIVE: DE VRIES: Having increased the width of the stairs per Comment No. 101-46, Proposal 101-107 and related actions, and thus facilitated flow of evacuees and emergency responders, it is counterintuitive to fail to address the choke

point that will result at the primary means out of the stair. If not overturned by written ballot, I encourage the proponent to address the issues raised in the committee substantiation and resubmit this, or a similar, proposal. DI PILLA: I disagree with the committee’s action to reject this proposal. This text requires egress stairwell doors to be comparable to the accepted proposal increasing the width of the stairs. The cost differential between keeping doors as they are and increasing them is negligible. The benefits of increasing the stair width, which the committee agreed to do, is limited without a comparable increase in the door width. I don’t understand how the committee could accept one portion of the change and reject the other. ELVOVE: First of all, the modifications made by the occupancy technical committees to comment 101-46 et al subsequent to the MEA ROC meeting seem to have improved upon the text of the proposed new requirements for wider stairs in high-rise (or extremely high occupancy) buildings. Therefore, if wider stairs will be required to allow for sufficient (downward) egress capacity and (upward) counterflow, then the egress (ingress) doors really need to be increased in size to accommodate bidirectional flow. Should this comment not be accepted, then I would change by affirmative vote on Comments 101-44, 45, 46 and 59 to negative as I would not widen stairs without adequately sized doors. KULIGOWSKI: The committee voted to reject this comment (to widen the doors at the base of the stair) after voting to accept the comment to widen the staircase depending upon the total number of occupants using the staircase in the building. I am not in favor of widening the stairs without widening the door at the base of the staircase. Without commensurate increase in door width at the stairway exit, the exit discharge capacity may become the controlling factor in occupant egress, negating any positive effects of increased stair width. PAULS: I am persuaded by the concerns raised in the negative ballots of de Vries, Di Pilla and Kuligowski on MEA TC actions on comments 101-67 and 5000-324. Please record me as changing my ballot to negative on MEA TC action on comment 101-67 and 5000-324. The comments should have been accepted by the TC. I was silent on this during the first round of balloting (even with 101-67 and 5000-324 being my comments) because I had been led to believe that the codes already addressed the sizing of exit discharge doors when the stair width was increased. As the committee comment claimed, there would be self correction. However, this assumption is tied into an assumption that capacity concerns would lead to making the doors wider without making any change in the Code. However, whether there is a desire to utilize the full capacity of wider stairs or not, I now believe that it is important for the exit discharge doorways to be designed to have a minimum width of at least two-thirds that of the nominal width of the stairs; indeed, it is essential and should be required by the Code. For stairs required to have a minimum width of 56 inches, this means exit discharge doorways with a minimum clear width of 37.33 inches. Note that the text proposed in comment 101-67 and 5000-324 would be simplified if the proposal on wider minimum stairs is accepted with reference only to the usual nominal width (i.e., 56 inches), not the clear width of 48 inches between handrails. That is, there would be a deletion of the proposed clause, “where the nominal width of the stair is the width clear between handrails plus 9 inches (228 mm).” Furthermore, the proposed first sentence of the annex note would not be needed. Finally, even if the wider stair width is justified (as it was in the committee statement) on the basis of emergency responder counterflow, recognition should still be made of the improved egress capacity of the stair and the discharge door width should not be a “choke point” for egress flow. This, as well as emergency responder access to the exit, was also a concern of members of the newly formed NFPA High-Rise Building Safety Advisory Committee which met a couple of days prior to the deadline for submitting this circulation ballot. This new advisory committee’s apparent support for wider stairs, and its specific concern that the discharge doorway would be appropriately sized, also influenced my last-minute submission of this negative ballot. _______________________________________________________________101-68 Log #238 SAF-MEA FINAL ACTION: Accept in Principle (7.2.3.12) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs, in response to Koffel’s comment, that the language of 7.2.3.12 be revised as follows: 7.2.3.12 Emergency Power Supply System (EPSS). Power shall be provided as follows: (a) A Type 60 / Class 2 / Level 2 EPSS for new mechanical ventilation equipment shall be provided in accordance with NFPA 110, Standard for Emergency and Standby Power Systems. (b) A previously approved existing standby power generator installation with a fuel supply adequate to operate the equipment for 2 hours shall be permitted in lieu of 7.2.3.12(a). (c) The generator shall be located in a room having a minimum 1-hour fire resistance-rated separation from the remainder of the building.SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-120 RECOMMENDATION: Change to reject action to Accept in Principle to 7.2.3.12 Standby Power Emergency Supply System (EPSS). Standby Power A type 60/Class 2/Level 2 EPSS for...be provided by an...house current. The generator...building. The generator...2 hours. SUBSTANTIATION: My proposal has not added “a big effect” on the electrical system. I tried to clarify for owners, designers and AHJs which system is required based upon NFPA 110 definitions. See Mr. Koffel’s explanation of negative to my statement. KOFFEL: As used in NFPA 110, the phrase Emergency Power Supply System (EPSS) includes what has been

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Report on Comments — Copyright, NFPA NFPA 101 traditionally referred to as a standby power supply. Type 60 refers to power restoration in 60 seconds. Class 2 refers to 2-hour duration. Level 2 indicates that failure is less critical to human life and safety (as compared to Level 1). I believe the proposed language adds clarity to the Code. COMMITTEE MEETING ACTION: Accept in Principle Revise 7.2.3.12 as follows: 7.2.3.12 Standby Power Emergency Power Supply System (EPSS). Standby power A Type 60 / Class 2 / Level 2 EPSS for mechanical ventilation equipment shall be provided in accordance with NFPA 110, Standard for Emergency and Standby Power Systems. by an approved, self-contained generator that is set to operate whenever there is a loss of power in the normal house current. The generator shall be located in a room having a minimum 1-hour fire resistance-rated separation from the remainder of the building. The generator shall have a fuel supply not less than that which is adequate to operate the equipment for 2 hours. COMMITTEE STATEMENT: The action does what the submitter requested, but also adds the word “Power” to complete the phrase “Emergency Power Supply System (EPSS). NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 23 Negative: 1 EXPLANATION OF NEGATIVE: ELVOVE: Because there is no exception for existing occupancies. Should such one be included, I would vote affirmatively on this comment. COMMENT ON AFFIRMATIVE KOFFEL: I would encourage the TCC to insert language that would exempt previously approved installations from the proposed requirement. In the Committee Action on Comment 101-93 it should be noted that the Committee retained existing requirements for existing installations and imposed the new language only on new installations. The same action should be considered for this section. I understand that paragraph 7.2.3.1 provides an overall exception for approved, existing smokeproof enclosures but I think the exemption for existing standby power systems should be explicitly stated. _______________________________________________________________101-69 Log #156 SAF-MEA FINAL ACTION: Accept in Principle (7.2.5.3(b)) _______________________________________________________________ SUBMITTER: Joseph T. Holland, Hoover Treated Wood Products COMMENT ON PROPOSAL NO: 101-122 RECOMMENDATION: Proposed 7.2.5.3 Ramp Details. 7.2.5.3.1 Construction. Ramp construction shall be as follows: (a) All ramps serving as required means of egress shall be of permanent fixed construction. (b) Each ramp in buildings required by this Code to be of Type I or Type II construction shall be any combination of noncombustible or limited-combustible or fire-retardant treated wood throughout. The ramp floor and landings shall be solid and without perforations. Revised (b) Each ramp in buildings required by this Code to be of Type I or Type II construction shall be any combination of noncombustible or limited-combustible or fire-retardant treated wood throughout. The ramp floor and landings shall be solid and without perforations. Ramps constructed with fire-retardant-treated wood shall not be more than 30 in. high, or more than 3000 sq ft, or occupy more than 50 percent of the room. SUBSTANTIATION: The revision is suggested to address the concerns expressed in the committee statement. The revision was requested for ramps in the interior of a building. We did not give any limitations for exterior use because of the opening phrase in this section, “Each ramp in buildings...” We read it to mean the section spoke to ramps inside of buildings. However, having said that, there is no limitation on the use of the exterior product. This is not a brush-on or spray-on treatment. This is a pressure treated product that has been tested to ASTM D2898, the Standard Rain Test. It’s been subjected to 800 in. of water to simulate a 10-year exposure to rain fall. After the test the product is subjected to the ASTM E84 Tunnel Test. The exterior products have been in use for more than 25 years. COMMITTEE MEETING ACTION: Accept in Principle Revise 7.2.5.3.1 as follows: 7.2.5.3.1 Construction. Ramp construction shall be as follows: (1) All ramps serving as required means of egress shall be of permanent fixed construction. (2) Each ramp in buildings required by this Code to be of Type I or Type II construction shall be any combination of noncombustible or limited-combustible material or fire-retardant treated wood throughout. (3) Ramps constructed with fire-retardant-treated wood shall be not more than 30 in. (760 mm) high, not more than 3000 ft 2 (277 m 2 ) in area, and shall not occupy more than 50 percent of the room area. (4) (3) The ramp floor and landings shall be solid and without perforations. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE ELVOVE: Proposed text exceeds that of a definition and should therefore be truncated. And if NFPA 5000 reads similarly, then its definition needs to change as well. Note: use term consistently through the code where used (e.g., “fire retardant-treated wood”).

KOFFEL: It should be noted that the defined term in Comment 101-13a is “fire retardant-treated wood.” The Committee Action on this comment shows an additional hyphen between “fire” and “retardant.” The phrase should be consistent throughout the Code. _______________________________________________________________101-70 Log #220 SAF-MEA FINAL ACTION: Reject (7.2.12.2.4(3)) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-125 RECOMMENDATION: Reconsider the original proposal and revise to read as follows: The elevator shall be located in a shaft system meeting the requirements for smokeproof enclosures of Section 8.6.1 in accordance with 7.2.3 unless otherwise provided in 7.2.12.2.4.1 and 7.2.12.2.4.2. SUBSTANTIATION: The committee comment misinterprets the change in the proposed language and its application. This change will not require elevator doors to be smoke-rated. Rather, this reference will provide for the isolation of the elevator shaft in accordance with the code’s current basic requirements for vertical shafts. A fire on a lower floor can communicate smoke and heat into the vertical shaft used as the access to a public way. Isolation of the elevator allows for the designer to use any of several available design methods to isolate the elevator shaft. The existing language addresses smokeproof enclosures used primarily as exit stairs and requiring a vestibule. When an elevator based Area of Refuge is chosen it not then required on all floors. The integrity of an area of refuge and its path to the outside must be maintained. A building may have a single floor with such an Area of Refuge or 30 percent of its floors, or all of its floors. For most multi-story buildings under NFPA 5000 automatic sprinklers are likely to be installed and the 0.05 in. of water column enclosure pressurization would than apply. This pressure difference is adequate for a stair vestibule arrangement as an initial safeguard to smoke intrusion into the stairwell. This level is not a good benchmark for elevator shafts that in addition to wind and stack effects must also contend with the piston effects of elevators in the shaft. In several texts the piston pressure which varies according to number of cars and the speed at which the car moves is acknowledged as being 0.06 in. wc. The reference to the 8.6.1 requirements for vertical shafts will result in barrier meeting in 0.10 in. of water column enclosure pressurization. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s text does not improve the language. Such a change appears to be a downgrading of the 7.2.3 smokeproof enclosure requirements. If the change were to be made, it would require yet unspecified additional changes to be made for correlation and co-ordination. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-71 Log #20 SAF-MEA FINAL ACTION: Accept in Principle (7.2.12.3.4.2 and A.7.2.12.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes, in response to Koffel’s comment, that it has not searched all proposals and comments to correlate use of the terms limit, prevent, resist, retard. However, the issue is addressed in Comment 101-122.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-126 RECOMMENDATION: Review and take any action needed on the subject of the proposed change by SAF-FIR to 7.2.12.3.4.2, given that SAF-MEA has primary responsibility for the text. Give consideration to Holmes’, Kapalczynski’s, and Roeper’s Explanation of Negative so as to make any needed changes. HOLMES: The use of the word, “limit”, implies a prescribed maximum amount, quantity, or number. As noted in the Committee Substantiation, limit means to bound or set a boundary. The Life Safety Code does not presently, nor does it intend to, establish a maximum amount or numerical boundary for smoke movement. KAPALCZYNSKI: The committee has reviewed numerous proposals for requiring specific air leakage requirements in smoke barriers and smoke partitions. Each of these proposals has been rejected on the basis that existing smoke barriers and smoke partitions already perform adequately with respect to the intent of the code and that the necessity for additional technical requirements is not substantiated. Consequently, proposals to more finely calibrate the wording alone, when additional technical requirements have already been rejected, should be rejected, too. If semantic calibration is necessary to make the code more comprehendible to lawyers and juries then the preferable word is “resist” as it is commonly understood. Applying “resist” to smoke partitions and “limit” to smoke barriers confuses the clarity of the code intent and will coerce the committee into reconsidering proposals for unenforceable technical specifications that have been presently determined to be unnecessary. Note also, that 101-68 (Log #CP610) proposes “limit or resist” while 101-126 (Log #CP611) proposes, “limit,” and 101-179 (Log #CP609) proposes, “limiting.” ROEPER: I am returning my ballot with negatives for each of the above referenced logs. My reasons for doing so follow: (1) The definitions to the terms retard, resist, restrict and limit, as determined by the committee, provide no discernible difference to the user of the standard.

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Report on Comments — Copyright, NFPA NFPA 101 (2) 101-179 (Log #CP609) strikes the term “restrict” and seeks to replace it with “limit”. Unfortunately, the definitions to these two terms each reference the other term, i.e., restrict is to limit, and limit is to restrict. I realize that the debate over these terms has gone on for some time, however, I do not feel that the committee’s current position on the use of the terms provides clear and actionable language for the user of the standard. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 7.2.12.3.4.2 and leave the first paragraph of A.7.2.12.3.2 unchanged to read as follows: 7.2.12.3.4.2* The barriers specified in 7.2.12.3.4, and any openings in them, shall minimize air leakage and retard resist the passage of smoke. A.7.2.12.3.2 The method of meeting the tenability performance criteria required of an area of refuge of less than 93 m2 (1000 ft2) can involve controlling the exposing fire (for example, via automatic sprinkler protection), installing smoke-resisting doors in the smoke-resisting barriers (see NFPA 105, Standard for the Installation of Smoke Door Assemblies), providing smoke control to prevent or limit smoke migration through cracks or other leakage paths (see NFPA 92A, Recommended Practice for Smoke-Control Systems), or providing other means or a combination of these means. COMMITTEE STATEMENT: The term “resist” has been chosen for consistency between the mandatory Code text and the advisory annex text. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE KOFFEL: A number of Public Comments were submitted regarding the use of the terms limit, prevent, resist, and retard. The TCC should review all of these Public Comments to ensure consistency between the actions of the various Technical Committees. _______________________________________________________________101-72 Log #167 SAF-MEA FINAL ACTION: Reject (7.2.14) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes, in response to Koffel’s comment, that Comment 101-72a by SAF-DET provides the needed clarification that the action in ROP Proposal 101-128 is not to go forward.SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: This material is not appropriate for the Life Safety Code. Attention is directed to the long TCC note. At best, these could be used in one- and two-family dwellings and that chapter does not use it. All of the occupancy committees except one have rejected the concept and there is a comment to reject it in that occupancy. The material has several flaws including: can they be used to satisfy arrangement of means of egress, and travel distance. How does this work with less than 10 people?? The one place the AXM committee accepted it, would not normally be occupied by more than 10 people. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See action on Comment 101-78. The concept for the 10-person criterion recognizes that a family, for example, should be able to voluntarily install and use supplemental evacuation equipment for their own dwelling unit without additional regulation. Where more than 10 persons are subject to use of such devices, there needs to be regulation to assure a co-ordinated plan and a system of devices. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 20 Negative: 2 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: See my Explanation of Negative on Comment 101-12. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts.

5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Depending on the ballot results on Comment 101-78 an additional ballot of SAF-MEA on this comment to reject the proposal may be appropriate. Otherwise, if Comment 101-78 fails ballot the recommendation of the Committee will be the Committee Action in the ROP. Please see my ballot comment regarding Comment 101-78. _______________________________________________________________101-72a Log #CC401 SAF-DET FINAL ACTION: Accept (7.2.14) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that in the last paragraph of the Substantiation developed by SAF-DET, the reference to 11.2.14 should be a reference to 7.2.14.SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Reject Proposal 101-128 so as NOT to add a new 7.2.14 subsection on Escape Devices and Systems that can serve as components within the required means of egress. SUBSTANTIATION: The SAF-MEA committee used an Accept in Principle action on Comment 101-78 to achieve two things: (1) Not go forward with a new 7.2.14 subsection on Escape Devices and Systems that can serve as components within the required means of egress. (2) Create a new Section 7.13 on Supplemetntal Evacuation Devices that receive no credit as satisfying any means of egress provisions. There is the possibility that the SAF-MEA meeting action might not pass ROC ballot because some members are opposed to any mention of such devices [that is, they oppose item (2) above, favor item (1), but must vote on the comment as a whole]. A failed ballot would leave the original ROP text for 7.2.14 standing. This comment clarifies the intent of the committee that the 11.2.14 subsection on Escape Devices and Systems is not to go forward. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-73 Log #21a SAF-MEA FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Give consideration to DiPilla’s and Shulman’s Explanation of Negative, and Koffel’s Comment on Affirmative, so as to make any needed changes. The TCC learned that (1) UL has withdrawn its certification of components of such systems, and (2) ASTM has established a project to develop a product standard.

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Report on Comments — Copyright, NFPA NFPA 101 DI PILLA: While I believe this concept has great potential, I don’t believe it is ready to be inserted into a national consensus code. At present, there are no approved/listed/certified products. In fact, there is not even a listing organization yet. If placed in the code, this would place the AHJ in the position of evaluating these complex egress components even though there has yet to be any substantial research on even HOW to evaluate them. Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered—and there is no methodology (nor sufficient research to date) to do so. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. In addition, the impact of these components on marking/signage, and related physical aspects of egress have not been established. I believe that this proposal should not be accepted until: 1. a listing organization program has been established, 2. a methodology for assessing installation and use has been developed, and 3. clear, minimum operational controls have been standardized. SHULMAN: The Code currently includes a comprehensive set of egress and escape requirements for various occupancies that have been well thought out and ingrained into the building and life safety codes used by our society. They are based on the concept of either evacuating occupants in an orderly, safe fashion, or protecting them in place in a protected area of refuge within the building. This proposal includes provisions for permitting escape devices and systems to be used in addition to required means of egress and escape provisions. On the surface this would appear to be acceptable, using the “more is better” argument. However, we have serious concerns about the actual impact that such systems have on the behavior and safety of occupants during emergency evacuation conditions that have not yet been adequately addressed in this proposal. This includes the possibility that the existence of such systems in a building may disrupt the orderly evacuation of the building or the efforts of fire service professionals, and that occupants attempting to use these systems under panic conditions may expose themselves or others to potentially dangerous conditions as they struggle to use these systems. UL has received input from members of the fire service that indicates a strong preference for building occupants to follow established plans for egress of the building if at all possible, or “stay put” if they find the existing means of escape blocked and permit fire service personnel to undertake rescue activities. UL is of the opinion that, on the whole, this is the more advisable course of action in the present state. Both the building infrastructure and the education provided to building occupants have for many years focused on moving people towards the marked “EXITS” within the building during any evacuation scenario. Providing widely variable alternatives to be used at unpredictable times, at the discretion of particular individuals, throws out the certainty and familiarity with the established routine that is essential for its smooth operation during the high percentage of the time that the routine presents the best method for minimizing fire deaths. The “counter-flow” created by intentional attempts to redirect people or individual decisions of occupants – in high-panic mode – will in itself likely lead to significant injuries and problems. It will be nearly impossible for the decision whether to utilize an external and supplemental evacuation system to be made in a rational, informed manner. The entire premise behind these systems is that they will serve as a “last resort” – an act of desperation when all hope in the other established systems fail. To argue that “any option” is acceptable as a last resort is fallacious. The premise assumes the conclusion, i.e., the individual has not other changes of rescue, that the alternative is viable, and that the individual is capable of making a rational choice under extremely stressful circumstances. Further, the simple existence of the option will likely cause it to be considered prematurely. Decisions will be made by occupants based on limited knowledge and information, with a lack of firsthand experience with both the secondary equipment and the emergency scenario. The individual(s) responsible for making the decision may also be under considerable pressure by other building occupants, further degrading their capability to make a rational decision. The decision is a challenging one with serious implications, and decision-making quality will decline during times of high stress. The proposal does not provide AHJs or building owners with sufficient guidance on how to select and coordinate appropriate systems. The proposal also does not contain adequate measures to promote reliable and adequate testing and maintenance of the systems on an ongoing basis. There will (hopefully) be no real opportunities to rigorously test any number of these systems in a manner that can lead to a decision as to their ability to perform effectively when needed – during a time of some indeterminate facility escape route failure and imminent total infrastructure collapse. The uncertain human factors alone – including the behavioral unpredictability of both the system deployment decision makers and the other facility occupants – render any attempt at a system effectiveness evaluation highly unreliable. We also suspect that occupants attempting to utilize the equipment in a panic situation are likely to overload it in the escape frenzy. In conclusion, it is our belief that sufficient research into the potential use of these products, including detailed human factor/behavior studies, have not been

conducted to address the potential hazards associated with their installation and use under emergency evacuation conditions. Further, the overall effect of these products and inherently variable decisions about their use as they relate to occupant behaviors with respect to emergency evacuation plans in general needs to be carefully considered. Based on these and other concerns, UL has chosen to not list such secondary emergency escape devices, and at this time has no intention to develop a certification program for such products. KOFFEL: It is my understanding that some Committee members supported the proposed action on the basis that the Committee was seeking additional input from the public. Therefore, the record should clearly show that the Committee recognizes that additional work and consideration may be necessary and that Public Comment, both favorable and negative, should be encouraged. In 101-129 (Log #294) the Submitter justifies, in part, the proposal as a need to provide selection criteria. As an alternative to providing the material in this Code, a product standard may be a more appropriate method to accomplish this objective. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The action on the comment referenced in the committee action field incorporates applicable parts of the ballot comments. With respect to DiPilla’s ballot comment, emergency plans need to address issues on a case-by-case basis. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: I agree with the negative explanations of DiPilla and Shulman on Proposal 101-128. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions.EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me.

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Report on Comments — Copyright, NFPA NFPA 101 COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. Regardless of the outcome of the ballot on Comment 101-78, the action on this comment probably will not need to be revised. However, I am providing this comment merely to highlight the entire package of comments for review by the TCC pending the outcome of the ballot on Comment 101-78. _______________________________________________________________101-74 Log #21b SAF-AXM FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: (a) Give consideration to DiPilla’s and Shulman’s Explanation of Negative (on Proposal 101-128) so as to make any needed changes in its action on Proposal 101-297 and Proposal 101-338 as SAF-AXM was the only technical committee to recognize the use of the escape devices or systems. (b) Reconsider the applicability of the new provision for catwalks given that the proposed 7.2.14 seems not to be applicable to use inside a building. (c) Take care in the proper use of the terms “means of egress” and “means of escape.” (d) Take note that UL has withdrawn its certification of components of such systems, and ASTM has established a project to develop a product standard. DI PILLA: While I believe this concept has great potential, I don’t believe it is ready to be inserted into a national consensus code. At present, there are no approved/listed/certified products. In fact, there is not even a listing organization yet. If placed in the code, this would place the AHJ in the position of evaluating these complex egress components even though there has yet to be any substantial research on even HOW to evaluate them. Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered—and there is no methodology (nor sufficient research to date) to do so. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. In addition, the impact of these components on marking/signage, and related physical aspects of egress have not been established. I believe that this proposal should not be accepted until: 1. a listing organization program has been established, 2. a methodology for assessing installation and use has been developed, and 3. clear, minimum operational controls have been standardized. SHULMAN: The Code currently includes a comprehensive set of egress and escape requirements for various occupancies that have been well thought out and ingrained into the building and life safety codes used by our society. They are based on the concept of either evacuating occupants in an orderly, safe fashion, or protecting them in place in a protected area of refuge within the building. This proposal includes provisions for permitting escape devices and systems to be used in addition to required means of egress and escape provisions. On the surface this would appear to be acceptable, using the “more is better” argument. However, we have serious concerns about the actual impact that such systems have on the behavior and safety of occupants during emergency evacuation conditions that have not yet been adequately addressed in this proposal. This includes the possibility that the existence of such systems in a building may disrupt the orderly evacuation of the building or the efforts of fire service professionals, and that occupants attempting to use these systems under panic conditions may expose themselves or others to potentially dangerous conditions as they struggle to use these systems. UL has received input from members of the fire service that indicates a strong preference for building occupants to follow established plans for egress of the building if at all possible, or “stay put” if they find the existing means of escape blocked and permit fire service personnel to undertake rescue activities. UL is of the opinion that, on the whole, this is the more advisable course of action in the present state. Both the building infrastructure and the education provided to building occupants have for many years focused on moving people towards the marked “EXITS” within the building during any evacuation scenario. Providing widely variable alternatives to be used at unpredictable times, at the discretion of

particular individuals, throws out the certainty and familiarity with the established routine that is essential for its smooth operation during the high percentage of the time that the routine presents the best method for minimizing fire deaths. The “counter-flow” created by intentional attempts to redirect people or individual decisions of occupants – in high-panic mode – will in itself likely lead to significant injuries and problems. It will be nearly impossible for the decision whether to utilize an external and supplemental evacuation system to be made in a rational, informed manner. The entire premise behind these systems is that they will serve as a “last resort” – an act of desperation when all hope in the other established systems fail. To argue that “any option” is acceptable as a last resort is fallacious. The premise assumes the conclusion, i.e., the individual has not other changes of rescue, that the alternative is viable, and that the individual is capable of making a rational choice under extremely stressful circumstances. Further, the simple existence of the option will likely cause it to be considered prematurely. Decisions will be made by occupants based on limited knowledge and information, with a lack of firsthand experience with both the secondary equipment and the emergency scenario. The individual(s) responsible for making the decision may also be under considerable pressure by other building occupants, further degrading their capability to make a rational decision. The decision is a challenging one with serious implications, and decision-making quality will decline during times of high stress. The proposal does not provide AHJs or building owners with sufficient guidance on how to select and coordinate appropriate systems. The proposal also does not contain adequate measures to promote reliable and adequate testing and maintenance of the systems on an ongoing basis. There will (hopefully) be no real opportunities to rigorously test any number of these systems in a manner that can lead to a decision as to their ability to perform effectively when needed – during a time of some indeterminate facility escape route failure and imminent total infrastructure collapse. The uncertain human factors alone – including the behavioral unpredictability of both the system deployment decision makers and the other facility occupants – render any attempt at a system effectiveness evaluation highly unreliable. We also suspect that occupants attempting to utilize the equipment in a panic situation are likely to overload it in the escape frenzy. In conclusion, it is our belief that sufficient research into the potential use of these products, including detailed human factor/behavior studies, have not been conducted to address the potential hazards associated with their installation and use under emergency evacuation conditions. Further, the overall effect of these products and inherently variable decisions about their use as they relate to occupant behaviors with respect to emergency evacuation plans in general needs to be carefully considered. Based on these and other concerns, UL has chosen to not list such secondary emergency escape devices, and at this time has no intention to develop a certification program for such products. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action by SAF-AXM on Comment 101-209. COMMITTEE STATEMENT: The action should satisfy the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-75 Log #153 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ SUBMITTER: Edward Klinger, Ozonelink Inc. COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: In their committee statement and as referenced in ballot comments submitted by committee members, the Means of Egress Committee sought comments on the subject of escape devices and systems. I support the concept of providing guidance in NFPA 101 on this subject, as indicated below. SUBSTANTIATION: Context for Comments. In testimony before 9/11 Commission in May 2004 Homeland Security Secretary Tom Ridge encouraged the private sector to improve its building evacuation readiness through the ANSI/NFPA voluntary standards—calling them “essential elements” in preparing for a potential attack. On 9/11 the populace watched in horror as WTC inhabitants plummeted to their deaths because it was the only alternative to evade the engulfing flames, smoke and gas. Unable to get to the stairwells, a secondary method of egress potentially could have saved many lives that day. The question that needs to be asked now is not solely focused on evacuation plans but on evacuation methods. The public is now rightly asking, “Could more people have been saved on 9/11 if they had a secondary method of egress?” As an international consultant and system integrator in the domain of homeland security and safety we are encouraged that the NFPA and other organizations are diligently working to create standardization and codes for secondary methods of egress. In parallel innovation by manufacturers around the world to develop secondary egress systems is yielding real results. For these solutions, it is essential that the NFPA, manufacturers, and integrators work closely with each other complementing each other’s strengths. In particular,

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Report on Comments — Copyright, NFPA NFPA 101 because this is a new challenge to be served, the NFPA be providing broad guidance for selection, installation and use of external evacuation equipment. The detailed technical issues of suitability and safety should be addressed by product standards. Evacuation Plans. The only way to ensure the complete safety of all of a building’s occupants in the event of a fire is by conducting a full-scale evacuation. At present, primary evacuation systems in most high-rise buildings are inadequate in that they fail to provide 100 percent of the occupants with a timely, safe, and effective method of egress which in turn makes the essential task of evacuation problematic. Moreover, the challenging issues facing primary evacuation methods are seemingly uncorrectable. In the event of a fire a building’s passenger elevators are automatically returned to its main level and shut down to await reactivation by fire-fighters rendering elevators unusable for egress. A building’s stairways are typically designed according to the evacuation needs of their respective floor populations rather than the evacuation needs of the entire building and are therefore incapable to handle inevitable congestion associated with the cumulative effect of fleeing occupants. By inhibiting occupant egress and fire-fighter ingress, congested stairways increase the risk of injury and death to both. Additionally, the Stack Effect and the Breaking-of-the-Seal effect cause smoke and toxic gases to be carried upward and throughout a building. Even in buildings that are compartmentalized to contain the spread of smoke and fire, the stairwells can quickly become the most dangerous place for occupants to be due to the Breaking-of-the-Seal Effect. Unavoidably, in order to evacuate a building occupants will open doors to corridors and stairwells on lower floors. Fire and rescue crews repeat this action when they enter a burning building. These actions facilitate smoke and toxic gases to naturally diffuse into stairwells and begin rising towards the upper floors. Occupants on higher floors, therefore, become unable to use the stairways for egress due to their rapid contamination. That being said, the Chicago Fire Department issues this statement of evacuation plans for High Rise Buildings in Chicago: The building management should develop a floor plan which will be posted in key locations throughout each floor. Additionally, each employee will be given the name of their Floor Leader to be kept in his/her assigned work area. Copies of Evacuation/Emergency Procedures and the location of physically disabled personnel will be posted at each work station and at the lobby desk. Every employee and tenant will be orientated in the emergency procedure for the building and will be required to participate in any drills. In the event of a fire in a high-rise office building, only 8 floors will be evacuated: the fire floor, three floors above and four floors below the fire. If the building has an outside fire escape, it should be used only as an alternative means of escape. Many other establishments nationwide offer this type of simple, generic evacuation plan. However, this type of evacuation plan does not comply with what we know about the likely progression of smoke and toxic gases according to the Stack Effect and the Break-of-the-Seal Effect, nor does it comply with the necessity to completely evacuate the building in order to ensure 100 percent safety. The point is that because primary evacuation plans are not always adequate, we can learn important lessons to help us shape secondary egress systems. Certainly secondary egress systems are not to replace primary systems, but to complement them. Any plan should specify, but not be limited to: • The role of the escape device or system in the overall plan i.e., the method. • The role and authority of emergency response personnel with respect to the escape device or system. • The person or persons authorized to direct the deployment of, and to operate, the escape device, group of escape devices or system. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The submitter made no specific recommendation, but the sense of the comment was incorporated into the action on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: DI PILLA: As mentioned in my earlier negative, it’s clear to me that this material is not ready to be inserted into a national consensus code. I was disappointed that neither of my key points were even remotely addressed by the committee, despite direction from the TCC to do so. • There is no basic product standard. While an ASTM committee has been formed, it can (and usually does) take several years before a standard is completed. • As an “interim measure” (which will likely be several years), the code text offers only a series of “things to consider,” providing no actual, usable guidance to AHJs who will be required to approve these devices. • Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered - and there is no methodology (nor sufficient research to date) to do so. • Contrary to what has been argued, there are no technical authorities other than manufacturers for the AHJ to call upon for assistance. These are fundamental requirements of placing provisions into the code. The committee has always required not only a standard, but a standard that has been obtained, distributed, discussed, and accepted prior to instituting language in the code specifying it. Here we are not even requiring a standard at all! I fear

that the committee is acting prematurely - and setting up the potential for disaster. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized, or even completely inventoried. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. This too remains unaddressed. Finally, the impact of these components on marking/signage, and related physical aspects of egress have not been even been discussed, let alone established. Does the committee true expect an AHJ to competently evaluate this myriad of issues, most of which have yet to be fully identified? I believe that this proposal should not be accepted until: 1. a standard with a listing program has been established, 2. a methodology for assessing installation and maintenance has been developed, and 3. clear, minimum operational controls have been standardized. In summary, there has not been nearly enough development on these devices (or controls established) to believe that placing them into buildings will provide a greater degree of safety than remaining in the building in the vast majority of cases. In fact, there is reason to believe that greater injury could occur from the use of these devices by building occupants that are 1. unfamiliar with their operation; 2. fearful of critical factors such as heights and enclosed places, and 3. in a panic mode. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE BRYAN: The submitter in the comment relative to Proposal 101-128 has indicated three criteria for secondary egress systems. None of these criteria have been established in detail in the comments for escape devices or systems to the Means of Egress Committee. A subcommittee has been established by ASTM E.06. We should let this subcommittee fulfill their scope in developing these items. ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its

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Report on Comments — Copyright, NFPA NFPA 101 installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. Regardless of the outcome of the ballot on Comment 101-78, the action on this comment probably will not need to be revised. However, I am providing this comment merely to highlight the entire package of comments for review by the TCC pending the outcome of the ballot on Comment 101-78. _______________________________________________________________101-76 Log #160 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ SUBMITTER: Rami Nir, Ben-Gurion International Airport COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: In their committee statement and as referenced in ballot comments submitted by committee members, the Means of Egress Committee sought comments on the subject of escape devices and systems. I support the concept of providing guidance in NFPA 101 on this subject, as indicated below. SUBSTANTIATION: Context for Comments. As chairman of the special Evacuation from Sky Scrapers Committee, in Israel I am seeking information from abroad regarding External Evacuation of high-rise structures. We have had this subject on our agenda since 9/11. The Israel committee is very interested in the development of standards and specifications which legally define the need for and establish the acceptability of external evacuation equipment which provide for the evacuation of trapped people and will aid the firefighters in rescuing and delivering equipment. We wish to participate in related activities with your organization and are seeking the following information and participation opportunities: – To receive and review evacuation plans that are prepared to facilitate the utilization of external evacuation equipment which includes the coordination with the building occupants, the building caretakers and the interface with the fire service. – Information developed regarding the application of external evacuation equipment and access to that equipment as it relates to the upper floors of high-rise buildings in order to reduce the number of evacuees using the stairs. At Ben-Gurion International Airport we are about to complete our new main terminal, Terminal 3, which was planned according to the NFPA standards. Both my deputy and I were directly involved on a daily basis in the construction process in order to ensure that these standards were implemented. We are very interested in the activity being undertaken by NFPA regarding External Evacuation Equipment and wish to participate by receiving Standards, Codes and other documents. We will be pleased to provide comment and information based on our experience and understanding of the need for this capability. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The submitter made no specific recommendation, but the sense of the comment was incorporated into the action on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: DI PILLA: As mentioned in my earlier negative, it’s clear to me that this material is not ready to be inserted into a national consensus code. I was disappointed that neither of my key points were even remotely addressed by the committee, despite direction from the TCC to do so. • There is no basic product standard. While an ASTM committee has been formed, it can (and usually does) take several years before a standard is completed. • As an “interim measure” (which will likely be several years), the code text offers only a series of “things to consider,” providing no actual, usable guidance to AHJs who will be required to approve these devices. • Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered - and there is no methodology (nor sufficient research to date) to do so. • Contrary to what has been argued, there are no technical authorities other than manufacturers for the AHJ to call upon for assistance. These are fundamental requirements of placing provisions into the code. The committee has always required not only a standard, but a standard that has been obtained, distributed, discussed, and accepted prior to instituting language in the code specifying it. Here we are not even requiring a standard at all! I fear that the committee is acting prematurely - and setting up the potential for disaster. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized, or even completely inventoried. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. This too remains unaddressed. Finally, the impact of these components on marking/signage, and related physical aspects of egress have not been even been discussed, let alone established. Does the committee true

expect an AHJ to competently evaluate this myriad of issues, most of which have yet to be fully identified? I believe that this proposal should not be accepted until: 1. a standard with a listing program has been established, 2. a methodology for assessing installation and maintenance has been developed, and 3. clear, minimum operational controls have been standardized. In summary, there has not been nearly enough development on these devices (or controls established) to believe that placing them into buildings will provide a greater degree of safety than remaining in the building in the vast majority of cases. In fact, there is reason to believe that greater injury could occur from the use of these devices by building occupants that are 1. unfamiliar with their operation; 2. fearful of critical factors such as heights and enclosed places, and 3. in a panic mode. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE BRYAN: See my Explanation of Negative on Comment 101-12 and my Affirmative with Comment on 101-75.. ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. Regardless of the outcome of the ballot on Comment 101-78, the action on this comment probably will not need to be revised. However, I am providing this comment merely to highlight the entire package of comments for review by the TCC pending the outcome of the ballot on Comment 101-78.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-77 Log #161 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ SUBMITTER: Micha Swissa, The Standards Institution of Israel COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: The Standard Institution of Israel supports the concept of providing guidance in NFPA 101 on this subject. SUBSTANTIATION: Standards organizations as Standard Institution of Israel and ASTM established process to develop standards that address the technical issues of suitability and safety of various products of external evacuation. Development of such standards would be much enhanced by code-level guidance from NFPA, in the process those organizations are looking to NFPA for broad guidance. A lack of such direction from NFPA early on, could result ultimately in contradiction directions. Standard Institution of Israel has drafted and is near finalizing product standards for platform systems, chutes and controlled descent devices, as is ASTM. There is an existing European standard (EN 341) for controlled descent devices for rescue use. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The submitter made no specific recommendation, but the sense of the comment was incorporated into the action on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: DI PILLA: As mentioned in my earlier negative, it’s clear to me that this material is not ready to be inserted into a national consensus code. I was disappointed that neither of my key points were even remotely addressed by the committee, despite direction from the TCC to do so. • There is no basic product standard. While an ASTM committee has been formed, it can (and usually does) take several years before a standard is completed. • As an “interim measure” (which will likely be several years), the code text offers only a series of “things to consider,” providing no actual, usable guidance to AHJs who will be required to approve these devices. • Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered - and there is no methodology (nor sufficient research to date) to do so. • Contrary to what has been argued, there are no technical authorities other than manufacturers for the AHJ to call upon for assistance. These are fundamental requirements of placing provisions into the code. The committee has always required not only a standard, but a standard that has been obtained, distributed, discussed, and accepted prior to instituting language in the code specifying it. Here we are not even requiring a standard at all! I fear that the committee is acting prematurely - and setting up the potential for disaster. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized, or even completely inventoried. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. This too remains unaddressed. Finally, the impact of these components on marking/signage, and related physical aspects of egress have not been even been discussed, let alone established. Does the committee true expect an AHJ to competently evaluate this myriad of issues, most of which have yet to be fully identified? I believe that this proposal should not be accepted until: 1. a standard with a listing program has been established, 2. a methodology for assessing installation and maintenance has been developed, and 3. clear, minimum operational controls have been standardized. In summary, there has not been nearly enough development on these devices (or controls established) to believe that placing them into buildings will provide a greater degree of safety than remaining in the building in the vast majority of cases. In fact, there is reason to believe that greater injury could occur from the use of these devices by building occupants that are 1. unfamiliar with their operation; 2. fearful of critical factors such as heights and enclosed places, and 3. in a panic mode. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised

and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE BRYAN: NFPA 101 SAF-MEA should utilize the Standards Institute of Israel and the ASTM Subcommittee E.066-77 to determine the suitability of these devices for submittal to the Life Safety Code. ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. Regardless of the outcome of the ballot on Comment 101-78, the action on this comment probably will not need to be revised. However, I am providing this comment merely to highlight the entire package of comments for review by the TCC pending the outcome of the ballot on Comment 101-78. _______________________________________________________________101-78 Log #278 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that it permits the action to go forward as it is in agreement with the explanation in Koffel’s comment which follows: “Probably the deciding factor in voting affirmative on this comment was the result that would be achieved. The Code gives no credit or recognition to escape devices or systems in any other section (pending final action by other Technical Committees). The proposed new section merely provides a set of requirements should someone propose to install such equipment on a building. Therefore, I no longer see harm in providing this set of requirements in the Code and in fact I can rationalize a benefit. If the Code remains silent on the issue and in the absence of a product standard, building owners are free to install and use anything they might chose. At least by including this section, the Code now provides a minimum set of requirements for such optional equipment. In so doing, the Code may in fact be minimizing danger from fire by preventing the use of equipment that could be dangerous to the occupants of the building.”SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Revise text to read: 7.2.14* Escape Devices and Systems. 7.2.14.1 General. Where an escape device, group of devices, or system serves 10 or more persons in a single tenant space or coordinated group of multiple tenant spaces within a building or floor thereof, the escape device, group of devices, or system shall comply with be permitted provided that the following criteria are met:

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Report on Comments — Copyright, NFPA NFPA 101 (1) Where permitted by Chapter 11 through 42. ( 2 1 ) Each escape device or system shall be of an approved type. The authority having jurisdiction shall be permitted to require an approved, independent third party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction. ( 3 2 ) Use of the escape device, group of deices, or system shall not pose a safety hazard to non-users, including emergency response personnel, and to users of adjacent devices or systems. (4) One hundred percent of the egress capacity shall be provided independently of the escape device or system. (5) The escape device or system shall not be considered the primary means of egress or primary means of escape. ( 6 3 ) The escape device, group of devices, or system shall be installed, inspected, tested, maintained and used in accordance with the manufacturer’s instructions. (7) Instructions for use shall be clearly visible and affixed in an approved location, on the device or adjacent to the system access points, as appropriate. ( 8 4 ) Where building electrical power is required to operate the escape device, group of devices, or system, standby power shall be provided within one story of the escape device or system electric-utilization components. ( 10 5 ) An evacuation plan in accordance with 4.8.2 and 7.2.14. 2 3 shall be implemented. ( 9 6 ) The escape device, group of devices, or system shall provide sufficient capacity to evacuate all occupants above the first floor in accordance with the approved evacuation plan. Where the building served exceeds the height of fire department equipment access. Where the building served is 20 or more stories in height, the escape device, group of devices, or system shall provide sufficient capacity such that the time required for evacuation of all spaces served by the installation above the level of fire department equipment access shall not exceed the fire resistance rating of load bearing components of the building’s structural system. capacity to evacuate not less than all the occupants of the 10 contiguous floors with the highest occupant load in 30 minutes from the system’s deployment. (11 7) Staff personnel shall be trained in operations and procedures for use of the escape device or system. (12 8) Where two or more escape devices or systems are installed in new construction, at least two shall be remotely located from one another. Where two or more escape devices or systems are installed in existing construction, at least two shall be remotely located from one another, where practical. 7.2.14.32 Secondary Means of Egress or Escape. An escape device, group of devices or system shall be permitted as a component in the secondary means of egress or secondary means of escape provided that the following criteria are met: (1) Where specifically permitted as a secondary component in the means of egress or a secondary means of escape by Chapter 11 through Chapter 42. (2) The device, group of devices or system shall be in accordance with 7.2.14.1 (2), (3), (4), (5), (6), (7), (8), (10), (11) and (12). (3) One hundred percent of the egress capacity shall be provided independently of the escape device, group of devices or system. (4) At least one means of egress or means of escape shall be provided that does not include an escape device, group of devices, or system as a component in that means of egress or means of escape. 7.2.14.23 Evacuation Plan. The evacuation plan shall specify, but shall not be limited to, the following: (1) The role of the escape device, group of devices or system in the overall plan. (2) The role and authority of emergency response personnel with respect to the escape device or system. (3) The person or persons authorized to direct the deployment of, and to operate, the escape device, group of escape devices or system. A.7.2.14 The guiding principles that govern the acceptability of installing and using escape devices and systems, whether voluntary, or to satisfy a need for a secondary means of egress or escape, are specified in the text. In granting approval for a specific device or system, the Authority Having Jurisdiction may consider, among other things, listing by a nationally recognized testing laboratory, where testing criteria exist for a particular type of device or system. Additionally, in granting approval of an electrically powered system or device, the AHJ may choose to reference NFPA 110, Standard for Emergency and Standby Power Systems and NFPA 111, Standard on Stored Electrical Emergency and Standby Power Systems. Except where specifically approved in accordance with 7.2.14.2, escape devices and systems are not considered an element of the required means of egress or escape. Consequently, even if devices or systems are installed in compliance with 7.2.14.1, one hundred percent of the egress capacity and number of means of egress must still be provided in accordance with the requirements of Chapter 7 and the applicable occupancy chapter(s). Balance of A.7.2.14 unchanged. SUBSTANTIATION: In the current edition of the Life Safety Code, no credit towards egress capacity or numbers of means of egress is given for escape devices or systems as defined by Proposal 101-32. BUT there are also no prohibitions in the current edition that prevent the voluntary installation of escape devices or systems, either. Based on the action on this proposal and related proposals, there are now significant restrictions that in effect prohibit the voluntary installation of many escape devices or systems that comply with the intent of the proposal. This was not the intent

• at least three manufacturers of evacuation equipment have successfully field tested prototype installations on high-rise buildings that satisfy the draft Israeli standards and one product has been certified for installation in Israel based on one of those draft standards, • both ASTM and the Standards Institute of Israel are committed to working towards internationally recognized product standards for this equipment, • at least one AHJ in Israel has confirmed their ability to evaluate an installation for a particular situation and make a determination on approval, though they are looking for guidance to NFPA and other standards writing bodies, • the New York City Council committee responsible for the city’s building code held a public hearing that specifically addressed external evacuation and their advisory committee is considering recommended amendments to the NYC Building Code that will provide criteria for installation and use of such equipment, and • this concept has received enthusiastic support and interest by the Israeli Homeland Security Command and the Israeli Fire Service. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Accept in Principle Do not go forward with the addition of a new Section 7.2.14. Rather, revise and add text as follows: 7.1.1* Application. Means of egress for both new and existing buildings shall comply with this chapter Sections 7.1 through 7.12. Supplemental evacuation equipment shall comply with Section 7.13. (See also 4.5.3. ) 7.13 Supplemental Evacuation Equipment. 7.13.1* Escape Devices and Systems. Where an escape device or system serves 10 or more persons, the escape device or system shall comply with the following criteria: (1) Each escape device or system shall be of an approved type. (2) In approving the device or system as required by 7.13.1(1), the authority having jurisdiction shall be permitted to require an approved, independent third party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction. (3) Use of the escape device or system shall not pose a safety hazard to non-users, including emergency response personnel, and to users of adjacent devices or systems. (4) The escape device or system shall be installed, inspected, tested, maintained and used in accordance with the manufacturer’s instructions. (5) Where electrical power is required to operate the escape device or system, at least one source of power generation shall be provided within one story of the escape device or system electric-utilization components. (6) An evacuation plan in accordance with 4.8.2 shall be implemented and shall specify, but shall not be limited to, the following: (a) The role of the escape device or system in the overall plan. (b) The role and authority of emergency response personnel with respect to the escape device or system. (c) The person or persons authorized to direct the deployment of, and to operate, the escape device or system. (d) Special considerations that affect the usability of the escape device or system. (e) The intended evacuation time in consideration of the capacity of the escape device or system. (7) Staff personnel and the person or persons authorized to direct the deployment of and to operate the escape device or system shall be trained in its operations and procedures for use. (8) Where two or more escape devices or systems are installed in new construction, at least two shall be remotely located from one another in accordance with 7.5.1.3.1 through 7.5.1.3.4. (9) Where two or more escape devices or systems are installed in existing construction, at least two shall be remotely located from one another in accordance with 7.5.1.3.1, as deemed practical by the authority having jurisdiction. 7.13.2 Reserved. A.7.13.1 In the context used in 7.13.1. two or more escape devices, if installed to evacuate a single tenant space or multiple tenant spaces that have a common evacuation plan,would constitute an escape system. The guiding principles that govern the acceptability of installing and using escape devices and systems are specified in the text. In granting approval for a specific device or system, the authority having jurisdiction may consider, among other things, listing by a nationally recognized testing laboratory, where testing criteria exist for a particular type of device or system. The approval process may also incorporate a detailed review of the proposed device or system and the associated evacuation plan by a registered professional engineer experienced in fire and life safety systems and procedures. Regardless of who does the review, it should anticipate special considerations such as the capacity of the device or system, the reliability of equipment under adverse weather conditions, exposure to fire, structural loading, availability of emergency lighting or supplemental lighting, human behavior under evacuation conditions during system use and communications during the evacuation. The review

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Report on Comments — Copyright, NFPA NFPA 101 should, in particular, address the device or system’s capability of transporting small children and disabled persons. That review should also verify that the equipment selected for installation has the capacity to evacuate the persons covered by the evacuation plan within a reasonable time. In determining the probable evacuation times, such conditions as capability of occupants, availability and capability of evacuation equipment; hazards of use in the building, protective features in the building, foreseeable events that would require use of the evacuation equipment, and the building’s geometry should be considered. Some devices or systems, such as parachutes, helium balloons, helicopters, helicopter-suspended platforms and vertical take-off and landing craft should not be considered as meeting the criteria specified in 7.13.1. Escape devices and systems should be used in accordance with the evacuation plan, but may include deployment by the authorized person to provide supplemental evacuation means or capacity for disabled persons who cannot use the standard means of egress. Generally, deployment will be when preferred options no longer exist. As such, the required level of redundancy within the particular device or system is not the same as one where it is used as a primary piece of equipment. For example, a window washer who uses a single cable supported bosun’s chair in a manner similar to a controlled descent device, also uses a full body harness with an attached vertical life line as a backup in the event of failure of the primary positioning equipment. That level of redundancy is not deemed necessary or appropriate during use of a controlled descent device when all other means of egress or escape have been compromised, just as the use of backup cables for deploying a lifeboat from a sinking ship is not deemed necessary or appropriate. Use of the escape device or system typically requires that a window or exterior door be opened. It is preferable that the window or door be closed except when it is in use for escape. Where the design of the building does not provide exterior doors or operable windows and a window must be broken to use the device or system, consideration needs to be given to the probable effect of that action, such as showering the emergency response personnel and equipment below with sharp pieces of glass. In such a situation, to obtain approval it may be appropriate to require tempered safety glass on windows that must be broken to deploy the escape device or access the system. Once the window has been broken out, it is desirable to have a means for closing the open space to minimize stack effect and the potential for falls, which may be accomplished by providing a secondary, operable window. Because the variety of devices, systems and situations is extensive, no single set of requirements can cover all contingencies for proper use. Consequently, where the evacuation device or system is intended to serve 10 or more persons, a coordinated plan needs to be provided. It should address such concerns as the training needed to operate the equipment and under what circumstances the equipment should be deployed. The more sophisticated the equipment and the greater the number of potential evacuees, the greater is the need to have a trained and qualified person decide what equipment to deploy and when it should be deployed based on the circumstances at the time. It is anticipated that such a person would be the emergency response officer in charge, whether from a private brigade or public service. Since the escape device or system may sit idly for many years and then suddenly need to be used, and given the problematic nature of the probable circumstances surrounding its deployment, the proper use of the escape device or system should be readily apparent to the evacuees and should require minimal training or instruction. In addition to their escape component, some escape systems have the capability of transporting emergency response personnel to the upper floors of buildings to assist in the evacuation process, provide a means of communication from the incident command center to persons stranded on the affected floors, and provide related emergency functions. COMMITTEE STATEMENT: There is insufficent basis at this time for escape devices and systems to be recognized as a part of the means of egress. The action moves the subject and related criteria to a new section titled Supplementary Evacuation Equipment with applicability if such devices are used. This action resolves the issues raised in public comments and technical committee ballot comments. This should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 18 Negative: 4 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: This section is premature and has not received deliberate and studied evaluation by the SAF-MEA Committee. Suggested wording changes could include the following prior to being resubmitted to the Committee 7.13.1 Escape Devices and Systems. Where an escape device or system serves an area with an occupant load of 10 or more persons in a building defined as a High-Rise Building by 3.3.27.7 of the Life Safety Code, the escape device or system shall comply with the following criteria: (1) The Life Safety Code considers the appropriate and efficient utilization of fire department aerial ladder and aerial platform apparatus by trained personnel the supplemental evacuation equipment for buildings not meeting the high rise definition of 3.3.27.7 of the Life Safety Code. (2) Use of the escape device or system shall not pose a safety hazard to users, or non-users, including emergency response personnel, and to users of adjacent devices or systems. (3) Special identification wording and marking to identify the access areas for the supplemental evacuation systems needs to be developed following the concept for means of egress from Section 7.10 of the Life Safety Code. (4) Access systems if utilized to enter or participate with an escape device should meet the provisions of the Life Safety Code. If ramps are utilized they should meet the criteria of 7.2.5. If stairs are used they should meet the criteria of 7.2.2, and emergency lighting should comply with Section 7.9. Access areas

should have special marking developed from the Life Safety Code, Section 7.10 relative to minimum letter size, marking placement, contrast ratios, directional signs and viewing distances. (5) An evacuation plan in accordance with 4.8.2 of the Life Safety Code should be approved by the Authority Having Jurisdiction prior to implementation of an escape device system. Such approval should consider the effects of climatic or fire conditions on the utilization of the system. (6) Where electric power is required to operate the escape device or system both normal and standby power shall meet the requirements of 7.2.13.7 of the Life Safety Code. A.17.13.1 Fourth paragraph reword generally: Deployment will be when the provided options of means of egress or means of escape as defined in 3.3.136 and 3.3.137 of the Life Safety Code no longer exist. Same paragraph, last sentence: term “Controlled Descent Device” should be replaced with “escape device” as used in proposed Section 7.13. Sixth paragraph, add after: “10 or more people” “in a high-rise building.” Seventh paragraph, last sentence delete “minimal”. DI PILLA: As mentioned in my earlier negative, it’s clear to me that this material is not ready to be inserted into a national consensus code. I was disappointed that neither of my key points were even remotely addressed by the committee, despite direction from the TCC to do so. • There is no basic product standard. While an ASTM committee has been formed, it can (and usually does) take several years before a standard is completed. • As an “interim measure” (which will likely be several years), the code text offers only a series of “things to consider,” providing no actual, usable guidance to AHJs who will be required to approve these devices. • Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered - and there is no methodology (nor sufficient research to date) to do so. • Contrary to what has been argued, there are no technical authorities other than manufacturers for the AHJ to call upon for assistance. These are fundamental requirements of placing provisions into the code. The committee has always required not only a standard, but a standard that has been obtained, distributed, discussed, and accepted prior to instituting language in the code specifying it. Here we are not even requiring a standard at all! I fear that the committee is acting prematurely - and setting up the potential for disaster. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized, or even completely inventoried. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. This too remains unaddressed. Finally, the impact of these components on marking/signage, and related physical aspects of egress have not been even been discussed, let alone established. Does the committee true expect an AHJ to competently evaluate this myriad of issues, most of which have yet to be fully identified? I believe that this proposal should not be accepted until: 1. a standard with a listing program has been established, 2. a methodology for assessing installation and maintenance has been developed, and 3. clear, minimum operational controls have been standardized. In summary, there has not been nearly enough development on these devices (or controls established) to believe that placing them into buildings will provide a greater degree of safety than remaining in the building in the vast majority of cases. In fact, there is reason to believe that greater injury could occur from the use of these devices by building occupants that are 1. unfamiliar with their operation; 2. fearful of critical factors such as heights and enclosed places, and 3. in a panic mode. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation

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Report on Comments — Copyright, NFPA NFPA 101 plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. As Chair of the Means of Egress Technical Committee, I note that in taking the action that they did at the ROC meeting, the Committee did not find that there was sufficient basis at this time for recognizing escape devices and systems as part of the means of egress, but did recognize value in it as supplemental equipment. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). GUEST: I am voting to support this proposal. I commend the committee for soliciting public comment and then modifying their proposal to address the concerns raised in the public comments. In carefully reading all of the comments, I believe the committee has addressed all issues raised and developed good language to provide rules that must be followed if supplemental evacuation equipment is used with approval of the AHJ. Major issues addressed include: • A device approval process • Safety of use of such device • Maintenance and testing of such device • The need for an evacuation plan and the role of the device in the overall evacuation plan • Training of personnel used for deployment • Ease of use • The role and authority of emergency response personnel, • The code section does not authorize use of the devices since a listing organization has not been established for such devices to date, but allow the AJH to authorize use once such listing is available and encourages the development of such a process. • Such devices do not substitute for or reduce any existing requirements for means of egress, but rather provide additional options for egress. • Defining dangerous devices that do not meet the criteria noted. Because primary evacuation plans are not always adequate, we can learn important lessons to help shape secondary egress systems. The secondary egress systems are not to replace primary systems, but to complement them. I believe NFPA’s support of the development of such devices and the testing thereof, is a big step to help solve the egress problems often encountered in major disasters. Who better than the code professionals and diversely experienced engineers, code officials, etc. in NFPA to help guide the development of a standard that will work with the current codes in place? Yes a testing body will have to provide testing criteria and process and design and develop tests for such devices; however, such devices must work in conjunction with and must support, not hinder current safety codes in order to be of any value to the public. I commend this task group for developing language to encourage development and therefore become part of the process. KOFFEL: I have given considerable consideration to this issue since the Committee’s meeting. My first concern with accepting this Public Comment is the precedence that may be set by providing a set of requirements for a device or system that is not given any credit by the Code nor is it required or recognized elsewhere in the Code. However, there are other sections of the Code that regulate optional devices. My second concern is the fact that there does not currently exist a product standard for this equipment. During the Committee meeting we heard comments regarding which should come first (the product standard or the code change) and how the various interested organizations are watching what each other is doing.

Probably the deciding factor in voting affirmative on this comment was the result that would be achieved. The Code gives no credit or recognition to escape devices or systems in any other section (pending FINAL ACTION by other Technical Committees). The proposed new section merely provides a set of requirements should someone propose to install such equipment on a building. Therefore, I no longer see harm in providing this set of requirements in the Code and in fact I can rationalize a benefit. If the Code remains silent on the issue and in the absence of a product standard, building owners are free to install and use anything they might chose. At least by including this section, the Code now provides a minimum set of requirements for such optional equipment. In so doing, the Code may in fact be minimizing danger from fire by preventing the use of equipment that could be dangerous to the occupants of the building. I have noted numerous other Public Comments that are related to escape devices and systems. If this comment fails ballot, it should be recognized that the Committee Report that will be presented to the Association will still include the Committee Action in the ROP. Based upon the discussions during the ROC meeting, I am not convinced that SAF-MEA believes that to be the correct action. Therefore, either by an informational ballot of SAF-MEA or by TCC action, if Comment 101-78 fails ballot I would strongly encourage that the action on Public Comment 101-72 be changed to Accept. _______________________________________________________________101-79 Log #306 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14.1) _______________________________________________________________ SUBMITTER: Edward Klinger, Ozonelink Inc. COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Delete text as follows: Where the building served is 20 ore more stories in height. Capacity to evacuate not less than all the occupants of the 10 contiguous floors with the highest occupant load in 30 minutes from the system’s deployment. SUBSTANTIATION: Both of these comments are too restricting and limiting for what is to be accomplished. Secondary methods of egress are designed to assist and support the primary methods. Secondary methods should only be used when the primary methods cannot be. Therefore it is too restrictive and unnecessary to specify when and how many occupants should be able to use these methods and in what amount of time as they are a last resort. If a fire breaks out on a floor, and one cannot get out into the hallway to the stairs, a rapid secondary method of escape is essential. Even if the fire ladders could reach - sometimes it may take too long to have them set up - sometimes it is too little too late. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The gist of the submitter’s comment was incorporated into the action on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: Substantiation relative to the use of interior corridor as “exit access” to “an exit” appears to imply an escape device would prevent the need to use the interior corridor. This would only occur with an escape device from each room or area. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use

101-42

Report on Comments — Copyright, NFPA NFPA 101 under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78 _______________________________________________________________101-80 Log #307 SAF-MEA FINAL ACTION: Accept in Principle (7.2.14.3) _______________________________________________________________ SUBMITTER: Edward Klinger, Ozonelink Inc. COMMENT ON PROPOSAL NO: 101-128 RECOMMENDATION: Add new text to read as follows: Evacuation Plan: The evacuation plan shall specify, but shall not be limited to the following: (1) The role of the escape device (2) The role and authority of emergency response personnel with respect to the escape device system (3) The person or persons authorized to direct the deployment of, and to operate the escape device, group of escape devices or system SUBSTANTIATION: The only way to ensure the complete safety of all of a building’s occupants in the event of a fire is by conducting a full-scale evacuation. At present, primary evacuation systems in most high-rise buildings are inadequate in that they fail to provide 100% of the occupants with a timely, safe, and effective method of egress which in turn makes the essential task of evacuation problematic. Moreover, the challenging issues facing primary evacuation methods are seemingly uncorrectable. In the event of a fire a building’s passenger elevators are automatically returned to its main level and shut down to await reactivation by firefighters rendering elevators unusable for egress. A building’s stairways are typically designed according to the evacuation needs of their respective floor populations rather than the evacuation needs of the entire building and are therefore incapable to handle inevitable congestion associated with the cumulative effect of fleeing occupants. By inhibiting occupant egress and firefighters ingress, congested stairways increase the risk or injury and death to both. Additionally, the Stack Effect and the Breaking-of-the-Seal effect cause smoke and toxic gases to be carried upward and throughout a building. The Stack Effect refers to a natural air draft which causes the upper floors to become contaminated with smoke first, and then proceeding downward, contaminate the subsequent floors back down to the fire floor. Even in buildings that are compartmentalized to contain the spread of smoke and fire, the stairwells can quickly become the most dangerous place for occupants to be due to the Breaking-of-the-Seal Effect. Unavoidably, in order to evacuate a building occupants will open doors to corridors and stairwells on lower floors. Fire and rescue crews repeat this action when they enter a burning building. These actions facilitate smoke and toxic gases to naturally diffuse into stairwells and begin rising towards the upper floors. Occupants on higher floors, therefore, become unable to use the stairways for egress due to their rapid contamination. That being said, the Chicago Fire Department issues this statement of evacuation plans for High Rise Buildings in Chicago: The building management should develop a floor plan which will be posted in key locations throughout each floor. Additionally, each employee will be given the name of their Floor Leader to be kept in his/her assigned work area. Copies of Evacuation/Emergency Procedures and the location of physically disabled personnel will be posted at each work station and at the lobby desk. Every

employee and tenant will be orientated in the emergency procedure for the building and will be required to participate in any drills. In the event of a fire in a high-rise office building, only 8 floors will be evacuated: the fire floor, three floors above and four floors below the fire. If the building has an outside fire escape, it should be used only as an alternative means of escape. Many other establishments nationwide offer this type of simple, generic evacuation plan. However, this type of evacuation plan does not comply with what we know about the likely progression of smoke and toxic gases according to the Stack Effect and the Break-of-the-Seal Effect, nor does it comply with the necessity to completely evacuate the building in order to ensure 100 percent safety. The point is that because primary evacuation plans are not always adequate, we can learn important lessons to help us shape secondary egress systems. Certainly secondary egress systems are not to replace primary systems, but to complement them. Any plan should specify, but not be limited to: • The role of the escape device or system in the overall plan i.e., the method. • The role and authority of emergency response personnel with respect to the escape device or system. • The person or persons authorized to direct the deployment of, and to operate, the escape device, group of escape devices or system. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-78. COMMITTEE STATEMENT: The gist of the submitter’s comment was incorporated into the action on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 19 Negative: 3 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: The submitter in the comment relative to Proposal 101-128 has indicated three criteria for secondary egress systems. None of these criteria have been established in detail in the comments for escape devices or systems to the Means of Egress Committee. A subcommittee has been established by ASTM E.06. We should let this subcommittee fulfill their scope in developing these items. SHULMAN: In regard to the remaining items, please see Shulman comments submitted with the ROP ballot under 101-128. In addition, based on the information received subsequent to submitting the above noted comments, the following supplements our comments for all of the above negative votes: 1) It is premature for the Code to adopt the proposed requirements. Until the MEA TC has an opportunity to review the yet-to-be-drafted standard from the just-formed ASTM E06.77 committee, for thoroughness and the level of safety provided, it is not possible to know what guidance or requirements need to be provided to the installer and/or AHJ to ensure that the overall building safety system operates as intended. 2) It is unknown whether any products or equipment that comply with the yet-to-be drafted-standard will be available. 3) The proposal as submitted during the ROC stage was significantly revised from that submitted during the ROP stage, by a task force meeting the night before the MEA TC voted on the matter. While the proposal may be ‘improved’ in the sense that the task force acknowledged many of the issues raised (both through written comments and verbally by the TC during the first day of the meeting), this revised proposal merits greater review so interested stakeholders can both assess whether the revisions adequately address the concerns raised and ensure that new potential problems have not been introduced through the revisions. 4) There is still much work to be done to better understand the behavioral factors introduced when additional ‘choices’ are offered to a building population under duress and in need of immediate evacuation. This topic alone merits consideration by an appropriate task force of human behavior and building safety experts. 5) The proposal does not offer any recommendations as to how visitors or the general public would be educated as to the procedures to follow in a building equipped with such equipment. Such education would be part of the evacuation plan made familiar to the regular daily occupants of an office or residential high rise, but this is not the only population at risk in this situation. 6) The proponents provide no substantiation to support the premise that an external evacuation system will survive or remain operational or ‘safe’ to use under the conditions that might have compromised an internal evacuation system. Making internal evacuation systems (i.e., stairs) more remote from one another would likely accomplish the same effect as being attempted here without introducing many other uncertainties. STRULL: To require an escape device that is in excess of the required egress capacity and that requires persons to read instructions on its use in an emergency seems to be excessive and unnecessary. How many people will read the instructions prior to the need for its use? Why spend money on such devices? The money is better spent hardening the required and traditional means of egress that do not require a set of instructions. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me.

101-43

Report on Comments — Copyright, NFPA NFPA 101 COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. _______________________________________________________________101-81 Log #351 SAF-MEA FINAL ACTION: Reject (7.3.1.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-130 RECOMMENDATION: Reconsider. SUBSTANTIATION: Fundamental Concepts:1- The total capacity of the means of egress for any story, balcony, tier or other occupied space shall be sufficient for the occupant load therof. 7.3.1.12- Two means of egress, as a minimum, shall be provided in every building or structure, section, and area where size, occupancy, and arrangement endanger occupants attempting to use a single means of egress that is blocked by fire or smoke. 4.5.3.13- Means of egress are not required to be sized equally. Rejection of 101-135 Log #2134- Means of egress capacities are not required to be balanced. Rejection of 101-130 Log #2125- When one exit is blocked by fire, means of egress capacity may be less 100% of occupant load. The only time that means of egress capacity is in compliance with Section 7.3.1.1 is in the absence of fire. As requested by the technical committee, the following analysis and summary chart is enclosed. Code minimum conditions that were applied:1- Minimum clear widths: 32 inches for doors (7.2.1.2.4); 44 inches for stairs per (7.2.2.2.1(1). Stair model shown (more restrictive)2- Minimum number of exits per 7.4.1.2. See the table shown on the following page. Beyond two minimum width means of egress, any additional required egress width is applied to only one exit. This is the exit which is presumed blocked in a fire emergency. Without balanced sizing of the means of egress, the deficiency grows with increasing occupancy until partially relieved at the minimum number of exits requirement. In the worst case, but permitted condition, when the occupant load approaches 499 and later 999, the resultant deficiency reaches 71%. In other words, at those two occupant loads, the remaining exit capacity, if the large imbalanced exit is lost, will be only 29%. Increasing minimum required widths does not have as great an impact as does increasing the minimum number of exits. Contrary to the technical committees’ statement:1- Analysis of the data shows that small spaces are not affected, due to the minimum width requirements.2- 2nd, 3rd, and 4th exits will not, in combination, provide required capacity. However, additional exits, above minimum number, will provide required capacity. The impact on larger spaces is usually mitigated by the presence of extra exits provided to meet travel distance requirements.3- This is not an overdesign. This is a correction to prevent an undersign which is made possible by the code’s silence on imbalance and distribution.4- Historical data does not change the fact that the code does not prevent a deficiency as great as 71% from occurring. This proposal, coinciding with 101-135 Log #213, addresses the definciency. An additional proposal would change the minimum number of exits thresholds. Change: 7.4.1.2 The number of means of egress from any story or portion thereof, other than for existing buildings as permitted in Chapter 12 through Chapter 42, shall be as follows:(1) Occupant load more than 300 500 but not more than 600 1000 – not less than 3(2) Occupant load more than 600 1000 but not more than 900 – not less than 4(3) Occupant load more than 900 – not less than 5 At these thresholds, as the analysis shows, the potential underdesign is minimized.COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The proposed requirement for 100 percent redundancy in a two exit building is too stringent and too expensive to implement as the only solution to the problem the submitter raised. The subject needs additional study. For example, maybe a sliding scale needs to developed so that when there are only 2 exits, the loss of one must leave available 50 percent of the egress capacity; with 3 exits, the loss of one exit must leave available 70 percent of the egress capacity.

The chair of the Means of Egress Technical Committee has formed a task group to address the subject for the next revision cycle. The proponent, Mr. Kapalczynski, will be invited to join the task group. Other members include Jim Lathrop-Chair, Larry Brown, and Joe Versteeg. This is being reported here so that it becomes part of the offical record of the committee action. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-82 Log #22 SAF-IND FINAL ACTION: Accept in Principle (7.3.1.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-132 RECOMMENDATION: Develop storage USE occupant load factor(s) for purposes of piecing together a total occupant load in facilities with multiple uses; and for use in calculating the occupant load of an area when applying the maximum number of persons criteria for sliding doors, spiral stairs, ladders and alternating tread devices. Take any other applicable actions if the determination of the occupant load of a storage OCUPANCY is to continue to be exempted from a calculation using an occupant load factor. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: The committee supports the action taken by SAF-MEA on comment 101-84a with regard to the proposed occupant load factors for storage use areas in other than storage occupancies. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-83 Log #362 SAF-MEA FINAL ACTION: Reject (7.3.1.2) _______________________________________________________________ SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-131 RECOMMENDATION: Reject or hold Proposal 101-131. SUBSTANTIATION: Although I agree that the Code should contain an occupant load factor for storage facilities, I urge the rejection of this proposal. The proposal calls for a 300 sq ft per person load factor for an occupancy that has not, in the past, had a load factor. Based on the substantiation provided by Ken Bush, I can only conclude that the 300 sq ft factor was basically pulled out of the air. In all due respect to Ken, it is time that the Technical Committee demand technical substantiation for major changes to the Code. What has been provided is far from that. Even if Mr. Bush had only conducted a survey of several warehouses in the State of Maryland to determine occupant load conditions, this might have been sufficient basis for a load factor. If you accept the 300 sq ft requirement, it will become the “Standard of Care” for storage occupancies. The committee will then require, in the future, that any change to the 300 sq ft be technically substantiated. It is difficult to impossible to technically substantiate why a number that is not based on technical substantiation should be changed. The International Building Code uses 500 sq ft and the current NFPA Building code has no requirement. It is time that Technical Committees demand a more rigorous process to approve major changes to the Code. Lastly, this major change as proposed would apply retroactively to all existing storage facilities. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Comment 101-84a (Log #CC53). An occupant load factor is needed for storage spaces in other than storage occupancies. See the substantiation for the referenced comment. The 300 ft 2

value proposed in the ROP has been changed to 500 ft2 which should be helpful to the submitter. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

_______________________________________________________________101-84 Log #363 SAF-MEA FINAL ACTION: Reject (7.3.1.2) _______________________________________________________________ SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-132 RECOMMENDATION: Reject. SUBSTANTIATION: See comment to reject Proposal 101-131. COMMITTEE MEETING ACTION: Reject

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Occupant Load

Minimum Number of

Exits

Vertical Component

Required Exit Width

Exiting Deficiency With One Vertical Exit

Unusable1 Additional

Exit2 Additional

Exits3 Additional

Exits4 Additional

Exits

10 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

20 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

30 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

40 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

50 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

60 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

70 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

80 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

90 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

100 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

110 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

120 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

130 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

140 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

150 2 45 2.2% 0.0% 0.0% 0.0% 0.0%

160 2 48 8.3% 0.0% 0.0% 0.0% 0.0%

170 2 51 13.7% 0.0% 0.0% 0.0% 0.0%

180 2 54 18.5% 0.0% 0.0% 0.0% 0.0%

190 2 57 22.8% 0.0% 0.0% 0.0% 0.0%

200 2 60 26.7% 0.0% 0.0% 0.0% 0.0%

210 2 63 30.2% 0.0% 0.0% 0.0% 0.0%

220 2 66 33.3% 0.0% 0.0% 0.0% 0.0%

230 2 69 36.2% 0.0% 0.0% 0.0% 0.0%

240 2 72 38.9% 0.0% 0.0% 0.0% 0.0%

250 2 75 41.3% 0.0% 0.0% 0.0% 0.0%

260 2 78 43.6% 0.0% 0.0% 0.0% 0.0%

270 2 81 45.7% 0.0% 0.0% 0.0% 0.0%

280 2 84 47.6% 0.0% 0.0% 0.0% 0.0%

290 2 87 49.4% 0.0% 0.0% 0.0% 0.0%

300 2 90 51.1% 2.2% 0.0% 0.0% 0.0%

310 2 93 52.7% 5.4% 0.0% 0.0% 0.0%

320 2 96 54.2% 8.3% 0.0% 0.0% 0.0%

330 2 99 55.6% 11.1% 0.0% 0.0% 0.0%

340 2 102 56.9% 13.7% 0.0% 0.0% 0.0%

350 2 105 58.1% 16.2% 0.0% 0.0% 0.0%

360 2 108 59.3% 18.5% 0.0% 0.0% 0.0%

370 2 111 60.4% 20.7% 0.0% 0.0% 0.0%

380 2 114 61.4% 22.8% 0.0% 0.0% 0.0%

390 2 117 62.4% 24.8% 0.0% 0.0% 0.0%

400 2 120 63.3% 26.7% 0.0% 0.0% 0.0%

410 2 123 64.2% 28.5% 0.0% 0.0% 0.0%

420 2 126 65.1% 30.2% 0.0% 0.0% 0.0%

430 2 129 65.9% 31.8% 0.0% 0.0% 0.0%

440 2 132 66.7% 33.3% 0.0% 0.0% 0.0%

450 2 135 67.4% 34.8% 2.2% 0.0% 0.0%

460 2 138 68.1% 36.2% 4.3% 0.0% 0.0%

470 2 141 68.8% 37.6% 6.4% 0.0% 0.0%

480 2 144 69.4% 38.9% 8.3% 0.0% 0.0%

490 2 147 70.1% 40.1% 10.2% 0.0% 0.0%

500 3 150 41.3% 12.0% 0.0% 0.0% 0.0%

510 3 153 42.5% 13.7% 0.0% 0.0% 0.0%

101-45


520 3 156 43.6% 15.4% 0.0% 0.0% 0.0%

530 3 159 44.7% 17.0% 0.0% 0.0% 0.0%

540 3 162 45.7% 18.5% 0.0% 0.0% 0.0%

550 3 165 46.7% 20.0% 0.0% 0.0% 0.0%

560 3 168 47.6% 21.4% 0.0% 0.0% 0.0%

570 3 171 48.5% 22.8% 0.0% 0.0% 0.0%

580 3 174 49.4% 24.1% 0.0% 0.0% 0.0%

590 3 177 50.3% 25.4% 0.6% 0.0% 0.0%

600 3 180 51.1% 26.7% 2.2% 0.0% 0.0%

610 3 183 51.9% 27.9% 3.8% 0.0% 0.0%

620 3 186 52.7% 29.0% 5.4% 0.0% 0.0%

630 3 189 53.4% 30.2% 6.9% 0.0% 0.0%

640 3 192 54.2% 31.3% 8.3% 0.0% 0.0%

650 3 195 54.9% 32.3% 9.7% 0.0% 0.0%

660 3 198 55.6% 33.3% 11.1% 0.0% 0.0%

670 3 201 56.2% 34.3% 12.4% 0.0% 0.0%

680 3 204 56.9% 35.3% 13.7% 0.0% 0.0%

690 3 207 57.5% 36.2% 15.0% 0.0% 0.0%

700 3 210 58.1% 37.1% 16.2% 0.0% 0.0%

710 3 213 58.7% 38.0% 17.4% 0.0% 0.0%

720 3 216 59.3% 38.9% 18.5% 0.0% 0.0%

730 3 219 59.8% 39.7% 19.6% 0.0% 0.0%

740 3 222 60.4% 40.5% 20.7% 0.9% 0.0%

750 3 225 60.9% 41.3% 21.8% 2.2% 0.0%

760 3 228 61.4% 42.1% 22.8% 3.5% 0.0%

770 3 231 61.9% 42.9% 23.8% 4.8% 0.0%

780 3 234 62.4% 43.6% 24.8% 6.0% 0.0%

790 3 237 62.9% 44.3% 25.7% 7.2% 0.0%

800 3 240 63.3% 45.0% 26.7% 8.3% 0.0%

810 3 243 63.8% 45.7% 27.6% 9.5% 0.0%

820 3 246 64.2% 46.3% 28.5% 10.6% 0.0%

830 3 249 64.7% 47.0% 29.3% 11.6% 0.0%

840 3 252 65.1% 47.6% 30.2% 12.7% 0.0%

850 3 255 65.5% 48.2% 31.0% 13.7% 0.0%

860 3 258 65.9% 48.8% 31.8% 14.7% 0.0%

870 3 261 66.3% 49.4% 32.6% 15.7% 0.0%

880 3 264 66.7% 50.0% 33.3% 16.7% 0.0%

890 3 267 67.0% 50.6% 34.1% 17.6% 1.1%

900 3 270 67.4% 51.1% 34.8% 18.5% 2.2%

910 3 273 67.8% 51.6% 35.5% 19.4% 3.3%

920 3 276 68.1% 52.2% 36.2% 20.3% 4.3%

930 3 279 68.5% 52.7% 36.9% 21.1% 5.4%

940 3 282 68.8% 53.2% 37.6% 22.0% 6.4%

950 3 285 69.1% 53.7% 38.2% 22.8% 7.4%

960 3 288 69.4% 54.2% 38.9% 23.6% 8.3%

970 3 291 69.8% 54.6% 39.5% 24.4% 9.3%

980 3 294 70.1% 55.1% 40.1% 25.2% 10.2%

990 3 297 70.4% 55.6% 40.7% 25.9% 11.1%1000 4 300 56.0% 41.3% 26.7% 12.0% 0.0%

COMMITTEE STATEMENT: See Comment 101-84a (Log #CC53). An occupant load factor is needed for storage spaces in other than storage occupancies. See the substantiation for the referenced comment. The 300 ft 2 value proposed in the ROP has been changed to 500 ft 2 which should be helpful to the submitter. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-84a Log #CC53 SAF-MEA FINAL ACTION: Accept (Table 7.3.1.2) _______________________________________________________________ SUBMITTER: Technical Committee on Means of Egress COMMENT ON PROPOSAL NO: 101-131 RECOMMENDATION: Revise the Storage Use entry in Table 7.3.1.2 Occupant Load Factor as follows:

Table 7.3.1.2 Occupant Load FactorUse ft2 (per person) m2 (per person)

Storage Use (other than mercantile storerooms)

NA NA

In storage occupancies NA NAIn mercantile occupancies 300 27.9In other than storage and mercantile occupancies

500 46.5

SUBSTANTIATION: The committee action preserves the staus quo for storage occupancies which per 42.1.7 do not use an occupant load factor to establish occupant load. Rather, occupant load is established as the maximum probable population of the storage space. The committee action also retains the 300 ft 2 occupant load factor currently specified under mercantile use for storage areas. The 500 ft 2 occupant load factor was developed for storage uses in other than storage and mercantile occupancies. Research at the University of Maryland reported that the 100 ft 2 factor for business occupancies is overly conservative. A typical business occupancy is occupied at somewhere between 250-300 ft 2 per person. Thus, the 300 ft 2 factor for mercantile storerooms is too conservative for storage uses in other than mercantile and storage occupancies. The 500 ft 2 value represents the committee’s best judgment. An occupant load factor for storage uses in other than storage and mercantile occupancies is needed for application of numerous code requirements. Also, occupancies other than storage occupancies need an occupant load factor for storage use spaces so as to be able to piece-together a realistic occupant load for the entire building. The Code currently provides the occupant load factor needed for the various uses within a building, except for storage uses. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-85 Log #23 SAF-MEA FINAL ACTION: Accept in Principle (7.3.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-134 RECOMMENDATION: Give consideration to the correlative exemption requested by the SAF-HEA technical committee, given that SAF-MEA has primary responsibility for the provisions of Chapter 7. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain Acceptance of Proposal 101-134. COMMITTEE STATEMENT: The exemption is justified for health care occupancy corridors that are at least 6 ft wide. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-86 Log #350 SAF-MEA FINAL ACTION: Reject (7.3.3.3) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-135 RECOMMENDATION: Reconsider. SUBSTANTIATION: Fundamental Concepts:1- The total capacity of the means of egress for any story, balcony, tier or other occupied space shall be sufficient for the occupant load therof. 7.3.1.12-Two means of egress, as a minimum, shall be provided in every building or structure, section, and area where size, occupancy, and arrangement endanger occupants attempting to use a single means of egress that is blocked by fire or smoke. 4.5.3.13- Means of egress are not required to be sized equally. Rejection of 101-135 Log #2134-Means of egress capacities are not required to be balanced. Rejection of 101-130 Log #2125- When one exit is blocked by fire, means of egress capacity may be less 100% of occupant load. The only time that means of egress capacity is in compliance with Section 7.3.1.1 is in the absence of fire. As requested by the technical committee, the following analysis and summary chart is enclosed. Code minimum conditions that were applied:

1- Minimum clear widths: 32 inches for doors (7.2.1.2.4); 44 inches for stairs per (7.2.2.2.1(1). Stair model shown (more restrictive)2- Minimum number of exits per 7.4.1.2 See the table shown on the following page. Beyond two minimum width means of egress, any additional required egress width is applied to only one exit. This is the exit which is presumed blocked in a fire emergency. Without balanced sizing of the means of egress, the deficiency grows with increasing occupancy until partially relieved at the minimum number of exits requirement. In the worst case, but permitted condition, when the occupant load approaches 499 and later 999, the resultant deficiency reaches 71%. In other words, at those two occupant loads, the remaining exit capacity, if the large imbalanced exit is lost, will be only 29%. Increasing minimum required widths does not have as great an impact as does increasing the minimum number of exits. Contrary to the technical committees’ statement:3-Analysis of the data shows that small spaces are not affected, due to the minimum width requirements.4-2nd, 3rd, and 4th exits will not, in combination, provide required capacity. However, additional exits, above minimum number, will provide required capacity. The impact on larger spaces is usually mitigated by the presence of extra exits provided to meet travel distance requirements.5- This is not an overdesign. This is a correction to prevent an undersign which is made possible by the code’s silence on imbalance and distribution.6-Historical data does not change the fact that the code does not prevent a deficiency as great as 71% from occurring. This proposal, along with 101-130 Log #212, correct the numerical exiting deficiencies created by code permitted imbalanced egress systems. While the reduced minimum number of exits proposal greatly reduces this inherent flaw in the code, this proposal eliminates the flaw by establishing minimum width on the basis of all related code factors. An additional proposal would change the minimum number of exits thresholds. Change: 7.4.1.2 The number of means of egress from any story or portion thereof, other than for existing buildings as permitted in Chapter 12 through Chapter 42, shall be as follows:(1) Occupant load more than 300 500 but not more than 600 1000 – not less than 3(2) Occupant load more than 600 1000 but not more than 900 – not less than 4(3) Occupant load more than 900 – not less than 5 At these thresholds, as the analysis shows, the potential underdesign is minimized.COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The proposed requirement for balanced egress capacity is tied to Comment 101-81 on 100 percent redundancy. See committee statement for the rejection of Comment 101-81. The submitter’s suggested requirement is too stringent as the only solution to the problem he raises. The subject needs additional study. The chair of the Means of Egress Technical Committee has formed a task group to address the subject for the next revision cycle. The proponent, Mr. Kapalczynski, will be invited to join the task group. Other members include Jim Lathrop-Chair, Larry Brown, and Joe Versteeg. This is being reported here so that it becomes part of the offical record of the committee action. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-86a Log #CC477 SAF-IND FINAL ACTION: Reject (7.4.1.7) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT. SAF-MEA which has primary responsibility for Chapter 7 was information balloted on the action by SAF-IND with 15 in agreement and 6 in disagreement. The dissenting comments were technically convincing that the proposed text should not go forward. Also, the proposed text, because it singles out industrial and storage occupancies, would seem to incorrectly direct that in all other occupancies the AHJ must enforce means of egress requirements on utility chases.SUBMITTER: Technical Committee on Industrial, Storage, and Miscellaneous Occupancies COMMENT ON PROPOSAL NO: 101-136 RECOMMENDATION: Revise proposed new section 7.4.1.7, Utility Chases, as indicated in the ROP to read as shown below and retain section A.7.4.1.7 as indicated in the ROP. 7.4.1.7 Utility Chases. Normally unoccupied utility chases in industrial and storage occupancies which are secured from unauthorized access and are used exclusively for routing of electrical, mechanical or plumbing equipment shall not be required to comply with the provisions of Chapter 11. SUBSTANTIATION: This comment is in response to the action taken by SAF-MEA on comment 101-87. SAF-IND does not believe that current Section 7.12 adequately addresses the issues associated with utility chases in storage and industrial occupancies. Section 7.12 pertains to mechanical equipment rooms, boiler rooms and furnace rooms which these spaces are not. The utility spaces addressed by this comment are intended to be unoccupied, contain no operating equipment such as furnaces and only be used for the running of mechanical, electrical or plumbing equipment. Access to the utility spaces would be restricted and limited only for the repair and maintenance of such equipment. As currently worded, such utility spaces would need to be comply with all of Chapter 7.

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Occupant Load

Minimum Number of

Exits

Vertical Component

Required Exit Width

Exiting Deficiency With One Vertical Exit

Unusable1 Additional

Exit2 Additional

Exits3 Additional

Exits4 Additional

Exits

10 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

20 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

30 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

40 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

50 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

60 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

70 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

80 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

90 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

100 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

110 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

120 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

130 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

140 2 44 0.0% 0.0% 0.0% 0.0% 0.0%

150 2 45 2.2% 0.0% 0.0% 0.0% 0.0%

160 2 48 8.3% 0.0% 0.0% 0.0% 0.0%

170 2 51 13.7% 0.0% 0.0% 0.0% 0.0%

180 2 54 18.5% 0.0% 0.0% 0.0% 0.0%

190 2 57 22.8% 0.0% 0.0% 0.0% 0.0%

200 2 60 26.7% 0.0% 0.0% 0.0% 0.0%

210 2 63 30.2% 0.0% 0.0% 0.0% 0.0%

220 2 66 33.3% 0.0% 0.0% 0.0% 0.0%

230 2 69 36.2% 0.0% 0.0% 0.0% 0.0%

240 2 72 38.9% 0.0% 0.0% 0.0% 0.0%

250 2 75 41.3% 0.0% 0.0% 0.0% 0.0%

260 2 78 43.6% 0.0% 0.0% 0.0% 0.0%

270 2 81 45.7% 0.0% 0.0% 0.0% 0.0%

280 2 84 47.6% 0.0% 0.0% 0.0% 0.0%

290 2 87 49.4% 0.0% 0.0% 0.0% 0.0%

300 2 90 51.1% 2.2% 0.0% 0.0% 0.0%

310 2 93 52.7% 5.4% 0.0% 0.0% 0.0%

320 2 96 54.2% 8.3% 0.0% 0.0% 0.0%

330 2 99 55.6% 11.1% 0.0% 0.0% 0.0%

340 2 102 56.9% 13.7% 0.0% 0.0% 0.0%

350 2 105 58.1% 16.2% 0.0% 0.0% 0.0%

360 2 108 59.3% 18.5% 0.0% 0.0% 0.0%

370 2 111 60.4% 20.7% 0.0% 0.0% 0.0%

380 2 114 61.4% 22.8% 0.0% 0.0% 0.0%

390 2 117 62.4% 24.8% 0.0% 0.0% 0.0%

400 2 120 63.3% 26.7% 0.0% 0.0% 0.0%

410 2 123 64.2% 28.5% 0.0% 0.0% 0.0%

420 2 126 65.1% 30.2% 0.0% 0.0% 0.0%

430 2 129 65.9% 31.8% 0.0% 0.0% 0.0%

440 2 132 66.7% 33.3% 0.0% 0.0% 0.0%

450 2 135 67.4% 34.8% 2.2% 0.0% 0.0%

460 2 138 68.1% 36.2% 4.3% 0.0% 0.0%

470 2 141 68.8% 37.6% 6.4% 0.0% 0.0%

480 2 144 69.4% 38.9% 8.3% 0.0% 0.0%

490 2 147 70.1% 40.1% 10.2% 0.0% 0.0%

500 3 150 41.3% 12.0% 0.0% 0.0% 0.0%

510 3 153 42.5% 13.7% 0.0% 0.0% 0.0%

520 3 156 43.6% 15.4% 0.0% 0.0% 0.0%

101-48


530 3 159 44.7% 17.0% 0.0% 0.0% 0.0%

540 3 162 45.7% 18.5% 0.0% 0.0% 0.0%

550 3 165 46.7% 20.0% 0.0% 0.0% 0.0%

560 3 168 47.6% 21.4% 0.0% 0.0% 0.0%

570 3 171 48.5% 22.8% 0.0% 0.0% 0.0%

580 3 174 49.4% 24.1% 0.0% 0.0% 0.0%

590 3 177 50.3% 25.4% 0.6% 0.0% 0.0%

600 3 180 51.1% 26.7% 2.2% 0.0% 0.0%

610 3 183 51.9% 27.9% 3.8% 0.0% 0.0%

620 3 186 52.7% 29.0% 5.4% 0.0% 0.0%

630 3 189 53.4% 30.2% 6.9% 0.0% 0.0%

640 3 192 54.2% 31.3% 8.3% 0.0% 0.0%

650 3 195 54.9% 32.3% 9.7% 0.0% 0.0%

660 3 198 55.6% 33.3% 11.1% 0.0% 0.0%

670 3 201 56.2% 34.3% 12.4% 0.0% 0.0%

680 3 204 56.9% 35.3% 13.7% 0.0% 0.0%

690 3 207 57.5% 36.2% 15.0% 0.0% 0.0%

700 3 210 58.1% 37.1% 16.2% 0.0% 0.0%

710 3 213 58.7% 38.0% 17.4% 0.0% 0.0%

720 3 216 59.3% 38.9% 18.5% 0.0% 0.0%

730 3 219 59.8% 39.7% 19.6% 0.0% 0.0%

740 3 222 60.4% 40.5% 20.7% 0.9% 0.0%

750 3 225 60.9% 41.3% 21.8% 2.2% 0.0%

760 3 228 61.4% 42.1% 22.8% 3.5% 0.0%

770 3 231 61.9% 42.9% 23.8% 4.8% 0.0%

780 3 234 62.4% 43.6% 24.8% 6.0% 0.0%

790 3 237 62.9% 44.3% 25.7% 7.2% 0.0%

800 3 240 63.3% 45.0% 26.7% 8.3% 0.0%

810 3 243 63.8% 45.7% 27.6% 9.5% 0.0%

820 3 246 64.2% 46.3% 28.5% 10.6% 0.0%

830 3 249 64.7% 47.0% 29.3% 11.6% 0.0%

840 3 252 65.1% 47.6% 30.2% 12.7% 0.0%

850 3 255 65.5% 48.2% 31.0% 13.7% 0.0%

860 3 258 65.9% 48.8% 31.8% 14.7% 0.0%

870 3 261 66.3% 49.4% 32.6% 15.7% 0.0%

880 3 264 66.7% 50.0% 33.3% 16.7% 0.0%

890 3 267 67.0% 50.6% 34.1% 17.6% 1.1%

900 3 270 67.4% 51.1% 34.8% 18.5% 2.2%

910 3 273 67.8% 51.6% 35.5% 19.4% 3.3%

920 3 276 68.1% 52.2% 36.2% 20.3% 4.3%

930 3 279 68.5% 52.7% 36.9% 21.1% 5.4%

940 3 282 68.8% 53.2% 37.6% 22.0% 6.4%

950 3 285 69.1% 53.7% 38.2% 22.8% 7.4%

960 3 288 69.4% 54.2% 38.9% 23.6% 8.3%

970 3 291 69.8% 54.6% 39.5% 24.4% 9.3%

980 3 294 70.1% 55.1% 40.1% 25.2% 10.2%

990 3 297 70.4% 55.6% 40.7% 25.9% 11.1%1000 4 300 56.0% 41.3% 26.7% 12.0% 0.0%

101-49

Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-87 Log #24 SAF-MEA FINAL ACTION: Accept in Principle (7.4.1.7 and A.7.4.1.7 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-136 RECOMMENDATION: Review and take any action needed on the subject of the proposed 7.4.1.7 by SAF-IND, given that SAF-MEA has primary responsibility for the chapter. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-136 which would have exempted utility chases from means of egress requirements. COMMITTEE STATEMENT: Utility chases are not defined, yet they might encompass an entire floor or interstitial space. Utility chases, if large, do need means of egress, including a need for two means of egress. The provisions of Section 7.12 capture this concept and offer as much leniency as should be afforded such spaces. What are these other codes addressed in the proposed annex text? How do they assure safe egress? What are the section numbers of the OSHA provisions that assure safe egress from such spaces? NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE DE VRIES: The submitter of the original proposal requested exempting utility chases from the means of egress requirements and the committee appropriately rejected that action as stated in the committee substantiation, although there remains ambiguity as to what means of egress requirements apply, or should apply, to normally unoccupied building spaces (attics, utility chases, crawl spaces, etc.). These spaces seem to fall into a crack between those Permit-Required Confined Spaces regulated by OSHA and covered by ANSI Z117.1, and “any point in a building or structure ...” covered by the Life Safety Code. This subject should be addressed in future editions of the Code. _______________________________________________________________101-88 Log #25 SAF-MEA FINAL ACTION: Accept in Principle (7.5.4.7 and 7.5.4.8 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-139A RECOMMENDATION: Give consideration to the proposal so as to make any needed changes. The proposal will permit a recently issued Formal Interpretation (FI) to be retired. In accordance with Section 6.6 of the Regulations Governing Committee Projects, once a Formal Interpretation has been issued, the appropriate Technical Committee is required to prepare a committee proposal clarifying the text of the Document involved. In this case, the appropriate Technical Committee (SAF-MEA) has already completed its Report on Proposals work. Therefore, a TCC Proposal is needed to enter this issue into the current cycle, so that the FI can be retired upon issuance of the next edition. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain the Acceptance of Proposal 101-139a as prepared by the Technical Correlating Committee. COMMITTEE STATEMENT: The proposal accurately capture the essence of the Formal Interpretation processed by the Means of Egress Commmittee. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-89 Log #1 SAF-MEA FINAL ACTION: Reject (7.6.5) _______________________________________________________________ SUBMITTER: Richard W. Bukowski, Building and Fire Research Lab, NIST COMMENT ON PROPOSAL NO: 101-141 RECOMMENDATION: Accept proposal 101-141 (Log #31). SUBSTANTIATION: It appears that the committee did not understand the gravity of the issue. The example cited clearly shows that where several exits are required the provision of only one exit within the maximum travel distance that provides only a small fraction of the total required egress capacity would comply with the code as presently written. This situation would clearly lead to extreme congestion at that exit or would require significant numbers of occupants to travel extended distances to other exits. This would result in long egress times and the potential for jamming of the one exit as seen n the Chicago nightclub evacuation and Station Nightclub fire. In the Committee Statement for the rejection of the proposal the last sentence reads: “As long as occupants of each area can reach a minimum of one exit within travel distance, it is not important that the nearby” exits provide one half the total capacity.” I disagree if that one exit does not provide enough of the required capacity to

allow the occupants to exit in a timely fashion. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The issue raised by the submitter has merit so as to warrant additional consideration, but the submitter has not adequately substantiated such a provision that would have huge implications to the design of buildings used for all occupancies. The subject might better be handled not as a travel distance consideration but under the requirements for arrangement of means of egress. As was done with Comments 101-81 and 101-86, the chair of the Means of Egress Technical Committee has formed a task group to address the subject for the next revision cycle. The proponent will be invited to join the task group. Other members include Jim Lathrop-Chair, Larry Brown, and Joe Versteeg. This is being reported here so that it becomes part of the offical record of the committee action. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 23 Negative: 1 EXPLANATION OF NEGATIVE: KULIGOWSKI: I am voting in favor of the proposal requiring that at least half the required egress capacity be within the travel distance limit. In a space with multiple exits, only one needs to be within the travel distance limit, and the egress capacity provided by that one exit is not currently specified. This can lead to the potentially lethal condition where the only close exit is grossly undersized and the remaining exits are too far away with access that is exposed to the fire. The result could be jamming of the one close exit. There clearly needs to be some minimum required capacity for the exit(s) required to be within the travel distance to avoid this life safety risk. Half is a reasonable number since this would result in the “main entrance” alone within the minimum travel distance to satisfy the requirement. _______________________________________________________________101-90 Log #26 SAF-MEA FINAL ACTION: Accept in Principle (7.9.1.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-147 RECOMMENDATION: Give consideration to Shulman’s Explanation of Negative with respect to expansion of the illumination provisions, so as to make any needed changes. SHULMAN: : In alignment with our negative vote on 101-128 (Log #CP207), there is no need to provide illumination for devices/systems that we do not support being permitted in the first place. In regards to the specific content of this proposal, the proposed amendment to the base text of 7.9.1.1 (adding the phrase “…and escape…”) is not appropriate. “Means of Escape” is defined (3.3.137) in a broader sense than Means of Egress (3.3.136) and this addition to 7.9.1.1 could inadvertently render many existing structures as non-conforming (where alternative escape devices are not provided). In regards to the proposed addition of a new subclause (6) to 7.9.1.1, any illumination that is needed for proper operation of these devices/systems should be integral to and powered by the device/system itself. Provision of any such required illumination (for operation or reading of instructions), along with the ready availability and functionality of other needed accessories (for example, a means to break a window if such action is deemed appropriate) should be part of the device/system evaluation as discussed in [proposed 101-128 (Log #CP207) new 7.2.14.1(2), (6), and (7).] It should not necessarily be considered as part of the facility emergency lighting system under the purview of Section 7.9. This section requires illumination of the path of egress, to prescribed minimum levels, which levels are not correlated to the illumination that may be appropriate or necessary for the reading of instructions or operation of equipment. That this companion proposal is even deemed necessary furthers our argument [under 101-128 (Log #CP207)] that insufficient analysis of the scenario has been undertaken to date as to the likely effectiveness of these systems. The time for reading instructions for access to and proper operation of these devices/systems is NOT during the extremely high stress moment when they may be desired for use. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-147 so as NOT to add a new item (6) to 7.9.1.1 on the subject of escape devices. COMMITTEE STATEMENT: The supplemental evacuation equipment will not receive credit for satisfying any means of egress requirements. As such, it need not be addressed under the subject of emergency lighting of means of egress. However, the proposed Section 7.13 calls for lighting to be addressed as part of the evacuation plan. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 21 Negative: 1 Abstain: 2 EXPLANATION OF NEGATIVE: BRYAN: Proposed Section 7.13 should be modified to require emergency lighting. See my Explanation of Negative on Comment 101-78. EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the

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Report on Comments — Copyright, NFPA NFPA 101 Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. _______________________________________________________________101-91 Log #168 SAF-MEA FINAL ACTION: Accept (7.9.1.1) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-147 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: Comments have been submitted to delete the new material on escape devices and this needs to be deleted for correlation should that material be deleted. COMMITTEE MEETING ACTION: Accept Reject Proposal 101-147 so as NOT to add a new item (6) to 7.9.1.1 on the subject of escape devices. COMMITTEE STATEMENT: The supplemental evacuation equipment will not receive credit for satisfying any means of egress requirements. As such, it need not be addressed under the subject of emergency lighting of means of egress. However, the proposed Section 7.13 calls for lighting to be addressed as part of the evacuation plan. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 22 Abstain: 2 EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me.COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. _______________________________________________________________101-92 Log #346 SAF-MEA FINAL ACTION: Accept in Principle (7.9.1.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified per Koffel’s comment to insert the word “new” so as to read: (6) New access-controlled egress doors in accordance with 7.2.1.6.2.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-146 RECOMMENDATION: Add: (6) access controlled egress doors.

SUBSTANTIATION: Section 7.9.1.1 does not include access controlled doors in its requirements for emergency lighting, therefore the signs identified by 7.2.1.6.2 (4) have no assurance of being visible under all lighting conditions during the time that the conditions of occupancy require that the means of egress be available for use. COMMITTEE MEETING ACTION: Accept in Principle Add an item (6) to 7.9.1.1 as follows: (6) Access-controlled egress doors in accordance with 7.2.1.6.2 COMMITTEE STATEMENT: The action does what the submitter requested but also makes the connection to 7.2.1.6.2. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 COMMENT ON AFFIRMATIVE ELVOVE: Though this requirement is retroactive, I believe it is essential that emergency lighting be provided to illuminate new or existing doors where emergency manual release buttons and/or door hardware are installed to release a door in the event a motion sensor fails so emergency release devices are visible when normal lighting fails (similar to what is currently required by 7.9.1.1(5) for doors equipped with delayed egress locks). Note: in my opinion, emergency lighting only needs to be of sufficient capability to make emergency release devices visibly apparent and not necessarily have the same capability needed to illuminate egress pathways. KOFFEL: I would encourage the TCC to insert the work “New” at the beginning of the proposed new text. As pointed out by the submitter the requirement for emergency lighting has not been in the Code in the past. Possibly this is because access-controlled egress doors should typically be unlocked when the occupant reaches the door. While I am not opposed to this requirement for new installations, I am not convinced that the substantiation supports making the requirement apply to existing installations of previously approved access-controlled egress doors. _______________________________________________________________101-93 Log #27 SAF-MEA FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration to Koffel’s Explanation of Negative so as to make any needed changes. KOFFEL: As noted in my comments on 101-120 (Log #55), the proposed language would add clarity to the Code. The language could be added to 7.9.2 so as not to affext existing 7.9.4 (battery-operated equipment). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Accept Proposal 101-149 in Principle by creating a new 7.9.2.2 (and renumber 7.9.2.2 through 7.9.2.5 to become 7.9.2.3 through 7.9.2.6) as follows: 7.9.2.2 New emergency power systems for emergency lighting shall be at least Type 10 / Class 1.5 / Level 1 in accordance with NFPA 110, Standard for Emergency and Standby Power Systems. COMMITTEE STATEMENT: The action should meet the intent of Koffel’s negative ballot comment and that of the submitter of Proposal 101-149. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

_______________________________________________________________101-94 Log #27a SAF-BCF FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The board and care facility chapters do not specify any requirements for emergency or standby power; therefore, no action is necessary. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-95 Log #27b SAF-BSF FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111.

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Report on Comments — Copyright, NFPA NFPA 101 SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: No action required in Chapter 9. Chapter 9 provides mandatory references to NFPA 110 and 111 where emergency or standby power is required by another section of the Code. It would be up to those other sections of the Code to specify a particular Type/Class/Level of emergency or standby power based on the application. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-96 Log #27c SAF-DET FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-DET. COMMITTEE STATEMENT: Chapters 22 and 23 do not specify emergency or standby power criteria. NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-97 Log #27d SAF-END FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-END. COMMITTEE STATEMENT: Chapters 14 through 17 do not specify emergency or standby power criteria. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-98 Log #27e SAF-FIR FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle The committee gave consideration to the submitter’s recommendation and decided that no specific action is necessary with regard to Chapter 8. COMMITTEE STATEMENT: it is the committee’s intent that any source of standby power described in Article 701 of NFPA 70 be permitted to be used. It is not the committee’s intent to limit the source of standby power to only a generator set installed in accordance with NFPA 110. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH

_______________________________________________________________101-99 Log #27f SAF-FUN FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111.

SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action required by SAF-FUN. COMMITTEE STATEMENT: The chapters under the purview of SAF-FUN do not address emergency or standby power. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-100 Log #27g SAF-FUR FINAL ACTION: Accept (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept No action necessary as reference to NFPA 110 is not made in Chapter 10. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-101 Log #27h SAF-HEA FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-HEA. COMMITTEE STATEMENT: Chapters 18 through 21 do not specify emergency or standby power criteria. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-102 Log #27i SAF-IND FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to include deletion of current annex item A.11.8.4.2(A) as it is no longer accurate and not needed given the change to 11.8.4.2.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 11.8.4.2(A) to read as follows: “(A)* Type 60, Class I, Level 1 Class I, Type 60, standby power in accordance with Article 701 of NFPA 70 ...” COMMITTEE STATEMENT: This action meets the intent of the submitter, and clarifies the committee’s position with regard to standby power systems in high rise buildings. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-103 Log #27j SAF-MEA FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-93. COMMITTEE STATEMENT: The action on the referenced comment should meet the TCC’s intent.

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Report on Comments — Copyright, NFPA NFPA 101 NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________ 101-104 Log #27k SAF-MER INAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: The committee believes that chapters 36, 37, 38 and 39 correctly make reference to section 7.9 for the types of standby power intended. Chapter 7 is within the scope of SAF-MEA., and specific recommendations with regard to the type of standby power system for means of egress should be made by SAF-MEA. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES

_______________________________________________________________101-105 Log #27l SAF-RES FINAL ACTION: Accept in Principle (7.9.2.x (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The residential occupancy chapters do not specify any requirements for emergency or standby power; therefore, no action is necessary. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM ______________________________________________________________ 101-106 Log #239 SAF-MEA FINAL ACTION: Accept in Principle (7.9.2.3.1) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-149 RECOMMENDATION: Change TC action from reject to accept in principle with the following: 7.9.2.3.1 The emergency power supply system shall be designed as a Type 10/Class 2/ Level 1 system. SUBSTANTIATION: The proposal is an attempt to add clarity for designers, owners and AHJs. Without the new language, the performance requirement of the EPSS is unclear. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-93. COMMITTEE STATEMENT: The action on the referenced comment should meet the TCC’s intent. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-107 Log #257 SAF-MEA FINAL ACTION: Reject (7.10) _______________________________________________________________ SUBMITTER: Harold Coughlin, Coughlin Design COMMENT ON PROPOSAL NO: 101-156 RECOMMENDATION: Accept this Proposal 101-156. SUBSTANTIATION: First, I’d like to thank the Committee on Means of Egress, Chair David de Vries, Secretary Ron Cote’ and all the principals, alternates, and nonvoting members for reviewing my original Go-To-Green-Exit proposal and these Rejection Comments. Before reading this comment I would like to suggest that readers go back and review the pages mentioned above to refresh the original proposal submission. This way you can see where “I’m coming from”. As a graphic designer since the early 60’s I’ve worked on a great number of Graphic Viewing Problems and it from this point I ask you first review this comment from a “FOCUS” point of view.

Many artists and graphic designer don’t consider “FOCUS” as it’s not a real graphics term...but it is! The distance from which it’s viewed has to be considered. When was the last time you went driving down the highway and you tried to read the tiny wording on a 44 ft billboard at high speed? When viewing a website and the type was so small and you had to get your nose up close to screen to read? This is two examples of “UnFocused for the need.” A few examples of why we should further revisit; stores are larger, schools are larger, theaters are larger and multi-divided and you have to get out of your theater and into the building egress path and out the door. And a question...has the number of building exits per building kept up with the larger buildings and the possible “longer” focus requirements? Hence, some what larger signage. For reference the signage on page 101-66 was based on the NFPA specs for the height of the word EXIT. From this you can determine the size of a finished sign including the “black” background as part of the final signage. This is why I submitted my Proposal as I believe many EXIT signs are “UnFocused for the need”. WHILE THE NFPA GUIDELINES ARE WELL MEANING...I think the mission of the egress message has changed some and should be revisited. Responding to your REJECTION COMMENTS. Rejection #1...Your comment is absolutely correct. I’d like to say that I’m a graphic designer not an engineer, scientist, fire authority, lighting authority, construction authority, etc. I can’t say to you this is the final answer we need to save the lives at such fatalities as the Station fire. I do not have the funds to test these items at a Underwriters Laboratory type provider. I believe that it would be the industries responsibility to do this if you shared the same need about considering new signage. Example: the word EXIT should not be a condensed letter as it doesn’t register well in the brain as does normal type. I’ve covered some of these items in the original proposal. Rejection #2...Again, I believe this is an industry responsibility to further research to first retest the existing EXIT type in a laboratory environment and have a baseline then maybe test the designs I provided and perhaps some other examples to see whether what you have is still working (I would be happy work with you on other possible variations on signs). This would be the correct way to establish if the signage once tested would “sink into the mindset” and proved a faster exit flow. Personally I’ve seen some very sick EXIT signs between condensed letters, poor or no lighting, EXIT letters smushed up into holding frame so it makes it slower and harder for the brain to absorb. Rejection #3...If you will take a look at the images in book you will see the background is Black. This would be part of the final signage and it would back up to any wall. The present installation DO have this problem with walls as they have no separation like the ones I presented. If you look at the NO EXIT sign you’ll notice it set on the accepted international red symbol for the word “NO” since the 1960s. This color I’m sure has a present color designation by PMS Color Matching System. As far as the green for the Go-To-Green-Exit I’m sure a suitable green also could be tested with PMS color. As far as blending into wall, please see above comments. Rejection #4...Sorry, I don’t quite know what you trying explain? I would be happy to discuss this with you further. Rejection #5...The designs presented were based on the 100 ft rule but I did not place enough emphasis for needed reference in the proposal and I apologize for that. With EXIT 6 in. high the overall size can be figured and the signage including the black background will be a larger. The rest of you questions here are basically YES it will be more expensive if used. But like many other industries who had to go through this the results improve safety conditions (seat belts, breakaway ski boots, electrical etc.). Yes it would get into a multidollar deal as it did for the automotive industry had to deal with and both would have a major impact on improving ones safety if, hopefully, some test could be performed on these designs. I hope that NFPA might discuss funding and think about what could be done for some basic testing to reevaluate the existing signage and perhaps use the signage I provided and see if it or another designs might help save lives. This is not an ego thing or a money thing it’s a safety thing. Rejection #6...I would want to see the test results of the “running man” before buying into it. I personally feel this might excite “panic” faster that any flame. Today with the USA being more bilingual than ever the flame is my vote graphically. While we’re at it...maybe when the fire call is placed a sound tone should be added to the installation to help in smoked filled rooms! Thank you for review my comments...Harold Coughlin COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter has addressed a product design issue that is outside the scope of NFPA 101. Such material is better suited to documents like NFPA 170 on symbols and the ISO graphical symbols documents. This is a subject that will require agreement among the human behavior experts before it can be justified to change the product standards. If that were to occur, NFPA 101 could then be changed to reflect the installation requirements for the new sign. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

Sequence No. 101-108 was not used

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-109 Log #382 SAF-MER FINAL ACTION: Hold (7.10.1.7) _______________________________________________________________ SUBMITTER: Scott W. Adams, Park City Fire Service District COMMENT ON PROPOSAL NO: 101-155 RECOMMENDATION: Add new text to read as follows: NFPA 1 UFC 20.12.2.3 Floor proximity egress path marking shall be provided in Class A mercantile occupancies in accordance with 7.10.1.6 and 7.10.1.7 of NFPA 101. NFPA 101 36.2.12 Floor proximity egress path marking complying with Section 7.10.1.6 and 7.10.1.7 of NFPA 101 shall be provided in Class A mercantile occupancies. SUBSTANTIATION: NFPA 1 UFC Section 14.14 and NFPA 101 Section 7.10 require that the means of egress shall be marked by readily visible exit signs. This is typically accomplished with the use of internally illuminated exit signs located at a vertical distance of not more than 80 inches above the top edge of the egress opening. In essence, they are “ceiling proximity” exit signs as opposed to floor proximity exit signs. NFPA 1 UFC Section 14.14.6.4.1 and NFPA 101 Section 7.10.7.1 require internally illuminated exit signs be listed in accordance with UL 924, Standard for Emergency Lighting and Power Equipment. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material for Chapter 36 that has not had public review via the ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-110 Log #383 SAF-IND FINAL ACTION: Hold (7.10.1.7) _______________________________________________________________ SUBMITTER: Scott W. Adams, Park City Fire Service District COMMENT ON PROPOSAL NO: 101-155 RECOMMENDATION: Add new text to read as follows: NFPA 1 UFC 20.16.1.3 Floor proximity egress path marking shall be provided in accordance with 7.10.1.6 and 7.10.1.7 of NFPA 101. NFPA 101 11.8.6 Floor proximity egress path marking complying with Section 7.10.1.6 and 7.10.1.7 shall be provided in interior exit corridors of new high-rise buildings. SUBSTANTIATION: NFPA 1 UFC Section 14.14 and NFPA 101 Section 7.10 require that the means of egress shall be marked by readily visible exit signs. This is typically accomplished with the use of internally illuminated exit signs located at a vertical distance of not more than 80 inches above the top edge of the egress opening. In essence, they are “ceiling proximity” exit signs as opposed to floor proximity exit signs. NFPA 1 UFC Section 14.14.6.4.1 and NFPA 101 Section 7.10.7.1 require internally illuminated exit signs be listed in accordance with UL 924, Standard for Emergency Lighting and Power Equipment. On October 24, 2003, Underwriters Laboratories announced that it is clarifying the scope of UL 924 with the following new language: “1.9 These requirements cover the performance of emergency lighting equipment (signs and luminaires) in clear air conditions only. These requirements also do not attempt to compensate for human visual deficiencies such as near- or far-sightedness, color- or night-blindness, or astigmatism. Applications that require visibility through smoke or way-finding assistance to those with visual impairments are beyond the scope of this standard.” [Emphasis added] Smoke from a fire typically stacks from the ceiling and descends to the floor. What this means is that internally illuminated exit signs listed to UL 924 located near the ceiling were never tested for visibility through smoke or intended to be visible in a fire. Occupancies with only ceiling proximity exit signs essentially have no marking of the means of egress that is tested and listed for use in fires. Floor proximity exit signs and egress path marking, however, are intended for use in fire by locating them within eighteen (18) inches above the floor. Floor proximity egress path marking provides continuous delineation of the egress system and terminates at the exit door which is marked with a floor proximity exit sign. This will greatly improve timely occupant evacuation and provide firefighters with vital information on the egress system for rescue and firefighting operations. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment.

COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material for Chapter 11 that has not had public review via the ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-111 Log #374 SAF-MEA FINAL ACTION: Reject (7.10.7.2) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: 101-161 RECOMMENDATION: Revise text to read as follows: NFPA 1 UFC 14.14.6.4.2* Photoluminescent Signs and Floor Proximity Egress Path Markings. The face of a photoluminescent sign or floor proximity egress path marking shall be continually illuminated while the building is occupied. The illumination levels on the face of the photoluminescent sign or floor proximity egress path marking shall be in accordance with its listing. The charging illumination shall be a reliable light source as determined by the authority having jurisdiction. The charging light source shall be of a type specified in the product markings. A.14.14.6.4.2 Photoluminescent signs or floor proximity egress path markings need a specific minimum level of light on the face of the sign or floor proximity egress path marking to ensure that the sign or floor proximity egress path marking is charged for emergency operation and legibility in both the normal and emergency modes. Additionally, the type of light source (for example, incandescent, fluorescent, halogen, metal halide) is important. Each light source produces different types of visible and invisible light (for example, UV) that might affect the ability of some photoluminescent signs or floor proximity egress path markings to charge and might also affect the amount of light output available during emergency mode. This type of sign or floor proximity egress path marking would not be suitable where the illumination levels are permitted to decline. The charging light source should not be connected to automatic timers, because the continuous illumination of the sign or floor proximity egress path marking is needed; otherwise, the sign or floor proximity egress path marking illumination would not be available because it would be discharged. NFPA 101 7.10.7.2* Photoluminescent Signs and Floor Proximity Egress Path Markings. The face of a photoluminescent sign or floor proximity egress path marking shall be continually illuminated while the building is occupied. The illumination levels on the face of the photoluminescent sign or floor proximity egress path marking shall be in accordance with its listing. The charging illumination shall be a reliable light source as determined by the authority having jurisdiction. The charging light source shall be of a type specified in the product markings. A.7.10.7.2 Photoluminescent signs or floor proximity egress path markings need a specific minimum level of light on the face of the sign or floor proximity egress path marking to ensure that the sign or floor proximity egress path marking is charged for emergency operation and legibility in both the normal and emergency modes. Additionally, the type of light source (for example, incandescent, fluorescent, halogen, metal halide) is important. Each light source produces different types of visible and invisible light (for example, UV) that might affect the ability of some photoluminescent signs or floor proximity egress path markings to charge and might also affect the amount of light output available during emergency mode. This type of sign or floor proximity egress path marking would not be suitable where the illumination levels are permitted to decline. The charging light source should not be connected to automatic timers, because the continuous illumination of the sign or floor proximity egress path marking is needed; otherwise, the sign or floor proximity egress path marking illumination would not be available because it would be discharged. SUBSTANTIATION: The provisions of Section 14.14.6.4.2 and 7.10.7.2 are appropriate for listed photoluminescent floor proximity egress path markings. Photoluminescent floor proximity egress path markings are tested and listed under standard UL 1994, Low Level Path Marking and Lighting Systems and comply with ASTM E 2072-00, Standard Specification for Photoluminescent (phosphorescent) Safety Markings. The proposal will clarify the use of photoluminescent floor proximity egress path markings. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s proposed blending of the exit sign and path marking subjects will confuse the Code user. Where will the required product marking (per UL 1994) be positioned? The submitter is encouraged to submit a proposal during the next revision cycle that expands 7.10.1.7 to pick up the needed language. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-112 Log #375 SAF-MEA FINAL ACTION: Reject (7.10.7.2) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: 101-161 RECOMMENDATION: Revise text to read as follows: NFPA 1 UFC 14.14.6.4.2* Photoluminescent Signs and Floor Proximity Egress Path Markings. The face of a photoluminescent sign or floor proximity egress path marking shall be continually illuminated while the building is occupied. The illumination levels on the face of the photoluminescent sign or floor proximity egress path marking shall be in accordance with its listing. The charging illumination shall be a reliable light source as determined by the authority having jurisdiction. The charging light source shall be of a type specified in the product markings. A.14.14.6.4.2 Photoluminescent signs or floor proximity egress path markings need a specific minimum level of light on the face of the sign or floor proximity egress path marking to ensure that the sign or floor proximity egress path marking is charged for emergency operation and legibility in both the normal and emergency modes. Additionally, the type of light source (for example, incandescent, fluorescent, halogen, metal halide) is important. Each light source produces different types of visible and invisible light (for example, UV) that might affect the ability of some photoluminescent signs or floor proximity egress path markings to charge and might also affect the amount of light output available during emergency mode. This type of sign or floor proximity egress path marking would not be suitable where the illumination levels are permitted to decline. The charging light source should not be connected to automatic timers, because the continuous illumination of the sign or floor proximity egress path marking is needed; otherwise, the sign or floor proximityegress path marking illumination would not be available because it would be discharged. NFPA 101 7.10.7.2* Photoluminescent Signs and Floor Proximity Egress Path Markings. The face of a photoluminescent sign or floor proximity egress path marking shall be continually illuminated while the building is occupied. The illumination levels on the face of the photoluminescent sign or floor proximity egress path marking shall be in accordance with its listing. The charging illumination shall be a reliable light source as determined by the authority having jurisdiction. The charging light source shall be of a type specified in the product markings. A.7.10.7.2 Photoluminescent signs or floor proximity egress path markings need a specific minimum level of light on the face of the sign or floor proximity egress path marking to ensure that the sign or floor proximity egress path marking is charged for emergency operation and legibility in both the normal and emergency modes. Additionally, the type of light source (for example, incandescent, fluorescent, halogen, metal halide) is important. Each light source produces different types of visible and invisible light (for example, UV) that might affect the ability of some photoluminescent signs or floor proximity egress path markings to charge and might also affect the amount of light output available during emergency mode. This type of sign or floor proximity egress path marking would not be suitable where the illumination levels are permitted to decline. The charging light source should not be connected to automatic timers, because the continuous illumination of the sign or floor proximity egress path marking is needed; otherwise, the sign or floor proximity egress path marking illumination would not be available because it would be discharged. SUBSTANTIATION: The provisions of Section 14.14.6.4.2 and 7.10.7.2 are appropriate for listed photoluminescent floor proximity egress path markings. Photoluminescent floor proximity egress path markings are tested and listed under standard UL 1994, Low Level Path Marking and Lighting Systems and comply with ASTM E 2072-00, Standard Specification for Photoluminescent (phosphorescent) Safety Markings. The proposal will clarify the use of photoluminescent floor proximity egress path markings. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s proposed blending of the exit sign and path marking subjects will confuse the Code user. Where will the required product marking (per UL 1994) be positioned? The submitter is encouraged to submit a proposal during the next revision cycle that expands 7.10.1.7 to pick up the needed language. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

_______________________________________________________________101-113 Log #305 SAF-FIR FINAL ACTION: Accept in Principle (8.2.2) _______________________________________________________________ SUBMITTER: Joseph T. Holland, III, Hoover Treated Wood Products COMMENT ON PROPOSAL NO: 101-168 RECOMMENDATION: Proposed Wording 8.2.2.2* Fire compartments shall be formed with fire barriers that are continuous from outside wall to outside wall, from one fire barrier to another, or a combination thereof, including continuity through all concealed spaces, such as those found above a ceiling, including interstitial spaces. Walls used as fire barriers shall comply with Chapter 3 8 of NFPA 221 5000, Building Construction and Safety Code Standard for Fire Walls and Fire Barrier Walls. The NFPA 221 limitation on percentage width of openings shall not apply Revised Wording 8.2.2.2* Fire compartments shall be formed with fire barriers that are continuous from outside wall to outside wall, from one fire barrier to another, or a combination thereof, including continuity through all concealed spaces, such as those found above a ceiling, including interstitial spaces. Walls used as fire barriers shall comply with Chapter 3 7 of NFPA 221, Standard for Fire Walls and Fire Barrier Walls. The NFPA 221 limitation on percentage width of openings shall not apply SUBSTANTIATION: While I still feel the appropriate reference is 5000 the new chapter number for fire barrier walls is Chapter 7. Currently there are references to several standards like NFPA 221, NFPA 220 and NFPA 703 in the Life Safety Code. All of the information in these and others referenced in NFPA 101 are contained in NFPA 5000. Reference one standard instead of many that way the user only needs to buy one book instead of several. COMMITTEE MEETING ACTION: Accept in Principle Revise 8.2.2.2 to read as indicated in the submitter’s “Revised Wording”. COMMITTEE STATEMENT: The submitter’s recommendation was accepted by the committee. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: CAHANIN: NFPA 5000 is not nationally recognized equal to NFPA 101 and should not be referenced. NFPA 101 is adopted by many states using the IBC. _______________________________________________________________101-114 Log #293 SAF-FIR FINAL ACTION: Accept in Principle (8.2.3, A.8.2.3.1) _______________________________________________________________ SUBMITTER: Tony Crimi, A.C. Consulting Solutions, Inc. / Rep. International Firestop Council COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Revise text as follows: 8.2.3.1* The fire resistance of structural elements and building assemblies shall be determined in accordance with test procedures set forth in NFPA 251, or other approved test methods, or analytical methods approved by the authority having jurisdiction. Materials used to construct fire resistance rated elements and assemblies shall be limited to those permitted in this Code. Testing of dedicated active suppression systems in combination with building elements or assemblies shall not be considered as equivalent to material or assembly fire resistance ratings. A.8.2.3.1 NFPA 251, ANSI/UL 263, and ASTM E119 are considered nationally recognized methods of determining fire resistance and have been found to yield equivalent test methods. Materials used to construct fire resistance-rated elements and assemblies are limited to those permitted in this Code. Inherent in the use of these materials is the intent that this specialized, tested materials and assemblies provide an established level of risk. Given the absence of any specific test methods and any historical data for evaluation of combinations of elements and assemblies designed to rely upon dedicated active suppression systems in combination with the materials themselves, performance during the conventional standard fire tests identified in this Code cannot ensure an equivalent level of risk or reliability. SUBSTANTIATION: In order to address concern that were expressed by some negative voters, my proposal intends to clarify that it is those elements and assemblies employing dedicated active suppression systems in conjunction with the elements or assemblies that should not be considered equivalent. The proponent has identified a potential misuse of established fire-resistance test Standards relied upon in the Code to determine performance of elements and assemblies tested as systems in conjunction with dedicated active suppression systems. An example of such a system could be an unprotected steel building column which relies solely on it’s inherent fire resistance (which is solely related to it’s W/D ratio) and a dedicated system of sprinklers to provide a continuously wetted surface or a water curtain in close proximity around it. While this type of system could be “tested” using the Standardized fire-resistance tests required in the Code, the conventional, generic, fire test standards do not envision or address these combinations of active and passive fire protection systems. Consequently, their requirements do not foresee the unique risks that such systems inherently introduce. In contrast, the difference between testing a floor assembly versus a building column is far less than that of testing a combination of elements and assemblies in conjunction with

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Report on Comments — Copyright, NFPA NFPA 101 dedicated active suppression systems, yet all of these standards have seen the need to develop specially tailored testing and performance criteria for these independent assemblies. Similarly, there are no installation standards or maintenance requirements for these types of systems. In the wetted column example above, how does one provide this level of protection for the portion of the building column above the membrane of a ceiling or in a plenum. NFPA 13 also does not envision a level of protection equivalent to that necessary for a combination of dedicated active suppression system used to provide an equivalent fire resistance rating to NFPA 251 both from the standpoint of the wetting pattern that would be needed. The continuous water flow, or the handling of obstructions like cable trays and ducting. Even if it were possible to interconnect the sprinkler heads to a fire alarm system, for example, what then would be the impact on the membrane used as part of the fire-resistance rated floor assembly once the sprinklers activated? As a result, how about the remainder of the floor area? Inherent in the application and use of a fire resistance rated assembly in the Code is the intent that this specialized, tested, construction provide not only the required fire-resistance rating but be designed to resist physical damage (arising out of both normal use and during a fire incident of the types evaluated in the referenced test standards) that would otherwise compromise the rating of the assembly. In the absence of any specific test methods for evaluation of these combinations of protection, equivalent performance during the conventional standard fire tests identified in this Code cannot ensure equivalent risk or reliability performance. Elements and assemblies tested in conjunction with active suppression systems would need to retain all of the characteristics of traditional tested fire resistance rated construction inherently provided by building elements and assemblies which do not rely on any active suppression component. Evaluating these systems to our existing standard fire tests, which do not envision such applications, is not adequate to ensure equivalent safety or performance. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-117. COMMITTEE STATEMENT: See committee action and statement on Comment 101-117. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 13 Negative: 8 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: DEVLIN: I vote negative on this proposal. This proposal introduces language that conflicts with the existing requirements of Section 1.4, Equivalency, and Chapter 5, Performance-Based Option. Section 1.4 and Chapter 5 of NFPA 101 were written with the sole intent to permit the use of systems, methods, or devices that do not meet the strict letter of the code yet can provide equal or superior performance to that intended by the code for the specific application. NFPA 101 and other NFPA standards/codes currently recognize the use of water spray on building materials as affording an equivalent means of fire resistance to conventional products. This includes water spray/wetting of atrium windows to achieve an equivalent 1-hour fire separation (NFPA 101/NFPA 5000), and water spray/wetting of columns in storage occupancies as a means in lieu of fireproofing (NFPA 13). There is no data that proves these concepts have failed. To merely exempt a specific means of achieving fire resistance - the use of an active fire suppression system in combination with building elements and assemblies - that satisfies the requirements of Section 1.4 and Chapter 5 is prejudice. FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. GERDES: The effect of the comment is to limit equivalent protection. There has been laboratory testing to show water curtains are effective in protecting elements. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. KLEIN: Please register my vote as negative on Code Comments 101-114, 101-116, 101-117, 101-118, and 101-119. These code comments are on ROP Code Proposal 101-170, which I voted against during the ROP ballot stage. ROP Code Proposal 101-170 did not receive the required 2/3 majority during the ballot, and was therefore rejected. As I stated on my ROP ballot, the existing code language in Chapter 1, under Section 1.4, “Equivalency”, or in Chapter 5, “Performance-Based Option”, adequately covers any proposed modification of code requirements in this Code. If these Code Comments are approved for Chapter 8, do other Committees need to add similar verbiage permitting the application of Section 1.4 or Chapter 5 to their chapters of the Code? The proposed new sentence to Section 8.2.3.1 and new Annex Note to this section are not needed. In fact, the wording of the new annex note may appear to some users of the Code to discourage the application of anything

other than the literal code text requirements. Such strict application of the Code has never been proposed by any of the TCs or TCC in the past editions of the Code. MCCORMICK: Please change my vote to negative on these committee actions. This is consistent with my previous negative ballots on #101-117 and #101-118. I am voting negative on these committee actions, because these changes either limit the use of sprinklers and glazing as an equivalency in a fire rated separation or prohibit them entirely. The combination of automatic sprinklers and a glazed barrier has been accepted by the Code for many years. For example, the atrium provisions have accepted the substitution of sprinklers/glass in lieu of a 1-hour fire separation wall for over 20 years. These code change essentially void that acceptance. They require a performance-based evaluation or an equivalency evaluation. The UL test for the WS sprinkler and glazing to achieve a 2-hour fire resistance would not be accepted without further evaluation. I believe that these are unnecessary restrictions. Again, the proposals are not based on any unsatisfactory experience. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice for many years without any unsatisfactory experience that I am aware of. This proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of current code requirements and favorable field experience regarding this issue. WOOD: I am voting negative on this item. No data has been submitted to justify a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice of many years without any unsatisfactory experience that I am aware of. The proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of the current code requirements and favorable field experience regarding this issue. COMMENT ON AFFIRMATIVE CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards. _______________________________________________________________101-115 Log #28 SAF-FIR FINAL ACTION: Reject (8.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT given that Comment 101-117, referenced in the committee meeting action, failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-117. COMMITTEE STATEMENT: See committee action and statement on Comment 101-117. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 19 Negative: 2 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. COMMENT ON AFFIRMATIVE CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-116 Log #259 SAF-FIR FINAL ACTION: Reject (8.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT given that Comment 101-117, referenced in the committee meeting action, failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Vickie J. Lovell, InterCode Incorporated COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Revise section as follows: Elements and assemblies tested in conjunction with active suppression system shall not be considered as equivalent unless such design incorporating the element or assembly and active suppression system includes supporting documentation, and such design and supporting documentation has been evaluated and approved as part of the performance-based option in accordance with Chapter 5 by the authority having jurisdication. SUBSTANTIATION: I commend the Mr. Kapalszynski for raising one of the most often abused and most seldom discussed code provisions in all of the codes at the Fire Protection Features TC meeting. Although the proponent’s concern is directed primarily at the concept of water washed glass and water washed steel columns, the principle of the proposal is more far-reaching. The field practice of combining the test results on unrelated “apples” and “oranges” into the ubiquitous engineering judgment (EJ) is often used as a convenient and cost-effective circumvention of actual testing and legitimate evaluation of such tests. AHJs, designers, manufacturers, and project managers are often (usually) in a hurry to resolve a field problem, and so the EJ can be little more than a S.W.A.G. with no relevant data, test method, or analytical method from which a conclusion could be drawn. I encourage the FIR TC to tackle this important issue. The section should be revised so as to clarify the terms under which such equivalency should be based while continuing to permit the use of alternate methods and materials when relevant data, test methods, or analytical method are available. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-117. COMMITTEE STATEMENT: See committee action and statement on Comment 101-117. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 13 Negative: 8 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: DEVLIN: I vote negative on this proposal. This proposal introduces language that conflicts with the existing requirements of Section 1.4, Equivalency, and Chapter 5, Performance-Based Option. Section 1.4 and Chapter 5 of NFPA 101 were written with the sole intent to permit the use of systems, methods, or devices that do not meet the strict letter of the code yet can provide equal or superior performance to that intended by the code for the specific application. NFPA 101 and other NFPA standards/codes currently recognize the use of water spray on building materials as affording an equivalent means of fire resistance to conventional products. This includes water spray/wetting of atrium windows to achieve an equivalent 1-hour fire separation (NFPA 101/NFPA 5000), and water spray/wetting of columns in storage occupancies as a means in lieu of fireproofing (NFPA 13). There is no data that proves these concepts have failed. To merely exempt a specific means of achieving fire resistance - the use of an active fire suppression system in combination with building elements and assemblies - that satisfies the requirements of Section 1.4 and Chapter 5 is prejudice. FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. GERDES: The effect of the comment is to limit equivalent protection. There has been laboratory testing to show water curtains are effective in protecting elements. Performance-based option in Chapter 5 is too restrictive for a simple issue. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. KLEIN: Please register my vote as negative on Code Comments 101-114, 101-116, 101-117, 101-118, and 101-119. These code comments are on ROP Code Proposal 101-170, which I voted against during the ROP ballot stage. ROP Code Proposal 101-170 did not receive the required 2/3 majority during the ballot, and was therefore rejected. As I stated on my ROP ballot, the existing code language in Chapter 1, under Section 1.4, “Equivalency”, or in Chapter 5, “Performance-Based Option”, adequately covers any proposed modification of code requirements in this Code. If these Code Comments are approved for Chapter 8, do other Committees need to add similar verbiage permitting the application of Section 1.4 or Chapter 5 to their chapters of the Code? The proposed new sentence to Section 8.2.3.1 and new Annex Note to this section are not needed. In fact, the wording of the new annex note may appear to some users of the Code to discourage the application of anything

other than the literal code text requirements. Such strict application of the Code has never been proposed by any of the TCs or TCC in the past editions of the Code. MCCORMICK: Please change my vote to negative on these committee actions. This is consistent with my previous negative ballots on #101-117 and #101-118. I am voting negative on these committee actions, because these changes either limit the use of sprinklers and glazing as an equivalency in a fire rated separation or prohibit them entirely. The combination of automatic sprinklers and a glazed barrier has been accepted by the Code for many years. For example, the atrium provisions have accepted the substitution of sprinklers/glass in lieu of a 1-hour fire separation wall for over 20 years. These code change essentially void that acceptance. They require a performance-based evaluation or an equivalency evaluation. The UL test for the WS sprinkler and glazing to achieve a 2-hour fire resistance would not be accepted without further evaluation. I believe that these are unnecessary restrictions. Again, the proposals are not based on any unsatisfactory experience. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice for many years without any unsatisfactory experience that I am aware of. This proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of current code requirements and favorable field experience regarding this issue. WOOD: I am voting negative on this item. No data has been submitted to justify a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice of many years without any unsatisfactory experience that I am aware of. The proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of the current code requirements and favorable field experience regarding this issue. COMMENT ON AFFIRMATIVE CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards. _______________________________________________________________ 101-117 Log #268 SAF-FIR FINAL ACTION: Reject (8.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT given that Comment 101-117, referenced in the committee meeting action, failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Delete the last sentence as revised by the Committee Action and substitute a new sentence as follows: “Elements and assemblies tested in conjunction with active suppression systems shall not be considered as equivalent to material fire resistance rating but shall be permitted to be evaluated on a performance basis.” 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 allowed to rely on an automatic fire protection system but shall be permitted to be evaluated as part of a performance-based option in accordance with Chapter 5. SUBSTANTIATION: We agree with the submitter’s intent to resolve the problem he has identified in his proposal. We believe that the revised wording we have proposed will better clarify the intent of the proposal. COMMITTEE MEETING ACTION: Accept in Principle 1. Accept the proposed new last sentence of 8.2.3.1 to read as recommended by the submitter with the following revision: 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 allowed to rely on an automatic fire protection system but shall be permitted to be unless evaluated as an equivalency in accordance with 1.4 or as part of a performance-based option in accordance with Chapter 5. 2. Replace the existing annex language in section A.8.2.3.1 with the following: The intent of fire resistance ratings determined in accordance with NFPA 251 or other approved test methods, and the intent of the requirements within this code for assemblies to posses a specific fire resistance rating, are that the element or assembly should by itself have an inherent resistance to the effects of fire. The fire-resistance rating that might be assigned to an element or assembly based on the intervention (effect) of one or more external factors during a fire-resistance test (e.g., in accordance with NFPA 251) should not be considered as a de facto equivalent to the required fire resistance rating. The fact that the modified (increased) fire resistance rating needs a combination of inherent plus external factors to all work together results in a solution that might be inherently less reliable, thus making it inherently non-equivalent. However, the combination of active suppression systems together with elements or assemblies of reduced fire resistance or of no fire resistance may be deemed as acceptable equivalencies to a specific fire-resistance requirement.

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE STATEMENT: The committee intends to clarify that discharge from an automatic fire protection system spraying on a membrane does not necessarily provide an equivalent measure of fire resistance unless it is verified as such through an equivalency or performance-based design. The existing annex text was deleted as the corresponding ASTM and UL fire test standards will be added to the body of the code in accordance with Comment 101-2. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 11 Negative: 10 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards. DEVLIN: I vote negative on this proposal. This proposal introduces language that conflicts with the existing requirements of Section 1.4, Equivalency, and Chapter 5, Performance-Based Option. Section 1.4 and Chapter 5 of NFPA 101 were written with the sole intent to permit the use of systems, methods, or devices that do not meet the strict letter of the code yet can provide equal or superior performance to that intended by the code for the specific application. NFPA 101 and other NFPA standards/codes currently recognize the use of water spray on building materials as affording an equivalent means of fire resistance to conventional products. This includes water spray/wetting of atrium windows to achieve an equivalent 1-hour fire separation (NFPA 101/NFPA 5000), and water spray/wetting of columns in storage occupancies as a means in lieu of fireproofing (NFPA 13). There is no data that proves these concepts have failed. To merely exempt a specific means of achieving fire resistance - the use of an active fire suppression system in combination with building elements and assemblies - that satisfies the requirements of Section 1.4 and Chapter 5 is prejudice. FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. GERDES: The effect of the comment is to limit equivalent protection. There has been laboratory testing to show water curtains are effective in protecting elements. Performance-based option in Chapter 5 is too restrictive for a simple issue. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. KLEIN: Please register my vote as negative on Code Comments 101-114, 101-116, 101-117, 101-118, and 101-119. These code comments are on ROP Code Proposal 101-170, which I voted against during the ROP ballot stage. ROP Code Proposal 101-170 did not receive the required 2/3 majority during the ballot, and was therefore rejected. As I stated on my ROP ballot, the existing code language in Chapter 1, under Section 1.4, “Equivalency”, or in Chapter 5, “Performance-Based Option”, adequately covers any proposed modification of code requirements in this Code. If these Code Comments are approved for Chapter 8, do other Committees need to add similar verbiage permitting the application of Section 1.4 or Chapter 5 to their chapters of the Code? The proposed new sentence to Section 8.2.3.1 and new Annex Note to this section are not needed. In fact, the wording of the new annex note may appear to some users of the Code to discourage the application of anything other than the literal code text requirements. Such strict application of the Code has never been proposed by any of the TCs or TCC in the past editions of the Code. MADDOX: I disagree with the proponents on the idea that a fire resistive system which relies on an active sprinkler system is less reliable or less effective. MCCORMICK: I am voting negative on this committee action because this change either limits the use of sprinklers and glazing as an equivalency in a fire rated separation or prohibit them entirely. The combination of automatic sprinklers and a glazed barrier has been accepted by the Code for many years. For example, the atrium provisions have accepted the substitution of sprinklers/glass in lieu of a 1-hour fire separation wall for over 20 years. This code change essentially voids that acceptance. They require a performance-based evaluation or an equivalency evaluation. The UL test for the WS sprinkler and glazing to achieve a 2-hour fire resistance would not be accepted without further evaluation. I believe that these are unnecessary restrictions. Again, the proposals are not based on any unsatisfactory experience. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice for many years without any unsatisfactory experience that I am aware of. This proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of current code requirements and favorable field experience regarding this issue.

WOOD: I am voting negative on this item. No data has been submitted to justify a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice of many years without any unsatisfactory experience that I am aware of. The proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of the current code requirements and favorable field experience regarding this issue. _______________________________________________________________101-118 Log #289 SAF-FIR FINAL ACTION: Reject (8.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT given that Comment 101-117, referenced in the committee meeting action, failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: John Valiulis, Hilti Inc. COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Delete the last sentence as revised by the Committee Action and substitute a new sentence as follows: “Elements and assemblies tested in conjunction with active suppression systems shall not be considered as equivalent to material fire resistance rating but shall be permitted to be evaluated on a performance bases.” In establishing compliance with a specific requirement within this code for an element or assembly to have a specified fire resistance rating, it shall not be permitted to use a fire resistance rating that is determined via a test that simultaneously utilizes active suppression together with an element or assembly that without the active suppression would have a lesser fire resistance rating. A.8.2.3.1 The intent of fire resistance ratings determined in accordance with NFPA 251 or other approved test methods, and the intent of the requirements within this code for assemblies to posses a specific fire resistance rating, are that the element or assembly should by itself have an inherent resistance to the effects of fire. The fire-resistance rating that might be assigned to an element or assembly based on the intervention (effect) of one or more external factors during a fire-resistance test (e.g., in accordance with NFPA 251) should not be considered as a de facto equivalent to the required fire resistance rating. The fact that the modified (increased) fire resistance rating needs a combination of inherent plus external factors to all work together results in a solution that is inherently less reliable, thus making it inherenly non-equivalent. However, the combination of active suppression systems together with elements or assemblies of reduced fire resistance or of no fire resistance may be deemed as acceptable alternatives to a specific fire-resistance requiement when so specified within the body of this code. SUBSTANTIATION: In cases where the intent of the Code is to accept an alternative to the use of a fire resistive assembly or element based on the consideration of risk reduction through the use of active fire suppression, such alternatives are stated explicitly throughout the Code, together with any accompanying restrictions or permissions. However, it is not and should not be the intention of this Code to allow a new wave of fire-resistance tests that would evaluate the performance of elements and assemblies and assign to them a new and improved fire resistance rating when they are fire tested together with some external factor being applied. such as water from automatic sprinklers or even a firefighter’s hose. With a fire-resistive assembly or element, that assembly or element either is there or it is not. There is no element of probability involved, so the fire resistance rating that is assigned to it is a deterministic evaluation of its contribution to fire safety. However, as soon as the influence of external elements are added, the evaluation becomes partly deterministic, and partly probabilistic, and really cannot and should not be compared to the pure results for the assembly or element itself. Using the effect of automatic sprinklers, for example, the discharge pressure, density and droplet size distribution could vary, and each of these effects could have an impact of the fire resistance rating that would be obtained if a fire test were done with sprinklers together with an assembly or element. Sprinkler discharge characteristics could be influenced based on whether the sprinkler head next to the assembly is the first or the last to operate out of the total number to eventually operate, whether the sprinkler head is closest or furthest to the riser of all the heads that operate in the given fire, on the orifice size and discharge coefficient of the sprinkler head, and on a myriad of other real-life sources of variability. Probabilistic factors such as a possibly obstructed head or blockage from within the pipe are also effects that would need to be considered, just as the possible obstruction or blockage of a sprinkler head is a considered factor in the sprinkler system designs that are specified by other codes for various hazards and commodity classifications. There are innumerable potential pitfalls in assigning a fire resistance rating to an assembly or material based on a combination of external factors which may or may not be there exactly as tested. It is probably worth mentioning that the tested and listed assemblies, every single element must be within the testing and listing bounds, without exception, or else that assembly cannot be said to have the listed fire resistance. That is an easy thing to do with construction elements. The variability of external factors such as active suppression should be recognized as not being consistent with the standardized testing the leads to the assignment of fire resistance ratings. Prohibiting the use of the Equivalency concept is certainly not the intention of this comment, nor did it seem to be the intention of the original submitter of the code change proposal. The proposed new appendix material is submitted so as to alleviate any worries that the addition of the useful new phrase could be misinterpreted as prohibiting equivalencies (as allowed by 1.4).

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-117. COMMITTEE STATEMENT: See committee action and statement on Comment 101-117. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 12 Negative: 9 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: DEVLIN: I vote negative on this proposal. This proposal introduces language that conflicts with the existing requirements of Section 1.4, Equivalency, and Chapter 5, Performance-Based Option. Section 1.4 and Chapter 5 of NFPA 101 were written with the sole intent to permit the use of systems, methods, or devices that do not meet the strict letter of the code yet can provide equal or superior performance to that intended by the code for the specific application. NFPA 101 and other NFPA standards/codes currently recognize the use of water spray on building materials as affording an equivalent means of fire resistance to conventional products. This includes water spray/wetting of atrium windows to achieve an equivalent 1-hour fire separation (NFPA 101/NFPA 5000), and water spray/wetting of columns in storage occupancies as a means in lieu of fireproofing (NFPA 13). There is no data that proves these concepts have failed. To merely exempt a specific means of achieving fire resistance - the use of an active fire suppression system in combination with building elements and assemblies - that satisfies the requirements of Section 1.4 and Chapter 5 is prejudice. FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. GERDES: The effect of the comment is to limit equivalent protection. There has been laboratory testing to show water curtains are effective in protecting elements. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. KLEIN: Please register my vote as negative on Code Comments 101-114, 101-116, 101-117, 101-118, and 101-119. These code comments are on ROP Code Proposal 101-170, which I voted against during the ROP ballot stage. ROP Code Proposal 101-170 did not receive the required 2/3 majority during the ballot, and was therefore rejected. As I stated on my ROP ballot, the existing code language in Chapter 1, under Section 1.4, “Equivalency”, or in Chapter 5, “Performance-Based Option”, adequately covers any proposed modification of code requirements in this Code. If these Code Comments are approved for Chapter 8, do other Committees need to add similar verbiage permitting the application of Section 1.4 or Chapter 5 to their chapters of the Code? The proposed new sentence to Section 8.2.3.1 and new Annex Note to this section are not needed. In fact, the wording of the new annex note may appear to some users of the Code to discourage the application of anything other than the literal code text requirements. Such strict application of the Code has never been proposed by any of the TCs or TCC in the past editions of the Code. MADDOX: I disagree with the proponents on the idea that a fire resistive system which relies on an active sprinkler system is less reliable or less effective. MCCORMICK: I am voting negative on this committee action because this change either limits the use of sprinklers and glazing as an equivalency in a fire rated separation or prohibit them entirely. The combination of automatic sprinklers and a glazed barrier has been accepted by the Code for many years. For example, the atrium provisions have accepted the substitution of sprinklers/glass in lieu of a 1-hour fire separation wall for over 20 years. This code change essentially voids that acceptance. They require a performance-based evaluation or an equivalency evaluation. The UL test for the WS sprinkler and glazing to achieve a 2-hour fire resistance would not be accepted without further evaluation. I believe that these are unnecessary restrictions. Again, the proposals are not based on any unsatisfactory experience. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice for many years without any unsatisfactory experience that I am aware of. This proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of current code requirements and favorable field experience regarding this issue. WOOD: I am voting negative on this item. No data has been submitted to justify a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice of many years without any unsatisfactory experience that I am aware of. The proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of the current code requirements and favorable field experience regarding this issue.

COMMENT ON AFFIRMATIVE CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards. _______________________________________________________________101-119 Log #347 SAF-FIR FINAL ACTION: Reject (8.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT given that Comment 101-117, referenced in the committee meeting action, failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-170 RECOMMENDATION: Revise: Elements and assemblies installed tested in conjunction with active fire suppression systems in lieu of required fire resistance ratings shall have their alternative fire protection performance evaluated relative to the original requirement for fire resistance. SUBSTANTIATION: Glass and steel are not appreciably nor inherently fire resistive. However, when they are wetted by special sprinklers, they have a combined performance that is not fire resistance, but may achieve a desirable, alternative, fire protection goal. Such alternative goals, because they do not meet explicit code specifications, can only be documented by performance based analysis. The code traditionally permits reductions in fire resistance ratings by sprinkler protection. The trend to wet, inherently non fire resistant materials, reduces the original requirement for fire resistance to zero. This is beyond the intent of permitting reductions. Note the committees’ own new wording of A.4.5.1 in Log #214. The resultant assembly must be fairly evaluated for the significance of the alternative performance rather than being accepted as equal to fire resistance. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-117. COMMITTEE STATEMENT: See committee action and statement on Comment 101-117. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 13 Negative: 8 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: DEVLIN: I vote negative on this proposal. This proposal introduces language that conflicts with the existing requirements of Section 1.4, Equivalency, and Chapter 5, Performance-Based Option. Section 1.4 and Chapter 5 of NFPA 101 were written with the sole intent to permit the use of systems, methods, or devices that do not meet the strict letter of the code yet can provide equal or superior performance to that intended by the code for the specific application. NFPA 101 and other NFPA standards/codes currently recognize the use of water spray on building materials as affording an equivalent means of fire resistance to conventional products. This includes water spray/wetting of atrium windows to achieve an equivalent 1-hour fire separation (NFPA 101/NFPA 5000), and water spray/wetting of columns in storage occupancies as a means in lieu of fireproofing (NFPA 13). There is no data that proves these concepts have failed. To merely exempt a specific means of achieving fire resistance - the use of an active fire suppression system in combination with building elements and assemblies - that satisfies the requirements of Section 1.4 and Chapter 5 is prejudice. FRANCIS: The reasons set out by Messrs. Humble and Klein are compelling. GERDES: The effect of the comment is to limit equivalent protection. There has been laboratory testing to show water curtains are effective in protecting elements. HUMBLE: Register my vote as negative on Comments 101-114 (Log #293), 101-115 (Log #28), 101-116 (Log #259), 101-117 (Log #268), 101-118 (Log #289), and 101-119 (Log #347). The original proposal and the revised proposals at the ROC meeting continue to reflect a departure from the remainder of the NFPA 101. Unclear and not substantiated was the need to specifically reference Section 1.4 and Chapter 5 with limitations. Sections 1.4 and Chapter 5 are available for use by the user on a voluntary basis when innovative materials, products, systems or methods that do not specifically meet the text and intent of the life safety code. In addition, by now adding this new provision to 8.2.3.1, it appears to restrict, and not compliment, the first sentence of 8.2.3.1 that states “…determined in accordance with test procedures… other analytical methods approved by the authority having jurisdiction….”. KLEIN: Please register my vote as negative on Code Comments 101-114, 101-116, 101-117, 101-118, and 101-119. These code comments are on ROP Code Proposal 101-170, which I voted against during the ROP ballot stage. ROP Code Proposal 101-170 did not receive the required 2/3 majority during the ballot, and was therefore rejected. As I stated on my ROP ballot, the existing code language in Chapter 1, under Section 1.4, “Equivalency”, or in

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Report on Comments — Copyright, NFPA NFPA 101 Chapter 5, “Performance-Based Option”, adequately covers any proposed modification of code requirements in this Code. If these Code Comments are approved for Chapter 8, do other Committees need to add similar verbiage permitting the application of Section 1.4 or Chapter 5 to their chapters of the Code? The proposed new sentence to Section 8.2.3.1 and new Annex Note to this section are not needed. In fact, the wording of the new annex note may appear to some users of the Code to discourage the application of anything other than the literal code text requirements. Such strict application of the Code has never been proposed by any of the TCs or TCC in the past editions of the Code. MCCORMICK: Please change my vote to negative on these committee actions. This is consistent with my previous negative ballots on #101-117 and #101-118. I am voting negative on these committee actions, because these changes either limit the use of sprinklers and glazing as an equivalency in a fire rated separation or prohibit them entirely. The combination of automatic sprinklers and a glazed barrier has been accepted by the Code for many years. For example, the atrium provisions have accepted the substitution of sprinklers/glass in lieu of a 1-hour fire separation wall for over 20 years. These code change essentially void that acceptance. They require a performance-based evaluation or an equivalency evaluation. The UL test for the WS sprinkler and glazing to achieve a 2-hour fire resistance would not be accepted without further evaluation. I believe that these are unnecessary restrictions. Again, the proposals are not based on any unsatisfactory experience. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice for many years without any unsatisfactory experience that I am aware of. This proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of current code requirements and favorable field experience regarding this issue. WOOD: I am voting negative on this item. No data has been submitted to justify a change in current requirements is necessary. The use of sprinklers to protect a glazed barrier has been an accepted practice of many years without any unsatisfactory experience that I am aware of. The proposal would specifically require a performance-based evaluation or equivalency evaluation, already permissible and addressed in the code, that I believe is not warranted in view of the current code requirements and favorable field experience regarding this issue. COMMENT ON AFFIRMATIVE CLARK: The proposed change by the committee to allow an element or assembly to be deemed to have an equivalent fire resistance rating when the element or assembly rely on external factors which are not an inherent part of the element or assembly to achieve this equivalency does not meet the definition of fire resistance rating as defined in Chapter 3. There is no equivalent to a fire resistance rating which has been substantiated by the current test standards. _______________________________________________________________101-120 Log #29 SAF-FIR FINAL ACTION: Accept in Principle (8.3.3.10) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-174 RECOMMENDATION: Revise as necessary its reference to the “four-part identification” which appears to have only three parts (D-H-xxx or D-NH-xxx). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-121. COMMITTEE STATEMENT: See committee action and statement on Comment 101-121. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH _______________________________________________________________101-121 Log #243 SAF-FIR FINAL ACTION: Accept (8.3.3.10.1) _______________________________________________________________ SUBMITTER: Jesse J. Beitel, Hughes Assoc., Inc. COMMENT ON PROPOSAL NO: 101-174 RECOMMENDATION: Revise the Committee’s Action on Section 8.3.3.10.1 as follows: 8.3.3.10.1 Fire protection-rated glazing used in doors shall bear the following four-part identification: “D - H or NH - T or NT - XXX”. “D” indicates that the glazing shall be used in fire door assemblies and that the glazing meets the fire endurance requirements of the test standard. “H” shall indicate that the glazing meets the hose stream requirements of the test standard. “NH” shall indicate that the glazing does not meet the hose stream requirements of the test. “T” shall indicate that the glazing shall have a maximum transmitted temperature endpoint of not more than 450°F (250°C) above ambient at the end of 30 minutes of standard fire test exposure. “NT” shall indicate that the glazing does not have a temperature rise rating. The placeholder “XXX” shall specify the fire-protection rating period, in minutes. SUBSTANTIATION: This comment addresses concerns expressed by the

Committee on Fire Protection Features regarding the temperature rating portion of the label. This comment retains the temperature limit identifier and adds additional information as to its meaning. The ICC-IBC has adopted the labeling system that was proposed in Proposal 5000-449. The ICC-IBC does have requirements for temperature transmission through doors and glazing installed in doors in specific applications. While NFPA 5000 and NFPA 101 do not currently have a requirement for temperature transmission for doors or glazing in doors, the comment language will maintain consistency between the various Codes. The new language is based on the testing requirements of the ICC-IBC and thus manufactures will not have to have different labels for NFPA or ICC-IBC. One label will suffice for all Codes. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH _______________________________________________________________101-122 Log #30 SAF-FIR FINAL ACTION: Accept in Principle (8.5.1 and A.8.5.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed so as to Reject ROP Proposal 101-179 as Holmes’ comments justify.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-179 RECOMMENDATION: Give consideration to Holmes’, Kapalczynski’s, and Roeper’s Explanation of Negative so as to make any needed changes. HOLMES: The use of the word, “limit”, implies a prescribed maximum amount, quantity, or number. As noted in the Committee Substantiation, limit means to bound or set a boundary. The Life Safety Code does not presently, nor does it intend to, establish a maximum amount or numerical boundary for smoke movement. KAPALCZYNSKI: The committee has reviewed numerous proposals for requiring specific air leakage requirements in smoke barriers and smoke partitions. Each of these proposals has been rejected on the basis that existing smoke barriers and smoke partitions already perform adequately with respect to the intent of the code and that the necessity for additional technical requirements is not substantiated. Consequently, proposals to more finely calibrate the wording alone, when additional technical requirements have already been rejected, should be rejected, too. If semantic calibration is necessary to make the code more comprehendible to lawyers and juries then the preferable word is “resist” as it is commonly understood. Applying “resist” to smoke partitions and “limit” to smoke barriers confuses the clarity of the code intent and will coerce the committee into reconsidering proposals for unenforceable technical specifications that have been presently determined to be unnecessary. Note also, that 101-68 (Log #CP610) proposes “limit or resist” while 101-126 (Log #CP611) proposes, “limit,” and 101-179 (Log #CP609) proposes, “limiting.” ROEPER: I am returning my ballot with negatives for each of the above referenced logs. My reasons for doing so follow: (1) The definitions to the terms retard, resist, restrict and limit, as determined by the committee, provide no discernible difference to the user of the standard. (2) 101-179 (Log #CP609) strikes the term “restrict” and seeks to replace it with “limit”. Unfortunately, the definitions to these two terms each reference the other term, i.e., restrict is to limit, and limit is to restrict. I realize that the debate over these terms has gone on for some time, however, I do not feel that the committee’s current position on the use of the terms provides clear and actionable language for the user of the standard. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle The committee gave consideration to the submitter’s recommendation and decided that no specific action is necessary. COMMITTEE STATEMENT: By taking this action on this comment the committee reaffirms its acceptance of Proposal 101-179. Also see the committee’s action on Comment 101-123 which establishes certain performance limits. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITHEXPLANATION OF NEGATIVE: HOLMES: The proposed text in 8.5.1 would introduce the word, “limit”. This word is defined as “a prescribed maximum or minimum amount, quantity, or number.” Despite proposals to introduce quantification for allowable leakage for systems or devices providing protection of openings in smoke barriers, NFPA 101 does not include any requirements to set a maximum amount of smoke leakage allowed in the smoke barrier itself. The proposed use of the word, “limit” in 8.5.1 is an incorrect use of the term. The provisions of NFPA 101 do not provide limits for the amount of smoke leakage through smoke barriers. The word “restricting” should not be replace by the word, “limiting.” While the committee meeting action and committee statement confirms that the committee considered the various negative comments, as directed by the

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Report on Comments — Copyright, NFPA NFPA 101 TCC, the committee does not present any technical justification for rejecting the concerns expressed in the negative ballots and comments. The NFPA Regulations Governing Committee Projects, 4-4.6.3 requires that TC action on Comments “Accepted in Principle” “shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC’s rationale for its action so the rebuttal may, if desired, be offered when the Committee presents its Technical Committee Report to the Association for consideration.” The TC has failed to meet this requirement in this case. _______________________________________________________________101-122a Log #CC351 SAF-END FINAL ACTION: Accept (8.5.2.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that Comment 101-123 has been rejected because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting. Thus, the action recommended by this comment stands.SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-181 RECOMMENDATION: Reject Comment 101-123 so as NOT to add maximum combined passage of smoke criteria for smoke barriers (0.75 cfm per sq ft of smoke barrier area, at 0.1 in. water column pressure). SUBSTANTIATION: Inadequate substanttiation for so serious a change. Even if it could be justifed to limit combined smoke leakage, the values chosen are excessive. The 0.1 in. water column pressure criterion is unsubstantiated, especially where automatic sprinkler protection is provided. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-122b Log #CC280 SAF-AXM FINAL ACTION: Accept (8.5.2.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that Comment 101-123 has been rejected because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting. Thus, the action recommended by this comment stands.SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-181 RECOMMENDATION: Reject Comment 101-123 so as NOT to add maximum combined passage of smoke criteria for smoke barriers (0.75 cfm per sq ft of smoke barrier area, at 0.1 in. water column pressure). SUBSTANTIATION: Inadequate substanttiation for so significant a change. The leakage values chosen are too conservative. The 0.1 in. water column pressure criterion is unsubstantiated, especially where automatic sprinkler protection is provided. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-122c Log #CC202 SAF-HEA FINAL ACTION: Accept (8.5.2.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that Comment 101-123 has been rejected because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting. Thus, the action recommended by this comment stands.SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-181 RECOMMENDATION: Reject Comment 101-123 so as NOT to add maximum combined passage of smoke criteria for smoke barriers (0.75 cfm per sq ft of smoke barrier area, at 0.1 in. water column pressure). SUBSTANTIATION: Inadequate substanttiation for this significant change by SAF-FIR. The leakage values chosen are too conservative. The 0.1 in. water column pressure criterion is unsubstantiated, especially where automatic sprinkler protection is provided. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-123 Log #31 SAF-FIR FINAL ACTION: Reject (8.5.2.4 and A.8.5.2.4 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-181 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Add new sections 8.5.2.4 and A.8.5.2.4 to read as follows: 8.5.2.4 New smoke barriers shall be designed to limit the combined passage of smoke through opening protective, smoke dampers, joints, and through-penetrations at any floor level to not more than 0.75 cfm per square foot of total wall area, measured at a pressure of 0.1 in. of water (25 Pa). The total wall surface area shall be measured from outside wall to outside wall and from floor slab to floor or roof deck above, including continuity through concealed spaces. A.8.5.2.4 The combined total smoke leakage rate through a smoke barrier can be calculated as follows: Average Leakage Rate per Square Foot = {∑ n (R

doors x A

doors ) + ∑ n (R

dampers x A

dampers x 0.32) + ∑ n (R

penetrations x A

penetrations x 0.58)+

∑ n (R joints

x L joints

x 0.58)} ÷ A Tot Wall Surface Area

Where: R represents the leakage rate of the item, cfm per ft2 (or cfm per lineal ft for joints) A represents the cross-sectional area of the individual item as identified, ft2 L represents the length of the joint, ft ∑ n represents the summation of the smoke leakage contributed by each individual item, l through n n represents the total number of individual doors, dampers, penetrations or joints COMMITTEE STATEMENT: This committee action is a result of a public comment submitted to NFPA 5000 on the same subject (Comment 5000-295). The committee agrees that criteria regarding the leakage of smoke through smoke barriers should be established. The criteria documented is intended to serve as a design requirement and not as a field test commissioning requirement. The committee further notes that the annex material is intended to serve as one example of a calculation method in estimating the flow through an orifice in the smoke barrier and that the estimated flow can vary considerably based upon the calculation method used. The user needs to verify the calculation method used. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 12 Negative: 9 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: DEVLIN: I vote negative on this proposal. The proposal limits smoke leakage through smoke barriers to not more than 0.75 cfm per sf of total wall area. This performance criterion is arbitrary and unenforceable. By definition, a smoke barrier is designed and constructed to restrict the movement of smoke. The intent of requiring a smoke barrier is to maintain a tenable condition on the non-fire side of the smoke barrier. While imposing performance criterion relative to smoke leakage in the fire barrier as a means of achieving tenability may be a move in the right direction, smoke leakage through the wall is only a small piece of the big puzzle. Also, there are many other building elements/features that affect room/space tenability including the volume of the room/space. The submitter provides no data that indicates a problem/weakness with the current construction means and methods of fire barriers in their ability to restrict the movement of smoke. Mandating this performance criterion is difficult to inspect and unnecessarily costly to field test. GERDES: The need for the criteria has not been established. Inspection and enforcement is impossible. Mr. Holmes’ comment during ROP is on target. HOLMES: The Committee Statements states, “The committee agrees that criteria regarding the leakage of smoke through smoke barriers should be established.” However, this proposed change does not accomplish what is stated. The allowable leakage requirements are only applied to the systems or devices providing protection of openings in smoke barriers and not to the smoke barrier itself. Smoke barriers are used to enclose smoke compartments on all sides, including the top and bottom. (See definitions 3.3.23.3 and 3.3.35.2) The proposed provisions in 8.5.2.4 are limited to walls, ignoring the potential for smoke leakage through floors or ceilings that are also smoke barriers. Other leakage paths might be much more significant than the limited scope of 8.5.2.4, as proposed.

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Report on Comments — Copyright, NFPA NFPA 101 The proposed 8.5.2.4 establishes a higher restriction on allowable smoke leakage for the protection of openings that for the smoke barrier itself. There are no restrictions on the amount of smoke that can pass through a smoke barrier wall, smoke barrier floor, or smoke barrier ceiling. The proposed 8.5.2.4 establishes a restriction on the amount of leakage through wall openings will ignoring the allowable smoke leakage through floor openings, including, but not limited to unprotected convenience openings. There is no technical justification for the safety significance of 0.7 cfm per square foot leakage at 0.1 in. of water. Establishing requirements for allowable leakage for protected openings in walls while ignoring leakage through the walls themselves, the floors, the ceilings, and any floor or ceiling openings is unreasonable and ridiculous. KAPALCZYNSKI: While leakage rates may have been quantified for opening protectives, smoke dampers, joints, and through-penetrations, the presumed leakage through solid wall materials has been assumed to be effectively zero. This new requirement now makes the solid wall material a component with a potentially permissible leakage. An intact solid wall will retain its zero leakage rate, but a wall with a hole may not leak enough to require repair. Presently, an unplanned hole in a smoke barrier wall, such as one created by a large mallet to pass a small wire, must be ordered repaired as a violation of the integrity of the wall. With this new requirement, it is possible to calculate the total allowable leakage for the entire wall, deduct the total permitted leakage from opening protectives, smoke dampers, joints, and through-penetrations, and determine an excess permissible leakage. Calculating the excess permissible leakage back at the established pressure differential yields a maximum theoretical unstopped opening that can exist without compromising the design. This could be applied to illegal penetrations, incomplete sealing of joints, omitted smoke stopping, partially functioning smoke dampers, or partially open doors. A sample calculation for a 50 ft x 8 ft wall with two doors, two large dampers, twelve smoke stopped penetrations, and sealed joints, resulted in an allowable 180 cfm excess leakage (300 total cfm permitted minus 120 calculated cfm) that could be extrapolated into a single or aggregate unstopped penetrations of 2 ft 2 that would be permissible. It does not appear that the submitter anticipated this unintended consequence. KLEIN: Please register my vote as negative on this code proposal. This code comment is on ROP Code Proposal 101-181 that I voted against during the ROP ballot stage. ROP Code Proposal 101-181 did not receive the required 2/3 majority during the ballot, and was therefore rejected. A very similar code proposal was accepted by our committee during the 2003 code cycle, but was then promptly rejected by all the occupancy committees as being impossible to enforce in the field. This time around the Code Comments is making the leakage rate a “design” requirement, not a “field” test requirement. If one is using traditional construction materials in accordance with their listings, the added expense of such leakage “design” calculations is costly to the user with no added fire protection life safety benefit. One can inspect to see if all the listed components are installed per their listings. There was no fire data submitted with this code proposal that shows that the existing code provisions for smoke barriers are not adequate or not working in the field. In fact, if one reviews any NFPA fire data, I would believe it would be hard to justify that people are being killed or injured in buildings with smoke barriers. This code proposal only adds costs onto a building design with no reasonable life safety return. MCCORMICK: I am voting negative on this committee action because this change establishes quantitative criteria for smoke leakage through smoke barriers of 0.75 cfm per sf of total wall area. The proposal will result in requiring an unnecessary level of resistance to the passage of smoke. No data has been submitted that indicates that the current performance-based provisions of the Code have failed to perform as required in the field. In addition, it will be difficult to field verify and will result in a significant increase in construction and supervision costs. ROSENBAUM: This change establishes quantitative criteria for smoke leakage through smoke barriers of 0.75 cfm per sf of total wall area. Sufficient rational that supports 0.75 cfm on an engineering basis has not been provided. SCHNEIDER: No data has been submitted to justify that a change in current requirements is necessary. Furthermore, the integrity of the barriers in question is required to be maintained by various listed components such as door and window assemblies and through-penetration firestop materials. If these required components are installed properly, the integrity of the barrier is provided; inspections for these components are relatively straightforward and already commonplace. Changing the requirements to include additional measurements unenforceable in the field implies the listing and installation of the components is inadequate now. It also creates potential for designers to argue against the use of such listed components on a broad scale. I believe the best use for this is part of an analysis as permitted in Chapter 5, not mandated in text in Chapter 8. WOOD: I am voting negative on this item. The Committee’s actions to modify the language from “smoke barriers shall be constructed” to “smoke barrier shall be designed” creates enforcement difficulties. No data has been submitted to justify that a change in requirements is necessary. Furthermore, the integrity of the barriers in question is required to be maintained by various listed components such as door and window assemblies and through-penetration firestop materials. If these required components are installed properly, the integrity of the barrier is provide, inspections for these

components are relatively straight-forward and already commonplace. Changing the requirements to include additional measurements unenforceable in the field implies the listing and installation of the components is currently inadequate. It also creates potential for designers to argue against the use of such listed components on a broad scale. I believe the best use of this part of an analysis is permitted in Chapter 5, not mandated in text in Chapter 8. _______________________________________________________________101-123a Log #CC201 SAF-HEA FINAL ACTION: Accept (8.5.3.1) _______________________________________________________________ SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-183 RECOMMENDATION: Reject Comment 101-124 that was accepted by SAF-FIR. SUBSTANTIATION: In a change from what appeared as the action by SAF-FIR on Proposal 101-183 [later rejected by the technical correlating committee], the submitter has agreed to retain the words “where required by Chapters 12 through 42,” but inserted the word “new” to modify the word “doors.” The word “new” is not needed as the paragraph is written in the menu-format that requires occupancy chapter adoption for it to apply. The occupancy chapters need to decide for what doors, if any, the provision should apply. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-124 Log #219 SAF-FIR FINAL ACTION: Reject (8.5.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT for the reasons explained in Comment 101-123a.SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-183 RECOMMENDATION: Do not revise 8.5.3.1 as recommend by the submitter. In existing 8.5.3.2 [which is proposed to be renumbered to 8.5.4.2 by Committee Proposal 101-182 (Log #CP600), revise the wording to read as follows: “Where required by Chapter 12 through Chapter 42 new doors in smoke barriers shall comply with the requirements of 8.2.2.4.” SUBSTANTIATION: The committee’s proposed change applies only to new doors. NFPA 105 is now a standard and covers the clearance distance and does not permit undercuts, louvers, or grilles. Bringing the annex material forward with the new standard as a reference is appropriate for this opening protective. The embracing language of “Where required by Chapter 12 through Chapter 42” does in fact give the occupancy chapters the ability to opt out of this requirement if they so chose. With the coordination of building code requirements the defining of smoke partitions and smoke barriers with better requirements because a part of the LSC. Occupancy chapters should evaluate the need for either a smoke barrier or the lesser requirements of a smoke partition for application before diluting the requirements for smoke barriers as the more correct action in light of the above change. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Abstain: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF ABSTENTION: CAHANIN: I abstain in accordance with NFPA Committee Guidelines. COMMENT ON AFFIRMATIVE KLEIN: Please register my vote as Affirm with Comment on this code proposal. The substantiation of the proponent appears to be incorrect in its proposed application of this requirement. In my opinion, the way the code requirement is written, the occupancy chapters (i.e. “Where required by Chapter 12 through 42….”) have the ability to opt in, not as the proponent has state,. “opt out”, of this requirement if they so choose. I agree that it should be the choice of the Occupancy Committees to opt in if they so desire. I would recommend to the TCC to review the wording, and clarify whether this requirement is an opt in or opt out requirement. If the TCC believe it is an opt out requirement, there may be some Occupancy Committees that will be very upset that during the ROC stage they were not given the opportunity to opt out at their ROC meeting.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-124a Log #CC405 SAF-DET FINAL ACTION: Reject (8.5.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the text is not needed given the action on ROP Proposal 101-183 and the TCC action on Comment 101-124. The effect of the actions is that 8.5.4.2 will remain a menu option that the occupancy chapters can mandate: 8.5.4.2 Where required by Chapters 12 through 42, doors in smoke barriers shall comply with the requirements of 8.2.2.4.SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-186 RECOMMENDATION: Further revise current 8.5.3.2 from that shown as a new 8.5.4.2 in ROP Proposal 101-186 (related to Proposal 101-182 and Proposal 101-183) as follows: 8.5.4.2 [current 8.5.3.2] New doors in smoke barriers, in other than health care occupancies and detention and correctional occupancies, shall comply with the requirements of 8.2.2.4. SUBSTANTIATION: Detention and correctional occupancies need to avoid the use of swinging doors as such doors can be used as weapons by the residents. Rather, sliding doors are used. It is not practical to install and maintain S-rated (smoke-leakage rated) sliding doors. The gasketing systems can be removed by residents and used as weapons. The requirement for self-closers or automatic closers creates operational difficulties in detention and correctional occupancies where security is paramount. The current smoke barrier requirements adequately serve both the life safety and the security needs. See also Comment 101-295c. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-125 Log #117 SAF-FIR FINAL ACTION: Accept in Principle (8.5.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, per Holmes’ comments, to Accept in Principle – Reject ROP Proposal 101-187.SUBMITTER: Wayne D. Holmes, HSB Professional Loss Control COMMENT ON PROPOSAL NO: 101-187 RECOMMENDATION: Reconsider and reject the proposal. SUBSTANTIATION: The proposed action to accept is inconsistent with the committee action to reject Logs #208 and #209 (8.4.4 and 8.4.5). As part of the committee statements for Logs #208 and #209, the committee rejects the proposals because “no leakage criteria has (sic) been specified by the proposal for compliance with the listing criteria.” This statement is also true for Log #210. Further, requiring listed systems (to UL 1479 or other standard) adds a requirement that has no safety significance and is not technically justified. The current text “a system or material capable of limiting the transfer of smoke” is sufficient. The listing standard (e.g., UL 1479) does not test for leakage under fire conditions and is therefore not applicable. Air leakage tests (up to 400°F) are not smoke leakage tests and are not tests of performance under fire conditions. Some sealing materials actually get tighter under elevated temperatures or fire conditions. The Committee Statement is “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” It is also true that the Committee has not been presented with data indicating that materials used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc., need to be listed. The barriers themselves are not tested or listed for smoke tightness and may, in fact, be quite leaky. The proposed change in 101-Log #210 would establish a higher standard of tightness for penetration seals than is required for the barrier. There is no technical justification for this unnecessary increase in requirements. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee supports its previous action and substantiation on Proposal 101-187. By taking this action, the committee reaffirms its action of Accept-in-Principal on Proposal 101-187. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 19 Negative: 2 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: HOLMES: The Committee Statement on Proposal 101-187 stated, “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” Contrary to this statement, the Committee Action was to arbitrarily insert a requirement for listed systems to protect all penetrations.

The statement that the committee has not been presented with dated that systems used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc. need to be listed is correct. There is no justification to insert a requirement that systems be listed. WOOD: I am voting negative on this item. I continue to agree with Mr. Holme’s original negative comments in favor of rejecting this proposal. _______________________________________________________________101-126 Log #32 SAF-FIR FINAL ACTION: Accept in Principle (8.5.5.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to include: See TCC Note on Comment 101-125.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-188 RECOMMENDATION: Give consideration to the subject of an inconsistency as addressed in Holmes’ Explanation of Negative so as to make any needed changes. HOLMES: The proposed action to accept is inconsistent with the committee action to reject 101-177 (Log #208) and 101-178 (Log #209). AS part of the committee statements for 101-177 (Log #208) and 101-178 (Log #209), the committee rejects the proposals because “no leakage criteria has (sic) been specified by the proposal for compliance with the listing criteria.” This statement is also true for 101-188 (Log #232). Further, requiring listed systems (to UL 1479 or other standard) adds a requirement that has not safety significance and is not technically justified. The current text “a system or material capable of limiting the transfer of smoke” is sufficient. The listing standard (e.g., UL 1479) does not test for leakage under fire conditions and is therefore not applicable. Air leakage tests (up to 400°F) are not smoke leakage tests and are not tests of performance under fire conditions. Some sealing materials actually get tighter under elevated temperatures or fire conditions. The Committee Statement for 101-188 (Log #232) references the statement for 101-187 (Log #210) which states “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” It is also true that the Committee has not been presented with data indicating that materials used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc. need to be listed. There is no technical justification or demonstrated safety significance for the leakage rates referenced in UL 1479 or any other listing standard. There is no technical justification or safety significance demonstrated for including these requirements in the Life Safety Code. The barriers themselves are not tested or listed for smoke tightness and may, in fact, be quite leaky. The proposed change in 101-188 (Log #232) would establish a higher standard of tightness for penetration seals than is required for the barrier. There is no technical justification for this unnecessary increase in requirements. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-125. COMMITTEE STATEMENT: See committee action and statement on Comment 101-125. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: HOLMES: The Committee Statement on Proposal 101-187 (referenced by the Committee Statement on Proposal 101-188) stated, “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” Contrary to this statement, the Committee Action on Proposal 101-188 (Comment 101-126) was to arbitrarily insert a requirement for listed systems to protect all penetrations. The statement that the committee has not been presented with dated that systems used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc. need to be listed is correct. There is no justification to insert a requirement that systems be listed. While the committee meeting action and committee statement confirms that the committee considered the negative comment, as directed by the TCC, the committee does not present any technical justification for rejecting the concerns expressed in the negative ballot and comment. The NFPA Regulations Governing Committee Projects, 4-4.6.3 requires that TC action on Comments “Accepted in Principle” “shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC’s rationale for its action so the rebuttal may, if desired, be offered when the Committee presents its Technical Committee Report to the Association for consideration.” The TC has failed to meet this requirement in this case.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-127 Log #33 SAF-FIR FINAL ACTION: Accept in Principle (8.5.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, per Holmes’ and Koffel’s comments, to Accept in Principle – Reject ROP Proposal 101-189.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-189 RECOMMENDATION: Give consideration to Holmes’ Explanation of Negative and Koffel’s Comment on Affirmative so as to make any needed changes. HOLMES: This proposed action to accept is inconsistent with the committee action to reject 101-177 (Log #208) and 101-178 (#209). As part of the committee statements for 101-177 (Log #208) and 101-178 (#209), the committee rejects the proposals because “no leakage criteria has (sic) been specified by the proposal for compliance with the listing criteria.” This statement is also true for 101-189 (Log #207). Further, requiring listed systems (to UL 1479 or other standard) adds a requirement that has no safety significance and is not technically justified. The current text “a system or material capable of limiting the transfer of smoke” is sufficient. The listing standard (e.g., UL 1479) does not test for leakage under fire conditions and is therefore not applicable. Air leakage tests (up to 400oF) are not smoke leakage tests and are not tests of performance under fire conditions. Some sealing materials actually get tighter under elevated temperatures or fire conditions. The Committee Statement is “The Committee has not been presented with data indicating that all materials used to protect joints in smoke barriers need to be listed.” It is also true that the Committee has not been presented with data indicating that systems used to protect joints need to be listed. There is no technical justification or demonstrated safety significance for the leakage rates referenced in UL 1479 or other listing standards. There is no technical justification or safety significance demonstrated for including these requirements in the Life Safety Code. The barriers themselves are not tested or listed for smoke tightness and may, in fact, be quite leaky. The proposed change in 101-189 (Log #207) would establish a higher standard of tightness for joints than is required for the barrier. There is no technical justification for this unnecessary increase in requirements. KOFFEL: Additional work is necessary regarding the proposed new language to identify the performance criteria desired for the listed joint system. The issue of previously approved existing systems may need to be clarified, possibly through an Annex note, unless the alternative of a material capable of restricting the transfer of smoke is considered acceptable. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle The committee gave consideration to the submitter’s recommendation and reaffirms it previous action to accept Proposal 101-189. COMMITTEE STATEMENT: The committee notes that Proposals 101-177 and 101-178 pertain to smoke partitions and not to smoke barriers. The committee notes that the criteria of 400 degrees Fahrenheit is a relevant value in testing smoke doors with regard to NFPA 105, in testing smoke dampers in accordance with UL 555S and in testing air leakage of door assemblies in accordance with UL 1784. The committee further believes that the proposed language of “a material capable of limiting the passage of smoke “ provides an acceptable alternative for existing installations. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: HOLMES: The Committee Statement on Proposal 101-187 (referenced by the Committee Statement on Proposal 101-189) stated, “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” Contrary to this statement, the Committee Action on Proposal 101-189 (Comment 101-127) was to arbitrarily insert a requirement for listed systems to protect all penetrations. The statement that the committee has not been presented with dated that systems used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc. need to be listed is correct. There is no justification to insert a requirement that systems be listed. While the committee meeting action and committee statement confirms that the committee considered the negative comments, as directed by the TCC, the committee does not present any technical justification for rejecting the concerns expressed in the negative ballots and comments. The NFPA Regulations Governing Committee Projects, 4-4.6.3 requires that TC action on Comments “Accepted in Principle” “shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC’s rationale for its action so the rebuttal may, if desired, be offered when the Committee presents its Technical Committee Report to the Association for consideration.” The TC has failed to meet this requirement in this case.

_______________________________________________________________101-128 Log #118 SAF-FIR FINAL ACTION: Acccept in Principle (8.5.6.2 through 8.5.6.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, per Holmes’ comments, to Accept in Principle – Reject ROP Proposal 101-190.SUBMITTER: Wayne D. Holmes, HSB Professional Loss Control COMMENT ON PROPOSAL NO: 101-190 RECOMMENDATION: Reconsider and reject the proposal. SUBSTANTIATION: The proposed action to accept is inconsistent with the committee action to reject Logs #208 and #209 (8.4.4 and 8.4.5). As part of the committee statements for Logs #208 and #209, the committee rejects the proposals because “no leakage criteria has (sic) been specified by the proposal for compliance with the listing criteria.” This statement is also true for Log #207 and Log #233. Further, requiring listed systems (to UL 1479 or other standard) adds a requirement that has no safety significance and is not technically justified. The current text “a system or material capable of limiting the transfer of smoke” is sufficient. The listing standard (e.g., UL 1479) does not test for leakage under fire conditions and is therefore not applicable. Air leakage tests (up to 400°F) are not smoke leakage tests and are not tests of performance under fire conditions. Some sealing materials actually get tighter under elevated temperatures or fire conditions. The Committee Statement is “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” It is also true that the Committee has not been presented with data indicating that materials used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc., need to be listed. There is no technical justification or demonstrated safety significance for the leakage rates referenced in UL 1479 or other listing standards. There is no technical justification or safety significance demonstrated for including these requirements in the Life Safety Code. The barriers themselves are not tested or listed for smoke tightness and may, in fact, be quite leaky. The proposed change in 101-Log #207 and #233 would establish a higher standard of tightness for penetration seals than is required for the barrier. There is no technical justification for this unnecessary increase in requirements. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee supports its previous action and substantiation on Proposal 101-190. By taking this action, the committee reaffirms its action of Accept-in-Principal on Proposal 101-190. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: HOLMES: The Committee Statement on Proposal 101-187 (referenced by the Committee Statement on Proposal 101-189) stated, “The Committee has not been presented with data indicating that all materials used to protect penetrations in smoke barriers need to be listed.” Contrary to this statement, the Committee Action on Proposal 101-190 (Comment 101-128) was to arbitrarily insert a requirement for listed systems to protect all penetrations. The statement that the committee has not been presented with dated that systems used to protect penetrations for cables, cable trays, pipes, tubes, vents, etc. need to be listed is correct. There is no justification to insert a requirement that systems be listed. While the committee meeting action and committee statement confirms that the committee considered the negative ballot and comments, as directed by the TCC, the committee does not present any technical justification for rejecting the concerns expressed in the negative ballots and comments. The NFPA Regulations Governing Committee Projects, 4-4.6.3 requires that TC action on Comments “Accepted in Principle” “shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC’s rationale for its action so the rebuttal may, if desired, be offered when the Committee presents its Technical Committee Report to the Association for consideration.” The TC has failed to meet this requirement in this case. _______________________________________________________________101-129 Log #34 SAF-FIR FINAL ACTION: Accept in Principle (8.6.1(1)) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified, per Klein’s comment, to change the first word of 8.6.1(2) from “Is” to “It.”SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-191 RECOMMENDATION: Give consideration to the subject of an inconsistency as addressed in Kapalczynski’s Explanation of Negative so as to make any needed changes. KAPALCZYNSKI: 8.6.1 is in conflict with itself. If it is indeed the intent that “every floor that separates stories in a building shall be constructed as a smoke barrier to form a basic degree of compartmentation,” then part (2), specifically 8.6.8 convenience openings, makes that impossible. 8.6.6

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Report on Comments — Copyright, NFPA NFPA 101 communicating spaces and 8.6.7 atriums have specific conditions for their use. 8.6.8 convenience openings may be used in any occupancy, at any time, new or existing (thus they may be introduced at any time in the life of the building), in any location other than corridors (the term is undefined), in any size or dimension, and in any number. Consequently, any two adjacent floor areas within any building may be open to each other. This defines the basic area of vertical compartmentation as a two-floor area. Given the number of proposals which the technical committee evaluates with regard to opening, penetration and joint protection of smoke barrier walls, and the detailed requirements that it accepts from such proposals, it is not consistent that vertical smoke propagation between any two floors is permitted without any significant conditions. This conflict was originally brought to the attention of the technical committee in 1999. The TC established a task group to address this issue. A review of the TC minutes indicated that several events occurred. The TC took on the NFPA 5000 building code. The task group chairperson left the committee. The TC chairperson changed and the NFPA liaison changed. The only report from the task group was “no report.” In sum, the issue was lost. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise section 8.6.1 to read as follows: 8.6.1 Floor Smoke Barriers. Every floor that separates stories in a building shall meet one of the following criteria: (1) It shall be constructed as a smoke barrier in accordance with Section 8.5. (2) Is shall be permitted to have openings as permitted described by 8.6.6, 8.6.7, 8.6.8 or Chapter 11 through Chapter 42. COMMITTEE STATEMENT: Meets the intent of the submitter by correcting the inconsistency. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH COMMENT ON AFFIRMATIVE KLEIN: Please register my vote as Affirm with Comment on this code proposal. Editorial correction to the revised 8.6.1(2), change the first word “Is” should be changed to “It”. _______________________________________________________________101-130 Log #221 SAF-FIR FINAL ACTION: Reject (8.6.2.1 (New) ) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-192 RECOMMENDATION: Reconsider the original proposal to add a new section to read as follows: 8.6.2.1 Vertical openings through floors include stairways, hoistways for elevators, dumbwaiter, and inclined and vertical conveyors, shaftways used for light, ventilation or building service and expansion joints seismic joints used to allow structural movement. SUBSTANTIATION: The committees reason for rejecting the proposal is not consistent with the use of inclusive listings in the code as listed in the Explanation of Abstention. “Specifically as found in the current LSC are: 3.3.27.1 Airport Terminal Building. A structure used primarily for air passenger enplaning or deplaning, including ticket sales, flight information, baggage handling, and other necessary functions in connection with air transport operation. This term includes any extensions and satellite buildings used for passenger handling or aircraft service functions. Aircraft loading walkways and “mobile lounges” are excluded. [415:1.4] 3.3.50 Dwelling Unit. One or more rooms arranged for the use of one or more individuals living together, providing complete, independent living facilities, including permanent provisions for living, sleeping, eating, cooking, and sanitation. 7.8.1.1* Illumination of means of egress shall be provided in accordance with Section 7.8 for every building and structure where required in Chapter 11 through Chapter 42. For the purposes of this requirement, exit access shall include only designated stairs, aisles, corridors, ramps, escalators, and passageways leading to an exit. For the purposes of this requirement, exit discharge shall include only designated stairs, aisles, corridors, ramps, escalators, walkways, and exit passageways leading to a public way. 7.9.1.2 For the purposes of 7.9.1.1, exit access shall include only designated stairs, aisles, corridors, ramps, escalators, and passageways leading to an exit. For the purposes of 7.9.1.1, exit discharge shall include only designated stairs, ramps, aisles, walkways, and escalators leading to a public way. 8.3.3.1 Wall openings required to have a fire protection rating by Table 8.3.4.2 shall be protected by approved, listed, labeled fire door assemblies and fire window assemblies and their accompanying hardware, including all frames, closing devices, anchorage, and sills in accordance with the requirements of NFPA 80, Standard for Fire Doors and Fire Windows, except as otherwise specified in this Code. 12.7.4.3.6 Acoustical and decorative material including, but not limited to, cotton, hay, paper, straw, moss, split bamboo, and wood chips shall be flame-retardant treated to the satisfaction of the authority having jurisdiction. 18.1.1.1.2 The requirements established by this chapter shall apply to the design of all new hospitals, nursing homes, and limited care facilities. The

term hospital, wherever used in this Code, shall include general hospitals, psychiatric hospitals, and specialty hospitals. The term nursing home, wherever used in this Code, shall include nursing and convalescent homes, skilled nursing facilities, intermediate care facilities, and infirmaries in homes for the aged. 33.2.3.2.2 Spaces requiring protection by 33.2.3.2.1 shall include, but shall not be limited to, areas for cartoned storage, food or household maintenance items in wholesale or institutional-type quantities and concentrations, or mass storage of residents’ belongings.” COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee reaffirms its previous action and statement for Proposal 101-192. The committee further notes that the proposed language is a statement and not a requirement. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Abstain: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF ABSTENTION: CAHANIN: I abstain in accordance with NFPA Committee Guidelines.

_______________________________________________________________101-131 Log #294 SAF-FIR FINAL ACTION: Reject (8.6.5) _______________________________________________________________ SUBMITTER: Tony Crimi, A.C. Consulting Solutions, Inc. / Rep. International Firestop Council COMMENT ON PROPOSAL NO: 101-193 RECOMMENDATION: Add new text to read as follows: A.8.6.5(3) The fire resistance rating for the enclosure of floor openings required during repairs and replacements shall not be less than the applicable level of performance required or approved at the time of original installation. SUBSTANTIATION: The proponent has indicated that this is often misunderstood by Code users and the public. Based on the committee deliberations and published position, an Annex note clarifying the intent is warranted. The language I am suggesting here is built around the language in 1.4.2. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee believes that the proposed language is not necessary and that it conflicts with the text in proposed new Chapter 43, Building Rehabilitation. See Proposal 101-70. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH _______________________________________________________________101-132 Log #348 SAF-FIR FINAL ACTION: Reject (8.6.5) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-193 RECOMMENDATION: Reconsider as revised: A.8.6.5(3) Repairs and replacements shall not be less than the applicable requirements that were approved at the time of original installation. SUBSTANTIATION: This Annex note is supported by the accepted proposal 101-75 Log #355. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action and statement on Comment 101-131. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 1 MESSERSMITH

_______________________________________________________________101-133 Log #349 SAF-FIR FINAL ACTION: Reject (8.6.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-194 RECOMMENDATION: Reconsider revised: Unenclosed vertical openings permitted by Section 8.6.8, in buildings with complete automatic sprinkler systems shall be protected with draft stops as required by NFPA 13 Section 5.13.4. SUBSTANTIATION: Convenience openings when retrofitted in existing buildings require this statement to alert designers that the openings may not be appropriate due to ceiling heights that may be too low to provide draft curtains and still maintain headroom. Sprinkler contractors, who would be aware of this requirement, are rarely involved when these openings are created. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee reaffirms its previous action and statement with regard to Proposal 101-194. NFPA 13 adequately addresses the issue.

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Report on Comments — Copyright, NFPA NFPA 101 NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 1 MESSERSMITH EXPLANATION OF NEGATIVE: KAPALCZYNSKI: By not alerting the user of this document to a related requirement in NFPA 13, the typical scenario finds a newly installed convenience opening (per NFPA 101 Section 8.6.6) that will infringe on the minimum headroom requirements on the floor below. The sprinkler installer is forced to reduce headroom by 18 inches, violating NFPA 101 Section 7.1.5 where the floor-to-floor height is insufficient. To correct this condition, either the NFPA 13 requirement (8.14.4) must be ignored (illegal) or the vertical opening must be removed (an expensive correction that could have been prevented by a simple code reference). This proposal is not questioning the NFPA 13 requirement. This is a rare instance where a system installation standard requires a fire protection feature (draft curtains). It is appropriate for this chapter to acknowledge a coexisting requirement in the interest of alerting the user of this document of its existence rather than to foster its omission. _______________________________________________________________101-134 Log #234 SAF-BSF FINAL ACTION: Hold (9.1.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, per Larrimer’s comments, to HOLD. The TCC notes that the occupancy chapter technical committees were not informed of the action at their ROC meetings so they have not had the opportunity to evaluate the effect on their chapter/occupancy of the mandate for a “constantly attended location.” The subject should be addressed fully during the next revision cycle.SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-198 RECOMMENDATION: Change TC action from Reject to Accept in Principle with the change to the original proposal as follows: 9.1.3.1 New emergency generator systems shall be supervised for “running condition” not in automatic condition and “trouble” conditions by an approved system that will transmit the abnormal conditions to a constantly attended location. SUBSTANTIATION: The rewrite is to satisfy the TC to provide options for adding reliability to the generator system. COMMITTEE MEETING ACTION: Accept in Principle Revise 9.1.3 as follows: 9.1.3 Emergency Generators. 9.1.3.1 Emergency generators, where required for compliance with this Code, shall be tested and maintained in accordance with NFPA 110, Standard for Emergency and Standby Power Systems. 9.1.3.2 New generator controllers shall be monitored at a constantly attended location for the following conditions: (1) Generator running (2) Generator fault (3) Generator switch in non-automatic position COMMITTEE STATEMENT: The submittal has been editorially revised for compliance with the NFPA Manual of Style. The committee action should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: LARRIMER: While monitoring an emergency generator may be a good idea, no substantiation has been provided to add this text to the Life Safety Code. NFPA 101, 11.8.4.2 requires emergency standby power for high-rise buildings. 11.8.5 requires emergency generator status indicators to be provided at a central location. As a result, I believe it is adequately covered in that one instance where standby power by emergency generator is required in the code. I am concerned that it will be mis-interpreted. All occupancies that require emergency lighting under *.2.9 refers to 7.9 for the requirements. 7.9.2.3 is a follows: 7.9.2.3 Emergency generators providing power to emergency lighting systems shall be installed, tested, and maintained in accordance with NFPA 110, Standard for Emergency and Standby Power Systems. Stored electrical energy systems, where required in this Code, shall be installed and tested in accordance with NFPA 111, Standard on Stored Electrical Energy Emergency and Standby Power Systems. My concern is that AHJ will try to mandate that facilities that use emergency generators to provide emergency lighting will be required to monitor the generator status as required by this new verbiage at a remote constantly attended location above the requirements already contained in NFPA 110. For example, generators are installed in hospitals to provide, among other things, emergency lighting as required by NFPA 99 and NFPA 110. There is currently no requirement to monitor them at a constantly attended location. Adding this verbiage will be interpreted to require remote monitoring of the generators when the healthcare occupancy does not intend that to be mandatory.

_______________________________________________________________101-135 Log #35 SAF-BSF FINAL ACTION: Accept in Principle (9.1.3, 9.1.4, 9.3.4, 9.6.1.9, 9.6.1.10, 9.7.5, and 9.7.8) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-199 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: No action required in Chapter 9. Chapter 9 provides mandatory references to NFPA 110 and 111 where emergency or standby power is required by another section of the Code. It would be up to those other sections of the Code to specify a particular Type/Class/Level of emergency or standby power based on the application. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-136 Log #342 SAF-BSF FINAL ACTION: Reject (9.3.3.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-195 RECOMMENDATION: Refer revision to BSF: Newly installed smoke control systems shall have their design performance physically demonstrated by visual means such as aerosols, streamers, tracers, smoke candles, or other equivalent media acceptable to the authority having jurisdiction, to visually verify that patterns of smoke movement achieve the documented design criteria. SUBSTANTIATION: Per the committee statement, this proposal is renumbered 9.3.3.1 for forwarding to BSF. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Testing of smoke management systems is not within the scope of the Code. Such testing is more appropriately addressed in NFPA 92A and NFPA 92B, which are developed by the NFPA Technical Committee on Smoke Management Systems. In addition, it is understood that visual testing using the methods described in the submittal is contrary to the provisions of NFPA 92A and NFPA 92B. The Code requires acceptance testing to be performed by a special inspector who should have the required expertise to ensure the system will function as designed. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-137 Log #237 SAF-BSF FINAL ACTION: Reject (9.4.x) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-200 RECOMMENDATION: Change TC action from reject to accept by changing “ 9.4.x to 9.4.3.3 ”, changing “ new elevators ” from “ elevators ” and deleting second sentence in proposal. SUBSTANTIATION: In order to get to the NFPA 72 requirements, NFPA 101, NFPA 5000 or another building code msut make the requirement. It is my understanding that ASME A17.1 will accept stand alone detection which has a lower reliability than a system in accordance with NFPA 72. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: ASME A17.1 provides the necessary reference to NFPA 72. In addition, the submitter’s substantiation is incorrect; standalone detection is not permitted by ASME A17.1. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-138 Log #233 SAF-BSF FINAL ACTION: Accept (9.6.1.9 and 9.6.1.10) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-204 RECOMMENDATION: Change the TC action from Reject to Accept. SUBSTANTIATION: Retaining documentation and as-builts is in the scope of NFPA 72 but doubtful in NFPA 101. See Proposals 101-203 and 101-205 from NFPA 72’s TC. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-138a Log #138 SAF-BSF FINAL ACTION: Accept (9.6.1.9) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-203 RECOMMENDATION: Accept proposal to delete documentation requirements covered by NFPA 72. SUBSTANTIATION: Agree with Mr. Larrimer’s comments on the negative vote. Documentation requirements, and requirements for maintaining the documentation, are explicitly covered in NFPA 72, Section 10.6.1.3 “The owner shall be responsible for maintaining these records for the life of the system for examination by any authority having jurisdiction. Paper or electronic media shall be permitted.” The technical justification for an “approved, secure location” has not been substantiated, and is irrelevant as long as the owner maintains the records for review as required by NFPA 72. The specific means and location of records retention should be the purview of the building owner. In most cases, documentation is provided in electronic format, which makes the concept of a single storage location obsolete. In terms of whether these requirements should be located in NFPA 101 or NFPA 72, our understanding of the guidance provided by the Standards Council via the Committee Officers Guide Appendix A-9 is that the requirements should be located in NFPA 72. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-139 Log #139 SAF-BSF FINAL ACTION: Accept (9.6.1.10) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-205 RECOMMENDATION: Accept proposal to delete documentation requirements covered by NFPA 72. SUBSTANTIATION: Agree with Mr. Larrimer’s comments on the negative vote. Documentation requirements, and requirements for maintaining the documentation, are explicitly covered in NFPA 72, Section 10.6.1.3 “The owner shall be responsible for maintaining these records for the life of the system for examination by any authority having jurisdiction. Paper or electronic media shall be permitted.” The technical justification for an “approved, secure location” has not been substantiated, and is irrelevant as long as the owner maintains the records for review as required by NFPA 72. The specific means and location of records retention should be the purview of the building owner. In most cases, documentation is provided in electronic format, which makes the concept of a single storage location obsolete. In terms of whether these requirements should be located in NFPA 101 or NFPA 72, our understanding of the guidance provided by the Standards Council via the Committee Officers Guide Appendix A-9 is that the requirements should be located in NFPA 72. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-140 Log #343 SAF-BSF FINAL ACTION: Reject (9.6.2.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes, in response to the committee statement, that Comment 101-54 rejects ROP Proposal 101-103, so there is no conflict.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-206 RECOMMENDATION: Enforcement of this section conflicts with Section 7.2.1.6.3.2 as accepted in the Log 101-103 #426. SUBSTANTIATION: N/A. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No revision has been proposed by the submitter. The committee notes, however, the action taken by the Technical Committee on Means of Egress (SAF-MEA) on Proposal 101-103 creates a conflict with 9.6.2.2 by the creation of the proposed, new 7.2.1.6.3.2, which would permit a manual fire alarm box to function as an emergency door-release device. As such, the committee has forwarded an informational recommendation to SAF-MEA suggesting they delete the proposed 7.2.1.6.3.2 so as to avoid the conflict. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

_______________________________________________________________101-141 Log #396 SAF-BSF FINAL ACTION: Reject (9.6.2.5) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-207 RECOMMENDATION: Accept Proposal 101-207. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No new information has been provided by the submitter. The committee stands on its substantiation for the rejection of Proposal 101-207. See Comment 101-434a (Log #CC151) for proposed annex language to explain the intent of the manual fire alarm box required by 9.6.2.5. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: LARRIMER: The requirement for when the manual pull station is required belongs in, and is located in the occupancy chapters. Each occupancy chapter in the Life Safety Code establishes when a manual system is required, when one manual alarm box is required when automatic devices are used for activating the alarm system, or when all manual alarm boxes may be omitted while using automatic devices to activate the alarm system. Leaving this in Chapter 9 creates conflicts with the occupancy chapters. Below is a brief summary of all occupancy chapters in the Life Safety Code. In all cases, the occupancy chapters identify: • when at least one manual pull station is required in addition to when automatic devices are used to activate the fire alarm system • when automatic devices alone are permitted (which Chapter 9 does not permit) • when occupant notification or someone/someplace else is required to be notified upon activation of the system • when emergency forces are to be notified upon activation of the system Section 9.6.2.5 could be fixed by adding “Where required by another section of this code” to the beginning of the section. This would remove the conflicts that this generates with those sections that allow the omission of all manual alarm boxes (Assembly, Lodging and Rooming, Apartments, Business). Assembly occupancies 12/13.2.4.2 allow all manual stations to be eliminated when the building is provided with detection or sprinkler throughout (but Chapter 9 implies that this is not the case). Note that the manual station does not necessarily notify the occupants or bring the emergency forces. (12.3.4.3 Notification. The required fire alarm system shall sound an audible alarm in a constantly attended receiving station within the building when occupied for purposes of initiating emergency action.) Education, Mercantile, Industrial and Storage occupancies require at least one manual station without the need for this requirement to be repeated in Chapter 9. Day Care, Ambulatory Healthcare, occupancies require a manual system. Healthcare occupancies require a manual system with some explicit exemptions. Detention and correctional occupancies require a manual system with explicit directions. Lodging and Rooming occupancies do not require a manual alarm box in a new sprinklered facility. (Conflicts with 9.6.2.5) Hotels and Dormitory occupancies require one manual alarm box at a specific location. New Apartment Occupancies do not require a manual alarm box when sprinkler are used. (Conflicts with 9.6.2.5) Residential Board and Care occupancies specifically identify one manual pull at a specific location in addition to a manual system. Small Board and Care facilities require one manual box per floor that activate the smoke alarms. Business does not require one manual box but allows the automatic devices to activate the alarm system. (Conflicts with 9.6.2.5)

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-142 Log #125 SAF-BSF FINAL ACTION: Reject (9.6.2.10) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-210 RECOMMENDATION: Accept Proposal 101-210. SUBSTANTIATION: With reference to the substantiation in Proposals 101-211 and 101-212, which were the basis for the TCC Action on Proposal 101-210, the Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee concurs with the action taken by the Safety to Life Technical Correlating Committee on Proposal 101-210, based on input from the Technical Committee on Board and Care Facilities (Proposal 101-211) and the Technical Committee on Residential Occupancies (Proposal 101-212). NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-143 Log #36 SAF-BSF FINAL ACTION: Accept in Principle (9.6.2.10 and 9.6.2.11) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-213 RECOMMENDATION: Reconsider the proposal, given that Proposal 101-210 was rejected, so as to make any needed changes. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reconsidered the proposal as directed. No further action is necessary since the restoration of 9.6.2.10 by the rejection of Proposal 101-210 does not affect the action on Proposal 101-213. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

_______________________________________________________________101-143a Log #CC152 SAF-BSF FINAL ACTION: Accept (9.6.3.2.1) _______________________________________________________________ SUBMITTER: Technical Committee on Building Service and Fire Protection Equipment COMMENT ON PROPOSAL NO: 101-216 RECOMMENDATION: Revise 9.6.3.2.1 as follows: 9.6.3.2.1* Elevator lobby, hoistway, and associated machine room smoke detectors used solely for elevator recall, and heat detectors used solely for elevator power shutdown, shall not be required to activate the building evacuation alarm if the power supply and installation wiring to such detectors are monitored by the building fire alarm system, and if the activation of such detectors results in an audible and visible alarm initiates a supervisory signal at a constantly attended location. SUBSTANTIATION: The proposed revision is intended to coordinate with the action taken on Comment 101-144 (Log #180). COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

_______________________________________________________________101-144 Log #180 SAF-BSF FINAL ACTION: Accept in Principle (9.6.3.2.2) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-216 RECOMMENDATION: Revise 9.6.3.2.2 as follows: 9.6.3.2.2* Smoke detectors used solely for closing dampers or heating, ventilating, and air-conditioning system shutdown shall not be required to activate the building evacuation alarm if the power supply and installation wiring to these detectors are monitored by the building fire alarm system, and the activation of these detectors results in an audible and visible alarm signal at a constantly attended location. SUBSTANTIATION: Based on the committees statement in rejecting the original proposal, it is obvious that it is the intent that HVAC system smoke detectors are supposed to perform the same as elevator associated smoke detectors in 9.6.3.2.1, however the wording is different. This comment will make the wording consistent. COMMITTEE MEETING ACTION: Accept in Principle Revise 9.6.3.2.2 as follows: 9.6.3.2.2* Smoke detectors used solely for closing dampers or heating, ventilating, and air-conditioning system shutdown shall not be required to activate the building evacuation alarm if the power supply and installation wiring to these detectors are monitored by the building fire alarm system, and the activation of these detectors initiates a supervisory signal at a constantly attended location. COMMITTEE STATEMENT: The committee action replaces the reference to an audible and visible alarm signal with a reference to a supervisory signal to clarify that the Code does not intend the subject detectors to initiate an “alarm” condition. See also Comment 101-143a (Log # CC152) and Comment 101-145a (Log # CC153) for revisions to 9.6.3.2.1 and 9.6.3.2.3, respectively, for consistency with the action taken on 9.6.3.2.2. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-145 Log #181 SAF-BSF FINAL ACTION: Accept in Principle (9.6.3.2.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-217 RECOMMENDATION: Revise 9.6.3.2.2 as follows: 9.6.3.2.2* Smoke detectors located at doors for the exclusive operation of an automatic door release shall not be required to activate the building evacuation alarm if the power supply and installation wiring to these detectors are monitored by the building fire alarm system, and the activation of these detectors results in an audible and visible alarm signal at a constantly attended location. SUBSTANTIATION: Based on the committees statement in rejecting the original proposal, it is obvious that it is the intent that door closing smoke detectors are supposed to perform the same as elevator associated smoke detectors in 9.6.3.2.1, however the wording is different. This comment will make the wording consistent. NFPA 101 does not allow heat detectors to close doors, therefore the addition of “smoke” makes the paragraphs parallel, consistent and correct. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-145a (Log # CC153). COMMITTEE STATEMENT: The action on Comment 101-145a (Log # CC153) should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-145a Log #CC153 SAF-BSF FINAL ACTION: Accept (9.6.3.2.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to insert the word “Smoke” as the first word in 9.6.3.2.3 so as to read: “9.6.3.2.3 Smoke detectors located...” The recommendation in Comment 101-145, which was accepted in principle with a reference to Comment 101-145a, included the word “smoke” but it was not incorporated into the action on this comment.SUBMITTER: Technical Committee on Building Service and Fire Protection Equipment COMMENT ON PROPOSAL NO: 101-216 RECOMMENDATION: Revise 9.6.3.2.3 as follows: 9.6.3.2.3* Detectors located at doors for the exclusive operation of automatic door release shall not be required to activate the building evacuation alarm if the power supply and installation wiring to these detectors are monitored by the building fire alarm system, and the activation of these detectors initiates a supervisory signal at a constantly attended location. SUBSTANTIATION: The proposed revision is intended to coordinate with the action taken on Comment 101-144 (Log #180).

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-146 Log #232 SAF-BSF FINAL ACTION: Reject (9.6.3.6) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-218 RECOMMENDATION: Change the TC action from Reject to Accept. SUBSTANTIATION: It takes a fire or building code to make survivability a requirement. NFPA 72 only discussed survivability, but cannot require it. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject of survivability, as it pertains to voice alarm systems, is adequately addressed in NFPA 72. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-147 Log #37 SAF-BSF FINAL ACTION: Accept in Principle (9.6.3.7, 9.6.3.8, 9.6.3.9, and 9.6.3.11) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-219. Current provisions of 9.6.3.7, 9.6.3.8, 9.6.3.9 and 9.6.3.11 need to be maintained for existing systems.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-219 RECOMMENDATION: Reconsider the proposal, given the effect that a deletion of text would take on existing alarm systems which cannot be required to be upgraded to the current requirements of NFPA 72. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete 9.6.3.7, 9.6.3.8, 9.6.3.9, and 9.6.3.11, and replace them with a new 9.6.3.7 to read as follows: 9.6.3.7 Audible alarm notification appliances shall be of such character and so distributed as to be effectively heard above the average ambient sound level that exists under normal conditions of occupancy. 9.6.3.8 Audible alarm notification appliances shall produce signals that are distinctive from audible signals used for other purposes in a given building. 9.6.3.9 Automatically transmitted or live voice evacuation or relocation instructions shall be permitted to be used to notify occupants and shall be in accordance with NFPA 72®, National Fire Alarm Code®. 9.6.3.11 Alarm notification signals shall take precedence over all other signals. 9.6.3.7 Alarm notification appliances and notification appliance circuits shall comply with the requirements of NFPA 72, National Fire Alarm Code, unless they are approved, existing installations, which shall be permitted to continue in use. COMMITTEE STATEMENT: The committee concurs that existing, approved fire alarm systems should not be retroactively required to be upgraded to meet the current edition of NFPA 72. The revision to 9.6.3.7 should meet the intent of the TCC note. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: LARRIMER: This topic is already covered in 9.6.1.3, but 9.6.1.3 applies to the entire fire alarm system whereas 9.6.3.7 only applies to a portion of the fire alarm system. Therefore, 9.6.3.7 is not needed. Accepting this verbiage for 9.6.3.7 implies that permission to use approved existing installations might not apply to other portions of the fire alarm system. This creates confusion with 9.6.1.3. Section 9.6.1.3 says the same thing and applies to the whole system. I believe the committee should stand on its original action to delete the paragraphs but to use 9.6.1.3 as the justification. It reads with emphasis added: 9.6.1.3 A fire alarm system required for life safety shall be installed, tested, and maintained in accordance with the applicable requirements of NFPA 70, National Electrical Code®, and NFPA 72®, National Fire Alarm Code®, unless it is an approved existing installation, which shall be permitted to be continued in use. _______________________________________________________________101-148 Log #38 SAF-BSF FINAL ACTION: Accept in Principle (9.6.3.10) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-220 RECOMMENDATION: Reconsider the proposal, given the effect that a change of text would take on existing alarm systems which cannot be required to be upgraded to the current requirements of NFPA 72. SUBSTANTIATION: See the above recommendation.

COMMITTEE MEETING ACTION: Accept in Principle Reject proposal 101-220. COMMITTEE STATEMENT: The committee concurs with the TCC action on Proposal 101-220. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-149 Log #39 SAF-BSF FINAL ACTION: Accept in Principle (9.6.7 and 9.6.8) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-228. Existing text needs to be maintained as the occupancy chapters do not have the necessary pointers to mandate the use of 9.6.8 on annunciation zoning given that they reference the current 9.6.7 and not the new 9.6.8.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-228 RECOMMENDATION: Reconsider the proposal, given so as not to force existing alarm systems to be upgraded to the current requirements of NFPA 72. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Maintain the technical committee action on Proposal 101-228 as shown in the Report on Proposals. COMMITTEE STATEMENT: The committee does not intend for existing, approved fire alarm systems to be upgraded to meet the current edition of NFPA 72. The subject is adequately addressed by 4.6.6. The reference to NFPA 72 in 9.6.7.1 is appropriate. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN COMMENT ON AFFIRMATIVE LARRIMER: I agree with the committee action and believe that existing approved fire alarm systems do not have to be upgraded to the new requirement of NFPA 72 due to the existing verbiage found in NFPA 101, 9.6.1.3 as follows: 9.6.1.3 A fire alarm system required for life safety shall be installed, tested, and maintained in accordance with the applicable requirements of NFPA 70, National Electrical Code®, and NFPA 72®, National Fire Alarm Code®, unless it is an approved existing installation, which shall be permitted to be continued in use. _______________________________________________________________101-150 Log #365 SAF-BSF FINAL ACTION: Acccept in Principle (9.6.7 and 9.6.8) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-228. See TCC action on Comment 101-149.SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-228 RECOMMENDATION: Clarify that this new language is not to be applied retroactively to existing fire alarm systems. SUBSTANTIATION: The Life Safety Code is applied retroactively to more than 30,000 hospitals and nursing homes. It is very important that the Code is clear as to what reqirements apply to existing buildings. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No revised language has been proposed. Also see the action on Comment 101-149. Existing, approved systems are adequately addressed by 4.6.6. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-151 Log #40 SAF-BSF FINAL ACTION: Accept in Principle (9.6.7.3) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-229 RECOMMENDATION: Give consideration to Ball’s, Donga’s, Jardin’s, Larrimer’s, and Mundy’s Explanation of Negative so as to make any needed changes. BALL: This would allow a sprinkler system serving up to a six-story building to have a single waterflow switch for alarm annunciation. This appears to conflict with NFPA 72 4.4.6.3. (The building may not have automatic initiating devices that would provide the desired zone information.) DONGA: Buildings and occupancies with an installed sprinkler system in compliance with NFPA 13 and required to have alarm annunciation should be required to comply with the existing requirements of 9.6.7.3. It will assist fire departments in locating the floor of sprinkler activation and hence, will assist in rescue and suppression activities, particularly in buildings with populations not capable of self-preservation.

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Report on Comments — Copyright, NFPA NFPA 101 Sprinkler systems installed in residential occupancies in accordance with the requirements of NFPA 13D and NFPA 13R are required to utilize residential sprinklers. Additionally, NFPA 101 would require smoke alarms in residential occupancies. These elements in conjunction with other mandatory code requirements combine to establish the minimum level of life safety in residential occupancies. This high level of life safety improves the chances for occupants to evacuate or escape prior to the development of untenable conditions. JARDIN: As proposed, the exemption would allow an annunciation zone to consist of multiple stories in multi-story buildings (i.e., bird cage design). The potential impact is counter to the intent of enhancing a responder’s ability to determine and locate the source of a problem in the building. LARRIMER: I disagree with the submitter. This was not to apply to NFPA 13 systems. The intent of the annunciation was to provide a minimum of one zone per floor except for small systems such as NFPA 13D and NFPA 13R systems. Allowing one annunciation zone for an NFPA 13 system would permit a high-rise building to have only one annunciation point for the sprinkler system provided the area of each floor was less than 52,000 sq ft (assuming a light hazard occupancy). I don’t believe that the code would want the fire department to respond to a large building that had a fire alarm activate and the only annunciation that was provided was one zone for the whole building. This would leave the responder possibly following the leaking water up many floors until he came upon the actual sprinklers that were fused. As it is existing, it allows a NFPA 13R system (good up to 4 stories only) and a NFPA 13D system (one and two family dwelling) to have one annunciation point, but it was never intended to allow a multiple story NFPA 13 system to be annunciated with one zone. This is the reason that the NFPA 13 system was not included and should continue to be restricted so that as a minimum, each floor should be equipped with an annunciation zone to help responders whether they be fire department personnel or building maintenance personnel. MUNDY: Committee action on this proposal is not justified and creates further problems in identification of alarm initiation. Expanding of zone quantities to include multiple floors, rather than the single zone per floor presently required, presents a scenario of simplicity where upon responding firefighters and/or other in house responders must spend additional time in locating fire location. Timely access is critical and this proposal presupposes that simply because of sprinkler actuation that fire spread shall be totally contained through actuation of adjacent sprinkler devices. No technical justification is presented. Elimination of additional flow devices is poor cost justification for a delay at critical times. The vote, therefore, is contrary to committee action and in support of action taken on [5000-1109 (Log #819), 55.2.7.3] wherein the Committee rejected a similar proposal. The committee action is inconsistent with action taken in that regard. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-229. COMMITTEE STATEMENT: The committee concurs with the negative comments submitted by committee members Ball, Donga, Jardin, and Larrimer. The rejection of Proposal 101-229 is also consistent with action taken on a similar proposal on NFPA 5000. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: KELLY: Accept proposal 101-229. Rejection of this proposal will increase the cost of the sprinkler system by forcing small buildings to require water flow alarms on each floor. Tall buildings will have the ability to identify the fire floor by activation of the fire alarm system. It is restrictive to force sprinkler systems to perform the function of the fire alarm. This will limit the design option of vertical branch lines (installed in the walls), which are often installed to avoid installing sprinkler piping in freezing areas (for example in attics). If the committee believes that a vertical sprinkler system can be an equivalent alternate arrangement using Section 1.5 then the language in the code should state that by allowing this design option. _______________________________________________________________101-152 Log #217 SAF-BSF FINAL ACTION: Reject (9.7.2.1) _______________________________________________________________ SUBMITTER: Kevin J. Kelly, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-232 RECOMMENDATION: Revise Section 9.7.2.1 dedicated fire protection water tank levels. Revise Section 9.7.2.1 as follows: System components and parameters that shall be monitored shall include, but shall not be limited to, control valves, fire pump power supplies and running conditions, dedicated fire protecti on water tank levels and temperatures, tank pressure, and air pressure on dry-pipe valves. SUBSTANTIATION: This language clarifies and supports the committee statement that these supervision requirements do not apply to combination domestic/fire protection water tanks and are only intended to apply to dedicated fire protection water tanks. This comment is not a technical change but only a clarification of the code which has been misapplied. COMMITTEE MEETING ACTION: Reject

COMMITTEE STATEMENT: The proposed language does not clarify the Code’s intent. The provision is clear as written. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 15 Negative: 2 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: KELLY: The provisions of 9.7.2.1 are not clear as written. We continue to receive questions regarding requirements for water tanks, which are used for both fire protection and other uses. LARRIMER: I disagree with the committee substantiation that the existing text is clear. The submitter was trying to clarify what is required in the code. In both the proposal (private water tank conditions) and the comment (dedicated fire protection water tank), the verbiage clarified that the requirement is not intended to apply to combination tanks that are used for both fire protection and domestic water. The existing verbiage “water tank levels” is not clear and either the comment or proposal should have been accepted. _______________________________________________________________101-153 Log #369 SAF-BSF FINAL ACTION: Reject (9.7.2.1) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-231 RECOMMENDATION: Add new text to read as follows: 13.3.1.7.1 Supervision. Where....receiving facility. Exception No. 1: Existing control valves are not required to be electrically supervised if they are locked open and inspected weekly. Exception No. 2: Existing dry system air pressures are not required to be electrically supervised if the pressure is inspected daily. Exception No. 3: Existing tank water levels are not required to be electrically supervised if inspected weekly. SUBSTANTIATION: Both NFPA 13 and 25 allude to allowing locked or sealed valves. It should be a 1, 101, and 5000 issue, not 13 or 25, to allow or prohibit this. I took the issue farther to address other non-supervised sprinkler equipment that may be unsupervised if inspected frequently. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Where existing buildings require a supervised automatic sprinkler system for life safety purposes, supervision must be accomplished by electrical means to ensure a high degree of reliability. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-154 Log #338 SAF-RES FINAL ACTION: Accept in Principle (9.7.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-343 and 101-349.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-235 RECOMMENDATION: Reasonable inspection testing and maintenance provisions for required NFPA13D sprinkler systems in Board and Care facilities would satisfy the intent of the original proposal. SUBSTANTIATION: Optional installations should have the option whether to be maintained. Required installations as specified by BCF should be required to be maintained. Otherwise, the requirement cannot be assured. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment specifically references required NFPA 13D sprinkler systems in board and care facilities which are not within the scope of the TC on Residential Occupancies. The committee notes comments have been submitted to the TC on Board and Facilities to address this issue. See Comments 101-343 and 101-156. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-155 Log #344 SAF-BSF FINAL ACTION: Accept in Principle (9.7.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-343 and 101-349.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-233 RECOMMENDATION: Reasonable inspection testing and maintenance provisions for required NFPA13D sprinkler systems in Board and Care facilities would satisfy the intent of the original proposal. SUBSTANTIATION: Optional installations should have the option whether to be maintained. Required installations, as specified by BCF. should be required to be maintained. Otherwise, the requirement cannot be assured.

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No revised language has been submitted. The committee notes, however, that comments have been submitted to the Technical Committee on Board and Care Facilities addressing testing and maintenance provisions for required NFPA 13D sprinkler systems in that occupancy. See Comments 101-343 and 101-349. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

_______________________________________________________________101-156 Log #345 SAF-BCF FINAL ACTION: Accept in Principle (9.7.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to add reference to Comment 101-349 so as to read: See the action on Comment 101-343 and 101-349.SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-234 RECOMMENDATION: Reasonable inspection testing and maintenance provisions for required NFPA13D sprinkler systems in Board and Care facilities would satisfy the intent of the original proposal. SUBSTANTIATION: Optional installations should have the option whether to be maintained. Required installations as specified by BCF should be required to be maintained. Otherwise, the requirement cannot be assured. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-343. COMMITTEE STATEMENT: The action on Comment 101-343 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-157 Log #231 SAF-BSF FINAL ACTION: Reject (9.7.6) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-236 RECOMMENDATION: Change the TC action from Reject to Accept in Part. SUBSTANTIATION: The ROP only answered “shutdown vs. impairment” but not other extinguishing systems. Keep the requirement notify the AHJ for other shutdowns. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No new information has been submitted. The committee stands on its previous rejection of Proposal 101-236. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN _______________________________________________________________101-158 Log #313 SAF-FUR FINAL ACTION: Accept in Principle in Part (10.2.1) _______________________________________________________________ SUBMITTER: Kuma Sumathipala, American Forest & Paper Association COMMENT ON PROPOSAL NO: 101-240 RECOMMENDATION: Add new text as follows: 10.1 General 10.1.1 Application. The interior finish, contents, and furnishings provisions set forth in this chapter shall apply to new construction and existing buildings. 10.1.2 Special Definitions. Contents and Furnishings. See 3.3.33 Flashover. See 3.3.79 Interior Finish. See 3.3.112 Interior Ceiling Finish. See 3.3.112.1 Interior Floor Finnish. See 3.3.112.2 Interior Wall Finish. See 3.3.112.3 10.2* Interior Finnish 10.2.1 General. Classification of interior finish materials shall be in accordance with tests made under conditions simulating actual installations, provided that the authority having jurisdiction shall be permitted to establish the classification of any material on which a rating by standard test is not available. Exception 1 : Materials applied, in total thickness of less than 1/28 in. (0.09 cm), directly to the surface of walls or ceilings shall not be considered as interior finish and shall be exempt from tests simulating actural installation if they meet the requirements of Class A interior wall or ceiling finish when tested in accordance with 10.2.3.1 using inorganic reinforced cement board as the substrate material. Exception 2: Wood veneer materials less than 1/28 in. (0.09 cm) in thickness applied directly to the substrate surface of walls or ceilings shall not be considered as interior finish if such materials have surface burning

characteristics no greater than paper of this thickness applied directly to a noncombustible backing in the same manner. SUBSTANTIATION: The 1997 version of NFPA 101 read as: Exception: Materials less than 1/28 in. (0.09 cm) in thickness applied directly to the surface of walls or ceilings shall not be considered as interior finish if such materials have surface burning characteristics no greater than paper of this thickness applied directly to a noncombustible backing in the same manner.” This text was changed for the 2000 edition to require materials less than 1/28” to be Class A when tested according to NFPA 255. During this revision, the caveat that materials less than 1/28” are not considered interior finish was also dropped. • The current wording considers materials that are less than 1/28” and having a Class A rating as interior finish. Such materials could then be applied on any substrate, regardless of the substrate’s flame spread characteristics. This can create hazardous situations not intended by the committee. As such, the caveat that “materials less than 1/28” are not considered interior finish” needs to be reintroduced. • As noted in the current Life Safety Code handbook, the 1997 NFPA 101 wording recognized that thin coverings with surface burning characteristics no greater than that of paper will not significantly affect the fire performance of the basic wall or ceiling material. Thin wood veneers qualified under this exemption given their similarity to the chemical and physical composition of paper. The NFPA 101 2000 wording requires thin wood veneers to be tested according to NFPA 255 before they can be applied on a wall substrate to form an interior finish. Given the variety of wood species available and the varying thickness (from 0.03 cm to 0.08 cm) used on interior finish substrates, this requirement places an unfair financial burden on manufacturers. Thin wood veneers have historically performed well and, as such, should be exempt from the new requirement, intended to evaluate new materials. The text of Exemption 2 is proposed to clarify that wood veneer, applied on a substrate subject to the requirements of Clause 10.2, would be exempt as it was prior to 2000. COMMITTEE MEETING ACTION: Accept in Principle in Part 1. Revise section 10.2.1.2 to read as follows: 10.2.1.2 Materials applied directly to the surface of walls and ceilings in a total thickness of less than 1/28 in (0.9 mm) shall not be considered interior finish and shall be exempt from tests simulating actual installation if they meet the requirements of Class A interior wall or ceiling finish when tested in accordance with 10.2.3 using inorganic reinforced fiber cement board as the substrate material. 2. Do not accept the submitter’s recommended Exception No. 2 to 10.2.1.2. COMMITTEE STATEMENT: 1. The submitter’s recommendation is accepted and an editorial change was made regarding current terminology. 2. The proposed exception was not accepted as it is product specific and does not address the adhesives used in applying the veneer material. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-159 Log #183 SAF-FUR FINAL ACTION: Accept in Principle (10.2.1.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-240 RECOMMENDATION: Rearrange 10.2.1.3 to read: 10.2.1.3 Paneling, wall pads, and crash pads covering 10 percent or more of the area of the wall or of the ceiling to which it is applied; and fixed or movable walls and partitions, applied structurally or for decoration, acoustical correction, surface insulation or other purposes shall be considered interior finish and shall not be considered decorations or furnishings. SUBSTANTIATION: This comment only rearranges the proposed paragraph to clarify what the 10 percent applies to. Fixed or movable walls and partitions are not applied to a wall or a ceiling so the 10 percent would be difficult or impossible to calculate. The Code currently clearly applies the interior finish requirements to be fixed or movable walls and partitions so the 10 percent should not be applied to them. This is consistent with the TCC Action. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-161. COMMITTEE STATEMENT: See committee action and statement on Comment 101-161. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest.

_______________________________________________________________101-160 Log #41 SAF-FUR FINAL ACTION: Accept in Principle (10.2.1.3 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-240 RECOMMENDATION: Clarify what the words “10 percent or more” are meant to modify (that is, does it include fixed or movable walls and partitions, versus wall pads and crash pads).

101-71

Report on Comments — Copyright, NFPA NFPA 101 SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See committee action and statement on Comment 101-161. COMMITTEE STATEMENT: See committee action and statement on Comment 101-161. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. _______________________________________________________________101-161 Log #186 SAF-FUR FINAL ACTION: Accept in Principle (10.2.1.3 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-240 RECOMMENDATION: Revise text to read: 10.2.1.3* Fixed or movable walls and partitions, paneling, wall pads and crash pads, applied structurally or for decoration, acoustical correction, surface insulation or other purposes shall be considered interior finish if they cover 10% or more of the area of the wall or of the ceiling to which it is applied, and shall not be considered decorations or furnishings. A.10.2.1.3 Such partitions include wash room water closet partitions. The 10 percent of the area is not intended to involve the thickness of the wall or of the partitions, paneling, wall pads or crash pads. SUBSTANTIATION: This clarification is intended to resolve the concern expressed by the Technical Correlating Committee. COMMITTEE MEETING ACTION: Accept in Principle 1. Revise section 10.2.1.3 to read as follows: 10.2.1.3 Fixed or movable wall and partitions, paneling, wall pads and crash pads, applied structurally or for decoration, acoustical correction, surface insulation or other purposes shall be considered interior finish if they cover 10% or more of the area of the wall or of the ceiling to which it is applied, and shall not be considered decorations or furnishings. 2. Do not accept the submitter’s proposed revisions to A.10.2.1.3. COMMITTEE STATEMENT: The committee is concerned that 10 percent of a large wall could result in a substantial amount of paneling, wall pad and crash pad material. In addition, even lesser amounts of these types of materials could produce a significant hazard depending upon where the materials are applied. The committee also notes that wall pads and crash pads are normally comprised of low density foams and not the high density foams that are permitted for use as interior trim under certain conditions. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. _______________________________________________________________101-162 Log #207 SAF-FUR FINAL ACTION: Accept in Principle (10.2.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – To the end of 10.2.3 add “or UL 723, Standard Test Method of Surface Burning Characteristics of Building Materials.” See Comment 101-3 and101-14.SUBMITTER: Bob Eugene, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO: 101-241 RECOMMENDATION: Revise paragraph 10.2.3 to read as follows: 10.2.3* Interior Wall or Ceiling Finish Testing and Classification. Interior wall or ceiling finish that is required elsewhere in this Code to be Class A, Class B, or Class C shall be classified based on test results from NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials, or ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Materials or ANSI/UL 723, Standard Test Method of Surface Burning Characteristics of Building Materials, except as indicated in 10.2.3.1 or 10.2.3.2. SUBSTANTIATION: This adds the reference to the equivalent ANSI standard in accordance with the NFPA Manual of Style and the TCC direction on Proposal 101-5. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action and statement on Comments 101-3 and 101-15. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-163 Log #42 SAF-FUR FINAL ACTION: Accept in Principle (10.2.3 and A.10.2.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-162.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-241 RECOMMENDATION: Give consideration to adding UL 723 as an equivalent to NFPA 255 and ASTM E 84 as addressed in Proposal 101-5, so as to make any needed changes. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action required.

COMMITTEE STATEMENT: The committee gave consideration to the recommendation. See action and committee statement on Comments 101-3 and 101-15. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 COMMENT ON AFFIRMATIVE GANDHI: I do not fully agree with the committee action as UL 723 is technically equivalent to NFPA 255 with respect to calibration, test procedures (including mounting methods), and calculations. Please note that UL 723 was last revised in August 2003, when it was reissued as an ANSI document. _______________________________________________________________101-164 Log #43 SAF-FUR FINAL ACTION: Accept in Principle (10.2.3.2 and 10.2.3.7) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-243 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See committee action on Comment 101-165. COMMITTEE STATEMENT: See committee action on Comment 101-165. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-165 Log #187 SAF-FUR FINAL ACTION: Accept (10.2.3.2 and 10.2.3.7) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-243 RECOMMENDATION: Accept this proposal in part in principle and make the following change to the code text. 10.2.3.7.3 The following conditions shall be met when using the test protocol of NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth: (1) Flames shall not spread to the ceiling during the 40-kW exposure. (2) During the 160-kW exposure, the following criteria shall be met: (a) Flame shall not spread to the outer extremities of the sample on the 2440 mm x 3660 mm (96 in. x 144 in.) wall. (b) Flashover shall not occur. (3) The peak heat release rate throughout the test shall not exceed 800 kW. (4) For new installations, the total smoke released throughout the test shall not exceed 1000 m2. SUBSTANTIATION: An analysis of data from room corner tests shows that, in general, interior finish materials that do not flash over the room in the room corner test tend to have peak heat release rates (Pk RHR) under 400 kW if they have a flame spread index (FSI) values under 25. See the Table that follows.

FSI Pk RHR (kW) FSI Pk RHR (kW)ASTM E 84 Room Corner Test ASTM E 84 Room Corner Test

15 195 Old Textile Wall Covering Data (1986)27 359 Cases Where E 84 is Poor Predictor *10 40 25 684 (672˚C)70 1460 15 5771 (929˚C)15 128 15 928 (763˚C)15 153 25 1166 (785˚C)0 400 35 Cases Where E 84 Is not a Poor

Predictor #15 22 15 310 (388˚C)28 120 15 182 (448˚C)25 106 15 297 (369˚C)200 930 25 249 (477˚C)200 945 25 309 (578˚C)200 1070200 1075 Textile test used: NFPA 265 screening25 125

< 25 234 * The data in parentheses are maximum average ceiling temperatures. ASTM E 84 is a poor predictor when these materials (all Class A) caused flashover (at least in terms of average ceiling temperature) in the NFPA 265 screening test, as shown by the data.# The data in parentheses are maximum average ceiling temperatures. ASTM E 84 is not a poor predictor when these materials (all Class A) caused peak heat release rates of less than 400 kW; low enough to be reasonably safe materials.

101-72

Report on Comments — Copyright, NFPA NFPA 101 The following materials were tested in the much more severe ISO 9705 room corner test (where the ignition burner is at 100 kW for 10 min and then at 300 kW for a further 10 min):

FSI in ASTM E 84 Pk RHR (kW) in ISO 9705 Room Corner Test22 120 (walls and ceiling)< 25 54 (ceiling only, TSR: 145 m2)< 25 160 (ceiling only, TSR: 125 m2)< 25 154 (walls and ceiling, TSR: 219 m2)22 20 (@ 10 min; 548 @ 11 min) (walls & ceiling)22 110 (ceiling only; TSR: 145 m2)< 25 517 (walls and ceiling)< 25 58 (ceiling only, TSR: 151 m2)

Experience in the past has long shown that materials with FSI values of less than 25 when tested in accordance with ASTM E 84, particularly if they are thermally thin materials, such as wall coverings, cannot be guaranteed to be safe enough to be permitted unrestricted use. Similarly, experience continues to indicate that foam plastic insulation materials should not be permitted to be used as interior finish exposed (or covered by other than a thermal barrier) unless they have been found to perform satisfactorily using a room-corner test (or other full scale diversified test) in which the material performs truly and cannot have an incorrect “pass” due to the material not being capable of supporting itself in position during the test and generating incorrect information. The approach for foam plastic insulation is a good one and should be continued. Analyses of the data from room corner tests conducted in various series of studies reinforces the concept that a Class A FSI value is not a guarantee that a thermally thin material is safe as an interior finish wall covering and should not be permitted to be used in an unrestricted fashion. Similarly, however, analysis of a significant number of room corner test data and Steiner tunnel test also shows that those materials that are not thermally thin and achieve a Flame Spread Index rating of 25 or less (Class A rating or close to it) in the Steiner tunnel test would tend to produce a peak rate of heat release lower than 400 kW. The code proposal NFPA 101-243 recommended the following: (1) Materials that release over 600 kW in the room corner test, but still do not reach flashover, and have a moderate smoke release (Total Smoke Released less than 1,000 m2) should be considered suitable for use where a Class B classification in accordance with NFPA 255 or ASTM E 84 is required. (2) On the other hand, materials that release 600 kW or less and have a Total Smoke Released of less than 1,000 m2 shall be permitted to be used wherever a Class A classification in accordance with NFPA 255 or ASTM E 84 is required. I am well aware that NFPA 255 or ASTM E 84 is a much poorer test than NFPA 286, but I have been shown a significant amount of proprietary data where manufacturers found that their products could be made less expensive (and somewhat less fire safe) if they needed to simply meet the no flashover requirements from testing using NFPA 286 instead of testing to ASTM E 84 and getting a Class A, because less fire retardance was needed. In fact, it is rare for manufacturers to test their products using NFPA 286 if they just need a Class B or Class C in the ASTM E 84 tunnel, so that the real comparison is with Class A. Thus, for this comment, I took a safer approach and recommend simply to lower the peak rate of heat release permitted for a material to pass NFPA 286 and be allowed to substitute for a Class A material in ASTM E 84, from “no flashover” to 800 kW. The criterion was set at 800 kW to ensure materials that have already been tested are not unnecessarily penalized, since it is likely that most materials will be in the correct range. With regard to the comments made by Dr. Clarke: (1) the present code uses peak rate of heat release as a criterion for pass/fail, with the criterion being flashover (namely 1,000 kW), and this comment recommends dropping that number to 800 kW. (2) if a material generates heat release exceeding 600 kW and does not even reach a Class B in the Steiner tunnel, then the need for the change is even greater than I believe it is. The data demonstrates that materials that yield over 400 kW when tested with NFPA 286 are worse in fire performance than materials that meet a Class A in the Steiner tunnel, and yet they are allowed to be considered equivalent to a Class A material. Therefore, it is critical to ensure that materials that release abundant heat in the NFPA 286 test (but just under 1,000 kW) should not be considered fully safe (which is what the code implicitly considers Class A materials). With regard to the comments made by Mr. Talley, it is necessary to point out that neither the original proposal nor this comment require NFPA 286 testing: NFPA 286 testing is already a code requirement as an alternative to NFPA 255/ASTM E 84. The code proposal (and this comment) deal with the pass/fail criteria for NFPA 286 testing. Thus, the economic analysis made does not apply. With regard to the comments by Mr Fitch, this comment does not state that ASTM E 84/NFPA 255 is an adequate predictor of fire performance of interior finish: it is not. However, what is, hopefully, clear is that materials that release high heat in the room corner test (even if they just miss flashing over the room) should not be considered fully safe (which is what the code implicitly considers Class A materials).

With regard to the comments by Mr Lathrop, this comment modifies the proposal sufficiently to retain a single class or “pass” with NFPA 286, while still eliminating the poorer performers.COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. _______________________________________________________________101-166 Log #44 SAF-FUR FINAL ACTION: Accept in Principle (10.2.4.1 and 10.2.4.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-246 RECOMMENDATION: Give consideration to Fitch’s Comment on Affirmative and the apparent (but not identified) change to the subsection title, so as to make any needed changes. FITCH: In the proposed 10.2.4.2 it should read “Expanded Vinyl Wall and Textile Ceiling Materials.” SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Do not use the term “textile” in the proposed title of section 10.2.4.2 as indicated in the ROP. The title will read as follows: “Expanded Vinyl Wall and Expanded Textile Vinyl Ceiling Materials” COMMITTEE STATEMENT: Editorial correction. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-167 Log #45 SAF-END FINAL ACTION: Accept in Principle (10.2.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that the action on this comment is not meant to affect that on Comment 101-169.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-250 RECOMMENDATION: Give consideration to whether an exemption is needed to proposed 10.2.5.3 on posters given the provisions of 14.7.4.3 / 15.7.4.3 / 16.7.4.3 / 17.7.4.3 permit 50 percent wall area coverage in sprinklered buildings, so as to make any needed changes. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Further revise the action of ROP Proposal 101-250 as follows: 10.2.5.3 Bulletin Boards and Posters. 10.2.5.3.1 Bulletin ... they are applied. 10.2.5.3.2 The provision of 10.2.5.3.1 shall not apply to artwork and teaching materials in sprinklered educational or day-care occupancies in accordance with 14.7.4.3(2), 15.7.4.3(2), 16.7.4.3(2) or 17.7.4.3(2). COMMITTEE STATEMENT: The action maintains the staus quo of permitting 50 percent coverage by artwork and teaching materials in sprinklered educational and day-care occupancies. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-168 Log #302 SAF-FUR FINAL ACTION: Accept in Part (10.2.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified, editorially, to add the word “requirements” so the inserted phrase reads: “interior wall finish requirements for its location or the.”SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-250 RECOMMENDATION: Revise text as follows: 10.2.5.2 Wall base: Interior floor trim material used at the junction of the wall and the floor to provide a functional or decorative border, and not exceeding 6 in. 1 ft ( 152 304 mm) in height, shall meet the interior wall finish for its location or the requirements for Class II interior floor finish...” no further changes.

101-73

Report on Comments — Copyright, NFPA NFPA 101 SUBSTANTIATION: This comment makes two changes. First it clarifies that this is an “exception” and that traditional interior wall finish can be used. Second it allows the floor finish to go higher on the wall. There has been no justification to limit this to 6 in. In fact, this could probably be allowed up to 4 ft without any problems. Note that health care has allowed reductions in interior finish as high as 4 ft for many years with no problems. COMMITTEE MEETING ACTION: Accept in Part 1. Accept the submitter’s recommendation to add the phrase “interior wall finish for its location or the”. 2. Do not accept the submitter’s recommendation to revise “6 inches” to read “1 ft.” COMMITTEE STATEMENT: Insufficient technical justification has been provided supporting the submitter’s recommendation to increase the wall base height from 6 inches to 1 foot. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-169 Log #121 SAF-FUR FINAL ACTION: Accept in Principle (10.2.5.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that the action on this comment is not meant to affect that on Comment 101-167.SUBMITTER: Eddie Phillips, Southern Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-250 RECOMMENDATION: Add a new annex note to read: The term “bulletin board” is not intended to be applied to paper or cardboard often referred to as “bulletin paper”. The latter is often directly applied to walls in classrooms and corridors with artwork or teaching materials applied to the “bulletin paper”. The use of “bulletin paper” increases the risk of flame spread, fuel loading and heat release problems. SUBSTANTIATION: The proposed text better clarifies how and what materials can be applied to the walls. COMMITTEE MEETING ACTION: Accept in Principle Revise 10.2.5.3 to read as follows: “10.2.5.3 Bulletin Boards, and Posters and Paper. Bulletin boards and posters and paper attached directly ...” COMMITTEE STATEMENT: The committee believes the editorial change meets the intent of the submitter. The term bulletin paper is not specifically defined by the submitter or the code. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-170 Log #120 SAF-FUR FINAL ACTION: Reject (10.2.5.3.1 (New) ) _______________________________________________________________ SUBMITTER: Eddie Phillips, Southern Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-250 RECOMMENDATION: Add a new section to read: 10.2.5.3.1 Bulletin boards and posters outlined in 10.2.5.3.1 are not permitted in corridors. SUBSTANTIATION: Based on the committee substantiation materials applied to walls can effect flame spread, fire loading and heat release rates affecting life safety. The corridor is no place to have these material that could impact a safe evacuation from the building or area. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No supporting data has been provided regarding the associated hazard introduced by the submitter. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-171 Log #157 SAF-FUR FINAL ACTION: Accept in Principle in Part (10.2.6.1) _______________________________________________________________ SUBMITTER: Joseph T. Holland, Hoover Treated Wood Products COMMENT ON PROPOSAL NO: 101-251 RECOMMENDATION: Revise text to read as follows: The required flame spread or smoke development classification of existing surfaces of walls, partitions, columns, and ceilings shall be permitted to be secured by applying approved fire-retardant coatings to surfaces having higher flame spread ratings than permitted. Such treatments shall be listed and labeled for application the material to which it is applied. comply with the requirements of NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials. SUBSTANTIATION: To clarify our original reason, there seems to be a misunderstanding as to which material needs to be labeled and listed. Our intention was to require the brush-on or spray-applied coating to be listed and labeled for application to the material to which it is being applied. A review of listings in the UL directory shows that most coatings are listed for application to Douglas-Fir lumber. Some have been tested for application to some types of ceiling tiles, etc. Our concern is that the coatings are being applied to material for which they have not been tested. Therefore, the coatings would be listed and labeled in accordance with the NFPA definitions.

COMMITTEE MEETING ACTION: Accept in Principle in Part 1. Accept the submitter’s proposed recommendation to add the phrase “listed and labeled for application the material to which it is applied” with editorial changes as noted below. 2. Add the provision that requires the treatment to be tested as noted below. 3. Do no delete reference to NFPA 703. Section 10.2.6.1 will be revised to read as follows: 10.2.6.1* The required flame spread or smoke development classification of existing surfaces of walls, partitions, columns, and ceilings shall be permitted to be secured by applying approved fire-retardant coatings to surfaces having higher flame spread ratings than permitted. Such treatments shall be tested, or shall be listed and labeled for application to the material to which they are applied, and shall comply with the requirements of NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials. COMMITTEE STATEMENT: The committee notes that the treated product may not be listed but that it must be tested. Timing of the testing and listing process necessitates this change. A treated product may have been tested but not yet listed when being considered for use in the field. Reference to NFPA 703 was not deleted because of the testing requirements which were added. Editorial changes were also incorporated. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-172 Log #378 SAF-FUR FINAL ACTION: Accept in Principle (10.3.1) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: Revise text to read as follows: 20.1.4.3.2* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the flame propagation performance criteria contained in be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. A.20.1.4.3.2 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: This proposal addresses four issues: 1. Terminology: the correct terminology is flame spread index rather than flame spread classification. 2. Also, the correct terminology for NFPA 701 is that a textile “meets the flame propagation performance criteria contained in NFPA 701” rather than flame retardant. 3. Also, textile wall covering need to be tested in NFPA 255 and be in a sprinklered environment, per NFPA 101. 4. Finally, NFPA 265 is not applicable to films or any material other than textiles; NFPA 286 must be used for such materials. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Accept in Principle See Committee Comment 101-174a (Log #CC526). COMMITTEE STATEMENT: See Committee Comment 101-174a (Log #CC526). NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-173 Log #379 SAF-FUR FINAL ACTION: Accept in Principle (10.3.1) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: Revise text to read as follows: 20.23.3.2* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the flame propagation performance criteria contained in be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films.

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Report on Comments — Copyright, NFPA NFPA 101 A.20.23.3.2 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: This proposal addresses four issues: 1. Terminology: the correct terminology is flame spread index rather than flame spread classification. 2. Also, the correct terminology for NFPA 701 is that a textile “meets the flame propagation performance criteria contained in NFPA 701” rather than flame retardant. 3. Also, textile wall covering need to be tested in NFPA 255 and be in a sprinklered environment, per NFPA 101. 4. Finally, NFPA 265 is not applicable to films or any material other than textiles; NFPA 286 must be used for such materials. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Accept in Principle See Committee Comment 101-174a (Log #CC526). COMMITTEE STATEMENT: See Committee Comment 101-174a (Log #CC526). NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-174 Log #380 SAF-FUR FINAL ACTION: Accept in Principle (10.3.1) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: Revise text to read as follows: 20.4.2.5.2* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the flame propagation performance criteria contained in be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. A.20.4.2.5.2 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: This proposal addresses four issues: 1. Terminology: the correct terminology is flame spread index rather than flame spread classification. 2. Also, the correct terminology for NFPA 701 is that a textile “meets the flame propagation performance criteria contained in NFPA 701” rather than flame retardant. 3. Also, textile wall covering need to be tested in NFPA 255 and be in a sprinklered environment, per NFPA 101. 4. Finally, NFPA 265 is not applicable to films or any material other than textiles; NFPA 286 must be used for such materials. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Accept in Principle See Committee Comment 101-174a (Log #CC526). COMMITTEE STATEMENT: See Committee Comment 101-174a (Log #CC526).

NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-174a Log #CC526 SAF-FUR FINAL ACTION: Accept (10.3.1, A.10.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to delete from A.10.3.1 the parenthetical phrase “(with the appropriate use of sprinklers)” as it confuses more than helps.SUBMITTER: Technical Committee on Furnishings and Contents COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: 1. Revise section 10.3.1 to read as follows: 10.3.1 Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the fire flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. 2. Revise the first paragraph of section A.10.3.1 to read as indicated below. Do no make any changes to the second paragraph of section A.10.3.1. A.10.3.1 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: 1. Editorial correction. 2. Editorial corrections and proper reference to NFPA 265 and NFPA 286 was provided in the annex with respect to films. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-175 Log #155 SAF-FUR FINAL ACTION: Accept in Principle (10.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that Comment 101-176 has the effect of modifying this comment by removing from the lead-ins to 10.3.2.1 (1) and (2) the phrase “Where required by the applicable provisions of this Code” and that is the issue raised by Comments 101-175a and 101-175b. Comment 101-175a and 101-175b further revise the action on this comment to permit an occupancy chapter to exempt its occupancy from the requirement if such exemption specifically appears in the occupancy chapter. This option is being exercised by various occupancy chapters via comment 101-226a, 101-237a, 101-239a, 101-267a, 101-285a, 101-298, 101-314, 101-320, 101-330, 101-361, 101-398, 101-406 and 101-410.SUBMITTER: Whitney Davis, Charter Davis COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Revise text to read as follows: 10.3.2* Smoldering ignition of upholstered furniture and mattresses. 10.3.2.1 Upholstered furniture. Where required by the applicable provisions of this Code, upholstered Upholstered furniture and mattresses shall be resistant to a cigarette ignition (that is, smoldering) in accordance with one of the following: (1) Where required by the applicable provisions of this Code, the components of the upholstered furniture, unless located n rooms or spaces protected by an approved automatic sprinkler system, shall meet the requirements for Class I when tested in accordance with NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture. (2) Where required by the applicable provisions of this Code, mocked-up composites of the upholstered furniture, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall have a char length not exceeding 38 mm (1 1/2 in.) when tested in accordance with NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes. 10.3.2.2* Mattresses (3) Where required by the applicable provisions of this Code, mattresses, unless located in rooms or spaces protected by an approved automatic sprinkler system, Mattresses shall have a char length not exceeding 51 mm (2 in.) when tested in accordance with Part 1632 of the Code of Federal Regulations 16. SUBSTANTIATION: I don’t want to repeat all the arguments I gave at the proposal stage, on Proposal 101-269, for the need for fire safety of mattresses and upholstered furniture, although they are still valid. However, it is critical that safe upholstered furniture and safe mattresses be used wherever they are required by the occupancies committees (which right now seems to be only in health care, board and care and detention occupancies) and not be traded off because of sprinklers. I feel very upset that lives of innocent potential victims

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Report on Comments — Copyright, NFPA NFPA 101 are threatened by replacing safe upholstered furniture and mattresses with “standard” upholstered furniture and mattresses, when it is well known that these “standard” items produce incredibly high levels of heat and smoke and toxic products. We also know that it is unsafe to put “all of one’s eggs in a single basket”, since it is not unknown for sprinkler systems to fail, and when they fail, we are left with a massive fire from the furniture or mattress. It is pretty much immaterial whether the upholstered furniture components are tested by the UFAC test (NFPA 260) or the upholstered furniture mock-up is tested by the NBS mock-up test (or BIFMA test, NFPA 261). The critical issue is that the upholstered furniture be cigarette ignition resistant. It is doubly absurd that upholstered furniture be allowed to be used without resisting cigarette ignition when the upholstered furniture industry (as represented by either the Upholstered Furniture Action Council, UFAC, for residential furniture, or the Business and Institutional Furniture Manufacturing Association, BIFMA, for contract furniture) promotes the requirement that all of their furniture must be cigarette-ignition resistant. There is a federal law that requires mattresses to be cigarette ignition resistant. If the code does not approve the change requiring all mattresses to be cigarette ignition resistant, the code is promoting the use of mattresses in high risk environments that are illegal for sale in the United States. The State of California already requires that all upholstered furniture and mattresses (including residential ones) sold for use in the state meet cigarette ignition resistance and has done so for many years. It is really unreasonable that upholstered furniture or mattresses could be introduced into high risk occupancies and be so unsafe that they could not be sold in the State of California for residential use. This comment differs from my previous comment in that I hope that the occupancy committees reconsider the concept of exempting some upholstered furniture in high risk occupancies from having to meet the same requirements for cigarette ignition resistance that the upholstered furniture industry recommends all of its members to comply with. COMMITTEE MEETING ACTION: Accept in Principle 1. Revise 10.3.2 to read as follows: 10.3.2* Smoldering ignition of upholstered furniture and mattresses. 10.3.2.1 Upholstered furniture. Where required by the applicable provisions of this Code, Newly introduced upholstered furniture and mattresses shall be resistant to a cigarette ignition (that is, smoldering) in accordance with one of the following: (1) Where required by the applicable provisions of this Code, the components of the upholstered furniture, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall meet the requirements for Class I when tested in accordance with NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture, or with ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture. (2) Where required by the applicable provisions of this Code, mocked-up composites of the upholstered furniture, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall have a char length not exceeding 38 mm (1 1/2 in.) when tested in accordance with NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes, or with ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies. 10.3.2.2* Mattresses (3) Where required by the applicable provisions of this Code, mattresses, unless located in rooms or spaces protected by an approved automatic sprinkler system, Newly introduced mattresses shall have a char length not exceeding 51 mm (2 in.) when tested in accordance with Part 1632 of the Code of Federal Regulations 16. 2. Revise A.10.3.2 to read as follows: A.10.3.2 A.10.3.2.1 The Class I requirement associated with testing per NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture or with ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture and; the char length of not more than 38 mm (1.5 in.) required with testing per NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes or with ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies; and the char length of not more than 51 mm (2 in.) required in FF4-72, Standard for the Flammability of Mattresses, are indicators that the furniture item or mattress is resistant to a cigarette ignition. Although rooms or spaces protected by an approved automatic sprinkler system are exempt from cigarette ignition resistance testing, a A fire that smolders for an excessive period of time without flaming can reduce the tenability within the room or area of fire origin without developing the temperatures necessary to operate automatic sprinklers. The test results from NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture, or from ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture, and

NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes, or from ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies, are suitable for classification purposes but should not be used as input into fire models, because they are not generated in units suitable for engineering calculations. A.10.3.2.2 The char length of not more than 51 mm (2 in.) required in FF4-72, Standard for the Flammability of Mattresses, is an indicator that the mattress is resistant to a cigarette ignition. A.10.3.2(3) Regardless of sprinkler protection provided, U.S. federal regulations require mattresses in the United States to comply with 16 CFR 1632 and the fire test in FF4-72, Standard for the Flammability of Mattresses. Also, add ASTM E 1352 and ASTM E 1353 to Chapter 2 on mandatory references and to Annex B on Informational references. COMMITTEE STATEMENT: The submitter’s recommendations were accepted. In addition, the committee intends that the provisions only apply to newly introduced upholstered furniture and mattresses. References to the ASTM standards were added as the committee considers these documents equivalent to the NFPA standards identified. The annex was updated to reflect the renumbering changes. Also see the substantiation for Comment 101-176 with regard to the references to the ASTM standards and the revision of the the Annex material. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. COMMENT ON AFFIRMATIVE LATHROP: Since this is an improvement over the ROC we are voting affirmatively. However, we strongly encourage the TCC to change this from “newly introduced” to “new.” As pointed out by the Committee on Mercantile and Business Occupancies, the “newly introduced” concept would have significant problems with used furniture or “after market” furniture. It would also create problems with any furniture moved into the building by a new tenant. It may be advantageous to add an annex note clarifying that for this requirement “new” means newly manufactured furniture or furniture not previously used. In the future, we believe that the TCC should determine if it is desirable to have this material in the Code at all. It is not practical for fire marshals and similar AHJs to enforce this type of provision. It is more for purchasing agents. _______________________________________________________________101-175a Log #CC352 SAF-END FINAL ACTION: Accept (10.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that it is permitting the action on this comment to go forward. See Comment 101-175.SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Revise the text that results from the combination of actions on Comment 101-175 and Comment 101-176 as follows: 10.3.2.1 Upholstered Furniture. Newly introduced upholstered furniture, except as otherwise permitted by Chapters 12 through 42, shall be resistant to a cigarette ignition in accordance with one of the following: ... 10.3.2.2 Mattresses. Newly introduced mattresses, except as otherwise permitted by Chapters 12 through 42, shall have a char length not exceeding 2 in. (51 mm) when tested... SUBSTANTIATION: The SAF-FUR furnishings committee has not provided adequate substantiation to make cigarette ignition resistance a requirement for newly introduced upholstered furniture and mattresses in all occupancies. An argument like “the Feds require it anyway for NEW mattresses; and the majority of U.S. upholstered furniture manufacturers voluntarily do so” is inadequate. “Newly introduced” upholstered furniture might be existing furniture moved from an existing school to a new school; or in a day-care it might be a piece of furniture given to the operator of the day-care home. Smoking is not permitted in educational occupancies and day-care occupancies, so the concern for cigarette ignition resistance is minor. The phrase “ except as otherwise exempted by Chapters 12 through 42 ” will permit the occupancy chapters to exempt themselves from the requirement, or place conditions such as an exemption for sprinklered buildings. For example, see Comment 101-239a and Comment 101-237a. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-175b Log #CC281 SAF-AXM FINAL ACTION: Accept (10.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that it is permitting the action on this comment to go forward. See Comment 101-175.SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Revise the text that results from the combination of actions on Comment 101-175 and Comment 101-176 as follows: 10.3.2.1 Upholstered Furniture. Newly introduced upholstered furniture, except as otherwise permitted by Chapters 12 through 42, shall be resistant to a cigarette ignition in accordance with one of the following: ... 10.3.2.2 Mattresses. Newly introduced mattresses, except as otherwise permitted by Chapters 12 through 42, shall have a char length not exceeding 2 in. (51 mm) when tested... SUBSTANTIATION: The SAF-FUR furnishings committee has not provided adequate substantiation to make cigarette ignition resistance a requirement for newly introduced upholstered furniture and mattresses in all occupancies. An argument like “the Feds require it anyway for NEW mattresses; and the majority of U.S. upholstered furniture manufacturers voluntarily do so” is inadequate. “Newly introduced” upholstered furniture might be existing furniture moved from one building to another. The proposed requirement would be difficult to meet or enforce in theaters where props change from show to show. Smoking is prohibited in many assembly occupancies. The phrase “ except as otherwise exempted by Chapters 12 through 42 ” will permit the occupancy chapters to exempt themselves from the requirement. For example, see Comment 101-226a. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-176 Log #190 SAF-FUR FINAL ACTION: Accept in Principle (10.3.2 and A.10.3.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that Comments 101-175a and 101-175b further revise the action on this comment. See also Comment 101-175.SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Accept this proposal in part in principle and make the following changes: 10.3.2* Cigarette Ignition of Upholstered Furniture and Mattresses. Where required by the applicable provisions of this Code, upholstered furniture and mattresses 10.3.2.1* Upholstered furniture shall be resistant to ignition by a cigarette ignition (that is, smoldering) in accordance with either one of the following: (1) Where required by the applicable provisions of this Code, the The components of the upholstered furniture, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall meet the requirements for Class I when tested in accordance with NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture or with ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture. (2) Where required by the applicable provisions of this Code, mocked-up Mocked-up composites of the upholstered furniture, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall have a char length not exceeding 38 mm (1-1/2 in.) when tested in accordance with NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes or with ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies. 10.3.2.2* Mattresses (3)* Where required by the applicable provisions of this Code, mattresses, unless located in rooms or spaces protected by an approved automatic sprinkler system, shall have a char length not exceeding 51 mm (2 in.) when tested in accordance with Part 1632 of the Code of Federal Regulations 16. A.10.3.2 A.10.3.2.1 The Class I requirement associated with testing per NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture or with ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture and; the char length of not more than 38 mm (1.5 in.) required with testing per NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes or with ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies; and the char length of not more than 51 mm (2 in.) required in FF4-72,

Standard for the Flammability of Mattresses, are indicators that the furniture item or mattress is resistant to a cigarette ignition. Although rooms or spaces protected by an approved automatic sprinkler system are exempt from cigarette ignition resistance testing, a A fire that smolders for an excessive period of time without flaming can reduce the tenability within the room or area of fire origin without developing the temperatures necessary to operate automatic sprinklers. The test results from NFPA 260, Standard Methods of Tests and Classification System for Cigarette Ignition Resistance of Components of Upholstered Furniture, or from ASTM E 1353, Standard Test Methods for Cigarette Ignition Resistance of Components of Upholstered Furniture, and NFPA 261, Standard Method of Test for Determining Resistance of Mock-Up Upholstered Furniture Material Assemblies to Ignition by Smoldering Cigarettes, or from ASTM E 1352 Standard Test Method for Cigarette Ignition Resistance of Mock-Up Upholstered Furniture Assemblies, are suitable for classification purposes but should not be used as input into fire models, because they are not generated in units suitable for engineering calculations. A.10.3.2.2 The char length of not more than 51 mm (2 in.) required in FF4-72, Standard for the Flammability of Mattresses, is an indicator that the mattress is resistant to a cigarette ignition. A.10.3.2(3) Regardless of sprinkler protection provided, U.S. federal regulations require mattresses in the United States to comply with 16 CFR 1632 and the fire test in FF4-72, Standard for the Flammability of Mattresses. Also, add ASTM E 1352 and ASTM E 1353 to Chapter 2 on mandatory references and to Annex B on Informational references. SUBSTANTIATION: The State of California already requires that both residential and high risk upholstered furniture and mattress components used in the state meet smoldering (cigarette) ignition resistance: CA TB 106, CA TB 116, CA TB 117). The trade associations for the upholstered furniture industry (i.e. AFMA and UFAC, for residential furniture, and BIFMA, for contract furniture) and for the mattress industry (SPSC) promote the requirement that all of their products must be cigarette-ignition resistant. The Federal Government requires mattresses to be cigarette-ignition resistant (per CFR 1632). It seems absurd that the Life Safety Code promotes the use of upholstered furniture or mattresses in high risk occupancies that are not cigarette-ignition resistant (and, in the case of mattresses, are illegal for use in the United States). NFPA 260 (ASTM E 1353, UFAC test) is one way of assessing cigarette ignition resistance and NFPA 261 (ASTM E 1352, BIFMA test) is an alternative way, but both generate fairly similar results. In both cases, materials (or mock-ups) that do well in the test are pretty much cigarette resistant. It is unnecessary, therefore, to duplicate the testing, since what matters is that the upholstered furniture item be cigarette ignition resistant. The ASTM standards are virtually equivalent to the NFPA standards. CPSC has issued a federal law that requires mattresses to be cigarette ignition resistant in the 1970s. It would be absurd for the Life Safety Code to continue promoting the use of mattresses in high risk environments in other countries where the code may be used that are illegal for sale in the United States. The changes to the annex are to create consistency with the elimination of the sprinkler trade-offs in the body of the standard, and with the altered language.COMMITTEE MEETING ACTION: Accept in Principle 1. In 10.3.2.1(1) and 10.3.2.1(2), delete the phrase “Where required by the applicable provisions of this Code” as recommended by the submitter. 2. For other proposed changes recommended by the submitter, see proposed changes to 10.3.2 and A.10.3.2 as indicated in Comment 101-175. COMMITTEE STATEMENT: 1. The committee agrees with the submitter’s recommendation and substantiation to require all upholstered furniture to be in compliance with either NFPA 260, NFPA 261, ASTM E 1352 and ASTM E 1353. The committee further notes that it agrees with the submitter’s substantiation that the majority of upholstered furniture manufacturers require their products to be resistant to smoldering ignition. 2. These changes as proposed by the submitter are in conjunction with the changes indicated in Comment 101-175. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. _______________________________________________________________101-177 Log #154 SAF-FUR FINAL ACTION: Reject (10.3.3 and 10.3.4) _______________________________________________________________ SUBMITTER: Whitney Davis, Charter Davis COMMENT ON PROPOSAL NO: 101-269 RECOMMENDATION: Revise text to read as follows: 10.3.3* Where required by the applicable provisions of this Code, upholstered furniture, unless the furniture is located in a building protected throughout by an approved automatic sprinkler system, shall have limited rates of heat release when tested in accordance with ASTM E 1537, Standard Method for Fire Testing of Real Scale Upholstered Furniture Items, as follows: (1) The peak rate of heat release for the single upholstered furniture item shall not exceed 250 kW. (2) The total energy released by the single upholstered furniture item during the first 5 minutes of the test shall not exceed 40 MJ. 10.3.4* Where required by the applicable provisions of this Code, mattresses, unless the mattress is located in a building protected throughout by an approved

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Report on Comments — Copyright, NFPA NFPA 101 automatic sprinkler system, shall have limited rates of heat release when tested in accordance with ASTM E 1590, Standard Method for Fire Testing of Real Scale Mattresses, as follows: (1) The peak rate of heat release for the mattress shall not exceed 250 kW. (2) The total energy released by the mattress during the first 5 minutes of the test shall not exceed 40 MJ. SUBSTANTIATION: I don’t want to repeat all the arguments I gave at the proposal stage, although they are still valid. However, it is critical that safe upholstered furniture and safe mattresses be used wherever they are required by the occupancies committees (which right now seems to be only in health care, board and care and detention occupancies) and not be traded off because of sprinklers. I feel very upset that lives of innocent potential victims are threatened by replacing safe upholstered furniture and mattresses with “standard” upholstered furniture and mattresses, when it is well known that these “standard” items produce incredibly high levels of heat and smoke and toxic products. We also know that it is unsafe to put “all of one’s eggs in a single basket”, since it is not unknown for sprinkler systems to fail, and when they fail, we are left with a massive fire from the furniture or mattress. The State of California already requires that all mattresses sold in California effective January 1, 2005 must be fire retarded and meet a 200 kW maximum rate of heat release. It is really unreasonable that mattresses could be introduced into high risk occupancies and be so unsafe that they could not be sold in the State of California for residential use. For consistency, upholstered furniture should be equally safe in regulated occupancies. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action and statement on Comment 101-178. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest.

_______________________________________________________________101-178 Log #192 SAF-FUR FINAL ACTION: Reject (10.3.3 and A.10.3.3) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-269 RECOMMENDATION: This proposal should at least have been accepted in principle in part with the following language: 10.3.3* Where required by the applicable provisions of this Code, upholstered furniture, unless the furniture is located in a building protected throughout by an approved automatic sprinkler system, shall have limited rates of heat release when tested in accordance with ASTM E 1537, Standard Method for Fire Testing of Real Scale Upholstered Furniture Items, as follows: (1) The peak rate of heat release for the single upholstered furniture item shall not exceed 250 kW. (2) The total energy released by the single upholstered furniture item during the first 5 minutes of the test shall not exceed 40 MJ. A.10.3.3 The intent of the provisions of 10.3.3 is as follows. (1) The peak heat release rate of not more than 250 kW by a single upholstered furniture item was chosen based on maintaining a tenable environment within the room of fire origin. The sprinkler exception was developed because the sprinkler system helps to maintain tenable conditions even if the single upholstered furniture item were to have a peak rate of heat release in excess of 250 kW. (2) The total energy release of not more than 40 MJ by the single upholstered furniture item during the first 5 minutes of the test was established as an additional safeguard to protect against the adverse conditions that would be created by an upholstered furniture item that released its heat in other than the usual measured scenario. During the test for measurement of rate of heat release, the instantaneous heat release value usually peaks quickly and then quickly falls off so as to create a triangle-shaped curve. In the atypical case, if the heat release were to peak and remain steady at that elevated level, as opposed to quickly falling off, the 250-kW limit would not ensure safety. Again, only a sprinkler exception is permitted in lieu of the test because of the ability of the sprinkler system to control the fire. Actual test results for heat, smoke, and combustion product release from ASTM E 1537, Standard Method of Fire Testing of Real Scale Upholstered Furniture Items, might be suitable for use as input into fire models for performance-based design. SUBSTANTIATION: The State of California requires that all residential and high risk mattresses that are sold in the state after January 1, 2005 must have improved fire performance and meet a 200 kW maximum rate of heat release. The state of California is also working on requirements to improve the fire performance of upholstered furniture to a flaming ignition source, for residential furniture and high risk furniture. CPSC is also working on developing new fire tests for flaming ignition of upholstered furniture (also for both residential and high risk furniture). Does the rest of the country not deserve to have furniture that meets at least some fire safety requirements based on flaming ignition? For consistency, upholstered furniture should be as safe as mattresses, especially in regulated occupancies.

The regulated occupancies using these requirements in the Life Safety Code are health care, board and care and detention occupancies: all very high risk. Sprinkler trade-offs should not be acceptable alternatives, since upholstered furniture that is not fire retarded can release well over 5 megawatts of energy following simply a match ignition (I know since I have conducted fire tests to that effect, see “Residential Upholstered Furniture in the United States and Fire Hazard”, M.M. Hirschler, Business Communications Company Fifteenth Ann. Conference on Recent Advances in Flame Retardancy of Polymeric Materials, June 7-9, 2004, Stamford, CT, Ed. M. Lewin, pp., Norwalk, CT, 2004.). Acceptance of this comment does not tread over the jurisdiction of other occupancy committees, since each committee is still free to avoid including requirements. However, this comment is simply an issue of basic fire safety. The changes made to the Annex reflect the fact that, if the comment is accepted by the committee, the references to sprinkler trade-offs in the Annex would be incorrect. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is of the opinion that the presence of an approved automatic sprinkler system will serve to aid in the prevention of flashover which is the intent of this requirement. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest.

_______________________________________________________________101-179 Log #191 SAF-FUR FINAL ACTION: Reject (10.3.4 and A.10.3.4) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council (Fire Retardant Chemicals Association COMMENT ON PROPOSAL NO: 101-269 RECOMMENDATION: This proposal should at least have been accepted in principle in part with the following language: 10.3.4* Where required by the applicable provisions of this Code, mattresses, unless the mattress is located in a building protected throughout by an approved automatic sprinkler system, shall have limited rates of heat release when tested in accordance with ASTM E 1590, Standard Method for Fire Testing of Real Scale Mattresses, as follows: (1) The peak rate of heat release for the mattress shall not exceed 250 kW. (2) The total energy released by the mattress during the first 5 minutes of the test shall not exceed 40 MJ. A.10.3.4 The intent of the provisions of 10.3.4 is as follows. (1) The peak heat release rate of not more than 250 kW by a single mattress was chosen based on maintaining a tenable environment within the room of fire origin. The sprinkler exception was developed because the sprinkler system helps to maintain tenable conditions even if the single mattress were to have a peak rate of heat release in excess of 250 kW. (2) The total energy release of not more than 40 MJ by the single mattress during the first 5 minutes of the test was established as an additional safeguard to protect against the adverse conditions that would be created by a mattress that released its heat in other than the usual measured scenario. During the test for measurement of rate of heat release, the instantaneous heat release value usually peaks quickly and then quickly falls off so as to create a triangle-shaped curve. In the atypical case, if the heat release were to peak and remain steady at that elevated level, as opposed to quickly falling off, the 250-kW limit would not ensure safety. Again, only a sprinkler exception is permitted in lieu of the test because of the ability of the sprinkler system to control the fire. Actual test results for heat, smoke, and combustion product release from NFPA 267, Standard Method of Test for Fire Characteristics of Mattresses and Bedding Assemblies Exposed to Flaming Ignition Source, and ASTM E 1590, Standard Method for Fire Testing of Real Scale Mattresses, might be suitable for use as input into fire models for performance-based design. SUBSTANTIATION: The State of California requires that all residential and high risk mattresses that are sold in the state after January 1, 2005 must have improved fire performance and meet a 200 kW maximum rate of heat release. The state of California is also working on requirements to improve the fire performance of upholstered furniture to a flaming ignition source, for residential furniture and high risk furniture. CPSC is also working on developing new fire tests for flaming ignition of upholstered furniture and of mattresses (also for both residential and high risk furniture). Does the rest of the country not deserve to have mattresses that meet at least some fire safety requirements based on flaming ignition? The regulated occupancies using these requirements in the Life Safety Code are health care, board and care and detention occupancies: all very high risk. Sprinkler trade-offs should not be acceptable alternatives, since mattresses that are not fire retarded can release well over 5 megawatts of energy following simply a match ignition (I know since I have conducted fire tests to that effect, see “Mattress/Bedding Fires: Statistics and Fire Data Associated with Recent Experience”, M.M. Hirschler, Fire and Materials Conf., San Francisco, CA, Jan. 22-24, 2001, Interscience Communications, London, UK, pp. 129-140). Acceptance of this comment does not tread over the jurisdiction of other occupancy committees, since each committee is still free to avoid including requirements. However, this comment is simply an issue of basic fire safety.

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Report on Comments — Copyright, NFPA NFPA 101 The changes made to the Annex reflect the fact that, if the comment is accepted by the committee, the references to sprinkler trade-offs in the Annex would be incorrect. Also, the reference to NFPA 267 should be eliminated since it has been withdrawn. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action and statement on Comment 101-178. NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 10 Abstain: 1 EXPLANATION OF ABSTENTION: HIRSCHLER: Abstention, because of potential for client interest. _______________________________________________________________101-180 Log #46 SAF-IND FINAL ACTION: Accept in Principle (11.8.3.2(A), 11.8.4.2(D), and 11.8.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified to change, editorially, the reference from Chapter 8 to Section 11.8 as follows: “Replace the phrase ... in all locations it appears in Section 11.8.”SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-287 RECOMMENDATION: Give consideration, so as to make any needed changes, to using the term “emergency command center” in lieu of “fire command center” for correlation with NFPA 1, Uniform Fire Code. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Replace the phrase “fire command center” with the phrase “emergency command center” in all locations it appears in Chapter 8. COMMITTEE STATEMENT: This meets the intent of the submitter, and provides for correlation with NFPA 1. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-181 Log #103 SAF-IND FINAL ACTION: Reject (11.8.4.2) _______________________________________________________________ SUBMITTER: Edward A. Donoghue, Edward A. Donoghue Associates, Inc. / Rep. National Elevator Industry, Inc. (NEII) COMMENT ON PROPOSAL NO: 101-288 RECOMMENDATION: Revise text to read: At least Not less than one elevator providing access to serving all floors, with standby power transferable to all any elevator. SUBSTANTIATION: Clarification that a single elevator does not have to serve all floors. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee does not believe that the submitter’s revision clarifies the current requirement but rather makes it more confusing. The committee further notes that the recommendation introduces a new key technical change. It is not the committee’s intent to require one elevator to serve all floors. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-182 Log #47 SAF-IND FINAL ACTION: Accept in Principle (11.8.4.2 and 11.8.4.3 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-288 RECOMMENDATION: Give consideration, so as to make any needed changes, to specifying any requirements for emergency or standby power in the format of Type/Class/Level (for example, “Type 60, Class 1, Level 1”) for consistency with NFPA 110 and NFPA 111. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-102. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-102. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-183 Log #48 SAF-IND FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration, so as to make any needed changes, to allow any occupancy the same exemption offered to health care occupancies and ambulatory health care occupancies as addressed in the last paragraph (item 2) of the Substantiation: Modify the text so as to allow the exemption for any occupancy as follows: Elevator hoistway separation shall not be required where elevators serving the floor are located in at least two smoke compartments. SUBSTANTIATION: See the above recommendation.COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-189 and 101-194. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-189 and 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-184 Log #48a SAF-AXM FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Comments 101-194a and 101-224b. COMMITTEE STATEMENT: The action on the referenced comments should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-185 Log #48b SAF-BCF FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: No action is necessary because Chapter 32 does not reference Section 11.8 for high-rise buildings. The committee notes this might be an oversight and intends to reassess this omission during the next code development cycle. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-186 Log #48c SAF-DET FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-DET. COMMITTEE STATEMENT: The technical aspects of elevator hoistway separation are moot as related to the SAF-DET committee’s chapters. For the chapters under the purview of SAF-DET, only 22.4.3 makes reference to the high rise provisions, and then only to impose the requirements of subsection 11.8.2, not all of Section 11.8. So, the new requirement of 11.8.6 for elevator hoistway separation does not affect detention and correctional occupancies. For purposes of NFPA 5000, the subject of elevator hoistway separations in high-rise detention and correctional occupancies in not moot. See action on Comments 5000-591, 5000-589b, and 5000-480d. NUMBER ELIGIBLE TO VOTE: 18

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Report on Comments — Copyright, NFPA NFPA 101 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-187 Log #48d SAF-END FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-END. COMMITTEE STATEMENT: New educational occupancies in high-rise portions of high-rise buildings should be afforded separated elevator lobbies. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-188 Log #48e SAF-HEA FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-290 as it is no longer needed given that Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposal 101-290 as follows: Further revise the text proposed as a new 11.8.6 by SAF-IND’s action on ROP Proposal 101-292 by adding an exemption to read: Elevator hoistway separation shall not be required in health care and ambulatory health care occupancies where elevators serving the floor are located in at least two smoke compartments. COMMITTEE STATEMENT: The exemption for health care and ambulatory health care occupancies remains justified as explained in the committee statement for ROP Proposal 101-290. See also the committee action on Comment 101-192a. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-189 Log #48f SAF-IND FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: An exception to proposed 11.8.6 is not necessary as comment 101-194 rejects 11.8.6. See comment 101-194 and proposal 101-292. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-190 Log #48g SAF-MER FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – No further action needed given that Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292.

SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-202. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-202. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-191 Log #48h SAF-RES FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – No further action needed given that Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Give consideration for application of an exemption to fire resistance-rated smoke compartments from the elevator separation requirement proposed by Proposal 101-292. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-203. COMMITTEE STATEMENT: The action on Comment 101-203 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-192 Log #225 SAF-IND FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-188 and 101-194. ROP Proposal 101-292 is being rejected so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Delete the proposed change. Elevator hoistway separation shall not be required in health care and ambulatory health care occupancies where elevators serving the floor are located in at least two smoke compartments. SUBSTANTIATION: The change is not consistent with good fire protection or the defend-in-place philosophy for health care occupancies and should not be incorporated into the code. The defend-in-place provisions of the codes acknowledge that evacuation is not practical and therefore occupants will be moved from one area to another. The LSC has numerous provisions addressing staff response to fires. In today’s healthcare environment the movement of patients on a floor from one side of a barrier to another cannot be readily accomplished by the staff on a single floor, so other staffs from non-fire floors are used in fire emergencies. An elevator open to a fire compartment on one floor will allow the movement of smoke to other floors due to the pressures created by the fire (with or without sprinklers) the building stack effect, and elevator piston effect. Movement of smoke to other floors where staff has been called to assist in movement patients on the fire floor will result in a greater life risk. This code change should therefore result in evaluations by inspectors of the ability to provide staff for patient movement on all floors. Elevators in health care and other occupancies take several forms. First, a single elevator in a single hoistway - that would allow smoke spread to other floor. Second, a single elevator in a single shaft with door openings at the front and rear of the car- that would allow smoke spread to other floors and to separate smoke compartments on the same floor via the two doors on the same level. Third, two or more elevators in the same hoistway, but in different smoke compartments on each level- these could spread the smoke to other floors and to the other side of the smoke barrier on the same floor. This is likely to be the most common configuration created by the proposed change. A smoke barrier wall and door provide separation on a floor in a hallway with two or more elevators that are in a common shaft with an elevator door opening in such compartment that effectively negates the effectiveness of the smoke barrier. _____ 1ASHRAE/SFPE Principles of Smoke Management, J. H. Klote and J. A. Milke, 2002 2NFPA Quarterly 57(4)309-319, 1964, E. E. Juillerand COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement to Comments 101-189 and 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-192a Log #225a SAF-HEA FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-188 and 101-194. ROP Proposal 101-292 is being rejected so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-290 RECOMMENDATION: Delete the proposed change. Elevator hoistway separation shall not be required in health care and ambulatory health care occupancies where elevators serving the floor are located in at least two smoke compartments. SUBSTANTIATION: The change is not consistent with good fire protection or the defend-in-place philosophy for health care occupancies and should not be incorporated into the code. The defend-in-place provisions of the codes acknowledge that evacuation is not practical and therefore occupants will be moved from one area to another. The LSC has numerous provisions addressing staff response to fires. In today’s healthcare environment the movement of patients on a floor from one side of a barrier to another cannot be readily accomplished by the staff on a single floor, so other staffs from non-fire floors are used in fire emergencies. An elevator open to a fire compartment on one floor will allow the movement of smoke to other floors due to the pressures created by the fire (with or without sprinklers) the building stack effect, and elevator piston effect. Movement of smoke to other floors where staff has been called to assist in movement patients on the fire floor will result in a greater life risk. This code change should therefore result in evaluations by inspectors of the ability to provide staff for patient movement on all floors. Elevators in health care and other occupancies take several forms. First, a single elevator in a single hoistway - that would allow smoke spread to other floor. Second, a single elevator in a single shaft with door openings at the front and rear of the car- that would allow smoke spread to other floors and to separate smoke compartments on the same floor via the two doors on the same level. Third, two or more elevators in the same hoistway, but in different smoke compartments on each level- these could spread the smoke to other floors and to the other side of the smoke barrier on the same floor. This is likely to be the most common configuration created by the proposed change. A smoke barrier wall and door provide separation on a floor in a hallway with two or more elevators that are in a common shaft with an elevator door opening in such compartment that effectively negates the effectiveness of the smoke barrier. _____ 1ASHRAE/SFPE Principles of Smoke Management, J. H. Klote and J. A. Milke, 2002 2NFPA Quarterly 57(4)309-319, 1964, E. E. Juillerand COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement to Comments 101-189 and 101-194. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-193 Log #297 SAF-IND FINAL ACTION: Accept in Principle (11.8.6) _______________________________________________________________ SUBMITTER: Dave Frable, U.S. General Services Administration COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Delete entire new text. This proposal should be rejected. SUBSTANTIATION: We concur with the negative ballot comments submitted by Messrs. Klein and Spiro. Please note that no technical documentation has been submitted by the proponent to substantiate such a major change in this standard. In addition, this comment acknowledges that high-rise buildings protected by an operational automatic fire sprinkler system provide an acceptable level of safety for building occupants and therefore does not warrant the need for an enclosed elevator lobby. Research has shown that sprinklered fires in office buildings do not represent any hazards to occupants away the fire origin 1. This is because the sprinkler system activates and extinguishes the fire typically before it releases significant energy. Therefore, little or no smoke or gasses enter the elevator hoistway and therefore no smoke or gases reach remote locations regardless the height of the office building. It is also widely accepted that operating fire sprinklers will prevent room flashover and full floor fires, and will limit the size of room fires2. Therefore one can conclude that enclosed elevator lobbies are not necessary in highrise buildings protected throughout by an operational automatic fire sprinkler system. This conclusion can also be substantiated fro a paper presented by Dr John Klote at the Elevator Symposium on emergency Use of Elevators in March 20041. Past studies also indicate that the operational reliability for a typical commercial automatic fire sprinkler system is about 95 percent3. The purpose of the NFPA 101 is to provide minimum requirements to safeguard occupants of buildings from fire and other hazards attributed to the built environment that are based on sound technical documentation. Also, keep

in mind that deaths are very rare in office buildings, even rarer in high-rise buildings, and surpassingly rare in sprinkled high-rise buildings. Therefore, we believe the new requirement for enclosing elevator lobbies in high-rise buildings protected throughout by an operational automatic fire sprinkler system has not been based on sound technical documentation and will significantly increase building construction and maintenance costs without increasing the overall safety to the building occupants. In conclusion: 1. No sound technical justification has been provided to justify the installation of elevator lobby enclosures when a high-rise building is protected throughout by an operational automatic fire sprinkler system. 2. No technical substantiation has been provided that demonstrates how effective elevator lobby enclosures are in limiting smoke spread in a sprinklered high-rise building. 3. No life loss statistics have been provided to support the rationale that the lack of elevator lobby separation in sprinklered high-rise buildings impact the safety of the building occupants. 4. Available research has shown that sprinklers typically reduce the energy or driving force produced by the fire which serves to limit smoke spread and therefore does not result in any significant threat away from region of the fire.” References: ____________ 1Klote, J. H. Analysis of the Consequences of Smoke Migration through Elevator Shafts, Use of Elevators in Fires and other Emergencies Workshop. Proceedings. Co-sponsored by American Society of Mechanical Engineers (ASME International); National institute of Standards and Technology (NIST); International Code Council (ICC); National Fire Protection Association (NFPA): U.S. Access Board and international Association of Fire Fighters (IAFF). March 2-4, 2004, Atlanta, GA 2Guide on Methods for Evaluating Potential for Room Flashover, NFPA 555-2000 ed., Natl Fire Prot Assn., Quincy, MA 3Bukowski, R.W.; Budnick, E.K.; Schemel, C.F., Estimates of the Operational Reliability of Fire Protection Systems, International Conference on Fire Research and Engineering (ICFRE3), Third (3rd), Proceedings, October 4-8, 1999, Chicago, IL, Society of Fire Protection Engineers, Boston, MA 87-98 pp. 1999 COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-194. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-194 Log #398 SAF-IND FINAL ACTION: Accept (11.8.6) _______________________________________________________________ SUBMITTER: Jeffrey M. Shapiro, International Code Consultants COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: I agree with Mr. Klein’s negative ballot comments. The proposed addition of smoke barriers for elevator hoistways has not been substantiated for sprinklered buildings. The proponent’s substantiation relies in part on fire data from non-sprinklered structures, and there is no correlation in the data between smoke migration in sprinklered building fires and degree of property damage, injuries or life loss. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-194a Log #CC276 SAF-AXM FINAL ACTION: Reject (11.8.6) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Further revise the text proposed as a new 11.8.6 by SAF-IND’s action on Proposal 101-292 by adding an exemption to read: Elevator hoistway separations shall not be required in assembly occupancies. SUBSTANTIATION: Assembly occupancies subject to the provisions of Section 11.8 will be in fully sprinklered buildings. In sprinklered buildings there is no need for elevator separation. This is consistent with work done by Bukowski at NIST and per history in GSA buildings. The elevator is not part of the means of egress. See Comment 101-224b. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-195 Log #49 SAF-IND FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Give consideration to Klein’s and Shapiro’s Explanation of Negative, so as to make any needed changes. KLEIN: Please register my vote as negative on this code proposal. It is a similar code proposal that was accepted by our Committee last code cycle that will require elevator lobbies for smoke control in high-rise buildings. Last cycle I voted against that code change in the ROP, ROC at the NFPA Technical Session and my reason was that there was no adequate technical justification for this requirement in a sprinklered high-rise building. This issue went to the Standards Council by way of an appeal, and the Standards Council upheld the appeal for the same reason: There was no adequate technical justification for this requirement in a sprinklered high-rise building. Here we go again in this code cycle with the same issue, and there is still no adequate technical justification for this requirement in a sprinklered high-rise building. If there is a need for such smoke control, then I would recommend such control be made at the elevator door by requiring all elevator doors to be fire rated (per UL10B, “Fire Tests of Door Assemblies”) AND smoke-tight (UL 1749, “Air Leakage Test for Door Assemblies”). SHAPIRO: I agree with Mr. Klein’s comments. The proposed addition of smoke barriers for elevator hoistways has not been substantiated for sprinklered buildings. The proponent’s substantiation relies in part on fire data from non-sprinklered structures, and there is no correlation in the data between smoke migration in sprinklered building fires and degree of property damage, injuries or life loss. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-194. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-196 Log #49a SAF-AXM FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – No further action needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Comments 101-194a and 101-224b.COMMITTEE STATEMENT: The action on the referenced comments should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-197 Log #49b SAF-BCF FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: No action is necessary because Chapter 32 does not reference Section 11.8 for high-rise buildings. The committee notes this might be an oversight and intends to reassess this omission during the next code development cycle. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN

_______________________________________________________________101-198 Log #49c SAF-DET FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-DET. COMMITTEE STATEMENT: The technical aspects of elevator hoistway separation are moot as related to the SAF-DET committee’s chapters. For the chapters under the purview of SAF-DET, only 22.4.3 makes reference to the high rise provisions, and then only to impose the requirements of subsection 11.8.2, not all of Section 11.8. So, the new requirement of 11.8.6 for elevator hoistway separation does not affect detention and correctional occupancies. For purposes of NFPA 5000, the subject of elevator hoistway separations in high-rise detention and correctional occupancies in not moot. See action on Comments 5000-591, 5000-589b, and 5000-480d. NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-199 Log #49d SAF-END FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-END. COMMITTEE STATEMENT: New educational occupancies in high-rise portions of high-rise buildings should be afforded separated elevator lobbies. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON

_______________________________________________________________101-200 Log #49e SAF-HEA FINAL ACTION: Reject (11.8.6 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separationSUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposal 101-290 as follows: Further revise the text proposed as a new 11.8.6 by SAF-IND’s action on ROP Proposal 101-292 by adding an exemption to read: Elevator hoistway separation shall not be required in health care and ambulatory health care occupancies where elevators serving the floor are located in at least two smoke compartments. COMMITTEE STATEMENT: The exemption for health care and ambulatory health care occupancies remains justified as explained in the committee statement for ROP Proposal 101-290. See also the committee action on Comment 101-192a. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-201 Log #49f SAF-IND FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-194. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-202 Log #49g SAF-MER FINAL ACTION: Reject (11.8.6 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle 1. Revise 11.8.6 as modified by proposal 101-292 to read as follows: 11.8.6 Elevator Hoistway Separations. Unless otherwise specified in Chapters 12 through 42, elevator hoistways shall be separated from the remainder of the building, including corridors, by smoke barriers complying with Section 8.5 and 8.6 with self-closing or automatic closing doors. 2. Revise 36.4.2 to read as follows: 36.4.2 High-Rise Buildings. 36.4.2.1 High-rise buildings shall comply with the automatic sprinkler requirements of 11.8.2.1. 36.4.2.2 The elevator hoistway separation requirements of 11.8.6 shall not apply. 3. Revise 38.4.2 to read as follows: 38.4.2 High-Rise Buildings. 38.4.2.1 High-rise buildings shall comply with Section 11.8. 38.4.2.2 The elevator hoistway separation requirements of 11.8.6 shall not apply. COMMITTEE STATEMENT: Insufficient technical justification has been provided for the need to require smoke barriers for elevator hoistways in buildings protected with sprinkler systems. The substantiation for proposal 101-292 relies in part on fire data from non-sprinklered buildings, and includes no instances of failures where sprinklers are present. Current provisions rely on more than one safeguard for protection, and the need for additional protection in the form of smoke barriers is not warranted. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the fire and life safety concerns raised by Mr. Thornberry regarding the exemption of elevator hoistway separation requirements in high rise buildings for mercantile and business occupancies. High-rise buildings present greater risks and challenges for fire protection and life safety and we feel the committee should reconsider the action taken at the ROC meeting. EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment, I would vote to reject it. I do not agree with the Committee Action to specifically exempt high rise buildings from the elevator hoistway separation requirements for both office and mercantile occupancies. This is in direct conflict with the Technical Committee on Industrial, Storage, and Miscellaneous Occupancies which voted to require the elevator hoistway separation requirements for all high rise buildings under their jurisdiction. I can not agree with the Committee Statement that insufficient technical justification was provided for Proposal 101-292 which was thoroughly discussed at the SAF-IND TC ROP meeting. It should be noted that the original motion on this Comment was to Accept in Principle

and take no action but it failed by a vote of 5-6 with the chair casting the tie breaking vote. Obviously, this issue requires more careful consideration by the Committee. _______________________________________________________________101-203 Log #49h SAF-RES FINAL ACTION: Reject (11.8.6 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Review the proposed requirements for elevator separations, so as to take any needed action, given that the proposal was not available in time for review at most of the occupancy technical committee ROP meetings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 28.4.1 and 30.4.1 as follows: 28.4.1 High-Rise Buildings. 28.4.1.1 High-rise buildings shall comply with Section 11.8 as modified by 28.4.1.2. 28.4.1.2 High-rise buildings shall be exempt from the requirements of 11.8.6. 30.4.1 High-Rise Buildings. 30.4.1.1 High-rise buildings shall comply with Section 11.8 as modified by 30.4.1.2. Subsections 30.3.5.4 and 30.3.5.5 shall be permitted. 30.4.1.2 High-rise buildings shall be exempt from the requirements of 11.8.6. COMMITTEE STATEMENT: The committee action exempts new high-rise hotels and dormitories and new high-rise apartment buildings from the proposed elevator lobby provisions of 11.8.6. New high-rise residential occupancies are required to be protected by automatic sprinkler systems, and they are required to be provided with adequate compartmentation (rated separation between sleeping rooms/suites or units, and protected corridors). No data has been submitted to indicate the protection scheme currently prescribed affords insufficient protection. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM

_______________________________________________________________101-204 Log #218 SAF-IND FINAL ACTION: Reject (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Maintain the committee action to accept in principle. SUBSTANTIATION: The committee heard evidence of smoke travel in buildings from floor to floor based upon NFPA data as a part of the oral arguments. Substantial data exists on smoke movement via elevator shafts in buildings. The assertion that instead of this requirement that changes in elevator door design to include smoke should be made, while noble, is not one that the elevator market is ready to embrace. Several multiple fatality fires in the U.S. starting on the first floor had vertical elevator and stairwell shafts become smoke-logged and then spread heat and fire to upper floors due to stack effect within the building. The buoyant gas effects of the fire products in combination with stack effect in shafts resulted in the majority of deaths on upper floors. Three significant high-rise fires noted by Klote & Milke were the Roosevelt Hotel Fire, Jacksonville, FL (1963); the MGM Grand Hotel Fire, LAs Vegas, NV (1980); and the Retirement Center Fire, Johnson City, TN (1989). At the time of each of these fires the building codes in effect had hoistway shaft vent requirements identical in application to the current IBC. The present of hoistway vents in fires where hoistway shafts played a significant role in smoke movement is a clear demonstration of the inability of hoistway vents to effectively prevent smoke spread to upper floors of a multi-story building. The Roosevelt Hotel Fire had 21 fatalities with the fire having started on the first floor. Twenty of the fatalities were on the 9th through 11 floors of the 14-story building. Vertical shafts that allowed heat and smoke movement were a contributing factor in the loss of life. 2 The MGM Grand Hotel fire began in the first floor casino area with heat and smoke rapidly extending through seismic joints, elevator shafts, and stairways to the 21 sleeping floors of the 26-story building. The fire resulted in 785 injuries and 85 deaths. Body locations documented 14 fatalities on the casino level, 29 in guest rooms on upper floors, 21 in lobbies and corridors, 9 in stairwells, and 5 fatalities in elevators. The majority of the fatalities were on the 20th to 25th floors. The MGM Grand Fire was also significant in that it was the first high-rise fire in the U.S. in which helicopters evacuated nearly 300 people from the roof of the building. The people evacuated from the roof of the hotel were driven upward by the heat and smoke from the fire as it rose through the hotel. Had helicopters been unable to rescue victims from the roof, the life loss would have been greater. 3

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Report on Comments — Copyright, NFPA NFPA 101 The Johnson City Retirement Center fire began on the first floor of the 11-story building. Detection initiated elevator recall that stopped the two elevators at the first floor for Phase 1 recall in accordance with ASME A17.1 requirements and opened the elevator doors. As the fire progressed from a remote location on the ground floor and around the open elevator shaft smoke readily moved upward through the elevator hoistway. Fourteen of the 16 fatalities were on upper floors, most behind closed hallway doors to apartments. 4 Fires beginning on upper floors of high-rise buildings present a similar life risk to that demonstrated in the Roosevelt, MGM and Johnson City Retirement Center fires. The buoyancy of fire gases on a fire floor can enter hoistway shafts around elevator doors and then exit on upper floors due to smoke-logging and stack effect within the building. The variables of a fire in a building make it difficult to predict which floors above a fire will become filled with smoke. Isolating fire growth and its products to the floor of origin is a key to reducing property and life loss. Isolation of the hoistway from a fire is the most reliable method of keeping fire and smoke products out of the hoistway shaft where it can spread smoke to other floors. Passive protection in the form of elevator lobby protection or temporary barriers directly in front of elevator doors can extend the amount of time before occupants are at risk from an active fire and allow for extended use of elevators for rescue ad fire department staging of personnel and equipment. In a project funded by the National Institute of Standards and Technology the hazard to life due to smoke migration through elevator hoistways and the effectiveness of methods to reduce the hazard where studied. Two methods resulted in positive results in the study (1) enclosed elevator lobbies and (2) temporary roll-down barriers directly in front of elevator doors. The study utilized data from five buildings ranging from 6 to 58 stories in height. Both fully developed room fires and fully developed floor fires were evaluated with all but two scenarios placing the originating fire on the second floor. Scenarios in the study examined both open and enclosed elevator lobbies and the time that it took smoke obscuration and untenable conditions to occur on the top floor via elevator hoistways. Elevator lobbies with side-swinging doors substantially inhibit the flow of smoke into and through hoistways in this study. In one scenario the top floor becomes untenable in 56 minutes without elevator lobbies and with lobbies 120 minutes is required before the top floor is untenable. Other test scenarios saw increases of time to smoke obscuration on the top floor of 158 percent and 193 percent when lobbies were present. Elevator hoistway doors had gap areas of 0.50 to 0.66ft 2 while lobby doors had similar gap areas, which allowed for smoke to eventually enter the lobby and then the shafts. Elevator shafts had open top vents in some evolutions consistent with building code requirements. In an earlier study it was shown that the leakage area of the elevator doors is the primary factory in smoke movement to higher floors in buildings. Modeling using CONTAM96 for a 10 story building resulted in the conclusion that, the leakage area of the elevator doors is the primary factor in allowing smoke to migrate to upper floors in a building. If the leakage area of the elevator doors is controlled to reduced levels, then a threefold increase in visibility can be attained on the upper floors of a typical multi-story building regardless of whether the building was sprinklered or not. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee action and statement to comments 101-193 and 101-194 as well as the substantiations to these comments. The committee further notes that failures sited only pertain to non-sprinklered buildings. The example provided shows that where sprinklers are present no failures occurred. The current provisions rely on more than one safeguard for protection. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-205 Log #286 SAF-IND FINAL ACTION: Reject (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-291 RECOMMENDATION: Revise as follows: 11.8.6 Escape Devices or Systems. Escape devices or system complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: The benefit from installation of escape devices or systems is apparent: the equipment in cojunction with the required evacuation plan and training provides a controlled and reasonably safe alternative for evacuation when the reqired means of egress have been copromised. Additionally, based on a related comment submitted on Proposal 101-107, installation of an escape device, a coordinated group of devices or system that complies with 7.2.1.4 2 will reduce the minimum stair width requirement in new construction to that of the 2003 LSC. One requirement of that allowance is that an occupancy chapter (11 through 42) permit the escape device/system to serve as a component in the means of egress. The revised text indicated in this comment will permit that stair width reduction for new construction. The risks are addressed by the criteria in 7.2.14 and the evaluation, if one is required by the AHJ, as ndicated in Proposal 101-128 7.2.14.1(2). Because

building owners and occupants of buildings are purchasing and installing various types of escape devices and systems, whether reqired or not, guidance on appropriate selection and use is important. Since the ROP meetings, ASTM is actively developing standards and has formed a subcommittee of the E06 Committee on Building Performance to develop sandards for the certification, installation, testing and maintenance of three types of escape device/system products. Installations are now complete in numerous locations with three products successfully completed field trials and one has been completed the certification requirements for installation by the Standards Institution of Israel who is following NFPA and ASTM’s actions closely. The Safe Evacuation Coailition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members inclue Escape Rescue Systems ltd., Moseroth Ltd (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The recommendation as proposed by the submitter to chapter 7 regarding escape devices and systems was not accepted by SAF-MEA and therefore the appropriate action on this comment as recommended by the submitter at the ROC meeting is reject. See action by SAF-MEA on comment 101-78. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-206 Log #308 SAF-IND FINAL ACTION: Accept in Principle (11.8.6 (New) ) _______________________________________________________________ SUBMITTER: Lawrence G. Perry Silver Spring, MD COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Delete the proosed new text in its’ entirety. SUBSTANTIATION: I concur with the negative ballot comments of Messrs. Klein and Shapiro. The TC provides not a single word of technical substantiation for this change in the committee statement. The substantiation in the proposal conveniently mixes snippets of data from sprinklered and unsprinklered buildings to support their position. A review of any fire data from NFPA clearly indicates that sprinklered high-rise buildings have an excellent fire safety record, and that there is no justification from a life-safety standpoint (which is the scope of this code) to mandate enclosed lobbies. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-194. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN ______________________________________________________________101-206a Log #310 SAF-IND FINAL ACTION: Accept in Principle (11.8.6.1) _______________________________________________________________ SUBMITTER: Jeffrey M. Shapiro, International Code Consultants COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Reject the proposal. SUBSTANTIATION: I agree with Mr. Klein’s negative ballot comments. The proposed addition of smoke barriers for elevator hoistways has not been substantiated for sprinklered buildings. The proponent’s substantiation relies in part on fire data from non-sprinklered structures, and there is no correlation in the data between smoke migration in sprinklered building fires and degree of property damage, injuries or life loss. COMMITTEE MEETING ACTION: Accept in Principle See Committee and Statement on Comment 101-194. COMMITTEE STATEMENT: See Committee and Statement on Comment 101-194. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-207 Log #384 SAF-IND FINAL ACTION: Accept (11.9.1.4) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-33 RECOMMENDATION: Revise text to read as follows: 25.5.1.3 Flame Spread Classification. Flame spread Index. The flame spread index of all membrane materials exposed within the structure shall be Class A in accordance with Section 10.2 of NFPA 101. SUBSTANTIATION: This proposal simply addresses terminology: the correct terminology is flame spread index rather than flame spread classification. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the

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Report on Comments — Copyright, NFPA NFPA 101 text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN ______________________________________________________________101-208 Log #170 SAF-AXM FINAL ACTION: Accept in Principle (12.2.2.3.2.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-297 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: This material is not appropriate for the Life Safety Code. Attention is directed to the long TCC note attached with Proposal 128 and this proposal. At best, these could be used in one- and two-family dwellings and that chapter does not use it. All of the other occupancy committees have rejected the concept including industrial and storage occupancies. The material has several flaws including among others how does this work with less than 10 people? The one place the AXM committee accepted it, would not normally be occupied by more than 10 people. COMMITTEE MEETING ACTION: Accept in Principle See action by SAF-AXM on Comment 101-209. COMMITTEE STATEMENT: The action on the referenced comment should satisfy the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-209 Log #50 SAF-AXM FINAL ACTION: Accept in Principle (12.2.2.3.2.3 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-297 RECOMMENDATION: (a) Give consideration to DiPilla’s and Shulman’s Explanation of Negative (on Proposal 101-128) so as to make any needed changes in its action on Proposal 101-297 and Proposal 101-338 as SAF-AXM was the only technical committee to recognize the use of the escape devices or systems. (b) Reconsider the applicability of the new provision for catwalks given that the proposed 7.2.14 seems not to be applicable to use inside a building. (c) Take care in the proper use of the terms “means of egress” and “means of escape.” (d) Take note that UL has withdrawn its certification of components of such systems, and ASTM has established a project to develop a product standard. DI PILLA: While I believe this concept has great potential, I don’t believe it is ready to be inserted into a national consensus code. At present, there are no approved/listed/certified products. In fact, there is not even a listing organization yet. If placed in the code, this would place the AHJ in the position of evaluating these complex egress components even though there has yet to be any substantial research on even HOW to evaluate them. Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered—and there is no methodology (nor sufficient research to date) to do so. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. In addition, the impact of these components on marking/signage, and related physical aspects of egress have not been established. I believe that this proposal should not be accepted until: 1. a listing organization program has been established, 2. a methodology for assessing installation and use has been developed, and 3. clear, minimum operational controls have been standardized. SHULMAN: The Code currently includes a comprehensive set of egress and escape requirements for various occupancies that have been well thought out and ingrained into the building and life safety codes used by our society. They are based on the concept of either evacuating occupants in an orderly, safe fashion, or protecting them in place in a protected area of refuge within the building. This proposal includes provisions for permitting escape devices and systems to be used in addition to required means of egress and escape provisions. On the surface this would appear to be acceptable, using the “more is better” argument. However, we have serious concerns about the actual impact that such systems have on the behavior and safety of occupants during emergency evacuation conditions that have not yet been adequately addressed in this proposal. This includes the possibility that the existence of such systems in a building may disrupt the orderly evacuation of the building or the efforts of fire service professionals, and that occupants attempting to use these systems under

panic conditions may expose themselves or others to potentially dangerous conditions as they struggle to use these systems. UL has received input from members of the fire service that indicates a strong preference for building occupants to follow established plans for egress of the building if at all possible, or “stay put” if they find the existing means of escape blocked and permit fire service personnel to undertake rescue activities. UL is of the opinion that, on the whole, this is the more advisable course of action in the present state. Both the building infrastructure and the education provided to building occupants have for many years focused on moving people towards the marked “EXITS” within the building during any evacuation scenario. Providing widely variable alternatives to be used at unpredictable times, at the discretion of particular individuals, throws out the certainty and familiarity with the established routine that is essential for its smooth operation during the high percentage of the time that the routine presents the best method for minimizing fire deaths. The “counter-flow” created by intentional attempts to redirect people or individual decisions of occupants – in high-panic mode – will in itself likely lead to significant injuries and problems. It will be nearly impossible for the decision whether to utilize an external and supplemental evacuation system to be made in a rational, informed manner. The entire premise behind these systems is that they will serve as a “last resort” – an act of desperation when all hope in the other established systems fail. To argue that “any option” is acceptable as a last resort is fallacious. The premise assumes the conclusion, i.e., the individual has not other changes of rescue, that the alternative is viable, and that the individual is capable of making a rational choice under extremely stressful circumstances. Further, the simple existence of the option will likely cause it to be considered prematurely. Decisions will be made by occupants based on limited knowledge and information, with a lack of firsthand experience with both the secondary equipment and the emergency scenario. The individual(s) responsible for making the decision may also be under considerable pressure by other building occupants, further degrading their capability to make a rational decision. The decision is a challenging one with serious implications, and decision-making quality will decline during times of high stress. The proposal does not provide AHJs or building owners with sufficient guidance on how to select and coordinate appropriate systems. The proposal also does not contain adequate measures to promote reliable and adequate testing and maintenance of the systems on an ongoing basis. There will (hopefully) be no real opportunities to rigorously test any number of these systems in a manner that can lead to a decision as to their ability to perform effectively when needed – during a time of some indeterminate facility escape route failure and imminent total infrastructure collapse. The uncertain human factors alone – including the behavioral unpredictability of both the system deployment decision makers and the other facility occupants – render any attempt at a system effectiveness evaluation highly unreliable. We also suspect that occupants attempting to utilize the equipment in a panic situation are likely to overload it in the escape frenzy. In conclusion, it is our belief that sufficient research into the potential use of these products, including detailed human factor/behavior studies, have not been conducted to address the potential hazards associated with their installation and use under emergency evacuation conditions. Further, the overall effect of these products and inherently variable decisions about their use as they relate to occupant behaviors with respect to emergency evacuation plans in general needs to be carefully considered. Based on these and other concerns, UL has chosen to not list such secondary emergency escape devices, and at this time has no intention to develop a certification program for such products. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject ROP Proposals 101-297 and 101-338 so as NOT to recognize escape devices within the means of egress from catwalks and similar spaces. COMMITTEE STATEMENT: The SAF-MEA committee has revised its action so that escape devices will not be permitted to serve as required means of egress. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-210 Log #51 SAF-AXM FINAL ACTION: Accept in Principle (12.2.5.2 and 13.2.5.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-302A RECOMMENDATION: Give consideration to the proposal so as to make any needed changes given the TCC developed the proposal after AXM had completed its ROP. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposal 101-302a. COMMITTEE STATEMENT: The changes proposed in the ROP are needed to correct an error. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24

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Report on Comments — Copyright, NFPA NFPA 101 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-211 Log #399 SAF-AXM FINAL ACTION: Accept (12.2.5.2 and 13.2.5.2) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-302A RECOMMENDATION: Accept the proposal. SUBSTANTIATION: The prohibition against permitting egress across a stage or platform from an assembly area was deleted from the 2000 Code by an editorial move of the stage provisions. There was neither a proposal nor comment regarding this. When this was brought to the attention of the TC for the 2003 Code, the TC accepted it for legitimate stages, but not for stages and platforms, saying there was no justification for the restriction, disregarding that the restriction had been in the Code for decades and had been removed with no proposal or comment. The recently released material on the Station Night Club fire, clearly shows that this facility could have been built under the Code with two, exits, the front door and a door over the stage/platform. This fire, in concert with the fact that the former restriction was removed with no proposal or comment, justifies reinstatement of the restriction. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-212 Log #273 SAF-AXM FINAL ACTION: Reject (12.2.5.4.1, and 13.2.5.4.1) _______________________________________________________________ SUBMITTER: Stephen V. Skalko, Portland Cement Association COMMENT ON PROPOSAL NO: 101-303 RECOMMENDATION: Revise text to read as follows: 12.2.5.4.1 Festival seating, as defined in 3.3.188.1, shall be prohibited within a building, unless otherwise permitted by one of the following: (1) Festival seating shall be permitted in clubs, dance halls, discotheques and similar assembly occupancies with live entertainment having an occupant load of more than 300 and where an approved life safety evaluation has been performed. (2) Except as required in No. 1, festival seating shall be permitted in assembly occupancies having occupant loads of 250 1000 or less. (2) (3) Festival seating shall be permitted in assembly occupancies where occupant loads exceed 250 1000 and where approved life safety evaluation has been performed. Same change to 13.2.5.4.1. SUBSTANTIATION: Proposal 101-303 makes no distinction about the types of assembly occupancies that are required to have the life safety evaluation except to require it for any assembly occupancy where festival seating is used. Then, all assembly occupancies with an occupant load over 250 people and with festival seating must have the life safety evaluation. But, in the substantiating reason for the original proposal the focus has been on concerts, clubs and festival type functions with standing crowds and live entertainment. Two instances given in the substantiation were night club assemblies which invloved lower lighting levels during normal operation and alcoholic beverages (The Station, Warwick, RI, and E2 Club, Chicago, IL). Understandably, the 1000 person occupant load threshold to require a life safety evaluation for these types of assembly occupancy may need to be lower. Based on the definition of festival seating however, other assembly uses with an occupant load over 250 people such as church fellowship halls, multipurpose rooms in schools, gymnasiums and school lunchrooms with small stages, would have the burden and expense of these annual life safety evaluations without a proven need. The annex note for the definition of festival seating describes festival seating as “assembly occupancies where live entertainment events are held and that are expected to result in overcrowding and high audience density that can compromise public safety.” It goes on to point out that the intent is not to apply the festival seating term to “exhibitions; sporting events; dances; conventions; and bono fide political, religious and educational events”. Even with this explanation, the application of this requirement is still subject to interpretation of festival seating configurations and the present proposal is too broad in terms of the thresholds for all assembly occupancies. The proposed change maintains the present occupant load thresholds for requiring life safety evaluations to permit festival seating for most assembly occupancies. However, it adds more specific types of assembly occupancies with lower occupant load thresholds based on the documented need from the original proposal. The added categories of assembly occupancies focus on uses consistent with the given reasons for the problem being concert halls, dance halls and clubs with live entertainment. The proposal also establishes the occupant load threshold at 300 people to be consistent with threshold for present requirements of sprinkler protection and fire alarm systems. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The 250 person threshold is needed to assure assembly occupancy life safety where festival seating is used.

NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 21 Negative: 3 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: SKALKO: The committee reason for rejection states that the threshold for requiring the life safety evaluation needs to be 250 people to assure life safety is provided for assembly occupancies with festival seating. If that is the reason, then the proposal as submitted could be modified to change the proposed threshold from 300 to 250 persons while still approving the language change that clarified the types of assembly occupancies (i.e clubs, dance halls, discotheques and assembly occupancies with live entertainment) where the festival seating can present a life safety hazard to the occupants. These assembly occupancies are similar to the two examples used in justifying the original change to this section (The Station, Warwick, RI and E2 Club, Chicago, IL.). TUBBS: This change would realign the festival seating provisions with the intent of the original code changes, addressing hazards presented within clubs, dance halls, discotheques and similar occupancies with live entertainment. WILLS: I believe Mr. Skalko has a valid point in his substantiation. Proposal 101-301 did not contain sufficient documentation to justify extending these requirements to all the applications it impacted. Mr. Skalko’s comment 101-212 more appropriately defines and controls the real problem. _______________________________________________________________101-213 Log #376 SAF-AXM FINAL ACTION: Hold (12.2.5.6.3, 13.2.5.6.3) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: N/A RECOMMENDATION: Add new text to read as follows: 20.1.4, 20.12.3, and 20.15.1.3.5 In areas serving employees only, the minimum aisle width shall be 610 mm (24 inches) but not less than the width required by the number of employees served. SUBSTANTIATION: NFPA 1 serves as a guide to field inspectors. Field inspectors do not have access to all the standards during their course of work. This language should be added for quick field reference. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material that has not had public review via the NFPA 101 ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-214 Log #377 SAF-AXM FINAL ACTION: Hold (12.2.5.6.3, 13.2.5.6.3) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: N/A RECOMMENDATION: Add new text to read as follows: 20.1.4, 20.12.3, and 20.15.1.6 In public areas of Assembly, Mercantile, and Storage Occupancies, the minimum clear aisle width shall be 914 mm (36 inches) where seats tables, counter, furnishings, displays and similar fixtures or equipment are place on one side of the aisle only and 1118 mm (44 inches) when such fixtures or equipment are place on both sides of the aisle. SUBSTANTIATION: NFPA 1 serves as a field guide to inspectors. Field inspectors do not have access to all the standards when doing and inspection. Providing language to assist with the inspection is appropriate. This language was found in the 2000 edition of the Uniform Fire Code. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material that has not had public review via the NFPA 101 ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-215 Log #52 SAF-AXM FINAL ACTION: Accept in Principle (12.2.5.6.5 through 12.2.5.6.8) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-307 RECOMMENDATION: Give consideration to the subject of an error in reporting the new text raised in Roether’s Comment on Affirmative, so as to make any needed changes. ROETHER: The proposal accepted by the committee does not exactly match the proposal written in this ballot beyond editorial. I vote to affirm the committee’s action on the premise that the original proposal is correct. Specifically, (8)(a) should read: “The riser height is designed non-uniform.” The original proposed exception No. 2 to 15.2.5.6.6.2(C) allowed construction caused non-uniformities to occur where the design had non-uniform riser height. The ballot would require the contractor to make the riser heights uniform where it was designed non-uniform and then be allowed to exceed 3/16 in. where it was designed uniform. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 12.2.5.6.6(8)(a) from that shown in ROP Proposal 101-307 as follows: (a) The riser height is designed non- uniform. COMMITTEE STATEMENT: The action does what SAF-AXM member Roether requested. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-216 Log #140 SAF-AXM FINAL ACTION: Reject (12.3.4.1(1), and 12.3.4.1(2)) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-311 RECOMMENDATION: Revise 12.3.4.1(1) and 12.3.4.1(2) as originally proposed, i.e., 12.3.4.1.1 Assembly occupancies with occupant loads greater than 300 and all theaters with more than one audience-viewing room shall be provided with an approved fire alarm system in accordance with 9.6.1 and 12.3.4, unless otherwise permitted by 12.3.4.1.2. the following: 12.3.4.1.2 (1) Assembly occupancies that are a part of a multiple occupancy protected as a mixed occupancy (see 6.1.14) shall be permitted to be served by a common fire alarm system, provided that the individual requirements of each occupancy are met. 12.3.4.1.2(2) Voice communication or public address systems complying with 12.3.4.3.3 shall not be required to comply with Section 9.6.1. SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code. - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume

controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Voice communication systems for day-to-day use in assembly occupancies have performed in a fashion superior to those required by NFPA 72. The big venues need big speakers and such speakers are not listed for fire alarm system use. Big volume also is needed. Some of these sophisticated, non-72 systems, have synchronization features so signals are sent to different speakers at different times so the message doesn’t get garbled in a large space with multiple speakers. Such systems are maintained and tested because the successful operation of the venue depends on the speakers being in working order. Emergency power is already required. The submitter’s substantiation refers to manufacturers who have listed combination systems to permit paging. Such systems do not meet the unique needs of assembly occupancies. NFPA 72 systems are problematic. It is not justified to install two systems - one that can be heard and understood, and one that satifies the requirements of NFPA 72 but performs inadequately in assembly venues. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-217 Log #94 SAF-AXM FINAL ACTION: Reject (12.3.4.1(1) and 12.3.4.1(2)) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-311 RECOMMENDATION: Revise 12.3.4.1(1) and 12.3.4.1(2) as originally proposed, i.e., 12.3.4.1.1 Assembly occupancies with occupant loads greater than 300 and all theaters with more than one audience-viewing room shall be provided with an approved fire alarm system in accordance with 9.6.1 and 12.3.4, unless otherwise permitted by 12.3.4.1.2. the following: 12.3.4.1.2 (1) Assembly occupancies that are a part of a multiple occupancy protected as a mixed occupancy (see 6.1.14) shall be permitted to be served by a common fire alarm system, provided that the individual requirements of each occupancy are met. 12.3.4.1.2(2) Voice communication or public address systems complying with 12.3.4.3.3 shall not be required to comply with Section 9.6.1. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code.

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Report on Comments — Copyright, NFPA NFPA 101 − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72. If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards. 3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example; - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. 7. I also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Voice communication systems for day-to-day use in assembly occupancies have performed in a fashion superior to those required by NFPA 72. The big venues need big speakers and such speakers are not listed for fire alarm system use. Big volume also is needed. Some of these sophisticated, non-72 systems, have synchronization features so signals are sent to different speakers at different times so the message doesn’t get garbled in a large space with multiple speakers. Such systems are maintained and tested because the successful operation of the venue depends on the speakers being in working order. Emergency power is already required. The submitter’s substantiation refers to manufacturers who have listed combination systems to permit paging. Such systems do not meet the unique needs of assembly occupancies. NFPA 72 systems are problematic. It is not justified to install two systems - one that can be heard and understood, and one that satifies the requirements of NFPA 72 but performs inadequately in assembly venues. NUMBER ELIGIBLE TO VOTE: 30

BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-218 Log #368 SAF-AXM FINAL ACTION: Hold (12.3.4.3) _______________________________________________________________ SUBMITTER: David J. Quintero, FireSignals, LLC COMMENT ON PROPOSAL NO: 101-145 RECOMMENDATION: Add new text to read as follows: Exit doors from rooms or areas used for assembly occupancies with an occupant load exceeding 300 persons shall be illuminated around the perimeter of the door frame by visible notification appliances listed for the purpose. The visible notification appliance shall be continuous around the perimeter of the door frame consisting of individual lights with a maximum spacing of 24 in. around the doorway. The visible notification appliance shall produce a light that can readily be seen through smoke without undue reflection of light from smoke particles. The visible notification appliance shall flash in sync with other visible fire alarm notification appliances. The minimum total candela rating of the visible notification appliance shall be 1000 cd. SUBSTANTIATION: In the incidences involved in the nightclub fire in Rhode Island and the Chicago club stampede those involved had other options for exit had the exit doors been illuminated by more than the typical above door exit sign. If exits were marked more clearly, i.e. more lights, and made highly visible in dense smoke situations, loss of life may have been prevented by allowing means of exit through multiple locations. In accordance with the Life Safety Code purpose, “... to provide minimum requirements... for safety to life from fire...,” it seems only prudent that the Life Safety Code be made more stringent to keep with this purpose. A small change in the requirements can make a large different in loss of life in the future. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material that has not had public review via the NFPA 101 ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-219 Log #95 SAF-AXM FINAL ACTION: Reject (12.3.4.3.4) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-315 RECOMMENDATION: Revise 12.3.4.3.4 as originally proposed, i.e., 12.3.4.3.4 The announcement shall be made via an approved emergency voice/alarm communication or public address system, provided with an emergency power source, that is audible above the ambient noise level of the assembly occupancy system in accordance with NFPA 72®, National Fire Alarm Code. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code. − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72. If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in

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Report on Comments — Copyright, NFPA NFPA 101 accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards. 3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example; - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. 7. I also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Voice communication systems for day-to-day use in assembly occupancies have performed in a fashion superior to those required by NFPA 72. The big venues need big speakers and such speakers are not listed for fire alarm system use. Big volume also is needed. Some of these sophisticated, non-72 systems, have synchronization features so signals are sent to different speakers at different times so the message doesn’t get garbled in a large space with multiple speakers. Such systems are maintained and tested because the successful operation of the venue depends on the speakers being in working order. Emergency power is already required. The submitter’s substantiation refers to manufacturers who have listed combination systems to permit paging. Such systems do not meet the unique needs of assembly occupancies. NFPA 72 systems are problematic. It is not justified to install two systems - one that can be heard and understood, and one that satifies the requirements of NFPA 72 but performs inadequately in assembly venues. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-220 Log #141 SAF-AXM FINAL ACTION: Reject (12.3.4.3.4) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-315 RECOMMENDATION: Revise 12.3.4.3.4 as originally proposed, i.e., 12.3.4.3.4 The announcement shall be made via an approved emergency voice/alarm communication or public address system, provided with an emergency power source, that is audible above the ambient noise level of the assembly occupancy system in accordance with NFPA 72, National Fire Alarm Code®.

SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code. - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections maybe applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Voice communication systems for day-to-day use in assembly occupancies have performed in a fashion superior to those required by NFPA 72. The big venues need big speakers and such speakers are not listed for fire alarm system use. Big volume also is needed. Some of these sophisticated, non-72 systems, have synchronization features so signals are sent to different speakers at different times so the message doesn’t get garbled in a large space with multiple speakers. Such systems are maintained and tested because the successful operation of the venue depends on the speakers being in working order. Emergency power is already required. The submitter’s substantiation refers to manufacturers who have listed combination systems to permit paging. Such systems do not meet the unique needs of assembly occupancies. NFPA 72 systems are problematic. It is not justified to install two systems - one that can be heard and understood, and one that satifies the requirements of NFPA 72 but performs inadequately in assembly venues.

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Report on Comments — Copyright, NFPA NFPA 101 NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-221 Log #274 SAF-AXM FINAL ACTION: Reject (12.3.5.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected. SUBMITTER: Stephen V. Skalko, Portland Cement Association COMMENT ON PROPOSAL NO: 101-317 RECOMMENDATION: Delete the following text: 12.3.5.1 The following assembly occupancies shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1):’ (1) Bars with live entertainment (2) Dance Halls (3) Discotheques (4) Nightclubs (5) Assembly occupancies with festival seating SUBSTANTIATION: No convincing substantiation is presented in the reason statement, nor was it presented at the Technical Committee on Assembly Occupancies and Membrane Structures meeting, to show that all of the assembly occupancies listed in the new Section 12.3.5.1 should be provided with sprinkler protection when the occupant load exceeds 50 people. In the reasoning statement the focus is on nightclubs. However, the proposal includes bars with live entertainment, dance halls, and assembly occupancies with festival seating. These additional uses do not necessarily have characteristics like night clubs and discotheques, which were identified as problems because the interior configurations are constantly changing or the facility experienced overcrowding regularly. For example, consider a restaurant that will seat 150 people and has a small lounge (bar) with a seating capacity of 60 persons with a musician strolling around entertaining the patrons? That establishment is not likely to operate with constantly changing configurations, nor overcrowding because of space limitations. Proposal 101-317 would require sprinkler protection without showing justification. Or, consider the small church with a fellowship hall accommodating 150 youth every Friday night for dancing. Is this facility the type of assembly occupancy the committee intended should be sprinklered with the use of the term dance hall? Finally, consider a school dining hall that also functions as an auditorium without fixed seating. If occasionally festival type seating, which is defined in the code as “a form of audience/spectator accommodation in which no seating, other than a floor or ground surface is provided for the audience/spectators gathered to observe a performance” is used this new code provision will require sprinkler protection. In all of these examples no data was submitted to show a fire record exists that supports requiring sprinkler protection for these types of assembly occupancies. The present sprinkler threshold of 300 people is sufficient for these occupancy groups. COMMITTEE MEETING ACTION: Accept in Part Revise so as to delete only item (5) for festival seating as follows: 12.3.5.1 The following assembly occupancies shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1): (1) Bars with live entertainment (2) Dance Halls (3) Discotheques (4) Nightclubs (5) Assembly occupancies with festival seating COMMITTEE STATEMENT: Items (1) through (4) capture the assembly occupancies for which a proper life safety package needs sprinkler protection even where there are fewer than 300 occupants. Festival seating for a small number of patrons is difficult to define or recognize. The text proposed at the ROP stage would require sprinklering of a fire house where elementary school students visit and sit on the floor. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 14 Negative: 10 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: ADAMS: I still feel that festival sitting in assembly occupancies still need to be part of the original list. CONNER: I am voting negative on the Committee Action of Accept in Part (APA) and am in favor of rejecting the proposal. After review I have decided that the risk of an AHJ in determining that an occupancy will likely have festival seating or in misunderstanding festival seating is small and that the intent of our definition of festival seating is solely to address those occupancies where overcrowding and similar hazards exist. I do believe the committee should revise the definition and/or annex so it is clearer that school children in

a firehouse or Boy Scouts in a church hall are not construed as festival seating simply because there are not assigned chairs for everyone. FARR: I am voting negative on the Committee Action as I feel that Assembly Occupancies with Festival Seating should continue to be a part of the list as originally submitted. HAYES: Festival Seating by nature offers issues with over crowding. No exemption should apply here regarding a fire suppression system. A perfect example would be the West Warwick Fire, people were stepping on each other to get away from the fire. The crowd crush that ensued actually stopped people from getting out. A fire suppression system would have aided in the exiting of the building. HUGGINS: The potential for high loss of life from a fire is readily apparent in assembly occupancies with festive seating. sprinklers are extremely effective in reducing the risk as shown through field experience and testing at agencies such as NIST. The guidance in the Annex clearly shows what types of facilities are intended to be protected so extreme examples of misapplication is not a reason to reduce the level of fire protection. KELLY: Requiring sprinkler protection for assembly occupancies with festival seating is the one of the main reasons that the TIAs were issued. Assembly occupancies, that utilize festival seating, are regularly used as temporary nightclubs, discotheques, dance halls, and bars with live entertainment. Festival seating in any assembly occupancy increases the chance of “crowd crushing” during an evacuation in an emergency situation. This sprinkler requirement needs to be retained to allow occupants time to safely exit the building. LAKE: By the sheer definition this segment of an assembly occupancy should be protected. There is no clear argument that should exempt them from the sprinkler requirement. 3.3.188.1* Festival Seating. A form of audience/spectator accommodation in which no seating, other than a floor or ground surface, is provided for the audience/spectators gathered to observe a performance. A.3.3.188.1 Festival Seating. Festival seating describes situations in assembly occupancies where live entertainment events are held that are expected to result in overcrowding and high audience density that can compromise public safety. It is not the intent to apply the term festival seating to exhibitions; sports events, dances; conventions; and bona fide political, religious, and educational events. Assembly occupancies with 15 ft2 (1.4 m2) or more per person should not be considered festival seating. PAULS: Having a chance to review my fellow Assembly TC members ballots, please record me as voting negatively on 101-221, 101-233 and 5000-449. I am persuaded by the negative ballot comments of others that all the items should be included in the list of assembly occupancies requiring sprinkler protection. I appreciate that this requires some judgment on the part of enforcing authorities -- using the annex note to the definition of “Festival Seating.” Thus my desired action on the comments is “Reject” except that the reference to the NFPA 13 standard in NFPA 5000 16.3.5.1.1 could go ahead as editorial. PEAVEY: There is no clear argument to exempt assembly occupancies with festival seating from this requirement. Inherently these types of occupancies are subject to overcrowding as much if not more than the other types listed in this requirement. This is further supported by existing language in the definition section of NFPA 101, see excerpts below: 101-3.3.188.1* Festival Seating. A form of audience/spectator accommodation in which no seating, other than a floor or ground surface, is provided for the audience/spectators gathered to observe a performance. A 3.3.188.1 Festival seating describes situations in assembly occupancies where live entertainment events are held that are expected to result in overcrowding and high audience density that can compromise public safety. It is not the intent to apply the term festival seating to exhibitions; sports events; dances; conventions; and bona fide political, religious, and educational events. Assembly occupancies with 1.4 m2 (15 ft2) or more per person should not be considered festival seating. VICTOR: I agree with several of the other committee members, that festival seating should remain on the list. COMMENT ON AFFIRMATIVE SKALKO: Though the committee did agree to remove assembly occupancies with festival seating from the proposed sprinkler thresholds, the proposed language still lists some assembly occupancy types that are not consistent with the fire incidences in nightclubs (The Station, Warwick, RI and E2 Club, Chicago, IL.) that were used to justify the original proposal. The Technical Committee should consider further clarification in the future of the types of bars with live entertainment and dance halls that are of such a hazardous condition that sprinklers are necessary for life safety. If the bar is just a lounge with 50 seats in a larger restaurant, or the dance hall is for 200 people in a church fellowship hall, the justification for mandating sprinklers based on their fire record is far different than all bars with live entertainment or all dance halls. TUBBS: The life safety analysis may show that a sprinkler system would be necessary. To emphasize this, I would suggest that item 5 should read “Assembly occupancies with festival seating, where the required life safety analysis requires sprinklers.” Perhaps this would need to be revised to fit the manual of style.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-222 Log #315 SAF-AXM FINAL ACTION: Accept (12.3.5.2) _______________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-320 RECOMMENDATION: Reconsider the original proposal and accept: 12.3.5.2 The requirements of 12.3.5.1 shall not apply to the following: (1) Assembly occupancies used primarily for worship with fixed seating that are not part of a multiple occupancy protected as a mixed occupancy (see 6.1.14)) SUBSTANTIATION: We agree with the original submitter’s substantiation. Today churches are used for many other activities besides worship. Many new facilities are very large facilities and if they were any other place of assembly containing this many people they would require sprinklers. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 18 Negative: 6 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMEREXPLANATION OF NEGATIVE: CONNER: The cited examples of churches which regularly have scenery, props, special lighting, and other such trappings is not sufficient justification for sprinkling all churches. Many churches do not have this increased hazard and there is still no fire record to change this exception. Those churches where there is increased hazard as a result of elements common to stages should already be treated as stages which, with only a very few exceptions, must be sprinkled and have ventilation and generally conform to all the requirements of stages. An increased hazard justifies increased protection. Because some churches incorporate activities that rely on the increased hazards of stage accouterments does not justify the cost for all churches. MARTINDALE: I am opposed to changing the exemption allowed under this section of the code. There was no supporting evidence presented to the committee to warrant a change. Actions by the committee should be based on facts and not on emotions. The facts show the life safety record for assembly occupancies used primarily for worship with fixed seating has been exemplary and does not warrant more restrictive measures. MILLER: While well intentioned, I do not believe this code change has been entirely justified or thoroughly thought out. There needs to be parameters that are defined for sprinkler thresholds for this special assembly use. To summarily strike the exception is not warranted or responsible. The committee needs to quantify the concerns. A number of churches that I am familiar with would not have their life safety level significantly raised due to the lack of combustible loading and extremely high ceiling heights in most areas. I would suggest the committee stick with its original recommendation and study this issue further. Past fire record certainly does not warrant this change, although I recognize the changes in some of the more modern houses of worship. ROETHER: The facilities referenced in the supporting statement are typically multiple occupancy, therefore currently required to be sprinklered. This provision only permits a place of worship that is not part of a multiple occupancy to be unsprinklered. However, the current language does not limit the occupant load permitted in an unsprinklered place of worship. Even though a large place of worship in all likelihood would be part of a multiple occupancy an unlimited number of people should not be permitted in a place of worship without sprinklers. A church with 500 occupants is still a small church. The current provision addresses many small rural churches that would exceed 300 occupants. Even though many of the urban and suburban churches being constructed today are very large and used for many other activities, these churches are not the same as the small rural church, which is also still being constructed today. Although the action taken by the committee would clarify the point that the larger urban and suburban churches with an occupant load of 300 or more are required to be sprinklered it also compromises the many rural communities in their efforts to construct a new church. Therefore, I vote negative on the committee’s action. SKALKO: During committee discussions on this item many of the places of worship used to justify the elimination of the exception for sprinklers were assembly occupancies using worship halls with elaborate stages and performance type productions as part of the worship service. Though these types of worship centers are consistent with similar assembly occupancies that would require sprinkler protection under the present code, there are also many churches with physical arrangements within the sanctuary that follow the traditional setting with fixed seating, a small chancel platform and some choir seating. No fire record for these traditional church assembly occupancies has been presented to show that the lack of sprinkler protection has created a life safety hazard to the occupants. The committee should propose language to clarify the types of worship centers where sprinkler need to be required without requiring all places of worship to be sprinklered. WILLS: The TC has not been provided with sufficient documentation on the life safety record of churches. In the absence of such documentation, a change of this magnitude is not justified. COMMENT ON AFFIRMATIVE TUBBS: Some places of worship exceed the original intent of this exception.

_______________________________________________________________101-223 Log #339 SAF-AXM FINAL ACTION: Reject (12.3.5.2) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-319 RECOMMENDATION: Reconsider revised: (3) Partial Sprinkler Systems – Buildings shall be permitted to be partially sprinklered. Sprinkler protection may be omitted in the following locations in stadia and arenas: SUBSTANTIATION: The committee is modifying a fundamental requirement of NFPA 13. It is only fair that the partial sprinkler system be identified correctly with respect to the installation standard so that a false sense of property security is not fostered and so that property owners can realize that omissions for the purpose of life safety may affect their property investment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s text does not make an improvement. Rather, the introduction of the term “partial sprinkler systems” would complicate the issue. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-224 Log #340 SAF-AXM FINAL ACTION: Accept in Principle (12.3.5.2) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-320 RECOMMENDATION: Reconsider. SUBSTANTIATION: Many new and existing places of worship are being constructed such that they are indistinguishable from auditoriums with legitimate stages. Many places of worship also host theatrical performances within their facilities exactly because they are auditoriums with stages. The fire loss history of places churches is significant. The life loss is negligible, (though firefighters have been killed in churches), the property loss is total. Although the omission of sprinklers in places of worship is for life safety, it assures the total destruction of the facility. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-222. COMMITTEE STATEMENT: The action on the referenced comment should satisfy the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 18 Negative: 6 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: CONNER: The cited examples of churches which regularly have scenery, props, special lighting, and other such trappings is not sufficient justification for sprinkling all churches. Many churches do not have this increased hazard and there is still no fire record to change this exception. Those churches where there is increased hazard as a result of elements common to stages should already be treated as stages which, with only a very few exceptions, must be sprinkled and have ventilation and generally conform to all the requirements of stages. An increased hazard justifies increased protection. Because some churches incorporate activities that rely on the increased hazards of stage accouterments does not justify the cost for all churches. MARTINDALE: I am opposed to changing the exemption allowed under this section of the code. There was no supporting evidence presented to the committee to warrant a change. Even the person submitting this proposed change acknowledged that, “The life loss (in churches) is negligible...”. Actions by the committee should be based on facts and not emotions. The facts show the life safety record for assembly occupancies used primarily for worship has been exemplary and does not warrant more restrictive measures. MILLER: See my Explanation of Negative on Comment 101-222. ROETHER: The facilities referenced in the supporting statement are typically multiple occupancy, therefore currently required to be sprinklered. This provision only permits a place of worship that is not part of a multiple occupancy to be unsprinklered. However, the current language does not limit the occupant load permitted in an unsprinklered place of worship. Even though a large place of worship in all likelihood would be part of a multiple occupancy an unlimited number of people should not be permitted in a place of worship without sprinklers. A church with 500 occupants is still a small church. The current provision addresses many small rural churches that would exceed 300 occupants. Even though many of the urban and suburban churches being constructed today are very large and used for many other activities, these churches are not the same as the small rural church, which is also still being constructed today. Although the action taken by the committee would clarify the point that the larger urban and suburban churches with an occupant load of 300 or more are required to be sprinklered it also compromises the many rural communities in their efforts to construct a new church. Therefore, I vote negative on the committee’s action.

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Report on Comments — Copyright, NFPA NFPA 101 SKALKO: During committee discussions on this item many of the places of worship used to justify the elimination of the exception for sprinklers were assembly occupancies using worship halls with elaborate stages and performance type productions as part of the worship service. Though these types of worship centers are consistent with similar assembly occupancies that would require sprinkler protection under the present code, there are also many churches with physical arrangements within the sanctuary that follow the traditional setting with fixed seating, a small chancel platform and some choir seating. No fire record for these traditional church assembly occupancies has been presented to show that the lack of sprinkler protection has created a life safety hazard to the occupants. The committee should propose language to clarify the types of worship centers where sprinkler need to be required without requiring all places of worship to be sprinklered. WILLS: The TC has not been provided with sufficient documentation on the life safety record of churches. In the absence of such documentation, a change of this magnitude is not justified. The substantiation for this comment basically agrees that this is a property protection issue and not life safety. COMMENT ON AFFIRMATIVE TUBBS: Some places of worship exceed the original intent of this exception. _______________________________________________________________101-224a Log #CC279 SAF-AXM FINAL ACTION: Accept (12.4.2.4 and 13.4.2.4) _______________________________________________________________ SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-324 RECOMMENDATION: Insert a new 12.4.2.4 and 13.4.2.4 (and renumber existing 12.4.2.4 through 12.4.2.10 and 13.4.2.4 through 13.4.2.10 as needed) as follows: 12.4.2.4 Where smoke-protected assembly seating and its means of egress are located wholly outdoors, capacity shall be permitted to be provided in accordance with Table 12.4.2.4. 13.4.2.4 Where smoke-protected assembly seating and its means of egress are located wholly outdoors, capacity shall be permitted to be provided in accordance with Table 13.4.2.4.

Table 12.4.2.4 Capacity Factors for Outdoor Smoke-Protected Assembly Seating

Clear Width per Seat ServedStairs Passageways,

Ramps, and Doorways

Feature in. mm in. mmOutdoor smoke-protected assembly seating

0.08 AB 2.0 AB 0.06 C 1.5 C

Table 13.4.2.4 Capacity Factors for Outdoor Smoke-Protected Assembly Seating

Clear Width per Seat ServedStairs Passageways,

Ramps, and Doorways

Feature in. mm in. mmOutdoor smoke-protected assembly seating

0.08 AB 2.0 AB 0.06 C 1.5 C

SUBSTANTIATION: The sliding scale applied to capacity factors in Tables 12.4.2.3 and 13.4.2.3 was developed to address the peculiarities of indoor smoke-protected assembly seating. The concept was that a greater number of seats meant a greater overall volume of the room/bowl. The greater volume of space bought extra time for egress while conditions remained tenable. For outdoor assembly seating that is smoke protected, a reduced capacity factor should be offered regardless of total number of seats. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-224b Log #CC277 SAF-AXM FINAL ACTION: Reject (12.4.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. Comment 101-194 rejects ROP Proposal 101-292 so as NOT to include a new 11.8.6 on elevator hoistway separation.SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-292 RECOMMENDATION: Revise as follows: 12.4.4 High-Rise Buildings. High-rise assembly occupancy buildings and high-rise mixed occupancy buildings that house assembly occupancies in the

high-rise portions of the building shall comply with Section 11.8 other than 11.8.6. [Note: the reference above to 11.8.6 is meant to be the paragraph addressing Elevator Hoistway Separations created by Proposal 101-292.] SUBSTANTIATION: Assembly occupancies subject to the provisions of Section 11.8 will be in fully sprinklered buildings. In sprinklered buildings there is no need for elevator separation. This is consistent with work done by Bukowski at NIST and per history in GSA buildings. The elevator is not part of the means of egress. See Comment 101-194a. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-225 Log #222 SAF-AXM FINAL ACTION: Reject (12.4.5.6) _______________________________________________________________ SUBMITTER: Gregory J. Cahanin, Cahanin Fire & Code Consulting COMMENT ON PROPOSAL NO: 101-325 RECOMMENDATION: No revision proposed. Reconsider proposal as submitted. SUBSTANTIATION: The material and substantiation submitted with the original proposal was substantial and definitive in the consideration of defining types of stages that require fire curtains at a lower level and types of stages that would not be included in a fire curtain requirement. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Inadequate substantiation for the change requested. See Committee Statement for the rejection of ROP Proposals 101-325 and 101-326. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-226 Log #204 SAF-AXM FINAL ACTION: Reject (12.7.1 and 13.7.1) _______________________________________________________________ SUBMITTER: Michael Tierney, Builders Hardware Manufacturers Association COMMENT ON PROPOSAL NO: 101-332 RECOMMENDATION: Revise the new 12.7.1 and 13.7.1 being inserted by Proposal 101-332 as follows: 12.7.1 Means of Egress Inspection. 12.7.1.1 The building owner or agent shall inspect the means of egress to ensure it is maintained free of obstructions, and correct any deficiencies found, prior to each opening of the building to the public. 12.7.1.2 The building owner or agent shall assure that door assemblies are inspected annually for compliance with the operational provisions of 7.2.1. 12.7.1.3 The door assembly inspection required by 12.7.1.2 shall be performed by a qualified individual specifically trained to perform the inspection. 12.7.1.4 12.7.1.2 The building owner or agent shall prepare and maintain records of the date and time of each inspection on approved forms, listing any deficiencies found and actions taken to correct them. 13.7.1 Means of Egress Inspection. 13.7.1.1 The building owner or agent shall inspect the means of egress to ensure it is maintained free of obstructions, and correct any deficiencies found, prior to each opening of the building to the public. 13.7.1.2 The building owner or agent shall assure that door assemblies are inspected annually for compliance with the operational provisions of 7.2.1. 13.7.1.3 The door assembly inspection required by 13.7.1.2 shall be performed by a qualified individual specifically trained to perform the inspection. 13.7.1.4 13.7.1.2 The building owner or agent shall prepare and maintain records of the date and time of each inspection on approved forms, listing any deficiencies found and actions taken to correct them. Renumber existing 12.7.1 through 12.7.11 and 13.7.1 through 13.7.11 as needed. SUBSTANTIATION: Proper inspection of critical door and hardware components is not performed at adequate frequencies due to lack of specific code requirements. Annual inspection would be expected to improve compliance and safety of the doors and hardware, similar to elevators, fire alarms, fire extinguishers, sprinklers, and rolling fire doors which have formal programs. Site surveys consistently reveal doorways which have been modified, damaged and otherwise fail to meet original requirements. Associated Appendix Material: Associated Annex Notes: (1) It is not the intent of the annual inspection to verify design requirements, but to ensure that the door and hardware continue over time to function as required by 7.2.1 for life safety.

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Report on Comments — Copyright, NFPA NFPA 101 (2) Trained individual should refer to a certified Architectural Hardware Consultant (AHC) or other qualified individual acceptable to the Authority Having Jurisdiction. (3) Suggested inspection form TBD. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The provisions of 12.7.1 and 13.7.1 were drafted as necessary inspection items that are to be performed by the building owner/operator on a frequently recurring basis, not by special experts whose services need to be engaged. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-226a Log #CC282 SAF-AXM FINAL ACTION: Accept (12.7.3.5 and 13.7.3.5) _______________________________________________________________ SUBMITTER: Technical Committee on Assembly Occupancies and Membrane Structures COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add text as follows: 12.7.3.5 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to assembly occupancies. 13.7.3.5 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to assembly occupancies. SUBSTANTIATION: The action by SAF-FUR on Comment 101-175 and Comment 101-176 has the effect of mandating that newly introduced upholstered furniture and mattresses be cigarette ingition resistant in all occupancies. The SAF-FUR furnishings committee has not provided adequate substantiation to make cigarette ignition resistance a requirement for newly introduced upholstered furniture and mattresses in all occupancies. An argument like “the Feds require it anyway for NEW mattresses; and the majority of U.S. upholstered furniture manufacturers voluntarily do so” is inadequate. “Newly introduced” upholstered furniture might be existing furniture moved from one building to another and there is no substantiation to impose a requirement that would be difficult to meet or enforce. The proposed requirement would be difficult to meet or enforce in theaters where props change from show to show. Smoking is prohibited in many assembly occupancies. See Comment 101-175b that modifies the text of 10.3.2 to permit occupancy chapter exemptions. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-227 Log #276 SAF-AXM FINAL ACTION: Reject (12.7.5.1 and 13.7.5.1) _______________________________________________________________ SUBMITTER: Stephen V. Skalko, Portland Cement Association COMMENT ON PROPOSAL NO: 101-335 RECOMMENDATION: Revise text to read as follows: 12.7.5.1 Assembly occupancies listed in (1) or (2) shall be provided with a minimum of one trained crowd manager or crowd manager supervisor. (1) In clubs, dance halls, discotheques and similar assembly occupancies with live entertainment having an occupant load of more than 250. (2) Except as required in (1), in assembly occupancies having occupant loads exceeding 1000. Where the occupant load exceeds 250, additional trained crowd managers or crowd supervisors shall be provided at a ratio of 1 crowd manager/supervisor for every 250 occupant unless otherwise permitted by the following. No change to the remainder of section. Same change to 13.7.5.1. SUBSTANTIATION: Reducing the occupant threshold when crowd managers are required for all assembly occupancies from 1000 to 250 is not justified. Not all assembly occupancies with occupant loads over 250 need persons trained in crowd management. For example, school lunchrooms, church fellowship hall and small restaurants may have a poor track record for fire incidences without crowd managers present. The substantiation also states that the AHJ is given latitude for higher occupant load thresholds for assembly occupancies where the lack of crowd management has not been problematic. That may apply to the examples given. Note however, that latitude is predicated on the presence of an automatic sprinkler protection system in addition to the nature of the event. These smaller assembly occupancies may not have sprinkler protection since the sprinkler threshold for these buildings in Section 12.3.5.1 is for occupant loads more than 300 people. In addition, there are exceptions to the mandatory sprinkler requirements in Section 12.3.5.2 that can include school lunchrooms and

church fellowship halls. This may result in, based on the application of these proposed requirements for crowd managers, that the AHJ must now require sprinkler protection in order to relax the crowd management requirements. Where is the justification for increasing the stringency by requiring crowd managers or sprinkler systems for small restaurants, school lunchrooms, and church fellowship halls? The reasoning statement refers to assembly occupancies such as clubs which need a certain minimal level of management capability for life safety. Reference was also made to recent problems in assembly occupancies which one can infer is the unfortunate events that occurred at The Station in Warwick, RI and the E2 Club in Chicago, IL. If emergency events in assembly occupancies such as those are the intended problem that needs to be addressed by the code, then the proposed language should specifically refer to those types of assembly occupancies. This proposal revises Proposal 101-335 to divide the provisions for crowd management into assembly occupancies with characteristics like clubs and all other assembly uses. Those assembly occupancies with club characteristic have the threshold for crowd management set at more than 250, which is consistent with the intent of the original and is close to the occupant load threshold when sprinkler protection will be required. All other assembly occupancies will be required to have crowd managers when the occupant load exceeds 100 people, which is the present threshold in the code. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter provides no compelling evidence to change the langauge from that processed via the Tentative Interim Amendment (TIA). NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 22 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: MILLER: The proposed language of Comment 101-227 should be accepted as it addresses some of my previous concerns. The committee change would require a small fast food restaurant or corner tavern with an occupant load of 50 to have a crowd manager. Further, this requirement is essentially unenforceable by the authority having jurisdiction and lacks any real world controllability or accountability. First, what is the program and who are the teachers for training a crowd manager? Secondly, what are the pass/fail criteria for being a crowd manager? When the minimum wage workers who man most of these venues quit, then what is the follow up program for ensuring he/she is replaced immediately with a qualified new crowd manager? The proposed requirement places unenforceable requirements into the code that would seem to, in all probability, have had little to no impact in the recent incidents. In fact, much more enforceable and more meaningful existing code requirements have seemed to have not been followed, which would have possibly had a much greater impact in avoiding these incidents. In addition, the new requirements are much more stringent for much less hazardous or crowded assembly venues (i.e., venues other than nightclubs where there is alcohol, high occupant loads, low lights, and loud music, which make patrons much less aware of a developing emergency). These requirements should remain as currently written more appropriately for much larger venues when management has the resources and trained staff. For movie theaters which have had no recordable loss of life in years, the logistics and expense of conscientiously attempting to comply and enforce this proposed change is large and unwarranted. High turnover rates in this industry, as well as in the bar and restaurant industry further make this proposed change difficult and impractical. Additionally, local curfews and labor laws may preclude the use of teenage help for crowd managers. In assembly occupancies where this is the predominant labor force, it would be necessary to hire additional personnel to provide this service. Again, this proposal should be targeted toward nightclubs rather than be a blanket application to all assembly occupancies. EXPLANATION OF ABSTENTION: SKALKO: It was apparent from the deliberations at the committee meeting that the TC had previously committed itself to the Tentative Interim Amendment and was not willing to reconsider what effect their action will have on all assembly occupancies, though the justification used previously for lowering the occupant load threshold for crowd managers were assembly occupancies involving nightclub like environments. A negative ballot will not change the results of the committee but I cannot affirm the committee action, therefore I wish to be recorded as an abstention on this item. COMMENT ON AFFIRMATIVE CONNER: I believe that the requirement for a Crowd Manager is often seen as over burdensome in some assembly occupancies. I don’t believe that this is asking for more than having someone in charge and responsible for the occupants safety. Any time there is a building constructed or used for gathering together 50 or more people the changes that the typical occupant will trust that someone else has considered their safety increases. That trust is justified and should be met. Time after time bad or no management has allowed a hazardous condition to grow to one resulting in injuries and deaths. This does require some effort but in many cited examples of where this was inappropriate, not much effort is actually required. It is as little as the leader or an employee in attendance in the building knowing they have responsibility for the occupants

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Report on Comments — Copyright, NFPA NFPA 101 safety and having familiarized themselves with the means of egress, location of light switches, and similar such common sense items and that they have responsibility. In many instances it may not require more than the preparation one sitting in an emergency exit row of an airplane receives each flight. Training and assigning responsibility are the most cost effective safety precaution available. _______________________________________________________________101-228 Log #316 SAF-AXM FINAL ACTION: Accept in Principle (12.7.9.3) _______________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-337 RECOMMENDATION: Revise to read: 12.7.9.3 Where required by the authority having jurisdiction, the owner shall provide a copy of the inspection report and certification that such inspection has been performed. SUBSTANTIATION: A copy of the inspection report needs to be forwarded to the AHJ as requested not just a statement stating that an inspection was performed. The AHJ can look at the report and note any deficiencies and ensure corrective action has taken place. A certificate will only state that an inspection has taken place. COMMITTEE MEETING ACTION: Accept in Principle Revise as follows: 12.7.9.3 Where required by the authority having jurisdiction, the owner shall provide a copy of the inspection report and certification that such inspection has been performed. 13.7.9.3 Where required by the authority having jurisdiction, the owner shall provide a copy of the inspection report and certification that such inspection has been performed. COMMITTEE STATEMENT: The same change needs to be made to Chapter 13 for consistency. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-229 Log #172 SAF-AXM FINAL ACTION: Accept in Principle (13.2.2.3.2.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-338 RECOMMENDATION: Reject the Proposal. SUBSTANTIATION: This material is not appropriate for the Life Safety Code. Attention is directed to the long TCC note attached with Proposal 128 as well as to this proposal. At best, these could be used in one- and two-family dwellings and that chapter does not use it. All of the other occupancy committees have rejected the concept including industrial and storage occupancies. The material has several flaws including among others how does this work with less than 10 people? The one place the AXM committee accepted it, would not normally be occupied by more than 10 people. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-230. COMMITTEE STATEMENT: The action should satisfy the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-230 Log #53 SAF-AXM FINAL ACTION: Accept in Principle (13.2.2.3.2.3 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-338 RECOMMENDATION: (a) Give consideration to DiPilla’s and Shulman’s Explanation of Negative (on Proposal 101-128) so as to make any needed changes in its action on Proposal 101-297 and Proposal 101-338 as SAF-AXM was the only technical committee to recognize the use of the escape devices or systems. (b) Reconsider the applicability of the new provision for catwalks given that the proposed 7.2.14 seems not to be applicable to use inside a building. (c) Take care in the proper use of the terms “means of egress” and “means of escape.” (d) Take note that UL has withdrawn its certification of components of such systems, and ASTM has established a project to develop a product standard. DI PILLA: While I believe this concept has great potential, I don’t believe it is ready to be inserted into a national consensus code. At present, there are no approved/listed/certified products. In fact, there is not even a listing organization yet.

If placed in the code, this would place the AHJ in the position of evaluating these complex egress components even though there has yet to be any substantial research on even HOW to evaluate them. Taking into account environmental conditions, building loading, structure, and balance, adequacy of anchoring, and a host of other factors must be considered—and there is no methodology (nor sufficient research to date) to do so. In addition, the extent of operational/management control is essential for such a means of egress to be safe, let alone effective. These controls also have yet to be standardized. There is also the potential for these devices to be used (or misused) for purposes other than “last resort” egress. In addition, the impact of these components on marking/signage, and related physical aspects of egress have not been established. I believe that this proposal should not be accepted until: 1. a listing organization program has been established, 2. a methodology for assessing installation and use has been developed, and 3. clear, minimum operational controls have been standardized. SHULMAN: The Code currently includes a comprehensive set of egress and escape requirements for various occupancies that have been well thought out and ingrained into the building and life safety codes used by our society. They are based on the concept of either evacuating occupants in an orderly, safe fashion, or protecting them in place in a protected area of refuge within the building. This proposal includes provisions for permitting escape devices and systems to be used in addition to required means of egress and escape provisions. On the surface this would appear to be acceptable, using the “more is better” argument. However, we have serious concerns about the actual impact that such systems have on the behavior and safety of occupants during emergency evacuation conditions that have not yet been adequately addressed in this proposal. This includes the possibility that the existence of such systems in a building may disrupt the orderly evacuation of the building or the efforts of fire service professionals, and that occupants attempting to use these systems under panic conditions may expose themselves or others to potentially dangerous conditions as they struggle to use these systems. UL has received input from members of the fire service that indicates a strong preference for building occupants to follow established plans for egress of the building if at all possible, or “stay put” if they find the existing means of escape blocked and permit fire service personnel to undertake rescue activities. UL is of the opinion that, on the whole, this is the more advisable course of action in the present state. Both the building infrastructure and the education provided to building occupants have for many years focused on moving people towards the marked “EXITS” within the building during any evacuation scenario. Providing widely variable alternatives to be used at unpredictable times, at the discretion of particular individuals, throws out the certainty and familiarity with the established routine that is essential for its smooth operation during the high percentage of the time that the routine presents the best method for minimizing fire deaths. The “counter-flow” created by intentional attempts to redirect people or individual decisions of occupants – in high-panic mode – will in itself likely lead to significant injuries and problems. It will be nearly impossible for the decision whether to utilize an external and supplemental evacuation system to be made in a rational, informed manner. The entire premise behind these systems is that they will serve as a “last resort” – an act of desperation when all hope in the other established systems fail. To argue that “any option” is acceptable as a last resort is fallacious. The premise assumes the conclusion, i.e., the individual has not other changes of rescue, that the alternative is viable, and that the individual is capable of making a rational choice under extremely stressful circumstances. Further, the simple existence of the option will likely cause it to be considered prematurely. Decisions will be made by occupants based on limited knowledge and information, with a lack of firsthand experience with both the secondary equipment and the emergency scenario. The individual(s) responsible for making the decision may also be under considerable pressure by other building occupants, further degrading their capability to make a rational decision. The decision is a challenging one with serious implications, and decision-making quality will decline during times of high stress. The proposal does not provide AHJs or building owners with sufficient guidance on how to select and coordinate appropriate systems. The proposal also does not contain adequate measures to promote reliable and adequate testing and maintenance of the systems on an ongoing basis. There will (hopefully) be no real opportunities to rigorously test any number of these systems in a manner that can lead to a decision as to their ability to perform effectively when needed – during a time of some indeterminate facility escape route failure and imminent total infrastructure collapse. The uncertain human factors alone – including the behavioral unpredictability of both the system deployment decision makers and the other facility occupants – render any attempt at a system effectiveness evaluation highly unreliable. We also suspect that occupants attempting to utilize the equipment in a panic situation are likely to overload it in the escape frenzy. In conclusion, it is our belief that sufficient research into the potential use of these products, including detailed human factor/behavior studies, have not been conducted to address the potential hazards associated with their installation and use under emergency evacuation conditions. Further, the overall effect of these products and inherently variable decisions about their use as they relate to occupant behaviors with respect to emergency evacuation plans in general

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Report on Comments — Copyright, NFPA NFPA 101 needs to be carefully considered. Based on these and other concerns, UL has chosen to not list such secondary emergency escape devices, and at this time has no intention to develop a certification program for such products. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject ROP Proposals 101-297 and 101-338 so as NOT to recognize escape devices within the means of egress from catwalks and similar spaces. COMMITTEE STATEMENT: The SAF-MEA committee has revised its action so that escape devices will not be permitted to serve as required means of egress. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-231 Log #54 SAF-AXM FINAL ACTION: Accept in Principle (13.2.5.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-341 RECOMMENDATION: Give consideration to the subject of an error in reporting the new text raised in Roether’s Comment on Affirmative, so as to make any needed changes. ROETHER: The proposal accepted by the committee does not exactly match the proposal written in this ballot beyond editorial. I vote to affirm the committee’s action on the premise that the original proposal is correct. Specifically, (8)(a) should read: “The riser height is designed non-uniform.” The original proposed exception No. 2 to 15.2.5.6.6.2(C) allowed construction caused non-uniformities to occur where the design had non-uniform riser height. The ballot would require the contractor to make the riser heights uniform where it was designed non-uniform and then be allowed to exceed 3/16 in. where it was designed uniform. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise 13.2.5.6.6(8)(a) from that shown in ROP Proposal 101-341 as follows: (a) The riser height is designed non- uniform. COMMITTEE STATEMENT: The action does what SAF-AXM member Roether requested. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-232 Log #55 SAF-AXM FINAL ACTION: Accept in Principle (13.3.4.2.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-343 RECOMMENDATION: Reconsider the deletion and make any needed changes to assure that the requirement for emergency power is not lost for existing alarm systems which cannot be made to comply with the requirements of the current edition of NFPA 72. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject ROP Proposal 101-343 so as to retain the requirement for emergency power in 13.3.4.2.1. COMMITTEE STATEMENT: For existing systems, the requirement for emergency power needs to be maintained explicitly. For new systems, strict reliance on the installation requirements of NFPA 72 will suffice. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-233 Log #275 SAF-AXM FINAL ACTION: Reject (13.3.5.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT because the committee meeting action failed to receive the required 2/3 confirmation during letter balloting.NOTE: Since the ballot on this Comment did not confirm the Committee Action, the comment is being rejected.SUBMITTER: Stephen V. Skalko, Portland Cement Association COMMENT ON PROPOSAL NO: 101-346 RECOMMENDATION: Delete the following text: 13.3.5.1 The following assembly occupancies shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1):’ (1) Bars with live entertainment (2) Dance Halls (3) Discotheques

(4) Nightclubs (5) Assembly occupancies with festival seating SUBSTANTIATION: No convincing substantiation is presented in the reason statement, nor was it presented at the Technical Committee on Assembly Occupancies and Membrane Structures meeting, to show that all of the assembly occupancies listed in the new Section 12.3.5.1 should be provided with sprinkler protection when the occupant load exceeds 50 people. In the reasoning statement the focus is on nightclubs. However, the proposal includes bars with live entertainment, dance halls, and assembly occupancies with festival seating. These additional uses do not necessarily have characteristics like night clubs and discotheques, which were identified as problems because the interior configurations are constantly changing or the facility experienced overcrowding regularly. For example, consider a restaurant that will seat 150 people and has a small lounge (bar) with a seating capacity of 60 persons with a musician strolling around entertaining the patrons? That establishment is not likely to operate with constantly changing configurations, nor overcrowding because of space limitations. Proposal 101-317 would require sprinkler protection without showing justification. Or, consider the small church with a fellowship hall accommodating 150 youth every Friday night for dancing. Is this facility the type of assembly occupancy the committee intended should be sprinklered with the use of the term dance hall? Finally, consider a school dining hall that also functions as an auditorium without fixed seating. If occasionally festival type seating, which is defined in the code as “a form of audience/spectator accommodation in which no seating, other than a floor or ground surface is provided for the audience/spectators gathered to observe a performance” is used this new code provision will require sprinkler protection. In all of these examples no data was submitted to show a fire record exists that supports requiring sprinkler protection for these types of assembly occupancies. The present sprinkler threshold of 300 people is sufficient for these occupancy groups. COMMITTEE MEETING ACTION: Accept in Part Revise so as to delete only item (5) for festival seating as follows: 13.3.5.1 Where occupant load exceeds 100, the following assembly occupancies shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1): (1) Bars with live entertainment (2) Dance Halls (3) Discotheques (4) Nightclub s (5) Assembly occupancies with festival seating COMMITTEE STATEMENT: Items (1) through (4) capture the assembly occupancies for which a proper life safety package needs sprinkler protection even with small occupant loads. Festival seating for a small number of patrons is difficult to define or recognize. The text proposed at the ROP stage would require sprinklering of a fire house where 100 elementary school students visit and sit on the floor. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 15 Negative: 9 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: ADAMS: I still feel that festival sitting in assembly occupancies still need to be part of the original list. CONNER: I am voting negative on the Committee Action of Accept in Part (APA) and am in favor of rejecting the proposal. After review I have decided that the risk of an AHJ in determining that an occupancy will likely have festival seating or in misunderstanding festival seating is small and that the intent of our definition of festival seating is solely to address those occupancies where overcrowding and similar hazards exist. I do believe the committee should revise the definition and/or annex so it is clearer that school children in a firehouse or Boy Scouts in a church hall are not construed as festival seating simply because there are not assigned chairs for everyone. FARR: I am voting negative on the Committee Action as I feel that Assembly Occupancies with Festival Seating should continue to be a part of the list as originally submitted. HAYES: Festival Seating by nature offers issues with over crowding. No exemption should apply here regarding a fire suppression system. A perfect example would be the West Warwick Fire, people were stepping on each other to get away from the fire. The crowd crush that ensued actually stopped people from getting out. A fire suppression system would have aided in the exiting of the building. KELLY: Requiring sprinkler protection for assembly occupancies with festival seating is the one of the main reasons that the TIAs were issued. Assembly occupancies, that utilize festival seating, are regularly used as temporary nightclubs, discotheques, dance halls, and bars with live entertainment. Festival seating in any assembly occupancy increases the chance of “crowd crushing” during an evacuation in an emergency situation. This sprinkler requirement needs to be retained to allow occupants time to safely exit the building. LAKE: By the sheer definition this segment of an assembly occupancy should be protected. There is no clear argument that should exempt them from the sprinkler requirement.

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Report on Comments — Copyright, NFPA NFPA 101 3.3.188.1* Festival Seating. A form of audience/spectator accommodation in which no seating, other than a floor or ground surface, is provided for the audience/spectators gathered to observe a performance. A.3.3.188.1 Festival Seating. Festival seating describes situations in assembly occupancies where live entertainment events are held that are expected to result in overcrowding and high audience density that can compromise public safety. It is not the intent to apply the term festival seating to exhibitions; sports events, dances; conventions; and bona fide political, religious, and educational events. Assembly occupancies with 15 ft2 (1.4 m2) or more per person should not be considered festival seating. PAULS: Having a chance to review my fellow Assembly TC members ballots, please record me as voting negatively on 101-221, 101-233 and 5000-449. I am persuaded by the negative ballot comments of others that all the items should be included in the list of assembly occupancies requiring sprinkler protection. I appreciate that this requires some judgment on the part of enforcing authorities -- using the annex note to the definition of “Festival Seating.” Thus my desired action on the comments is “Reject” except that the reference to the NFPA 13 standard in NFPA 5000 16.3.5.1.1 could go ahead as editorial. PEAVEY: There is no clear argument to exempt assembly occupancies with festival seating from this requirement. Inherently these types of occupancies are subject to overcrowding as much if not more than the other types listed in this requirement. This is further supported by existing language in the definition section of NFPA 101, see excerpts below: 101-3.3.188.1* Festival Seating. A form of audience/spectator accommodation in which no seating, other than a floor or ground surface, is provided for the audience/spectators gathered to observe a performance. A 3.3.188.1 Festival seating describes situations in assembly occupancies where live entertainment events are held that are expected to result in overcrowding and high audience density that can compromise public safety. It is not the intent to apply the term festival seating to exhibitions; sports events; dances; conventions; and bona fide political, religious, and educational events. Assembly occupancies with 1.4 m2 (15 ft2) or more per person should not be considered festival seating. VICTOR: I agree with several of the other committee members, that festival seating should remain on the list. COMMENT ON AFFIRMATIVE SKALKO: Though the committee did agree to remove assembly occupancies with festival seating from the proposed sprinkler thresholds, the proposed language still lists some assembly occupancy types that are not consistent with the fire incidences in nightclubs (The Station, Warwick, RI and E2 Club, Chicago, IL.) that were used to justify the original proposal. The Technical Committee should consider further clarification in the future of the types of bars with live entertainment and dance halls that are of such a hazardous condition that sprinklers are necessary for life safety. If the bar is just a lounge with 50 seats in a larger restaurant, or the dance hall is for 200 people in a church fellowship hall, the justification for mandating sprinklers based on their fire record is far different than all bars with live entertainment or all dance halls. TUBBS: The life safety analysis may show that a sprinkler system would be necessary. To emphasize this, I would suggest that item 5 should read “Assembly occupancies with festival seating, where the required life safety analysis requires sprinklers.” Perhaps this would need to be revised to fit the manual of style.


_______________________________________________________________101-235 Log #122 SAF-AXM FINAL ACTION: Reject (13.3.5.2) _______________________________________________________________ SUBMITTER: Eddie Phillips, Southern Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-349 RECOMMENDATION: Reconsider the original proposal and accept. 13.3.5.2 Any assembly occupancy providing illumination levels less than 1ft-candle along the floors of exit access in accordance with the provision of 7.8.1.3(3) shall be protected throughout by an approved automatic sprinkler system in accordance with Section 9.7. SUBSTANTIATION: The low lighting conditions permitted by 7.8.1.3(3) are one of the prime conditions that contribute to confusion and panic in an emergency situation. However, normal levels of illumination, 1 ft-candle, are incompatible with performances or projections involving direct light. Therefore, the counter to this low lighting condition is an increased level of protection in other areas. Fire sprinkler protection is the most logical approach due to reliability and fire control at the area or origin. Lastly, this proposal addresses one of the primary concerns with TIA 739R. That is, there is no clear definition of a bar, dance hall, nightclub, or discotheques. Without a clear definition, endless debates will occur as to application. The utilization of 7.8.1.3(3) as a baseline will allow for a measurable standard to determine application. We need to be providing better protection for existing facilities where low lighting condition exist.

COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Statement for rejection of ROP Proposal 101-349. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-236 Log #341 SAF-AXM FINAL ACTION: Reject (13.3.5.2) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-348 RECOMMENDATION: Reconsider revised: Partial Sprinkler Systems – Buildings shall be permitted to be partially sprinklered. Sprinkler protection may be omitted in the following locations in stadia and arenas: SUBSTANTIATION: The committee is modifying a fundamental requirement of NFPA 13. It is only fair that the partial sprinkler system be identified correctly with respect to the installation standard so that a false sense of property security is not fostered and so that property owners can realize that omissions for the purpose of life safety may affect their property investment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter’s text does not make an improvement. Rather, the introduction of the term “partial sprinkler systems” would complicate the issue. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-237 Log #260 SAF-END FINAL ACTION: Reject (14.3.6) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-365 RECOMMENDATION: No revisions proposed. We support the proposal as submitted by the proponent. SUBSTANTIATION: We do not believe that such a trade-off is appropriate where life safety is concerned. In such cases, it is advantageous and desirable to maintain the built-in passive fire resistant protection, as well as to provide the active automatic sprinkler system protection, where life safety is involved. In our opinion, trade-offs are entirely inappropriate where life safety is concerned. We believe that a balanced approach should be used to assure that the appropriate level of life safety will be provided to the occupants of the building who must rely upon the corridors to exit the building. A secondary benefit of 1-hour fire resistance rated corridors is that they also assist fire fighters in doing their job by providing a protected means of access to the interior of the building where they can perform their search and rescue missions, as well as fire fighting operations, in relative safety. Fire resistance rated corridors can provide fire fighters with additional time to do their jobs more effectively and safely. We strongly believe that sprinkler trade-offs should not be allowed for means of egress components. At present, NFPA 5000 does not allow sprinkler trade-offs for the fire resistance ratings required for exit stair enclosures, horizontal exits, and exit passageways. So why should sprinkler trade-offs be allowed for the 1-hour fire resistance rating of corridors which provide a protected egress path giving access to these exit elements? Furthermore, other sprinkler trade-offs related to the means of egress in buildings have already been provided for in NFPA 5000. For example, travel distance is allowed to be increased from 150 feet to 200 feet where automatic sprinkler systems are provided. The separation of exits (remoteness) is also allowed to be reduced where automatic sprinkler systems are installed. Interior finish requirements are relaxed within corridors where Class C interior finish can be used in lieu of Class B interior finish and Class B interior finish can be used where Class A interior finish would otherwise be required if not for the installation of automatic sprinklers. And dead end corridors are allowed to be increased in length by 150%, i.e. from 20 feet to 50 feet, and the common path of travel is allowed to be increased from 75 feet to 100 feet where automatic sprinkler systems are provided. We are concerned that the compounding effect of sprinkler trade-offs could lead to greater risk to the life safety of the building occupants, especially if combined with the elimination of the 1-hour fire resistance rating for corridors providing access to the exits or the exit stairs. Too much reliance on automatic sprinkler systems may not be wise where life safety is a key consideration. We strongly believe that a balanced approach to fire and life safety in buildings should be provided to greatly enhance the probability that the intended level of fire and life safety prescribed by the building code will be provided when a fire occurs, even if something should go wrong.

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Report on Comments — Copyright, NFPA NFPA 101 We acknowledge that automatic sprinkler systems are an important fire protection tool, but they are not infallible. Like any mechanical system, they are subject to failure. In fact, a recent statistical analysis of automatic sprinkler system performance conducted by NFPA for the period from 1989-1998 has concluded that automatic sprinkler systems fail to operate in at least 1 out of every 6 fires that occur in sprinklered buildings where the fire was judged large enough to have activated the sprinklers. In our opinion such a level of performance does not justify trading-off built-in fire resistant protection for the means of egress in buildings where the occupant’s lives are at risk in a fire emergency. A balanced design approach of providing built-in fire resistive protection in conjunction with automatic sprinkler protection, in our opinion, will go a long way toward assuring that the level of fire and life safety intended by the building code will be delivered during a fire emergency. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: With sprinkler protection, the 30-min. smoke partition provides adequate protection at corridor walls. Educational occupancies operate via a mass, prompt, organized evacuation. The commenter’s statistics are based on non-sprinklered buildings. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-237a Log #CC353 SAF-END FINAL ACTION: Accept (14.7.4.4 and 15.7.4.4) _______________________________________________________________ SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add text as follows: 14.7.4.4 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to educational occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7. 15.7.4.4 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to educational occupancies protected throughout by an approved automatic sprinkler system in accordance with Section 9.7. SUBSTANTIATION: The action by SAF-FUR on Comment 101-175 and Comment 101-176 has the effect of mandating that newly introduced upholstered furniture and mattresses be cigarette ingition resistant in all occupancies. See Comment 101-175a that modifies the text of 10.3.2 to permit occupancy chapter exemptions. Educational occupancies are highly supervised when students are present. Smoking is not permitted. Evacuation procedures are practiced to effect a mass, prompt evacuation under fire conditions. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-238 Log #261 SAF-END FINAL ACTION: Reject (16.3.6) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-380 RECOMMENDATION: No revisions proposed. We support the proposal as submitted by the proponent. SUBSTANTIATION: We do not believe that such a trade-off is appropriate where life safety is concerned. In such cases, it is advantageous and desirable to maintain the built-in passive fire resistant protection, as well as to provide the active automatic sprinkler system protection, where life safety is involved. In our opinion, trade-offs are entirely inappropriate where life safety is concerned. We believe that a balanced approach should be used to assure that the appropriate level of life safety will be provided to the occupants of the building who must rely upon the corridors to exit the building. A secondary benefit of 1-hour fire resistance rated corridors is that they also assist fire fighters in doing their job by providing a protected means of access to the interior of the building where they can perform their search and rescue missions, as well as fire fighting operations, in relative safety. Fire resistance rated corridors can provide fire fighters with additional time to do their jobs more effectively and safely. We strongly believe that sprinkler trade-offs should not be allowed for means of egress components. At present, NFPA 5000 does not allow sprinkler trade-offs for the fire resistance ratings required for exit stair enclosures, horizontal exits, and exit passageways. So why should sprinkler trade-offs be allowed for the 1-hour fire resistance rating of corridors which provide a protected egress path giving access to these exit elements? Furthermore, other sprinkler trade-offs related to the means of egress in buildings have already been provided for in NFPA 5000. For example, travel

distance is allowed to be increased from 150 feet to 200 feet where automatic sprinkler systems are provided. The separation of exits (remoteness) is also allowed to be reduced where automatic sprinkler systems are installed. Interior finish requirements are relaxed within corridors where Class C interior finish can be used in lieu of Class B interior finish and Class B interior finish can be used where Class A interior finish would otherwise be required if not for the installation of automatic sprinklers. And dead end corridors are allowed to be increased in length by 150%, i.e. from 20 feet to 50 feet, and the common path of travel is allowed to be increased from 75 feet to 100 feet where automatic sprinkler systems are provided. We are concerned that the compounding effect of sprinkler trade-offs could lead to greater risk to the life safety of the building occupants, especially if combined with the elimination of the 1-hour fire resistance rating for corridors providing access to the exits or the exit stairs. Too much reliance on automatic sprinkler systems may not be wise where life safety is a key consideration. We strongly believe that a balanced approach to fire and life safety in buildings should be provided to greatly enhance the probability that the intended level of fire and life safety prescribed by the building code will be provided when a fire occurs, even if something should go wrong. We acknowledge that automatic sprinkler systems are an important fire protection tool, but they are not infallible. Like any mechanical system, they are subject to failure. In fact, a recent statistical analysis of automatic sprinkler system performance conducted by NFPA for the period from 1989-1998 has concluded that automatic sprinkler systems fail to operate in at least 1 out of every 6 fires that occur in sprinklered buildings where the fire was judged large enough to have activated the sprinklers. In our opinion such a level of performance does not justify trading-off built-in fire resistant protection for the means of egress in buildings where the occupant’s lives are at risk in a fire emergency. A balanced design approach of providing built-in fire resistive protection in conjunction with automatic sprinkler protection, in our opinion, will go a long way toward assuring that the level of fire and life safety intended by the building code will be delivered during a fire emergency. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: With sprinkler protection, the smoke partition provides adequate protection at corridor walls. Day-care occupancies operate via a mass, prompt, organized evacuation. The commenter’s statistics are based on non-sprinklered buildings. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-239 Log #126 SAF-END FINAL ACTION: Reject (16.6.3.4) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-384 RECOMMENDATION: Accept Proposal 101-384. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm systems disagrees with the Committee Statement “The deletion would have the effect of losing this important requirement for sleeping room smoke alarms. The day-care home is not required to have a fire alarm, so the requirements of NFPA 72 are not mandated. As such, the smoke alarm requirement must be retained.” First, “The deletion would have the effect of losing this important requirement for sleeping room smoke alarms” is not accurate. These requirements, including installation of smoke alarms in all rooms used for sleeping, are contained in NFPA 72 Section 11.5.7, and NFPA 101 Section 16.6.3.4.3 requires smoke alarms to be installed per NFPA 72 via Section 9.6.2.10. Second, “The day-care home is not required to have a fire alarm, so the requirements of NFPA 72 are not mandated” is not accurate because NFPA 101 Section 16.6.3.4.3 requires smoke alarms to be installed per NFPA 72 via Section 9.6.2.10. The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems affirms its position that performance, installation and siting requirements for smoke alarms and household smoke detectors falls under its committee scope. Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE STATEMENT: This occupancy employs “cot” areas which are not within bedrooms, so the current text needs to be maintained to assure that smoke alarms will be present. In other words, NFPA 101 imposes smoke alarm requirements that are stricter than those in NFPA 72. Also, see the Committee Statement for the rejection of ROP Proposal 101-384. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-239a Log #CC354 SAF-END FINAL ACTION: Accept (16.7.4.4 and 17.7.4.4) _______________________________________________________________ SUBMITTER: Technical Committee on Educational and Day-Care Occupancies COMMENT ON PROPOSAL NO: 101-260 RECOMMENDATION: Add text as follows: 16.7.4.4 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to day-care occupancies. 17.7.4.4 The provision of 10.3.2 for cigarette ignition resistance of newly introduced upholstered furniture and mattresses shall not aply to day-care occupancies. SUBSTANTIATION: The action by SAF-FUR on Comment 101-175 and Comment 101-176 has the effect of mandating that newly introduced upholstered furniture and mattresses be cigarette ingition resistant in all occupancies. See Comment 101-175a that modifies the text of 10.3.2 to permit occupancy chapter exemptions. Day-care occupancies are highly supervised when clients are present. Smoking is not permitted. Smoke detection. is required. Evacuation procedures are practiced to effect a mass, prompt evacuation under fire conditions. Enforcement of 10.3.2 by the AHJ would be very difficult in day-care occupancies. Compliance with 10.3.2 by the operator would be very difficult in day-care occupancies. Furniture can be expected to change frequently. Used furniture is commonly brought into day-care homes. If the U.S. government is requiring all new mattresses to be cigarette ignition resistant, so be it. Such requirement need not be in NFPA 101. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-240 Log #127 SAF-END FINAL ACTION: Reject (17.6.3.4) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-391 RECOMMENDATION: Accept Proposal 101-391. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm systems disagrees with the Committee Statement “The deletion would have the effect of losing this important requirement for sleeping room smoke alarms. The day-care home is not required to have a fire alarm, so the requirements of NFPA 72 are not mandated. As such, the smoke alarm requirement must be retained.” First, “The deletion would have the effect of losing this important requirement for sleeping room smoke alarms” is not accurate. These requirements, including installation of smoke alarms in all rooms used for sleeping, are contained in NFPA 72 Section 11.5.8, and NFPA 101 Section 17.6.3.4.3 requires smoke alarms to be installed per NFPA 72 via Section 9.6.2.10. Second, “The day-care home is not required to have a fire alarm, so the requirements of NFPA 72 are not mandated” is not accurate because NFPA 101 Section 17.6.3.4.3 requires smoke alarms to be installed per NFPA 72 via Section 9.6.2.10. The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems affirms its position that performance, installation and siting requirements for smoke alarms and household smoke detectors falls under its committee scope. Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed.

COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: This occupancy employs “cot” areas which are not within bedrooms, so the current text needs to be maintained to assure that smoke alarms will be present. In other words, NFPA 101 imposes smoke alarm requirements that are stricter than those in NFPA 72. Also, see the Committee Statement for the rejection of ROP Proposal 101-391. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-241 Log #334 SAF-HEA FINAL ACTION: Reject (18.1.1.5, 19.1.1.5) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-393 RECOMMENDATION: This proposal is more appropriate as Annex guidance. SUBSTANTIATION: NFPA 30 already addresses the use of Class 1 flammable liquids in institutional occupancies. The requirements are no different when the flammable liquid is gasoline, as a comparison. The only reason that there is no concern over gasoline is that it has no apparent health care application at present. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject needs to be addressed directly in the body of the Code as there is much misinformation on the subject of alcohol-based hand rub solutions. The provisions are an exemption to permit Class 1 flammable liquids, but the submitter’s characterization is incorrect. The alcohol-based hand rub solutions are not anything like gasoline whose characteristics are quite different. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-242 Log #158 SAF-HEA FINAL ACTION: Accept in Principle (18.1.6.2) _______________________________________________________________ SUBMITTER: Joseph T. Holland, Hoover Treated Wood Products COMMENT ON PROPOSAL NO: 101-396 RECOMMENDATION: Revise text to read as follows: 18.1.6.2 Health care occupancies shall be limited to the types of building construction shown in Table 18.1.6.2 (See 8.2.1.) Exception: Any building of Type I(443), Type I (332), Type II(222), or Type II(111) construction shall be permitted to include roofing systems involving combustible supports, decking, or roofing, provided that the following criteria are met: (a) The roof covering meets Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Covering s. and : (b) The roof is separated from all occupied portions of the building by a noncombustible floor assembly having not less than a 2-hour fire resistance rating that includes not less than 2 1/2 in. (6.4 cm) of concrete or gypsum fill. Structural elements supporting the 2-hour fire resistance-rated floor assembly shall be required to have only the fire resistance rating required of the building. or (c) The roof/ceiling assembly is constructed with fire-retardant-treated wood meeting the requirements of NFPA 5000. The roof/ceiling assembly shall have the required fire resistance rating for the type of construction and the roof covering meets Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Coverings. The use of fire-retardant-treated wood in the roof/ceiling assembly of Type I buildings over two stories in height shall not be permitted. SUBSTANTIATION: Fire-retardant-treated wood has several unique qualities that are not recognized by the current code provision. As we stated before you cannot start a fire with FRTW: it takes an external source of ignition and fuel to get the FRTW involved in a fire. It has a very low flame spread, less than 25 (actually in the 10 to 15 range), a very low smoke developed rating, 50. FRTW roofs have been allowed in these types of buildings by building codes for at least 30 years. A review of the types of construction covered by this code section reveals that in the Type II building the roof construction needs a one-hour fire rated assembly. It doesn’t matter whether its steel or wood it needs a one-hour assembly. When the steel assembly is compromised by a fire it can collapse. Collapse can occur very quickly (can be as soon as five minutes after exposure). Protecting occupants from collapse of a one-hour rated roof constructed of wood and not protecting them from collapse of a one-hour rated steel roof seems inconsistent. The proposal requires protection from below (either 2, 1.5 or 1 hour depending on the type of construction); protection from above (Class A roof covering) while recognizing the unique characteristics of FRTW.

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Report on Comments — Copyright, NFPA NFPA 101 While we like the committee’s position that because 220 will allow what we are asking our request is not necessary, we do not agree. It’s our understanding, in discussion, with staff that the provisions in the occupancy chapters, such as, 18 and 19 override general provisions in the LSC and other codes. COMMITTEE MEETING ACTION: Accept in Principle Insert a new 18.1.6.6 (and renumber existing 18.1.6.6 through 18.1.6.8 to become 18.1.6.7 through 18.1.6.9) as follows: 18.1.6.6 Any building of Type I(443), Type I(332), Type II(222), or Type II(111) construction shall be permitted to include roofing systems involving combustible supports, decking, or roofing, provided that the following criteria are met: (1) The roof covering shall meet Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Coverings. (2) The roof/ceiling assembly shall be constructed with fire-retardant-treated wood meeting the requirements of NFPA 220, Standard on Types of Building Construction. (3) The roof/ceiling assembly shall have the required fire resistance rating for the type of construction. COMMITTEE STATEMENT: The action accomplishes what the submitter intended, but does so as a stand-alone provision not tied to existing 18.1.6.5. The text not accepted is extraneous and unnecessary to meet the need. The submitter was present for the committee discussion on this comment and expressed his agreement with the action. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-243 Log #333 SAF-HEA FINAL ACTION: Hold (18.2.2.2.4(1), 19.2.2.2.4(1)) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-398 RECOMMENDATION: Add – Unlocking of all necessary locks shall be accomplished with not more than two separate keys and not more than ten locks. SUBSTANTIATION: Health Care staff should not be required to unlock more locks or require more keys than Detention and Correction. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material that has not had public review via the NFPA 101 ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-244 Log #242 SAF-HEA FINAL ACTION: Reject (18.2.2.2.9.2(c)) _______________________________________________________________ SUBMITTER: Linda Delano, Devenney Group Ltd. COMMENT ON PROPOSAL NO: 101-134 RECOMMENDATION: Revise text to read as follows: Multiple areas require revision regarding the amount of force required to operate the door. SUBSTANTIATION: The proposed horizontal sliding door opening and closing force requirements are not in compliance with ADA. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No specific code text suggested. ROP Proposal 101-134 addresses 7.3.2 on measurement of means of egress; it does not address door operating forces. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-245 Log #109 SAF-HEA FINAL ACTION: Reject (18.2.3.4(2) and 18.2.3.5.(2)) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-410 RECOMMENDATION: Revise the wording of this subparagraph as follows: Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above handrail height, shall be permitted for the installation of hand rub dispensing units in accordance with 18.3.3.2.5. SUBSTANTIATION: There seems to be no legitimate reason to permit restrictions to the clear widths of corridors only for the installation of hand rub dispensers. There are many other devices, such as decorations, building service equipment controls, and alarm initiation and notification appliances,

which would provide for less restriction and introduce less hazards, but are not permitted by the wording in the original proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: ROP Proposal 101-405 introduces text for 18.2.3.4(3) and 18.2.3.5(3) that addresses the generalized encroachment by things other than the alcohol-based hand rub solutions. ROP Proposal 101-410 introduces text for 18.2.3.4(2) and 18.2.3.5(2) that addresses the alcohol-based hand rub solutions. So, the text needs to be retained. The SAF-HEA committee recognized this by studying the draft that staff prepared that combines all the ROP actions. The point is not clear from looking only at Proposal 101-410 or only at Proposal 101-405. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-246 Log #184 SAF-HEA FINAL ACTION: Accept in Principle (18.2.3.4(3), 18.2.3.5(3) and 19.2.3.4(3)) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-405, 101-410, 101-445 RECOMMENDATION: Coordinate the action of proposals 101-405, 101-410, and 101-445 by revising 18.2.3.4(3). 18.2.3.5(3) and 19.2.3.4(3) to read: (3) where the minimum corridor width is 72 in. (1839 mm), projections shall be permitted in corridors, at both sides of the corridor, as follows: (a) Each projection shall not exceed a depth of 6 in. (152 mm). (b) Each projection shall not exceed a length of 36 in. (915 mm). (c) Each projection shall be positioned a minimum of 40 in. (1015 mm) above the floor. (d) Each projection shall be separated from adjacent projections by a minimum of 4 ft (1220 mm). SUBSTANTIATION: The three captioned proposals all addressed the same paragraphs. The material added in 101-410 and 101-445 regarding 18.2.3.4, 18.2.3.5, and 19.2.3.4 are not needed due to the changes made by 101-405. This comment adds material on separation of the projections since this was not addressed by 101-405. The 4 ft is established by 18/19.3.2.6. COMMITTEE MEETING ACTION: Accept in Principle Supplement the action on ROP Proposals 101-405, 101-410 and 101-445 by: 1. In 18.2.3.4(3), add a subitem (d) as follows: (d) Each projection shall have a minimum 48 in. (1220 mm) horizontal separation from adjacent projections. 2. In 18.2.3.5(3), add a subitem (d) as follows: (d) Each projection shall have a minimum 48 in. (1220 mm) horizontal separation from adjacent projections. 3. In 19.2.3.4(3), add a subitem (d) as follows: (d) Each projection shall have a minimum 48 in. (1220 mm) horizontal separation from adjacent projections. COMMITTEE STATEMENT: The new text will prevent projections from being placed with just a minimal gap between them so as to meet the requirement than no projection be wider than 36 in. Such continuous or nearly-continuous horizontal runs of projections need to be avoided. The 48-in. spacing is consistent with that proposed in 18.3.2.6 and 19.3.2.6 for alcohol-based hand rub solution dispensers. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-247 Log #241 SAF-HEA FINAL ACTION: Reject (18.2.3.5(2)) _______________________________________________________________ SUBMITTER: Linda Delano, Devenney Group Ltd. COMMENT ON PROPOSAL NO: 101-410 RECOMMENDATION: Revise text to read as follows: “..., projections of a maximum of 102 mm ( 4 in.) from the corridor wall...” SUBSTANTIATION: The proposed 6 in. maximum projections into the required corridor widths are not in compliance with ADA. ADA limits the projections to 4 in. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The 6-in. projections are an operational necessity. Note that the corridor must be at least 6-ft wide as a condition for allowing the 6-in. projections. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

101-99

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-247a Log #CC203 SAF-HEA FINAL ACTION: Accept (18.2.5) _______________________________________________________________ SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-406 RECOMMENDATION: Further revise the text from the action on ROP Proposal 101-406 as follows: 18.2.5.5.2 Exit access from a patient sleeping room with not more than eight patient beds shall be permitted to pass through one intervening room to reach an exit access corridor, provided the intervening room is equipped with an approved automatic smoke detection system in accordance with Section 9.6 or the furnishings and furniture, in combination with all other combustibles within the area, are of such minimum quantity and arrangements that a fully developed fire is unlikely to occur. ***** 18.2.5.6.1.3.2 Hazardous areas within a suite shall be separated from the remainder of the suite in accordance with 18.3.2.1, unless otherwise provided in 18.2.5.6.1.3.3. 18.2.5.6.1.3.3* Hazardous areas within a suite shall not be required to be separated from the remainder of the suite where complying with all the following: (a) The suite is primarily a hazardous area. (b) The suite is protected by an approved automatic smoke detection system in accordance with Section 9.6. (c) The suite is separated from the rest of the health care facility as required for a hazardous area by 18.3.2.1. ***** A.18.2.5.6.1.3.3 Examples of suites that might be hazardous areas are medical records and pharmaceutical suites. ****** 18.2.5.6.2 Sleeping Suites. 18.2.5.6.2.1 Sleeping Suite Arrangement. 18.2.5.6.2.1.1* Occupants of habitable rooms within sleeping suites shall have exit access to a corridor complying with 18.3.6 without having to pass through more than one intervening room. ***** A.18.2.5.6.2.1.1 For the purposes of this paragraph it is the intent that “habitable rooms” not include individual bathrooms, closets, and similar spaces, as well as briefly occupied work spaces such as control rooms in radiology and small storage rooms in a pharmacy. The term “intervening room” means a room serving as a part of the required means of egress from another room. ***** 18.2.5.6.2.1.2 Sleeping suites shall be provided with constant staff supervision within the suite. 18.2.5.6.2.1.3 Sleeping suites shall be arranged in accordance with one of the following: (a)* Sleeping suites shall allow for direct visual supervision of the suite by staff from a normally attended location within the suite; and cubicle curtains shall be permitted. Patient sleeping rooms within sleeping suites shall provide one of the following: (i) The patient sleeping rooms shall be arranged to allow for direct supervison from a normally attended location within the suite such as provided by glass walls, and cubicle curtains shall be permitted. (ii) Any patient sleeping rooms without the direct supervision required by 18.2.5.6.2.1.3(a)(i) shall be provided with smoke detection in accordance with Section 9.6 and 18.3.4. (b)* Interior walls and partitions within sleeping suites shall not exceed three-quarters of the floor-to-ceiling height or shall not exceed 8 ft (2440 mm) in height, whichever is less; and staff shall provide supervision from a normally attended location within the suite. (b) (c) Sleeping suites shall be provided with a total coverage (complete) automatic smoke detection system in accordance with 9.6.2.8 and 18.3.4. ***** A.18.2.5.6.2.1.3(a) A.18.2.5.6.2.1.2(a) The interior partitions or walls may extend full height to the ceiling provided they do not obscure visual supervision of the suite. Where they do obscure visual supervision, see 18.2.5.6.2.1.3(b) 18.2.5.6.2.1.2(c). A.18.2.5.6.2.1.2(b) This provision does not require the direct visual supervision of the suite that is required by 18.2.5.6.2.1.2(a). In this case, it just requires that staff be in the suite and capable of providing supervision. This supervision is a combination of audible, visible and olfactory. The supervision is somewhat indirect due to the low-height partitions. Where interior partitions or walls exceed three-quarters of the floor-to-ceiling height or 8 ft (2440 mm), or subdivide the suite so as to obscure visual supervision of the suite, it is the intent that the suite comply with 18.2.5.6.2.1.2(c). SUBSTANTIATION: Revisions from ROP are based on Comment 101-248, Comment 101-272, and the report of the health care occupancies task group on suites and arrangement of means of egress. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22

BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-248 Log #201 SAF-HEA FINAL ACTION: Accept in Principle (18.2.5.5.2, 18.2.6.6.1.3.2, 18.2.5.6.1.3.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-441 RECOMMENDATION: Revise text to read as follows: (1) 18.2.5.2.2 Delete “or the furnishings and furniture, in combination...” (2) 18.2.6.6.1.3.2 add: “unless otherwise provided in 18.2.5.6.1.3.3” to the end of the paragraph. (3) Add a 18.2.5.6.1.3.3 reading the same as 19.2.5.6.1.3.3 inserting “all” between “with” and “the”. (4) 18.2.5.6.2.1.2(c) add “and staff shall provide supervision from a normally attended location with the suite” at the end of the sentence. (5) Revise 18.2.5.6.2.1.2(b) by changing “8 ft (2440 mm)” to “5 ft (xxx mm). SUBSTANTIATION: (1) This material was from Chapter 19 (19.3.6.1 Ex. 6 (b) and should not be applied to new construction. Installing the smoke detector in new construction presents no hardship and allows flexibility during use of the building. (2) Is needed for comment (3). (3) Allows non-sleeping suites that are hazardous areas without further subdivision within the suite, such as pharmacies, medical records, etc. (4) It was never the intent to allow sleeping suites without supervision in the suite. (5) The higher partitions were negotiated based on existing conditions. Based on A.7.3.4.1 it is necessary to keep the partitions lower than 5 ft if most staff are going to be able to see above the partitions. This does not present a hardship in new construction, as if higher partitions are desired smoke detection can be provided and the higher partitions use. This will not affect existing installations as the height is not being changed in Chapter 19. COMMITTEE MEETING ACTION: Accept in Principle See Comment 101-247a and Comment 101-271a. COMMITTEE STATEMENT: The action on the referenced comments should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-249 Log #397 SAF-HEA FINAL ACTION: Accept in Principle (18.2.5.5.2.2.3 and 19.2.5.5.2.2.3) _______________________________________________________________ SUBMITTER: James R. Ambrose, Code Consultants, Inc. COMMENT ON PROPOSAL NO: 101-407 RECOMMENDATION: Add a new paragraph: When the second means of egress is through the adjacent suite, Section 18/19.2.5.5.2.4.1 does not apply and the travel distance to an exit shall meet Section 18/19.5.5.2.4.2. SUBSTANTIATION: This added text will clarify how travel distance should be measured when the second exit is through the adjacent suite. COMMITTEE MEETING ACTION: Accept in Principle Do not change text within body of Code. Rather, add annex text as follows (based on action on ROP Proposal s 101-406 and 101-441): 18.2.5.6.2.2.3 * For suites requiring two means of egress... 19.2.5.6.2.2.3 * For suites requiring two means of egress... 18.2.5.6.3.2.3 * For suites requiring two means of egress... 19.2.5.6.3.2.3 * For suites requiring two means of egress... A.18.2.5.6.2.2.3 Where the second exit access for a sleeping suite is through an adjacent suite, it is the intent that the 100 ft (30 m) travel distance limitation in the suite be applied only to the suite under consideration. A.19.2.5.6.2.2.3 Where the second exit access for a sleeping suite is through an adjacent suite, it is the intent that the 100 ft (30 m) travel distance limitation in the suite be applied only to the suite under consideration. A.18.2.5.6.3.2.3 Where the second exit access for a non-sleeping suite is through an adjacent suite, it is the intent that the adjacent suite not be considered an intervening room. A.19.2.5.6.3.2.3 Where the second exit access for a non-sleeping suite is through an adjacent suite, it is the intent that the adjacent suite not be considered an intervening room. COMMITTEE STATEMENT: The action clarifies the subject via annex guidance. See also Comment 101-250 submitted by the same commenter. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-250 Log #295 SAF-HEA FINAL ACTION: Accept in Principle (18.2.5.5.3.2.3, 19.2.5.5.3.2.3) _______________________________________________________________ SUBMITTER: James R. Ambrose, Code Consultants, Inc. COMMENT ON PROPOSAL NO: 101-407 RECOMMENDATION: Add a new paragraph: When the second means of egress is through the adjacent suite, Section 18/19.2.5.5.3.4 does not apply and the travel distance to an exit shall meet Section 18/19.5.5.3.6. SUBSTANTIATION: The added text will clarify how travel distance should be measured when the second exit is through the adjacent suite. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-249. COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-251 Log #240 SAF-HEA FINAL ACTION: Reject (18.2.5.6.2.3.2 (a)) _______________________________________________________________ SUBMITTER: Linda Delano, Devenney Group Ltd. COMMENT ON PROPOSAL NO: 101-406 RECOMMENDATION: Add new text as follows: 18.2.5.6.2.3.2 Sleeping suites shall not exceed 7500 ft 2 (700 m 2 ) where both of the following are provided in the suite: (a) Direct visual supervision in accordance with 18.2.5.6.2.1.2(a). Direct visual supervision is defined as...” SUBSTANTIATION: How is “direct visual supervision of the suite” determined? Is this only applicable to the space occupied by beds visible from the attended location or all spaces, rooms, etc., within the suite? COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The commenter submitted no specifc Code text. The term “direct supervision” has been in the Code for many editions and has not proved problematic. See NFPA 101-2003, 18.3.6.1(1)(c). NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

Sequence No. 101-252 was not used _______________________________________________________________101-253 Log #335 SAF-HEA FINAL ACTION: Reject (18.3.2.6) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-410 RECOMMENDATION: This proposal is more appropriate as Annex guidance. SUBSTANTIATION: NFPA 30 already addresses the use of Class 1 flammable liquids in institutional occupancies. The requirements are no different when the flammable liquid is gasoline, as a comparison. The only reason that there is no concern over gasoline is that it has no apparent health care application at present. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject needs to be addressed directly in the body of the Code as there is much misinformation on the subject of alcohol-based hand rub solutions. The provisions are an exemption to permit Class 1 flammable liquids, but the submitter’s characterization is incorrect. The alcohol-based hand rub solutions are not anything like gasoline whose characteristics are quite different. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-254 Log #203 SAF-HEA FINAL ACTION: Accept in Principle (18.3.2.6, 19.3.2.6, 20.3.2.6 and 21.3.2.6) _______________________________________________________________ SUBMITTER: Dale Woodin, ASHE-American Society for Healthcare Engineering of the American Hospital Association (AHA) COMMENT ON PROPOSAL NO: 101-410 RECOMMENDATION: Support the action of the Technical Committee on Health Care Occupancies. SUBSTANTIATION: The American Society for Healthcare Engineering (ASHE) of the American Hospital Association (AHA) strongly support the new

text being proposed by the Technical Committee. The TC has reviewed the scientific data, computer modeling and expert testimony provided to them and has developed a very functional set of new requirements. This change has the potential of saving thousands of lives in our nations healthcare facilities. In providing negative ballots, Mr. Bush (representing the International Association of Fire Marshals) and Mr. Harris (representing the California Office of Health Planning and Development) raise concerns on the annex language, total amount of flammable liquid, surfaces, corridor widths, and the validity of placing alcohol-based hand-rub dispensers in the corridors of patient care units. ASHE/AHA would like to go on record to address these concerns. Bush: While this proposed section has addressed many of the original concerns regarding the installation of these alcohol-based hand sanitizer dispensers, the proposal, as written, contains too many technical errors to be published and enacted as printed. ASHE: The ASHE proposal (101-393 Log #508) has been rewritten by the Technical Committee to address many of the concerns raised by IFMA. Over the past two years in preparing the TIA (2000 and 2003 editions of the LSC) and the proposal for the 2005 edition, IFMA has been a critical element of the process by giving direction and positively challenging the interim reports. Numerous meetings with IFMA leadership have taken place at the NFPA meetings along with those at the Technical Committee ROP meeting. As there is not a specific list of technical errors we are at a loss as to what needs to be fixed in the proposed body of the document. Bush: Much, if not all, of the proposed Annex material speaks more to the justification of this proposal and should not be included as a part of the text to be inserted into the Code. While it may serve as useful background information, there is no need to include the history of clinical studies concerning the effectiveness of hand hygiene facilities, the background and results of fire modeling studies, or recommendations made for infection control. There are also assumptions and indications of acceptable test results, threshold limits, tenability values, engineering judgments, field conditions, and needs for further studies that are stated by persons other than the Technical Committee responsible for the document that should not be included without proper source identification and clarification. The last paragraph of the Annex Note also contains an incomplete sentence. Rather, the Annex should be reserved for material that would be useful in the application of Code requirements and further state means and explanation of the requirements written in the Code text. What is missing from the Annex is guidance for the definition of what qualifies as an alcohol based hand rub solution. In addition, consideration should be given to add Annex material to further explain the total quantities of solution which would be permitted by this section of the Code; that the total amount of flammable liquids, including the alcohol-based hand rub solutions, should not exceed the maximum amounts permitted by other Codes, including NFPA 1; that dispensers would be permitted to be installed only in corridors having a clear width of at least 72 in.; and that dispensers installed in locations with combustible wall or floor coverings should be permitted only in smoke compartments provided with complete automatic sprinkler protection. Additional wording should be included in the Annex which would indicate that dispensers should be located such that flammables cannot be ignited from any external ignition source with consideration to possible container failure or leakage which may permit liquids or gels to come in contact with wall or floor mounted electrical contacts or other equipment or other potential sources of ignition. ASHE: ASHE/AHA is very willing to work with IFMA in formulating a new Annex. We are in agreement that the annex is for material that is useful in the application of the Code requirements and should clarify and aid in consistent interpretation and enforcement of the Code. Both IFMA and ASHE participated in the SAF-HEA ad-hock task group concerning alcohol-based hand rub and, if IFMA is of the opinion that additional material would assist the user of the 2005 edition, ASHE stands by ready to assist. Bush: This proposal still contains no indication of the total amount of flammable liquids that are permitted to be used or stored within a health care facility, and is somewhat misleading to the Code user by ignoring other amounts of such flammable liquids which may be present for reasons other than sanitizing purposes. The amounts of alcohol based hand rub solution permitted to be present should be included in, and not in addition to, the overall total of flammable liquids present in any fire area. ASHE: The intent of the new proposal was to give the reader a limit on the amount of alcohol-based hand-rubs that can be installed in the corridors or stored in bulk so as to limit the amount of this material in each smoke compartment. Compliance with NFPA 1 and NFPA 30 are also mandatory and it is expected they will be complied with if required by the authority having jurisdiction. Bush: Currently, there are provisions to limit the installation of containers in locations with carpeted floor coverings, however there is no restriction for the installation of containers on wall surfaces that may be of combustible construction or have combustible surfaces. Such surfaces may include wood paneling, vinyl coverings, or even carpet, and seem to pose as significant, if not more of a hazard due to container leakage or other failure. ASHE: The Code only permits Class C interior finishes to be installed in areas that are sprinklered so if there is wood paneling on the walls or the wall is wainscoted with carpet the area will be protected in the same manner as when the dispensers are installed over carpeted floors. A wall with a Class C finish is not as significant as a floor because the liquid will not pool on the wall.

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Report on Comments — Copyright, NFPA NFPA 101 19.3.3 Interior Finish. 19.3.3.1 Interior finish shall be in accordance with Section 10.2. 10.2.8 Automatic Sprinklers. 10.2.8.1 Unless specifically prohibited elsewhere in the Code, where an approved automatic sprinkler system is in accordance with Section 9.7, Class C interior wall and ceiling finish materials shall be permitted in any location where Class B is required, and Class B interior wall and ceiling finish materials.Bush: In addition, the requirement for the restriction of dispensers to sprinklered areas of new health care facilities where carpeted floors are present is not necessary since sprinkler protection is required throughout all such facilities. ASHE: The purpose for putting this in Chapter 18 for new was to remind healthcare organizations of the benefit of sprinklering remodeled or renovated space. This gives the risk manager, facility manager, and clinical team one more reason to push for the sprinklering of minor renovations and continues to move us forward in getting all of healthcare sprinklered. Bush: Several new paragraphs also permit the restriction of corridor widths for only the installation of hand-rub dispensing units. It is unclear why such restrictions can be permitted for these specific devices, and not address other obstructions, such as fire alarm system components, decorations, and lighting fixtures, which are permitted and routinely found as projections into clear corridor widths. ASHE: This is exactly what the TC did at the ROP meeting. The new section dealing with corridor projection stands on its own thereby permitting these other features typically installed in healthcare corridors to be within Code. See Log #388. Bush: This proposal has made great strides in the acceptable means for the installation and protection of alcohol-based hand rub dispensers, however the technical inconsistencies and details which still are not addressed, as well as the unnecessary Annex material included as a part of this proposal requires further work and modifications before being processed. The proposed background material presents compelling evidence that, with certain precautions, this material may be safe and effective to use. However, to reduce this wording to appear in code text for fire and life safety issues is not proper, and deserves further consideration before being moved forward at this time. ASHE: Our hope is that the fire community appreciates the importance of saving lives in healthcare facilities. Both the fire and healthcare communities have dedicated decades of Code improvements to make these buildings the safest occupancies. As with other provisions in the Code, there needs to be a mix of fire safety and good sound clinical practice. Door locking provisions have been altered to assist in reducing elopement, infant abductions, and for security purposes. If we are truly in the life safety business and there are 88,000 lives lost per year due to Healthcare-Associated-Infections we would hope that all professional organizations would be working side-by-side to give our caretakers the tools to fight this epidemic. Harris: Hand rub dispensers are currently allowed in patient rooms. This proposal would allow 10 gallons of alcohol-based hand rub solution in the corridors of every smoke compartment of unsprinklered health care facilities. These solutions are typically 60 percent or more alcohol, and can be as high as 95 percent alcohol. While I agree with the intent to provide more convenient and effective methods of hand washing, and therefore infection control, I feel this is an unacceptable risk. If staff will not use hand sanitizers located within the patient rooms, I’m not sure what will induce staff to use them in the corridors. ASHE: Where these devices are placed in a healthcare facility needs to be at the direction of the clinical staff. This new language, based on nationally recognized fire modeling, gives the infection control and epidemiology community the opportunity to place the dispensers where they will do the more good. There are many instances where placement of dispensers in the patient room is not possible. These include patient populations such as pediatric or behavioral health patients, clinical practice such as rounds of multiple medical students accessing handrub while discussing the patients condition prior to entry into the patient room, and older cramped space where there is no open wall space suitable for dispenser installation. The debate over whether the staff will or will not use them if placed in the corridor does not belong as a question in our writing of good fire code. Harris: Another minor issue deals with disabled access. The proposal allows hand rub dispensers to project 6 in. from the corridor wall. This is in conflict with NFPA 5000, Section 12.5, which requires protruding objects on circulation paths to comply with ICC/ANSI A117.1, Section 307, which in turn allows protruding objects to project not more than 4 in. from the wall, between 27 and 80 in. above the floor. If accepted, the proposal should be revised to coordinate with existing NFPA and federal requirements. ASHE: As with all features in a hospital many codes and standards are conflicting with the best practice of delivering quality healthcare. The ADA and ANSI A117.1 have made generic requirements that apply to all occupancies whether it is a school, business, hotel, or medical facility. In the Code we need to be cognizant of these differences and if necessary write the provisions that support the clinical use of the facility in hopes that other standards organizations will support our mission. The placement needs of ABHR dispensers should only be restricted due to a fire safety hazard. Once that is addressed, the placement should be the decision of the clinical staff to maximize effectiveness that directly translates to saving

patient lives. Let’s let the clinical hand-hygiene experts worry about where they are needed for maximum infection control prevention, let us worry about whether the fire modeling answered the code requirements on a performance-based approach. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposal 101-410 to place text within the body of the Code to address alcohol-based hand rub solution dispensers. Note that actions on Comments 101-438, 101-439, 101-440 and 101-441 reduce the size of the accompanying annex text. COMMITTEE STATEMENT: The Code text is needed. The shortened annex text will suffice. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-255 Log #230 SAF-HEA FINAL ACTION: Reject (18.3.4) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-412 RECOMMENDATION: Change TC action from reject to accept. SUBSTANTIATION: The scope of 72 is to define survivability, Class A, etc., but not to require such installations. It takes a 101 or 5000 requirement to make it happen. Presently, fire alarm requirements for health care are too minimal and allow a single open or ground to compromise a large health care building. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The total package of life safety offered by the protect-in-place strategy of Chapters 18 and 19 is adequate without complicating the alarm provisions. A Class C system provides an acceptabvle level of safety when combined with the other Code provisions for health care occupancies. Note that the Code specifies a minimum standard; it does not prohibit the user from installing a Class A system. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-256 Log #395 SAF-HEA FINAL ACTION: Accept in Principle (18.3.4.3.2.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-413 RECOMMENDATION: Accept Proposal 101-413. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The subject of Section 18.3.4.3.2.2 is emergency forces notification. This notification will not occur until positive alarm sequence or alarm verification (where used) is complete. If positive alarm sequence is specified, location in another section would be more appropriate. Note that Section 55.2.3.4 addresses positive alarm sequence under occupant notification. If “positive alarm sequence” is specified (as indicated in Proposal 101-414), the timing for this sequence should be consistent with that addressed in NFPA 72. The timing for positive alarm sequence is specified in NFPA 72 and includes an allowance of up to 15 seconds for acknowledgment and then up to 180 seconds for alarm investigation. The proposed language does not reflect this two-phase sequence terminology and will cause confusion in implementation. The acknowledgment period should agree with that in NFPA 72. (If a different timing of the investigation phase is specified, the rationale for the different timing should be addressed and provided as annex material for the related code section in accordance with Annex A-9 of the NFPA Committee Officer’s Guide.) COMMITTEE MEETING ACTION: Accept in Principle Do not make the changes shown in ROP Proposal 101-414. Rather, revise as follows: 18.3.4.3 Notification. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. 18.3.4.3.1 Occupant Notification. Occupant notification shall be accomplished automatically in accordance with 9.6.3, unless otherwise modified by the following: (1) Paragraph 9.6.3.2.3 shall not be permitted to be used. (2)* In lieu of audible alarm signals, visible alarm-indicating appliances shall be permitted to be used in critical care areas. 18.3.4.3.2 Emergency Forces Notification. 18.3.4.3.2.1 Fire department notification shall be accomplished in accordance with 9.6.4. 18.3.4.3.2.2 Reserved. Smoke detection devices, or smoke detection systems, equipped with reconfirmation features shall not be required to automatically notify the fire department unless the alarm condition is reconfirmed after a period not exceeding 120 seconds.

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Report on Comments — Copyright, NFPA NFPA 101 19.3.4.3 Notification. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted in health care occupancies protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 19.3.4.3.1 Occupant Notification. Occupant notification shall be accomplished automatically in accordance with 9.6.3, unless otherwise modified by the following: (1)* In lieu of audible alarm signals, visible alarm-indicating appliances shall be permitted to be used in critical care areas. (2) Where visual devices have been installed in patient sleeping areas in place of an audible alarm, they shall be permitted where approved by the authority having jurisdiction. 19.3.4.3.2 Emergency Forces Notification. 19.3.4.3.2.1 Fire department notification shall be accomplished in accordance with 9.6.4. 19.3.4.3.2.2 Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire department unless the alarm condition is reconfirmed after a period not exceeding 120 seconds. COMMITTEE STATEMENT: Positive alarm sequence will permit a 180 second delay before remote signals are sent off-site. This will help to prevent unnecessary runs by the fire department. With the addition of text permitting positive alarm sequence,18.3.4.3.2.2 can be deleted. However, 19.3.4.3.2.2 must be retained for existing systems utilizing the 120-second reconfirmation feature. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-257 Log #142 SAF-HEA FINAL ACTION: Reject (18.3.4.3.3) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-415 RECOMMENDATION: Accept proposal as written with last sentence: “Annunciation shall be at a constantly attended location” SUBSTANTIATION: It is our understanding that a staff response is required per 101-18.7.2.1, and the objective of locating annunciation at a constantly attended location is to facilitate that response. This would not replace the annunciation required at the command center by NFPA 101-9.6.6 and 9.6.7. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Health care facility staff response is addressed by the occupant notification provisions of 18.3.4.3 and 9.6.3. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR


_______________________________________________________________101-259 Log #331 SAF-HEA FINAL ACTION: Reject (18.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-448 RECOMMENDATION: 18.3.5.1 Delete “unless otherwise permitted by 18.3.5.3” There is no longer any credible technical reason to permit the construction of new unsprinklered health care facilities. There is no reason to perpetuate past practices when recent multiple fire fatalities demonstrate their inadequacy. See Comment Log 219. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in a national standard that prevents all health care facilities from being sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22

BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

Sequence No. 101-260 was not used _______________________________________________________________101-261 Log #336 SAF-HEA FINAL ACTION: Reject (18.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-417 RECOMMENDATION: Reconsider. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in a national standard that prevents all health care facilities from being fully sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-262 Log #337 SAF-HEA FINAL ACTION: Reject (18.3.5.3) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-418 RECOMMENDATION: Reconsider. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in a national standard that prevents all health care facilities from being sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. The original fire loading in health care (metal and ceramics) has changed to paper and plastics. Fires have the potential of greater heat release far more than when nonsprinklered facilities were first accepted. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-263 Log #360 SAF-HEA FINAL ACTION: Reject (18.3.5.4) _______________________________________________________________ SUBMITTER: Dawn LeBaron, Fletcher Allen Healthcare / Rep. New England Healthcare Engineer’s Society COMMENT ON PROPOSAL NO: 101-419 RECOMMENDATION: (Accept Proposal 101-419, option 2) Revise 18.3.5.4 as follows: Listed quick response sprinklers, or residential sprinklers in patient sleeping rooms, shall be used throughout. SUBSTANTIATION: After sharing an explanation of this proposal with written pros and cons, the New England Healthcare Engineers’ Society polled it’s 330 members. The membership voted 2 to 1 ratio to accept. The well-

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Report on Comments — Copyright, NFPA NFPA 101 known life safety benefits of QR vs standard sprinklers is worth the slight additional cost for new installations. Since sprinklers are going in anyway, this is a very responsible approach to take. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee statement for the rejection of ROP Proposal 101-419. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-264 Log #292 SAF-HEA FINAL ACTION: Reject (18.3.6.2.1) _______________________________________________________________ SUBMITTER: Tony Crimi, A.C. Consulting Solutions, Inc. / Rep. International Firestop Council COMMENT ON PROPOSAL NO: 101-420 RECOMMENDATION: Revise text to read as follows: 18.3.6.1 Corridors shall be constructed as a smoke barrier in accordance with Section 8.5 and separated from all other areas by partitions complying with 18.3.6.2 through 18.3.6.5 (see also 18.2.5.9), unless otherwise permitted by the following: No change to Exceptions 1 through 5. SUBSTANTIATION: The committee expressed concern regarding the potential need for dampers and door closers. Relocation of this proposed provision to 18.3.6.1 should satisfy the committee published reasons for rejection and retain the existing exceptions and conditions. Corridors in Health Care facilities are particularly vulnerable areas, for a variety of reasons previously cited. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The submitter has not provided adequate substantiation for the increased requirements. The corridor provisions are adequate. The health care occupancy chapters were the first major users of the smoke barrier provisions in this Code. The traditional requirements have served well. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-265 Log #326 SAF-HEA FINAL ACTION: Reject (18.3.6.3.9) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-455 RECOMMENDATION: Reconsider. SUBSTANTIATION: The current protection does not work adequately without door closers on patient room doors. The 16 fire fatalities in Hartford and the 16 fire fatalities in Nashville in 2003, occurred in patient rooms where the door was open and closers were not provided. These fatalities would not have happened as shown by the survival of patients in adjacent rooms where the doors remained closed. The committees’ assumptions are no longer valid: a) Staff is trained and drilled. The GAO report indicates that this is not dependably effective. b) Doors being left open 10- 40 degrees. Door hold open / self closing devices can have intermediate stops installed to achieve partial hold open. c) Door closure on staff attempting rescue suggests a rescue that is extremely risky and beyond the capability of unprotected staff. If the room is near flashover, the open door will guarantee fire spread to the corridor, preventing any additional staff intervention, such as closing doors. Minimal 3rd shift staffing prevents proper two person rescue attempts. Changes in the health care environment, from fire loading, types of patients, staff attitudes, training effectiveness, advances in technology, and the multiple fire fatality fires of 2003, all suggest that the committee reconsider its defense of past practices as effective without need of improvement. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: NFPA 101 has never required patient room doors to be self-closing. Inadequate substantiation to impose retroactively a patient room door closer requirement on existing health care facilities. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-266 Log #329 SAF-HEA FINAL ACTION: Reject (18.3.6.3.9) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-422 RECOMMENDATION: Reconsider. SUBSTANTIATION: The current protection does not work adequately without door closers on patient room doors. The 16 fire fatalities in Hartford

and the 14 fire fatalities in Nashville in 2003, occurred in patient rooms where the door was open and closers were not provided. These fatalities would not have happened as shown by the survival of patients in adjacent rooms where the doors remained closed. The committees’ assumptions are no longer valid: a) Staff is trained and drilled. The GAO report indicates that this is not dependably effective. b) Doors being left open 10- 40 degrees. Door hold open / self closing devices can have intermediate stops installed to achieve partial hold open. c) Door closure on staff attempting rescue suggests a rescue that is extremely risky and beyond the capability of unprotected staff. If the room is near flashover, the open door will guarantee fire spread to the corridor, preventing any additional staff intervention, such as closing doors. Minimal 3rd shift staffing prevents proper two person rescue attempts. Changes in the health care environment, from fire loading, types of patients, staff attitudes, training effectiveness, advances in technology, and the multiple fire fatality fires of 2003, all suggest that the committee reconsider its defense of past practices as effective without need of improvement. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: New health care occupancies are sprinklered. The submitter’s substantiation cites fires in non-sprinklered buildings. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-267 Log #291 SAF-HEA FINAL ACTION: Reject (18.4.3.7.1) _______________________________________________________________ SUBMITTER: Tony Crimi, A.C. Consulting Solutions, Inc. / Rep. International Firestop Council COMMENT ON PROPOSAL NO: 101-434 RECOMMENDATION: Revise text to read as follows: 18.4.3.7.1.1 Where the smoke compartment being modified is not protected throughout by an approved, supervised automatic sprinkler system in accordance with 19.3.5.2, corridor walls shall comply with the following, as modified by 18.4.3.7.1.2: (1) “...no change. (2) “...no change. (3) Resist the passage of smoke Be constructed as a smoke barrier in accordance with Section 8.5. SUBSTANTIATION: Corridors in Health Care facilities are particularly vulnerable areas, for a variety of reasons previously cited. The code needs to provide users with a means of complying with the stated objective. I agree with the Committees stated reason in as much as a smoke barrier is a specialized component/system. That is precisely why code users need to have more information on how to “resist the passage of smoke”. Contrary to the Committee’s stated reason for rejection, this provision would not apply to all corridor walls. The exceptions related to 19.3.5.2 & 18.4.3.7.1.2 are not altered. As I read it, the Committee’s reason supports the intent of this proposal. The tragic fire at the Greenwood Health Center in Hartford, CT in February 2003 is an example demonstrating there is insufficient control on smoke movement in modern building. This proposal simply fails to provide more definitive instruction on how to “resist the passage of smoke”. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The current provision is adequate. The intent behind the provisions of 18.4.3 is to preserve the Chapter 19 criteria for existing buildings undergoing rehabilitation but which are not fully sprinklered. The submitter has not substantiated imposing new requirements on existing corridors. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-267a Log #CC205 SAF-HEA FINAL ACTION: Accept (18.7.5 and 19.7.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the substantiation be corrected to read: “In ROC Comments 101-175 and 101-176, the SAF-FUR...”SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-266 RECOMMENDATION: Revise as follows: 18.7.5.2 Newly introduced upholstered furniture within health care occupancies shall meet comply with one of the following provisions: (1) the furniture shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(2) in 10.3.2 and 10.3.3. (2) the furniture shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 18.7.5.3 Reserved.

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Report on Comments — Copyright, NFPA NFPA 101 18.7.5.4 Newly introduced mattresses within health care occupancies shall meet comply with one of the following provisions: (1) the mattresses shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(3) in 10.3.2 and 10.3.4. (2) the mattresses shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 18.7.5.5 Reserved. ***** 19.7.5.2 Newly introduced upholstered furniture within health care occupancies shall meet comply with one of the following provisions, unless otherwise provided in 19.7.5.3: (1) the furniture shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(2) in 10.3.2 and 10.3.3. (2) the furniture shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 19.7.5.3 The requirement s of 19.7.5.2, 10.3.2 and 10.3.3 shall not apply to upholstered furniture belonging to the patient in sleeping rooms of nursing homes where the following criteria are met: (1) A smoke detector shall be installed in such rooms. (2) Battery-powered single-station smoke detectors shall be permitted. 19.7.5.4 Newly introduced mattresses within health care occupancies shall meet comply with one of the following provisions, unless otherwise provided in 19.7.5.5: (1) the mattresses shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(3) in 10.3.2 and 10.3.4. (2) the mattresses shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 19.7.5.5 The requirement of 19.7.5.4, 10.3.2 and 10.3.4 shall not apply to mattresses belonging to the patient in sleeping rooms of nursing homes where the following criteria are met: (1) A smoke detector shall be installed in such rooms. (2) Battery-powered, single-station smoke detectors shall be permitted. SUBSTANTIATION: In ROP Proposals 101-275 and 101-276, the SAF-FUR Furnishings Committee acted to remove the sprinkler exemption under which upholstered furniture and mattresses were not required to be tested for cigarette ignition resistance. The action on this comment retains the current sprinkler exemption for health care occupancies. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-268 Log #108 SAF-HEA FINAL ACTION: Reject (18.7.5.1, 19.7.5.1) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-435 RECOMMENDATION: Delete proposed subparagraph (3). SUBSTANTIATION: The intent of this paragraph is to regulate all types of draperies and curtains, including those at windows. The substantiation states that there is no justification for testing these draperies, however it must be considered that such a requirement has been in effect for years in previous Code editions with no adverse fire history, and that in order to make a change to these requirements, appropriate evidence of testing or history should be provided to justify the change. No such justification has been included with this proposal. In addition, it should be the nature of the material that is regulated and not its origin. Why is there special consideration for materials that are introduced by a patient rather than those introduced by the facility? Sufficient means currently exist for the proper fire retardant treatment to be easily and effectively applied to fabrics and textiles, whether purchased and installed by the facility or introduced from other outside private sources, in order to maintain an appropriate level of safety. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: In nursing homes, patients must be permitted to bring their own window drapes from home into their patient sleeping rooms. This is permitted to help create a more home-like, residential setting. Sprinklers exempt the need to regulate the upholstered furniture and mattresses, so sprinklers should also exempt patient room window drapes from NFPA 701 testing. There is no documentation that window drapes have been a problem in patient room fires. The ROP text is consistent with the goals and objectives of protecting those not intimate with initial fire development as sprinklers control the fire so as to prevent room flashover. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR EXPLANATION OF NEGATIVE: BUSH: The permission for patients to introduce materials into individual sleeping rooms in order to promote a more home like, residential setting should not be included in the Code when such materials also introduce an additional hazard without an associated increase in levels of protection. This proposal

introduces no technical justification to substantiate a change to requirements that have provided reasonable levels of protection for many years. In addition, there now seems to be more consideration on the source of materials introduced into a patient sleeping room than upon its nature and inherent levels of safety. It should also be noted that the comparison of textile materials to mattresses and other furnishings is not valid since there are major differences in the configuration, construction and burning characteristics of these materials. Curtains and draperies are hung in a vertical position and are of a light-weight construction that would permit more rapid fire spread even before the reaction of automatic sprinklers. The more substantial construction of mattresses and other furnishings would contribute to fire spread and associated sprinkler activation in a much different fashion. There is no direct correlation between the tests for mattresses and furnishings and those tests of NFPA 701 for textile materials as indicated in the Committee Statement. The Code was amended during a previous cycle to permit the introduction of patient-owned furnishings with increased levels of fire protection installed within the sleeping room. This action permits additional combustible material to be installed within the patient room without any fire protection consideration. Part of the justification of this proposal as addressed in the Committee Statement is to promote a more Residential setting, which seems misplaced for a Health Care Occupancy. _______________________________________________________________101-269 Log #159 SAF-HEA FINAL ACTION: Accept in Principle in Part (19.1.6.2) _______________________________________________________________ SUBMITTER: Joseph T. Holland, Hoover Treated Wood Products COMMENT ON PROPOSAL NO: 101-439 RECOMMENDATION: Revise text to read as follows: 19.1.6.2 Health care occupancies shall be limited to the types of building construction shown in Table 18.1.6.2 (See 8.2.1.) Exception: Any building of Type I(443), Type I (332), Type II(222), or Type II(111) construction shall be permitted to include roofing systems involving combustible supports, decking, or roofing, provided that the following criteria are met: (a) The roof covering meets Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Covering s. and : (b) The roof is separated from all occupied portions of the building by a noncombustible floor assembly having not less than a 2-hour fire resistance rating that includes not less than 2 1/2 in. (6.4 cm) of concrete or gypsum fill. Structural elements supporting the 2-hour fire resistance-rated floor assembly shall be required to have only the fire resistance rating required of the building. or (c) The roof/ceiling assembly is constructed with fire-retardant-treated wood meeting the requirements of NFPA 5000. The roof/ceiling assembly shall have the required fire resistance rating for the type of construction and the roof covering meets Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Coverings. The use of fire-retardant-treated wood in the roof/ceiling assembly of Type I buildings over two stories in height shall not be permitted. SUBSTANTIATION: Fire-retardant-treated wood has several unique qualities that are not recognized by the current code provision. As we stated before you cannot start a fire with FRTW: it takes an external source of ignition and fuel to get the FRTW involved in a fire. It has a very low flame spread, less than 25 (actually in the 10 to 15 range), a very low smoke developed rating, 50. FRTW roofs have been allowed in these types of buildings by building codes for at least 30 years. A review of the types of construction covered by this code section reveals that in the Type II building the roof construction needs a one-hour fire rated assembly. It doesn’t matter whether its steel or wood it needs a one-hour assembly. When the steel assembly is compromised by a fire it can collapse. Collapse can occur very quickly (can be as soon as five minutes after exposure). Protecting occupants from collapse of a one-hour rated roof constructed of wood and not protecting them from collapse of a one-hour rated steel roof seems inconsistent. The proposal requires protection from below (either 2, 1.5 or 1 hour depending on the type of construction); protection from above (Class A roof covering) while recognizing the unique characteristics of FRTW. While we like the committee’s position that because 220 will allow what we are asking our request is not necessary, we do not agree. It’s our understanding, in discussion, with staff that the provisions in the occupancy chapters, such as, 18 and 19 override general provisions in the LSC and other codes. COMMITTEE MEETING ACTION: Accept in Principle in Part Insert a new 19.1.6.6 (and renumber existing 19.1.6.6 through 19.1.6.8 to become 19.1.6.7 through 19.1.6.9) as follows: 19.1.6.6 Any building of Type I(443), Type I(332), Type II(222), or Type II(111) construction shall be permitted to include roofing systems involving combustible supports, decking, or roofing, provided that the following criteria are met: (1) The roof covering shall meet Class A requirements in accordance with NFPA 256, Standard Methods of Fire Tests of Roof Coverings. (2) The roof/ceiling assembly shall be constructed with fire-retardant-treated wood meeting the requirements of NFPA 220, Standard on Types of Building Construction.

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Report on Comments — Copyright, NFPA NFPA 101 (3) The roof/ceiling assembly shall have the required fire resistance rating for the type of construction. COMMITTEE STATEMENT: The action accomplishes what the submitter intended, but does so as a stand-alone provision not tied to existing 19.1.6.5. The text not accepted is extraneous and unnecessary to meet the need. The submitter was present for the committee discussion on this comment and expressed his agreement with the action. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-270 Log #110 SAF-HEA FINAL ACTION: Reject (19.2.3.4(2)) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-464 RECOMMENDATION: Revise the wording of this subparagraph as follows: Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above handrail height, shall be permitted for the installation of hand rub dispensing units in accordance with 18.3.2.6. SUBSTANTIATION: There seems to be no legitimate reason to permit restrictions to the clear widths of corridors only for the installation of hand rub dispensers. There are many other devices, such as decorations, building service equipment controls, and alarm initiation and notification appliances, which would provide for less restriction and introduce less hazards, but are not permitted by the wording in the original proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee statement for rejection of Comment 101-245. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-271 Log #358 SAF-HEA FINAL ACTION: Reject (19.2.5) _______________________________________________________________ SUBMITTER: Dawn LeBaron, Fletcher Allen Healthcare / Rep. New England Healthcare Engineer’s Society COMMENT ON PROPOSAL NO: 101-441 RECOMMENDATION: Delete Section 19.2.5.6.2.1.2 of the section 19.2.5 rewrite. SUBSTANTIATION: The New England Healthcare Engineers’ Society polled it’s 330 members after sharing written pros and cons explanation of Proposal 101-441. The membership voted a strong majority 2.5 to 1 ratio, to reject this one section which might require a retroactive reconfiguration of a patient sleeping suite or require installation of smoke detectors. The membership believes the cost of such changes are unreasonable given the suite complied with Code when it was constructed and there is no history of a fire safety problem. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The provisions proposed in the ROP get back what was lost in a recent “editorial re-organization.” The provisions will offer more options than were offered by the regulations under which the existing facility was built. A complying patient sleeping suite will not be required to be retroactively reconfigured or provided with smoke detectors as the smoke detection provision has been deleted. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-271a Log #CC204 SAF-HEA FINAL ACTION: Accept (19.2.5) _______________________________________________________________ SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-441 RECOMMENDATION: Further revise the text from the action on ROP Proposal 101-441 as follows: 19.2.5.6.1.1 Suite Permission. Suites complying with 19.2.5.6 18.2.5.6 shall be permitted to be used to meet the corridor access requirements of 19.2.5.5. ***** 19.2.5.6.1.3.2 Hazardous areas within a suite shall be separated from the remainder of the suite in accordance with 19.3.2.1, unless otherwise provided in 19.2.5.6.1.3.3 or 19.2.5.6.1.3.4. 19.2.5.6.1.3.3* Hazardous areas within a suite shall not be required to be separated from the remainder of the suite where complying with both of the following:

(a) The suite is primarily a hazardous area. (b) The suite is protected by an approved automatic smoke detection system in accordance with Section 9.6. (b) (c) The suite is separated from the rest of the health care facility as required for a hazardous area by 19.3.2.1. 19.2.5.6.1.3.4* Sterile surgical supplies limited to one-day supply in operating suites or similar areas shall be permitted. Spaces containing sterile surgical materials limited to a one-day supply in operating suites or similar spaces that are sprinklered in accordance with 19.3.5.3 shall be permitted to be open to the remainder of the suite without separation. ***** A.19.2.5.6.1.3.3 An example of a suite where the suite is a hazardous area is a medical records suite or a pharmaceutical suite. Examples of suites that might be hazardous areas are medical records and pharmaceutical suites. A.19.2.5.6.1.3.4 It is the intent that the provision of 19.2.5.6.1.3.4 apply only where the quantities of combustibles occupy an area exceeding 50 ft2 (4.6 m2) and therefore are considered so as to be a hazardous contents area areas. Where quantities of combustibles occupy less than 50 ft2 (4.6 m2) there is no restriction on quantity. ***** 19.2.5.6.2 Sleeping Suites. 19.2.5.6.2.1 Sleeping Suite Arrangement. 19.2.5.6.2.1.1* Occupants of habitable rooms within sleeping suites shall have exit access to a corridor complying with 19.3.6 without having to pass through more than one intervening room. ***** A.19.2.5.6.2.1.1 For the purposes of this paragraph it is the intent that “habitable rooms” not include individual bathrooms, closets, and similar spaces, as well as briefly occupied work spaces such as control rooms in radiology and small storage rooms in a pharmacy. The term “intervening room” means a room serving as a part of the required means of egress from another room. ***** 19.2.5.6.2.1.2 Sleeping suites shall be provided with constant staff supervision within the suite. 19.2.5.6.2.1.3 Sleeping suites shall be arranged in accordance with one of the following: (a)* Sleeping suites shall allow for direct visual supervision of the suite by staff from a normally attended location within the suite; and cubicle curtains shall be permitted. Patient sleeping rooms within sleeping suites shall provide one of the following: (i) The patient sleeping rooms shall be arranged to allow for direct supervison from a normally attended location within the suite such as provided by glass walls, and cubicle curtains shall be permitted. (ii) Any patient sleeping rooms without the direct supervision required by 19.2.5.6.2.1.3(a)(i) shall be provided with smoke detection in accordance with Section 9.6 and 19.3.4. (b)* Interior walls and partitions within sleeping suites shall not exceed three-quarters of the floor-to-ceiling height or shall not exceed 8 ft (2440 mm) in height, whichever is less; and staff shall provide supervision from a normally attended location within the suite. (b) (c) Sleeping suites shall be provided with a total coverage (complete) automatic smoke detection system in accordance with 9.6.2.8 and 18.3.4. ***** A.19.2.5.6.2.1.3(a) A.19.2.5.6.2.1.2(a) The interior partitions or walls may extend full height to the ceiling provided they do not obscure visual supervision of the suite. Where they do obscure visual supervision, see 19.2.5.6.2.1.3(b) 19.2.5.6.2.1.2(c) A.19.2.5.6.2.1.2(b) This provision does not require the direct visual supervision of the suite that is required by 19.2.5.6.2.1.2(a). In this case, it just requires that staff be in the suite and capable of providing supervision. This supervision is a combination of audible, visible and olfactory. The supervision is somewhat indirect due to the low-height partitions. Where interior partitions or walls exceed three-quarters of the floor-to-ceiling height or 8 ft (2440 mm), or subdivide the suite so as to obscure visual supervision of the suite, it is the intent that the suite comply with 19.2.5.6.2.1.2(c). ***** 19.2.5.6.3.3 Non-Sleeping Suite Maximum Size. Non-sleeping suites shall not note exceed 10,000 ft2 (930 m2). SUBSTANTIATION: Revisions from ROP are based on Comment 101-248, Comment 101-272, and the report of the health care occupancies task group on suites and arrangement of means of egress. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-272 Log #202 SAF-HEA FINAL ACTION: Accept in Principle (19.2.5.6.1, 19.2.5.6.1.1, 19.2.5.6.1.3.2, 19.2.5.6.1.3.3, 19.2.5.6.1.2.2(c)) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-441 RECOMMENDATION: Revise as follows: (1) 19.2.5.6.1.1 change reference from 18.2.5.6 to 19.2.5.6. (2) 19.2.5.6.1.3.2 change reference from 19.2.5.6.1.3.2 to 19.2.5.6.1.3.3 and 19.2.5.6.1.3.4. (3) 19.2.5.6.1.3.3 insert “all” between “with” and “all”. (4) 19.2.5.6.2.1.2(c) add “and staff shall provide supervision from a normally attended location with the suite” at the end of the sentence. SUBSTANTIATION: Comments (1) through (3) are editorial. Comment (4) is clarification. It was never the intent to have unattended suites. COMMITTEE MEETING ACTION: Accept in Principle See Comment 101-247a and Comment 101-271a. COMMITTEE STATEMENT: The actions on the referenced comments should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-273 Log #56 SAF-HEA FINAL ACTION: Accept in Principle (19.3.2.1.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-444 RECOMMENDATION: Reconsider the proposal and make any change needed to address the problem of vertical continuity of the separating partition. The current committee action would require Section 8.4 smoke partitions retroactively in existing installations. The current Code text appears to be adequate for existing installations in its use of the words “smoke-resisting” partitions, but might be deficient in the area of vertical continuity as explained by the submitter. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain action on ROP Proposal 101-444 so as to require smoke partitions in accordance with Section 8.4 for existing hazardous areas protected by sprinklers. COMMITTEE STATEMENT: The new language will not unfairly impact an existing installation. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-274 Log #272 SAF-HEA FINAL ACTION: Reject (19.3.2.1.2) _______________________________________________________________ SUBMITTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-444 RECOMMENDATION: Reject proposal to revise 19.3.2.1. Revert to 2003 code language. SUBSTANTIATION: Except for hazardous areas within relatively new or renovated facilities, the walls do stop at the ceiling where sprinkler protection is provided. If this were to become code, all of my network facilities would be affected with retroactive work to install walls slab to slab. Not worth the cost or disruption of patient care. COMMITTEE MEETING ACTION: Reject See action on Comment 101-273. COMMITTEE STATEMENT: The submitter’s substantiation is not correct. The smoke partition is permitted to stop at the underside of a monolithic ceiling. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-274a Log #330 SAF-HEA FINAL ACTION: Reject (19.3.2.6) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: This proposal is more appropriate as Annex guidance.

SUBSTANTIATION: NFPA 30 already addresses the use of Class 1 flammable liquids in institutional occupancies. The requirements are no different when the flammable liquid is gasoline, as a comparison. The only reason that there is no concern over gasoline is that it has no apparent health care application at present. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject needs to be addressed directly in the body of the Code as there is much misinformation on the subject of alcohol-based hand rub solutions. The provisions are an exemption to permit Class 1 flammable liquids, but the submitter’s characterization is incorrect. The alcohol-based hand rub solutions are not anything like gasoline whose characteristics are quite different. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-275 Log #394 SAF-HEA FINAL ACTION: Accept in Principle in Part (19.3.4.3.2.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-446 RECOMMENDATION: Accept Proposal 101-446. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The subject of Section 19.3.4.4 is emergency forces notification. This notification will not occur until positive alarm sequence or alarm verification (where used) is complete. If positive alarm sequence is specified, location in another section would be more appropriate. Note that Section 55.2.3.4 addresses positive alarm sequence under occupant notification. If “positive alarm sequence” is specified (as indicated in Proposal 101-414), the timing for this sequence should be consistent with that addressed in NFPA 72. The timing for positive alarm sequence is specified in NFPA 72 and includes an allowance of up to 15 seconds for acknowledgment and then up to 180 seconds for alarm investigation. The proposed language does not reflect this two-phase sequence terminology and will cause confusion in implementation. The acknowledgment period should agree with that in NFPA 72. (If a different timing of the investigation phase is specified, the rationale for the different timing should be addressed and provided as annex material for the related code section in accordance with Annex A-9 of the NFPA Committee Officer’s Guide.)COMMITTEE MEETING ACTION: Accept in Principle in Part See new text for 19.3.4.3 in action on Comment 101-256. Retain existing 19.3.4.3.2.2. COMMITTEE STATEMENT: See action and committee statement on Comment 101-256. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-276 Log #359 SAF-HEA FINAL ACTION: Accept in Principle (19.3.5.1) _______________________________________________________________ SUBMITTER: Dawn LeBaron, Fletcher Allen Healthcare / Rep. New England Healthcare Engineer’s Society COMMENT ON PROPOSAL NO: 101-449 RECOMMENDATION: Accept 101-449, support committee’s action. SUBSTANTIATION: The New England Healthcare Engineer’s Society polled it’s 330 members after sharing written pros and cons explanation of Proposal 101-449. The membership voted a strong majority 3.4 to 1 ratio, to accept the retroactive requirement to sprinkler protect existing nursing homes and buildings containing nursing homes. Sprinkler protection is well-known as the most reliable fire protection for life safety. COMMITTEE MEETING ACTION: Accept in Principle Retain action on ROP Proposal 101-449 so as to require existing nursing homes to be sprinklered. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-277 Log #370 SAF-HEA FINAL ACTION: Accept in Principle (19.3.5.1) _______________________________________________________________ SUBMITTER: Scott Adams, Uniform Fire Code Association/Chair COMMENT ON PROPOSAL NO: 101-449 RECOMMENDATION: Revise the following sections: NFPA 1 UFC 13.3.2.9.1 Nursing homes shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7, unless otherwise permitted by 19.3.5.3. Where required by 19.1.6, of NFPA 101,

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Report on Comments — Copyright, NFPA NFPA 101 other health care facilities shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7 of NFPA 101, unless otherwise permitted by 13.3.2.9.3. [ 101: 19.3.5.1]. A timeframe for compliance shall be established by the AHJ. NFPA 101 19.3.5.1 Nursing homes shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7, unless otherwise permitted by 19.3.5.3. Where required by 19.1.6, other health care facilities shall be protected throughout by an approved, supervised automatic sprinkler system in accordance with Section 9.7, unless otherwise permitted by 19.3.5.3. SUBSTANTIATION: The problem is well stated in the October 16, 2003 statement of NFPA President James M. Shannon calling for fire sprinklers in all nursing homes. October 16, 2003—The president of NFPA (National Fire Protection Association) today called for all nursing homes in the U.S. to be equipped with fire sprinklers, in the wake of two recent nursing home fires in Hartford and Nashville, where a total of 24 people died. In his statement, President James M. Shannon said that although the nursing home industry has made great strides in recent years to ensure residents are safe in the event of fire, more needs to be done. Sprinklers are already required in all new and many existing nursing homes, but where they are not yet required they must be added to the package of fire protection provided by existing codes and standards. He said nursing homes should be protected with more stringent fire protection because their residents are the least capable of saving themselves from fire. Shannon said his call for action is independent and does not interfere with the time-honored code-development process through which NFPA codes and standards are developed and revised. NFPA codes are developed by the consensus of diverse, experienced volunteers who serve on various NFPA committees, including those that pertain to fire and other life safety. “NFPA, as a century-old fire safety advocate, has an obligation to be an advocate and lead on issues crucial to safety, in this case, the need is for greater safety for nursing home residents,” he said. “These tragedies have taught us that we must do more to keep our elderly and disabled safe from fire. We know that fire sprinklers can control fires where they start and alleviate the burdens placed on staff to deal with the fire while relocating or evacuating patients,” said Shannon. “Sprinklers must be included in our stock of existing nursing homes because it is evident that common fire protection measures in nursing homes that work well now need to be strengthened.” According to NFPA research, when sprinklers are present in a building, the chances of dying in a fire are cut by one-half to two-thirds, compared to fires where sprinklers are not present. In fact, when measured by the average number of deaths per thousand fires in 1994-1998, the reduction associated with sprinklers is 82% for properties that care for the aged or sick. One-quarter of all nursing home fires occur in facilities not equipped with sprinklers. It is estimated that overall 10-15% of all nursing homes are not equipped with sprinklers. As a licensed nurse who worked in nursing homes prior to my entry into the fire service (firefighter/deputy state fire marshal, retired), I can attest to the difficulties of moving the elderly under normal conditions, never mind under fire conditions. Additionally, On March 13, 2003, the International Association of Fire Chiefs (IAFC) challenged the two major national code organizations—the National Fire Protection Association (NFPA) and the International Code Council (ICC)—to address a number of underlying fire safety issues that are in need of review, such as the concept of grandfathering. The IAFC said “Grandfathering must be eliminated from the codes for all target hazard buildings and occupancies, such as assemblies, multi-family occupancies and residential occupancies of substantial risk, such as group houses and 24-hour care facilities. All non-compliant, pre-existing occupancies must be required to come into full compliance with the most current fire and building codes within a specified phase-in time deadline.” Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Accept in Principle See action on ROP Proposal 101-449. COMMITTEE STATEMENT: The action does what the submitter requested. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-277a Log #324 SAF-HEA FINAL ACTION: Reject (19.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-450 RECOMMENDATION: Delete unless otherwise permitted by 19.3.5.2. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative

safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in a national standard that prevents all health care facilities from being sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. The conditions in hospitals and the conditions in limited care with respect to fire protection issues are the same. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-277b Log #332 SAF-HEA FINAL ACTION: Reject (19.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-449 RECOMMENDATION: Delete unless otherwise permitted by 19.3.5.2. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in a national standard that prevents all health care facilities from being sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. The conditions in hospitals and the conditions in limited care with respect to fire protection issues are the same. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-278 Log #325 SAF-HEA FINAL ACTION: Reject (19.3.5.3) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-451 RECOMMENDATION: Reconsider. SUBSTANTIATION: Section 9.7.3.1 addresses the needs of AHJ’s seeking to prohibit sprinklers. Prohibition of sprinklers without alternative suppression systems is a direct reduction of life safety requirements without alternative safeguards. A double jeopardy created by a minority of AHJ’s, in the manner described, indicates an issue more properly addressed by educational efforts rather necessitating an illogical requirement in national standard that prevents all health care facilities from being sprinklered. The multiple fatality fires in 2003 clearly indicate that unsprinklered health care facilities are inappropriate. The original fire loading in health care (metal an ceramics) has changed to paper and plastics. Fires have the potential of greater heat release far more than when non sprinklered facilities were first accepted. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Alternative protection acceptable to the AHJ is not necessarily an alternative suppression system. The provision of 19.3.5.2 is very much needed to prevent an AHJ who prohibits sprinklers in a particular area from then ruling that the building is not fully sprinklered and denying use of the features permitted for sprinklered buildings. This provision keeps such “Catch 22” situations for occurring. As long as the AHJ does not prohibit sprinklers in any area, the sprinklers will be installed throughout the building per NFPA 13. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17

101-108

Report on Comments — Copyright, NFPA NFPA 101 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-279 Log #371 SAF-HEA FINAL ACTION: Reject (19.3.5.5) _______________________________________________________________ SUBMITTER: Michael J. Jontry, Illinois Dept. of Public Health COMMENT ON PROPOSAL NO: 101-452 RECOMMENDATION: Revise text as follows: “...For new installations in existing health care occupancies, where more than two sprinklers are installed in a single area. waterflow detection shall be provided...”. SUBSTANTIATION: NFPA 1 Section 13.3.2.9.3 “Where this Code permits exceptions for fully sprinklered buildings or smoke compartments, the sprinkler system shall meet the following criteria:” NFPA 1 Sub-Section 13.3.2.9.3(1) “It shall be in accordance 9.7.1.1(1) of NFPA 101 unless it is an approved existing system.” NFPA 101 Section 9.7.1.1 “Each automatic sprinkler system required by another section of this Code shall be in accordance with one of the following:” NFPA 101 Sub-Section 9.7.1.1(1) “NFPA 13, Standard for the Installation of Sprinkler Systems.” NFPA 13, Installation of Sprinkler Systems, in Section 5-15.4.2 clearly calls for an inspectors test connection to represent the flow from one sprinkler head of the smallest diameter installed on the system. Similarly, NFPA 13, Section 5-15.4.3 also calls for a test connection sized to represent the flow from one sprinkler head of the smallest diameter installed on the system. The requirement established by the above references is that the flow from a single sprinkler shall initiate an alarm. The proposed deletion would achieve four goals. 1. NFPA 1, in the above referenced sections, would match NFPA 13 in requiring the flow from a single sprinkler head of the smallest diameter installed on the system to initiate an alarm. In the absence of wording to the contrary, a single flow switch could serve more than one hazardous area, provided the areas served are from the same domestic water source connection point. That reduces potential flow switch redundancy but still provides protection. 2. This change recognizes that where domestic fed sprinkler systems are permitted, the hazard is greater than that of the surrounding area. This is in keeping with the overall trend in dealing with such areas. In particular, over the years, this provision was changed to read “two sprinklers” from the original “three sprinklers”, and the provisions for “extra hazard” were eliminated in Healthcare Occupancies. In addition, NFPA 13 dictates that the flow from a single sprinkler, even in an area as potentially unhazardous as a walk-in freezer, requires the initiation of an alarm, while the present NFPA 1 Section 13-3.2.9.5 appears to discount the flow from one sprinkler, even in an area of greater hazard. 3. This change also clarifies potential misunderstanding in NFPA 1 Section 13.2.9.5 in that, as presently written, it is unclear if the flow from one sprinkler is required to initiate an alarm since installation of a flow sensing device is only required for TWO sprinklers in an area. 4. This change matches a proposed changes for NFPA 101 Section 19.3.5.5 and NFPA 5000 Section 55.3.1. Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee statement for rejection of ROP Proposal 101-452. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-280 Log #361 SAF-HEA FINAL ACTION: Accept in Principle (19.3.7.6) _______________________________________________________________ SUBMITTER: Dawn LeBaron, Fletcher Allen Healthcare / Rep. New England Healthcare Engineer’s Society COMMENT ON PROPOSAL NO: 101-458 RECOMMENDATION: Reject Proposal 101-458, Committee should take it out of 21.3.7.11. SUBSTANTIATION: The New England Healthcare Engineers’ Society polled it’s 330 members after sharing written pros and cons explanation of Proposal 101-458. The membership voted 2 to 1 to reject this proposed new retractive active requirement. The membership believes the cost and disruption to patient care would be unreasonable for the benefit gained. Doors are normally kept open, automatic closing, thereby avoiding the day to day door-person collision hazard. COMMITTEE MEETING ACTION: Accept in Principle Retain rejection of ROP Proposal 101-458.

COMMITTEE STATEMENT: The action is consistent with one of the submitter’s two options. Deletion of text from 21.3.7.11 is not permitted at the ROC stage as the subject has not had public review. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-281 Log #2 SAF-HEA FINAL ACTION: Hold (19.7.5.7(3)) _______________________________________________________________ SUBMITTER: Stephen Tourje, Blossom View Nursing Home COMMENT ON PROPOSAL NO: 101-460 RECOMMENDATION: Revise text to read as follows: Mobile soiled linen or trash collection receptacles with capacities greater than 32 gal shall be located in a room protected as a hazardous area when not attended. SUBSTANTIATION: Clarification is needed as to what constitutes “attended by staff”. In this instance, a 130 bed skilled nursing facility, the housekeeping staff places bedding etc., in the containers which are wheeled to the laundry by laundry staff on a continuing basis throughout the day. All areas are covered by staff 24/7 and all staff are trained to clear all corridors as part of our fire protection plan. These containers and this system of collection have been developed to address infection control and ergonomic issues. Some interpretations of this section may result in citations for what are safe policies. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The comment introduces new material that has not had public review via the ROP. As such, it must be held for processing during the next revision cycle. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-282 Log #111 SAF-HEA FINAL ACTION: Reject (20.2.3.3) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-464 RECOMMENDATION: Revise the wording of this subparagraph as follows: Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above handrail height, shall be permitted for the installation of hand rub dispensing units in accordance with 20.3.2.6. SUBSTANTIATION: There seems to be no legitimate reason to permit restrictions to the clear widths of corridors only for the installation of hand rub dispensers. There are many other devices, such as decorations, building service equipment controls, and alarm initiation and notification appliances, which would provide for less restriction and introduce less hazards, but are not permitted by the wording in the original proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The provision is meant to be specific to alcohol-based hand rub solution dispensers. See related explanation for rejecting same recommendation for health care occupancies in Comment 101-245. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-283 Log #327 SAF-HEA FINAL ACTION: Reject (20.3.2.6) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-464 RECOMMENDATION: This proposal is more appropriate as Annex guidance. SUBSTANTIATION: NFPA 30 already addresses the use of Class 1 flammable liquids in institutional occupancies. The requirements are no different when the flammable liquid is gasoline, as a comparison. The only reason that there is no concern over gasoline is that it has no apparent health care application at present. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject needs to be addressed directly in the body of the Code as there is much misinformation on the subject of alcohol-based hand rub solutions. The provisions are an exemption to permit Class 1 flammable liquids, but the submitter’s characterization is incorrect. The alcohol-based hand rub solutions are not anything like gasoline whose characteristics are quite different. NUMBER ELIGIBLE TO VOTE: 22

101-109

Report on Comments — Copyright, NFPA NFPA 101 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-284 Log #393 SAF-HEA FINAL ACTION: Accept in Principle (20.3.4.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-465 RECOMMENDATION: Accept Proposal 101-465. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The subject of Section 20.3.4.4 is emergency forces notification. This notification will not occur until positive alarm sequence or alarm verification (where used) is complete. If positive alarm sequence is specified, location in another section would be more appropriate. Note that Section 55.2.3.4 addresses positive alarm sequence under occupant notification. If “positive alarm sequence” is specified (as indicated in Proposal 101-466), the timing for this sequence should be consistent with that addressed in NFPA 72. The timing for positive alarm sequence is specified in NFPA 72 and includes an allowance of up to 15 seconds for acknowledgment and then up to 180 seconds for alarm investigation. The proposed language does not reflect this two-phase sequence terminology and will cause confusion in implementation. The acknowledgment period should agree with that in NFPA 72. (If a different timing of the investigation phase is specified, the rationale for the different timing should be addressed and provided as annex material for the related code section in accordance with Annex A-9 of the NFPA Committee Officer’s Guide.) COMMITTEE MEETING ACTION: Accept in Principle 20.3.4.3 Notification. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. 20.3.4.3.1 Occupant Notification. Occupant notification shall be accomplished automatically, without delay, in accordance with 9.6.3 upon operation of any fire alarm activating device. 20.3.4.3.2 20.3.4.4 Emergency Forces Notification. 20.3.4.3.2.1 20.3.4.4.1 Fire department notification shall be accomplished in accordance with 9.6.4. 20.3.4.3.2.2 20.3.4.4.2 Reserved. Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire department unless the alarm condition is reconfirmed after a period not exceeding 120 seconds. 20.3.4.4 20.3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. ( See 9.6.5. ) 21.3.4.3 Notification. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. 21.3.4.3.1 Occupant Notification. Occupant notification shall be accomplished automatically, without delay, in accordance with 9.6.3 upon operation of any fire alarm activating device. 21.3.4.3.2 21.3.4.4 Emergency Forces Notification. 21.3.4.3.2.1 21.3.4.4.1 Fire department notification shall be accomplished in accordance with 9.6.4. 21.3.4.3.2.2 21.3.4.4.2 Smoke detection devices or smoke detection systems equipped with reconfirmation features shall not be required to automatically notify the fire department unless the alarm condition is reconfirmed after a period not exceeding 120 seconds. 21.3.4.4 20.3.4.5 Emergency Control. Operation of any activating device in the required fire alarm system shall be arranged to accomplish automatically, without delay, any control functions required to be performed by that device. ( See 9.6.5. ) COMMITTEE STATEMENT: Positive alarm sequence will permit a 180 second delay before remote signals are sent off-site. This will help to prevent unnecessary runs by the fire department. With the addition of text permitting positive alarm sequence, 20.3.4.4.2 can be deleted. However, 21.3.4.4.2 must be retained for existing systems utilizing the 120-second reconfirmation feature. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-285 Log #262 SAF-HEA FINAL ACTION: Hold (20.3.6.1) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-468 RECOMMENDATION: Revise text as follows: 20.3.6.1 (See 18.3.6) Corridors shall comply with 18.3.6.1 through 18.3.6.4. SUBSTANTIATION: This Public Comment responds to the Committee Statement and implements the intent of the submitter’s Proposal.

COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: 1. The comment introduces new material that has not had public review via the ROP. As such, it must be held for processing during the next revision cycle. 2. The submitter based this comment on a Chapter 18 item and new health care occupancies must be sprinklered; here in Chapter 20, not all ambulatory health care occupancies are required to be sprinklered. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-285a Log #CC206 SAF-HEA FINAL ACTION: Accept (20.7.5 and 21.7.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the substantiation be corrected to read: “In ROC Comments 101-175 and 101-176, the SAF-FUR...”SUBMITTER: Technical Committee on Health Care Occupancies COMMENT ON PROPOSAL NO: 101-266 RECOMMENDATION: Revise as follows: 20.7.5.2 Newly introduced upholstered furniture shall meet comply with one of the following provisions: (1) the furniture shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(2) in 10.3.2 and 10.3.3. (2) the furniture shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 20.7.5.3 Newly introduced mattresses shall meet comply with one of the following provisions: (1) the mattresses shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(3) in 10.3.2 and 10.3.4. (2) the mattresses shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). ***** 21.7.5.2 Newly introduced upholstered furniture shall meet comply with one of the following provisions: (1) the furniture shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(2) in 10.3.2 and 10.3.3. (2) the furniture shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). 21.7.5.3 Newly introduced mattresses shall meet comply with one of the following provisions: (1) the mattresses shall meet the criteria specified when tested in accordance with the methods cited in 10.3.2(3) in 10.3.2 and 10.3.4. (2) the mattresses shall be in a building protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1). SUBSTANTIATION: In ROP Proposals 101-275 and 101-276, the SAF-FUR Furnishings Committee acted to remove the sprinkler exemption under which upholstered furniture and mattresses were not required to be tested for cigarette ignition resistance. The action on this comment retains the current sprinkler exemption for ambulatory health care occupancies. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-286 Log #112 SAF-HEA FINAL ACTION: Reject (21.2.3.3) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-472 RECOMMENDATION: Revise the wording of this subparagraph as follows: Where minimum corridor width is 1830 mm (72 in.), projections of maximum 152 mm (6 in.) from the corridor wall, above handrail height, shall be permitted for the installation of hand rub dispensing units in accordance with 21.3.2.6. SUBSTANTIATION: There seems to be no legitimate reason to permit restrictions to the clear widths of corridors only for the installation of hand rub dispensers. There are many other devices, such as decorations, building service equipment controls, and alarm initiation and notification appliances, which would provide for less restriction and introduce less hazards, but are not permitted by the wording in the original proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The provision is meant to be specific to alcohol-based hand rub solution dispensers. See related explanation for rejecting same recommendation for health care occupancies in Comment 101-245. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

101-110

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-287 Log #328 SAF-HEA FINAL ACTION: Reject (21.3.2.6) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-472 RECOMMENDATION: This proposal is more appropriate as Annex guidance. SUBSTANTIATION: NFPA 30 already addresses the use of Class 1 flammable liquids in institutional occupancies. The requirements are no different when the flammable liquid is gasoline, as a comparison. The only reason that there is no concern over gasoline is that it has no apparent health care application at present. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The subject needs to be addressed directly in the body of the Code as there is much misinformation on the subject of alcohol-based hand rub solutions. The provisions are an exemption to permit Class 1 flammable liquids, but the submitter’s characterization is incorrect. The alcohol-based hand rub solutions are not anything like gasoline whose characteristics are quite different. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-288 Log #386 SAF-HEA FINAL ACTION: Accept in Principle in Part (21.3.4.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-473 RECOMMENDATION: Accept Proposal 101-473. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The subject of Section 21.3.4.4 is emergency forces notification. This notification will not occur until positive alarm sequence or alarm verification (where used) is complete. If positive alarm sequence is specified, location in another section would be more appropriate. Note that Section 55.2.3.4 addresses positive alarm sequence under occupant notification. If “positive alarm sequence” is specified (as indicated in Proposal 101-466), the timing for this sequence should be consistent with that addressed in NFPA 72. The timing for positive alarm sequence is specified in NFPA 72 and includes an allowance of up to 15 seconds for acknowledgment and then up to 180 seconds for alarm investigation. The proposed language does not reflect this two-phase sequence terminology and will cause confusion in implementation. The acknowledgment period should agree with that in NFPA 72. (If a different timing of the investigation phase is specified, the rationale for the different timing should be addressed and provided as annex material for the related code section in accordance with Annex A-9 of the NFPA Committee Officer’s Guide.) COMMITTEE MEETING ACTION: Accept in Principle in Part See action on Comment 101-284. COMMITTEE STATEMENT: Positive alarm sequence will permit a 180 second delay before remote signals are sent off-site. This will help to prevent unnecessary runs by the fire department. With the addition of text permitting positive alarm sequence, 20.3.4.4.2 can be deleted. However, 21.3.4.4.2 must be retained for existing systems utilizing the 120-second reconfirmation feature. See Comment 101-284. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-289 Log #57a SAF-AXM FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of ROP Proposals 101-51 and 101-476. COMMITTEE STATEMENT: The SAF-AXM committee understands the need for special provisions for lock-ups to supplement the requirements for assembly occupancies. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-290 Log #57b SAF-BCF FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reviewed the proposed lock-up provisions and determined they do not affect board and care facililties. Therefore, no action is necessary. The committee notes it has no objection to the proposed lock-up provisions. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-291 Log #57c SAF-END FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain acceptance of Proposal 101-51 and Proposal 101-476. COMMITTEE STATEMENT: The BLD/SAF-END committee does not take exception to the proposed provisions for Lock-ups. The committee is aware that BLD/SAF-DET will hold its ROC meeting after all the other occupancy chapter committees have met. The committee has requested that BLD/SAF-DET add mandatory references (that is, “pointers” to the provisions for Lock-ups) in each of the occupancy chapters via a committee comment. NUMBER ELIGIBLE TO VOTE: 12 BALLOT RESULTS: Affirmative: 8 BALLOT NOT RETURNED: 4 BARTLETT, ONEISOM, SINSIGALLI, WARBURTON _______________________________________________________________101-292 Log #57d SAF-HEA FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See Comment 101-295a which accomplishes the recommended changes.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Further revise the text for lock-ups from that shown in ROP Proposal 101-476 as follows: 22.1.1.1.5* Lock-ups in other than detention and correctional occupancies and health care occupancies shall comply with the requirements of 22.4.5. 23.1.1.1.5* Lock-ups, other than approved existing lockups, in other than detention and correctional occupancies and health care occupancies shall comply with the requirements of 23.4.5. 22.4.5.1.1 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for more than 50 detainees shall comply with the requirements of Chapter 22 for detention and correctional occupancies. 22.4.5.1.2 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where any individual is detained for 24 or more hours shall comply with the requirements of Chapter 22 for detention and correctional occupancies. 22.4.5.1.3 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for not more than 50 detainees and where no individual is detained for 24 hours or more shall comply with 22.4.5.1.4 or 22.4.5.1.5. 23.4.5.1.1 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for more than 50 detainees shall comply with the requirements of Chapter 23 for detention and correctional occupancies. 23.4.5.1.2 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where any individual is detained for 24 or more hours shall comply with the requirements of Chapter 23 for detention and correctional occupancies.

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Report on Comments — Copyright, NFPA NFPA 101 23.4.5.1.3 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for not more than 50 detainees and where no individual is detained for 24 hours or more shall comply with 23.4.5.1.4 or 23.4.5.1.5. COMMITTEE STATEMENT: See A.22.1.1.1.4 and A.23.1.1.1.4 as proposed in ROP Proposal 101-476. Health care occupancies employ a defend-in-place strategy that permits door locking and relies on staff to unlock doors. Health care occupancies need to be exempt from the requirements of Chapters 22 and 23, including the new provisions for lock-ups. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-293 Log #57e SAF-IND FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation.COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: SAF-IND takes no issue with the provisions introduced by proposals 101-51 and 101-476, and notes that the provisions do not apply to industrial and storage occupancies. Also see committee action on comment 101-29. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-294 Log #57f SAF-MER FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action necessary. COMMITTEE STATEMENT: SAF-MER is in support of the action taken by SAF-DET on proposals 101-51 and 101-476. Also see Committee Action on Comment 101-9f. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-295 Log #57g SAF-RES FINAL ACTION: Accept in Principle (22.1.1, 22.4..5, 23.11, 23.4.5) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Review with respect to the impact the Lock-up provisions will have on the technical committee’s specific occupancy; take action as needed. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reviewed the proposed lock-up provisions and determined they do not affect the residential occupancy chapters. Therefore, no action is necessary. The committee notes it has no objection to the proposed lock-up provisions. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-295a Log #CC403 SAF-DET FINAL ACTION: Accept (22.1.1, 22.4.5, 23.1.1 and 23.4.5) _______________________________________________________________ SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Further revise the text for lock-ups from that shown in ROP Proposal 101-476 as follows: 22.1.1.1.5* Lock-ups in other than detention and correctional occupancies and health care occupancies shall comply with the requirements of 22.4.5.

23.1.1.1.5* Lock-ups, other than approved existing lockups, in other than detention and correctional occupancies and health care occupancies shall comply with the requirements of 23.4.5. 22.4.5.1.1 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for more than 50 detainees shall be classified as detention and correctional occupancies and shall comply with the requirements of Chapter 22 for detention and correctional occupancies. 22.4.5.1.2 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where any individual is detained for 24 or more hours shall be classified as detention and correctional occupancies and shall comply with the requirements of Chapter 22 for detention and correctional occupancies. 22.4.5.1.3 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for not more than 50 detainees and where no individual is detained for 24 hours or more shall comply with 22.4.5.1.4 or 22.4.5.1.5. 23.4.5.1.1 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for more than 50 detainees shall be classified as detention and correctional occupancies and shall comply with the requirements of Chapter 23 for detention and correctional occupancies. 23.4.5.1.2 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where any individual is detained for 24 or more hours shall be classified as detention and correctional occupancies and shall comply with the requirements of Chapter 23 for detention and correctional occupancies. 23.4.5.1.3 Lock-ups, in occupancies other than detention and correctional occupancies and health care occupancies, where the holding area has capacity for not more than 50 detainees and where no individual is detained for 24 hours or more shall comply with 23.4.5.1.4 or 23.4.5.1.5. SUBSTANTIATION: See A.22.1.1.1.4 and A.23.1.1.1.4 as proposed in ROP Proposal 101-476. Health care occupancies employ a defend-in-place strategy that permits door locking and relies on staff to unlock doors. Health care occupancies need to be exempt from the requirements of Chapters 22 and 23, including the new provisions for lock-ups. The SAF-HEA Health Care Occupancies Technical Committee requested the exemption when it reviewed the provisions for lock-ups at its ROC-preparation meeting. The other change made by this comment is a clarification that the lock-ups (1) where an individual stays more than 24 hours or (2) with more than 50 persons, constitute a detention and correctional facility that must meet all the provisions for a detention and correctional occupancy, not the provisions for lock-ups. The ROP language referring to following “the requirements of Chapter 22/23 for detention and correctional occupancies” could be misread so as to require following only the provisions of the new subsection on lock-ups. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-295b Log #CC404 SAF-DET FINAL ACTION: Accept (22.1.1, 22.4.5, 23.1.1 and 23.4.5) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that it is permitting the action to stand given that each occupancy chapter technical committee reviewed the new provisions for Lock-ups at its ROC meeting. Only health care occupancies exempted itself – see Comment 101-292 and 101-295a.SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-476 RECOMMENDATION: Add mandatory references, for the provisions for lock-ups, to the occupancy chapters as follows: (new assembly)12.2.11.2 Lock-ups. Lock-ups in assembly occupancies shall comply with the requirements of 22.4.5.(existing assembly)13.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in assembly occupancies shall comply with the requirements of 23.4.5.(new educational)14.2.11.2 Lock-ups. Lock-ups in educational occupancies shall comply with the requirements of 22.4.5.(existing educational)15.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in educational occupancies shall comply with the requirements of 23.4.5.(new day care)16.2.11.2 Lock-ups. Lock-ups in day-care occupancies shall comply with the requirements of 22.4.5.(existing day care)17.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in day-care occupancies shall comply with the requirements of 23.4.5.(new ambulatory health care)20.2.11 Special Means of Egress Features. (Reserved)

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Report on Comments — Copyright, NFPA NFPA 101 20.2.11.1 (Reserved)20.2.11.2 Lock-ups. Lock-ups in ambulatory health care occupancies shall comply with the requirements of 22.4.5.(existing ambulatory health care)21.2.11 Special Means of Egress Features. (Reserved)21.2.11.1 (Reserved)21.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in ambulatory health care occupancies shall comply with the requirements of 23.4.5.(new hotels and dormitories)28.2.11 Special Means of Egress Features. (Reserved)28.2.11.1 (Reserved)28.2.11.2 Lock-ups. Lock-ups in hotel and dormitory occupancies shall comply with the requirements of 22.4.5.(existing hotels and dormitories)29.2.11 Special Means of Egress Features. (Reserved)29.2.11.1 (Reserved)29.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in hotel and dormitory occupancies shall comply with the requirements of 23.4.5.(new apartment buildings)30.2.11 Special Means of Egress Features. (Reserved)30.2.11.1 (Reserved)30.2.11.2 Lock-ups. Lock-ups in apartment occupancies shall comply with the requirements of 22.4.5.(existing apartment buildings)31.2.11 Special Means of Egress Features.31.2.11.1 In high-rise buildings using Option 1, Option 2, or Option 3, smokeproof enclosures shall be provided in accordance with 7.2.3.31.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in apartment occupancies shall comply with the requirements of 23.4.5.(new residential board and care)32.3.2.11 Special Means of Egress Features. (Reserved)32.3.2.11.1 (Reserved)32.3.2.11.2 Lock-ups. Lock-ups in residential board and care occupancies shall comply with the requirements of 22.4.5.(existing residential board and care)33.3.2.11 Special Means of Egress Features. (Reserved)33.3.2.11.1 (Reserved)33.3.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in residential board and care occupancies shall comply with the requirements of 23.4.5.(new mercantile)36.2.11 Special Means of Egress Features. (Reserved)36.2.11.1 (Reserved)36.2.11.2 Lock-ups. Lock-ups in mercantile occupancies shall comply with the requirements of 22.4.5.(existing mercantile)37.2.11 Special Means of Egress Features. (Reserved)37.2.11.1 (Reserved)37.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in mercantile occupancies shall comply with the requirements of 23.4.5.(new business)38.2.11 Special Means of Egress Features. (Reserved)38.2.11.1 (Reserved)38.2.11.2 Lock-ups. Lock-ups in business occupancies shall comply with the requirements of 22.4.5.(existing business)39.2.11 Special Means of Egress Features. (Reserved)39.2.11.1 (Reserved)39.2.11.2 Lock-ups. Lock-ups, other than approved existing lock-ups, in business occupancies shall comply with the requirements of 23.4.5.(industrial)40.2.11 Special Means of Egress Features. (Reserved)40.2.11.1 (Reserved)40.2.11.2 Lock-ups. 40.2.11.2.1 Lock-ups in new industrial occupancies shall comply with the requirements of 22.4.5.40.2.11.2.2 Lock-ups, other than approved existing lock-ups, in existing industrial occupancies shall comply with the requirements of 23.4.5.(storage)42.2.11 Special Means of Egress Features. (Reserved)42.2.11.1 (Reserved)42.2.11.2 Lock-ups.42.2.11.2.1 Lock-ups in new storage occupancies shall comply with the requirements of 22.4.5.42.2.11.2.2 Lock-ups, other than approved existing lock-ups, in existing storage occupancies shall comply with the requirements of 23.4.5.SUBSTANTIATION: The occupancy chapter technical committees reviewed the provisions for lock-ups at their ROC-preparation meetings. The Technical Committee on Health Care Occupancies asked for an exemption for health care occupancies, but not for ambulatory health care occupancies. All the other occupancy chapter technical committees responded to the comments from the Technical Correlating Committee with an action of the form “accept in principle, no further action needed.”

The Technical Committee on Educational and Day-Care Occupancies asked that mandatory references to the new provisions for lock-ups be added to the occupancy chapters. A Code user applying the Code to an assembly occupancy with a lock-up (for example, a sports arena with a holding area for detaining unruly patrons) would not know to go to the detention and correctional occupancy chapter for requirements for lock-ups. The roadmap needs to be in the occupancy chapters. The detailed requirements need to be in the detention and correctional occupancy chapter. This comment accomplishes placing all the necessary mandatory references (that is, “pointers”) in the occupancy chapters. The x.2.11 subsection on special means of egress features was chosen as the appropriate spot for placing such pointers because doors are locked against egress in lock-ups. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-295c Log #CC406 SAF-DET FINAL ACTION: Reject (22.3.7.8) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT as the text is not needed. ROP Proposal 101-183 remains Rejected.SUBMITTER: Technical Committee on Detention and Correctional Occupancies COMMENT ON PROPOSAL NO: 101-186 RECOMMENDATION: Revise as follows: 22.3.7.8 Doors shall provide resistance to the passage of smoke. Doors shall be exempt from the requirements of 8.5.4.2 and 8.2.2.4. Swinging doors shall be self-latching, or the opening resistance of the door shall be a minimum of 5 lbf (22 N). [Note: the 8.5.4.2 referenced above is meant to refer to the new requirement for smoke barrier doors to be in complance with 8.2.2.4 as shown in ROP Proposal 101-183 that the TCC rejected at ROP stage, but whose staus was uncertain when SAF-DET met to prepare its ROC.] SUBSTANTIATION: Detention and correctional occupancies need to avoid the use of swinging doors as such doors can be used as weapons by the residents. Rather, sliding doors are used. It is not practical to install and maintain S-rated (smoke-leakage rated) sliding doors. The gasketing systems can be removed by residents and used as weapons. The requirement for self-closers or automatic closers creates operational difficulties in detention and correctional occupancies where security is paramount. The current smoke barrier requirements adequately serve both the life safety and the security needs. See also Comment 101-124a. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 18 BALLOT RESULTS: Affirmative: 13 BALLOT NOT RETURNED: 5 GORDON, MCNAMARA, MILLER, NEALY, PAVEY _______________________________________________________________101-296 Log #385 SAF-RES FINAL ACTION: Reject (24.1.2.2) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. COMMENT ON PROPOSAL NO: 101-490 RECOMMENDATION: Revise text as follows: 24.1.2.2 No dwelling unit of a residential occupancy shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 24.1.2.2.1 or 24.1.2.2.2. 24.1.2.2.1 in buildings that are protected by an automatic sprinkler system in accordance with Section 9.7. 24.1.2.2.1 Dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The dwelling unit of the residential occupancy shall comply with Chapter 24. (2) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4 24.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (2) (1) The sole means of egress from the dwelling unit of the residential occupancy to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The dwelling unit of the residential occupancy shall comply with Chapter 24 (3) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4

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Report on Comments — Copyright, NFPA NFPA 101 SUBSTANTIATION: The revisions we have proposed to this Committee Proposal eliminates the sprinkler trade-off that allows the 1-hour fire barrier separation of the sole means of egress which passes through a nonresidential occupancy to be omitted when the building is protected by an automatic sprinkler system. We believe that both automatic sprinkler protection and a 1-hour fire barrier separation are necessary in order to allow the sole means of egress to pass through a nonresidential occupancy. Traditionally, this code has required dwelling units to have their primary means of egress directly to the exterior of the building or through a 1-hour corridor leading to an exit enclosure or directly to the exterior in buildings classified as residential occupancies. Why should this requirement be lessened in order to allow the sole means of egress to pass through a nonresidential occupancy which would most likely be more hazardous than a residential occupancy? Redundant protection should be provided for the sole means of egress to better assure that it will be maintained sufficiently safe during a fire emergency to allow the occupants to escape safely. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The two options provided by Proposal 101-490 (automatic sprinkler protection or rated separation of the means of egress) afford a reasonable level of protection. No data has been submitted to substantiate the proposed requirement for both sprinkler protection and separation of the means of egress. It is noted the proposed revision could retrospectively impact existing buildings. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: The comment would make the means of egress through non-residential occupancy up to the same standard as residential occupancy, which seems a logical consistency. _______________________________________________________________101-297 Log #128 SAF-RES FINAL ACTION: Reject (24.3.4 (New) ) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-496 RECOMMENDATION: Accept Proposal 101-496. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The smoke alarm criteria, which has been proposed to be deleted by this comment, must be maintained in NFPA 101 because NFPA 72 addresses only new installations, whereas NFPA 101 addresses both new and existing conditions. The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee

Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document. With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101. _______________________________________________________________101-298 Log #58 SAF-RES FINAL ACTION: Accept in Principle (24.3.4 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-497 RECOMMENDATION: Give consideration, so as to make any needed changes, to: (a) Deleting proposed 24.3.4.1 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. (b) Renumbering the remainder of proposed 24.3.4 to be part of 24.3.3 (as done in Proposal 101-517) so as to retain the numbering format used in other occupancy chapters where the 3.4 subsection addresses alarms, 3.5 extinguishment, and 3.6 corridors. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the action on Proposal 101-497 by renumbering the proposed 24.3.4.1 and deleting the proposed 24.3.4.2 and 24.3.4.3: 24.3.4 24.3.4.1 24.3.3.4 Contents and Furnishings. Contents and furnishings shall not be required to comply with Section 10.3. Delete the proposed 24.3. 24.3.4.2 Furnishings or decorations of an explosive or highly flammable character shall not be used. 24.3.4.3 Fire-retardant coatings shall be maintained to retain the effectiveness of the treatment under service conditions encountered in actual use. COMMITTEE STATEMENT: Given the state of flux of the provisions of Ch.10, the committee is maintaining the exemption of one- and two-family dwellings from Section 10.3. In addition, it is deleting provisions regarding the use of explosive and highly flammable furnishings and decorations, and fire-retardant coatings because of the lack of enforcibility, and because such issues are better regulated by other national standards, such as those promulgated by the Consumer Product Safety Commission (CPSC) and the Upholstered Furniture Action Council (UFAC). NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-299 Log #152 SAF-RES FINAL ACTION: Reject (24.3.4.1) _______________________________________________________________ SUBMITTER: Wendy B. Gifford, National Electrical Manufacturers Association COMMENT ON PROPOSAL NO: 101-498 RECOMMENDATION: Accept Proposal 101-498. SUBSTANTIATION: The Committee rejects this proposal by stating there is “no technical justification” provided to “support a retroactive requirement for smoke alarms in sleeping rooms of existing apartment buildings.” We believe there is technical justification, as follows: 1) Wiring fires in residences are directly correlated to the age of the dwelling, according to a CPSC-sponsored study reported in the Fire Journal, January/February 1990. (What Causes Wiring Fires in Residences? Linda E. Smith and Dennis McCoskrie, p. 19-ff.) “Fire rate increased as the age of the dwelling increased.” According to the study, electrical fires have consistently represented about 8 percent of total residential fires. In buildings over 40 years of age, they would represent 1.64 times the average, or over 13 percent. A copy of the article has been submitted and is available via the CPSC website at http://www.cpsc.gov/LIBRARY/FOIA/FOIA04/os/firejournal.pdf.

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Report on Comments — Copyright, NFPA NFPA 101 2) “House Fire Deaths” by Elliot F. Eisenberg, reported in Housing Economics, (p. 11-13) November 2002, concludes “Lastly, older residential structures were shown to have much higher fire death rates than newer ones.” The conclusion was based on two surveys, a national study by the NAHB (1987) and one examining all residential fire deaths in California (1986-91). The death rate for older housing stock (five years+ or 15 years+ depending on the study) was five to ten times higher than that of new housing. There may be myriad reasons for this, but one, surely, is that new construction requires more complete fire protection than grandfathered existing residences. (Full article at http://www.nahb.org/fileUpload_details.aspx?contentID-4097. 3) There is new information which adds urgency to the case for thorough protection in existing structures. New smoke alarm studies released by the National Institute of Standards and Testing concluded that since the last comprehensive tests were conducted thirty years ago, anticipated escape time from flaming fires has dropped from 17 minutes to 3 minutes. This represents a dramatic decrease in the escape window for a family to get out alive. (Full report is available at http://smokealarm.nist.gov/.) Considering these facts, and the fact that deaths and injuries are twice as likely to occur in fires originating in bedrooms (U.S. Fire Problem Overview, NFPA Report, June 2003), the less than $15 cost of a typical smoke alarm seems nominal, not significant. There seems no technical justification for leaving existing residential sleeping rooms unprotected. Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee stands on its previous substantiation. Prior to adding new requirements to be applied retroactively to existing buildings, the committee must be convinced the level of protection currently prescribed is inadequate, and no compelling evidence in the form of fire loss data has been presented to do so. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 19 Negative: 3 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: The provision of inexpensive battery operated smoke alarms within sleeping areas of existing single family dwellings lacking same now would have an immediate impact reducing the occurrence of home fire deaths. Such a requirement also fits within the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. With these smoke alarms now routinely available at $10 or less and annual battery replacement cost minimal, this low cost/high benefit solution to the home fire death problem is warranted. GIFFORD: The data presented clearly shows that the fire danger is higher in older buildings, that escape time has plummeted, and that deaths are more likely in bedrooms. I do not understand the committee’s reluctance to protect the millions of existing homes in the U.S. HOWE: As a result of numerous NFPA studies and reports it is commonly understood that the broad use of smoke alarms in residential occupancies has led to a drop in fire deaths over the last few decades. By installing additional smoke alarms in all sleeping rooms the critical time needed to escape a fire will be improved under most fire scenarios, resulting in fewer fire deaths and injuries. At the cost of between $15 and $90 for a three bedroom dwelling the cost implications are not significant and are likely less of a cost factor than compiling with any other section in Chapter 24 or Chapter 34. _______________________________________________________________101-300 Log #59 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-499 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice.

BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: The increase in life safety that automatic sprinklers will provide new one- and two-family dwellings does not support their mandatory use in our minimum-based building codes. Most home fires and loss of life occur in older dwellings, as was established in the NAHB study titled “Residential Fire Deaths in the United States: Causes and Solutions”. I believe that any appreciable reductions in the current historically low death rate in one- and two-family dwellings will only come through public education and rehabilitation of older housing, rather than mandating the installation of automatic sprinklers. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-301 Log #60 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain.

COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-302 Log #61 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-501 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the intent of the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis

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Report on Comments — Copyright, NFPA NFPA 101 which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-303 Log #119 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Wayne Senter, Kitsap Fire District #7 COMMENT ON PROPOSAL NO: 101-499 RECOMMENDATION: Reconsider proposal 101-499 and change FINAL ACTION to “accept”. SUBSTANTIATION: The technical justification submitted by the proponent of 101-499 is overwhelming and convincing. Regardless of how the individual statistics are viewed, there is no doubt that the one- and two-family dwelling occupancy represent this country’s greatest hazard based on life loss. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation

of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-304 Log #123 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Jon Nisja, MN State Fire Marshal’s Office COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: Reconsider the original proposal and accept. Insert a new section: 24.3.5.1 All one-and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. SUBSTANTIATION: The technical committee has not shown a good reason for this proposal not going forward. The technical substantiation given in the proposal cannot be disputed and the proposed text should be approved.COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements.

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Report on Comments — Copyright, NFPA NFPA 101 HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-305 Log #211 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Ben Greene Davis, CA COMMENT ON PROPOSAL NO: 101-499 RECOMMENDATION: The residential committee should reconsider the rejection of the requirement: All new one-and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. SUBSTANTIATION: The proponents of the proposals to add this requirement have provided significant documentation as to the need for protection in one and two family dwellings. As the premier fire protection organization, it is time for NFPA to advocate for a reduction in life and property loss through a known and highly effective technology. It took several decades and many state and local ordinances enacted before smoke detectors became a part of the model

building and fire codes. And all the excuses that we hear for not passing this requirement are the same ones we heard then. We have been down the same road with residential sprinklers and it is time to take the next step and include the requirement in this model code. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units.

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Report on Comments — Copyright, NFPA NFPA 101 Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-306 Log #318 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-499 RECOMMENDATION: Reconsider the original action. SUBSTANTIATION: The technical substantiation submitted was over whelming and would help reduce the largest fire problem in this country. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific

cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-307 Log #320 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-502 RECOMMENDATION: Reconsider. SUBSTANTIATION: The arguments for sprinklers and against sprinklers in new one and two family dwellings result in rejection of the proposal once again. Only eight opposing opinions will silence the issue for another three-year code cycle. 1- Both sides of the argument agree that statistically, the majority of fire fatalities occur in one and two family dwellings and that children and the elderly are largely the victims. 2- The concept of sprinklers is effective in reducing fire losses and fatalities. By rejecting the proposal, the following adverse outcomes occur: 1- The committee fails to uphold the high standards and expectations of the NFPA. 2- The subject is silenced for three years. 3- The opportunity for communities to adopt sprinkler legislation is lost because the standard does not support it. 4- The opportunity for the debate to occur in the marketplace among consumers is lost. 5- Rather than being the leader in technology and safety, the committee and its minority become the sole participants in the debate. The discussion of the merits of sprinkler protection in one and two family dwellings must be returned to the individual communities that adopt legislation and the power of choice must be offered to the consumer so that they can make their own decisions. For those communities that find their life losses from domestic fires acceptable, a means of documenting the exempt status must be provided. As stated by Mr Puhlick, adults are capable of making their own decisions. Unfortunately, committee rejections of sprinkler proposals eliminate the possibility of pilot legislation or even sample residential homes that could be provided to allow consumers to see the product that they are buying. If the committee were to approve this proposal, communities would gain the opportunity to provide their local marketplace with a small percentage of sprinkler protected homes. The consumers could exercise their right of choice with their wallets. Proposal: All new one and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. Communities shall be permitted to omit sprinklers in new one and two family dwellings if they conduct, document and publish, a fire safety analysis which contains an evaluation of the community characteristics, losses, prevention and education programs and demonstrate that those programs and features offer a preferred level of fire protection. Such fire safety analysis shall be reevaluated by each new local administration and immediately following any fire fatality in the community. This proposal would raise the awareness of fire safety issues, cause a professional evaluation of fire safety to be conducted periodically, and permit the construction of pilot one and two family dwellings. The debate over fire safety would occur at the immediate local level between the powers in authority and the voting taxpayers / consumers. When the issue dies in technical committee, it never reaches the end consumer. In “Field of Dreams” the motto was, “If you build it, they will come.” For sprinklers in new homes, it will be, “If you accept it, they will be

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Report on Comments — Copyright, NFPA NFPA 101 installed.” A mere eight votes should not preserve the status quo for another three years when children and families are dying in homes fires every day. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry

estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-308 Log #321 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-501 RECOMMENDATION: Reconsider. SUBSTANTIATION: The arguments for sprinklers and against sprinklers in new one and two family dwellings result in rejection of the proposal once again. Only eight opposing opinions will silence the issue for another three-year code cycle. 1- Both sides of the argument agree that statistically, the majority of fire fatalities occur in one and two family dwellings and that children and the elderly are largely the victims. 2- The concept of sprinklers is effective in reducing fire losses and fatalities. By rejecting the proposal, the following adverse outcomes occur: 1- The committee fails to uphold the high standards and expectations of the NFPA. 2- The subject is silenced for three years. 3- The opportunity for communities to adopt sprinkler legislation is lost because the standard does not support it. 4- The opportunity for the debate to occur in the marketplace among consumers is lost. 5- Rather than being the leader in technology and safety, the committee and its minority become the sole participants in the debate. The discussion of the merits of sprinkler protection in one and two family dwellings must be returned to the individual communities that adopt legislation and the power of choice must be offered to the consumer so that they can make their own decisions. For those communities that find their life losses from domestic fires acceptable, a means of documenting the exempt status must be provided. As stated by Mr Puhlick, adults are capable of making their own decisions. Unfortunately, committee rejections of sprinkler proposals eliminate the possibility of pilot legislation or even sample residential homes that could be provided to allow consumers to see the product that they are buying. If the committee were to approve this proposal, communities would gain the opportunity to provide their local marketplace with a small percentage of sprinkler protected homes. The consumers could exercise their right of choice with their wallets. Proposal: All new one and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. Communities shall be permitted to omit sprinklers in new one and two family dwellings if they conduct, document and publish, a fire safety analysis which contains an evaluation of the community characteristics, losses, prevention and education programs and demonstrate that those programs and features offer a preferred level of fire protection. Such fire safety analysis shall be reevaluated by each new local administration and immediately following any fire fatality in the community. This proposal would raise the awareness of fire safety issues, cause a professional evaluation of fire safety to be conducted periodically, and permit the construction of pilot one and two family dwellings. The debate over fire safety would occur at the immediate local level between the powers in authority and the voting taxpayers / consumers. When the issue dies in technical committee, it never reaches the end consumer. In “Field of Dreams” the motto was, “If you build it, they will come.” For sprinklers in new homes, it will be, “If you accept it, they will be installed.” A mere eight votes should not preserve the status quo for another three years when children and families are dying in homes fires every day. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically

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Report on Comments — Copyright, NFPA NFPA 101 from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-309 Log #322 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-500 RECOMMENDATION: Reconsider. SUBSTANTIATION: The arguments for sprinklers and against sprinklers in new one and two family dwellings result in rejection of the proposal once again. Only eight opposing opinions will silence the issue for another three-year code cycle.

1- Both sides of the argument agree that statistically, the majority of fire fatalities occur in one and two family dwellings and that children and the elderly are largely the victims. 2- The concept of sprinklers is effective in reducing fire losses and fatalities. By rejecting the proposal, the following adverse outcomes occur: 1- The committee fails to uphold the high standards and expectations of the NFPA. 2- The subject is silenced for three years. 3- The opportunity for communities to adopt sprinkler legislation is lost because the standard does not support it. 4- The opportunity for the debate to occur in the marketplace among consumers is lost. 5- Rather than being the leader in technology and safety, the committee and its minority become the sole participants in the debate. The discussion of the merits of sprinkler protection in one and two family dwellings must be returned to the individual communities that adopt legislation and the power of choice must be offered to the consumer so that they can make their own decisions. For those communities that find their life losses from domestic fires acceptable, a means of documenting the exempt status must be provided. As stated by Mr Puhlick, adults are capable of making their own decisions. Unfortunately, committee rejections of sprinkler proposals eliminate the possibility of pilot legislation or even sample residential homes that could be provided to allow consumers to see the product that they are buying. If the committee were to approve this proposal, communities would gain the opportunity to provide their local marketplace with a small percentage of sprinkler protected homes. The consumers could exercise their right of choice with their wallets. Proposal: All new one and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. Communities shall be permitted to omit sprinklers in new one and two family dwellings if they conduct, document and publish, a fire safety analysis which contains an evaluation of the community characteristics, losses, prevention and education programs and demonstrate that those programs and features offer a preferred level of fire protection. Such fire safety analysis shall be reevaluated by each new local administration and immediately following any fire fatality in the community. This proposal would raise the awareness of fire safety issues, cause a professional evaluation of fire safety to be conducted periodically, and permit the construction of pilot one and two family dwellings. The debate over fire safety would occur at the immediate local level between the powers in authority and the voting taxpayers / consumers. When the issue dies in technical committee, it never reaches the end consumer. In “Field of Dreams” the motto was, “If you build it, they will come.” For sprinklers in new homes, it will be, “If you accept it, they will be installed.” A mere eight votes should not preserve the status quo for another three years when children and families are dying in homes fires every day. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and

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Report on Comments — Copyright, NFPA NFPA 101 to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-310 Log #323 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-499 RECOMMENDATION: Reconsider. SUBSTANTIATION: The arguments for sprinklers and against sprinklers in new one and two family dwellings result in rejection of the proposal once again. Only eight opposing opinions will silence the issue for another three-year code cycle. 1- Both sides of the argument agree that statistically, the majority of fire fatalities occur in one and two family dwellings and that children and the elderly are largely the victims. 2- The concept of sprinklers is effective in reducing fire losses and fatalities. By rejecting the proposal, the following adverse outcomes occur: 1- The committee fails to uphold the high standards and expectations of the NFPA. 2- The subject is silenced for three years. 3- The opportunity for communities to adopt sprinkler legislation is lost because the standard does not support it. 4- The opportunity for the debate to occur in the marketplace among consumers is lost. 5- Rather than being the leader in technology and safety, the committee and its minority become the sole participants in the debate. The discussion of the merits of sprinkler protection in one and two family dwellings must be returned to the individual communities that adopt legislation and the power of choice must be offered to the consumer so that they can make their own decisions. For those communities that find their life losses from domestic fires acceptable, a means of documenting the exempt status must be provided.

As stated by Mr Puhlick, adults are capable of making their own decisions. Unfortunately, committee rejections of sprinkler proposals eliminate the possibility of pilot legislation or even sample residential homes that could be provided to allow consumers to see the product that they are buying. If the committee were to approve this proposal, communities would gain the opportunity to provide their local marketplace with a small percentage of sprinkler protected homes. The consumers could exercise their right of choice with their wallets. Proposal: All new one and two family dwellings shall be protected throughout by an automatic fire sprinkler system installed in accordance with 24.3.5.2. Communities shall be permitted to omit sprinklers in new one and two family dwellings if they conduct, document and publish, a fire safety analysis which contains an evaluation of the community characteristics, losses, prevention and education programs and demonstrate that those programs and features offer a preferred level of fire protection. Such fire safety analysis shall be reevaluated by each new local administration and immediately following any fire fatality in the community. This proposal would raise the awareness of fire safety issues, cause a professional evaluation of fire safety to be conducted periodically, and permit the construction of pilot one and two family dwellings. The debate over fire safety would occur at the immediate local level between the powers in authority and the voting taxpayers / consumers. When the issue dies in technical committee, it never reaches the end consumer. In “Field of Dreams” the motto was, “If you build it, they will come.” For sprinklers in new homes, it will be, “If you accept it, they will be installed.” A mere eight votes should not preserve the status quo for another three years when children and families are dying in homes fires every day. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in

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Report on Comments — Copyright, NFPA NFPA 101 the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-311 Log #214 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1 and 24.3.5.2) _______________________________________________________________ SUBMITTER: Kevin J. Kelly, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-502 RECOMMENDATION: Accept Proposal 101-502. SUBSTANTIATION: The cost/benefit analysis that the NFSA submitted in Proposal 101-502 was criticized by several of the committee members in their negative ballots. The NFSA has modified the cost/benefit analysis to take these concerns into account, and fire sprinkler systems are still cost effective. One of the criticisms was that the NFSA stated that its analysis was not “definitive”. To that we respond that the information that we have presented is true and accurate. The non-definitive aspects of this analysis are those that would improve the benefits of sprinkler performance, but are difficult to quantify. Since these benefits have not been quantified, they have been eliminated from this analysis. If these intangible items could be clarified, the situation would be even more beneficial to fire sprinklers. Another of the criticisms was that the data submitted was contradictory. To that, we respond that the data is not contradictory. Many different studies were presented to show the wide range of data and information in existence. In each case, for the cost/benefit analysis, the NFSA chose the most conservative value for input. For each of the decisions in this cost/benefit analysis, the NFSA has taken the most conservative (non-beneficial to sprinklers) in order to show that fire sprinklers can best be cost effective, even if everything our opponents says about them is true. We know that many of these issues are much better and more favorable towards sprinklers, but have attempted to utilize the most conservative approach possible. The following is a complete description of each of the items in the cost/benefit analysis: YEAR - This analysis looks at the costs and benefits to fire sprinkler systems over a 50 year period. The assumptions that go into this analysis are that the homes (with the sprinkler systems in them) are built and paid for on the first day of each year while the sprinkler systems are not put in service until the last day of the year. Therefore, in each year, all of the costs associated with the sprinkler system start with the first year the home is proposed, but the benefits don’t begin until next year. In reality, sprinkler systems will be put in service before the end of the year and the benefits will begin before the end of the year, but this assumption is more conservative. NUMBER OF SPRINKLERED HOMES - The assumption is that all of the 1.9 million homes built in the United States will be sprinklered. According to the National Association of Homebuilders, this is the typical number of homes built in each year. While this number starts out as a relatively small percentage of total homes, after 50 years, the number of sprinklered homes grows to approximately 50 percent, a substantial number that will have a significant effect on future fire losses. TOTAL NUMBER OF HOMES - The total number of homes (one and two family dwellings) has been reported by the NAHB at 90 million prior to the start of this analysis. As 1.9 million new homes are built each year, the total number of homes grows at the same rate. The assumption in this analysis is that the new homes built are not replacements for existing homes.

NUMBER OF FIRES IN SPRINKLERED HOMES - This variable is a ratio of the number of sprinklered homes to the total number of homes. The NFPA fire incident data has shown that the number of fires each year in one and two family dwellings has averaged 300,000 fires per year fairly consistently. The NFSA believes that the number of fires in sprinklered homes should be a direct proportion of the number of sprinklered homes. The NAHB has contended that new homes are safer than older homes (a statement they have never been able to justify). Never-the-less, this analysis will agree with the NAHB position and state that fires are 50 percent less likely to occur in homes that are 10 years old or less. NUMBER OF FIRES IN UNSPRINKLERED HOMES - Since fire sprinklers do not actually prevent the fire from occurring, the total number of fires still has to add up to 300,000. So, the total number of fires in unsprinklered properties each year is equal to 300,000 minus the number of fires in sprinklered homes. NUMBER OF LIVES SAVED - According to NFPA fire data, there is approximately 1 death for every 100 fires. The number of potential lives that would be lost in sprinklered buildings is then a straight ratio of the number of fires. The NFSA has never stated that fire sprinklers will save 100 percent of the people who are inside of a building when there is a fire. Estimates of sprinkler effectiveness have ranged from 63 percent to 99 percent by different sources. The 63 percent effectiveness estimate (the lowest of any estimate) was made by NIST on a theoretical analysis (prior to the widespread installation of residential sprinklers) of the kind of deaths that occur in fires and the theoretical performance of what residential sprinklers might be able to do. We know now, with more than 20 years of experience, that the NIST study was extraordinarily conservative. For example, the NIST study states that no person that is intimate with ignition will ever be saved by a fire sprinkler. In reality, there have been a significant number of fires in sprinklered homes where people have been intimate with ignition and there has only been one reported situation where a person died (an older home sprinklered with standard response sprinklers). There are many people walking around today who were intimate with ignition and a fire sprinkler saved their life, in direct opposition to the NIST estimate. Even knowing that the NIST estimate is needlessly conservative, we have used 63 percent as an estimate of the number of lives that will be saved by the sprinkler systems. Note that this analysis only looks at civilian deaths and does not taken into account fire fighter fatalities. NUMBER OF INJURIES PREVENTED - The NFPA estimates that there are 4.3 injuries per every 100 fires that occur in one and two family dwellings. The number of injuries that could happen in sprinklered buildings would be expected to be proportional to the number of fires. Similar to the number of lives saved, the number of injuries that can be prevented by fire sprinklers has been estimated between 44 percent and 99 percent. Once again, the worst estimate comes from the NIST study that was performed as a theoretical analysis prior to residential sprinkler systems actually being installed. Even though we disagree with this low percentage, we will use this value in our analysis. Note that this analysis only takes into account civilian injuries and does not take into account fire fighter injuries. VALUE OF LIVES SAVED - While the value of human life is constantly debated, the NFSA has used $2 million in this analysis. The $2 million per life saved has been utilized by three independent sources as the average value of a human life. The first source has been settlements from large loss fires. The second source is the Federal Government for sponsoring cancer research (if the cost of the research per life saved is $2 million or less, the government will fund the research). And the third source is the 9-11 commission that paid families after the events of September 11, 2001. The commission award an average of a little over $2 million for each life lost during that tragic day. VALUE OF INJURIES - The most difficult variable to quantify in this analysis has been the dollar value of an injury. First, in order to qualify as in an injury, the person has to have been hospitalized. With hospital costs continuously rising, keeping this analysis constant over 50 years is extremely conservative. The value of $30,000 per injury was taken from an OSHA website as the average of the kind of injuries that occur in a fire. However, burn injuries are extremely expensive as multiple surgeries for skin grafts are frequently needed. It is quite possible that fire sprinklers can save many times what is estimated in this analysis. VALUE OF PROPERTY SAVED - This value comes directly from fire department reports and compares the average loss in a fire in an unsprinklered building ($17,000) to the average loss in a fire in a sprinklered building ($1900). This average savings is applied to 90 percent of the fires that occur in sprinklered buildings assuming that not all sprinkler systems will actually contain a fire. This extra consideration for sprinklers not working is extremely conservative because the fire data that generated the $1900 loss per fire already takes into account sprinkler systems that did not work, Note that fire departments only estimate the direct property loss (value of building and value of items that burned). VALUE OF INDIRECT SAVINGS - As stated above, the property saved only deals with the value of the building and the value of the items that burned. What also needs to be taken into account is the value of the goods and services that need to be used while a person’s home is being rebuilt after a fire. The Red Cross provides temporary housing on a short term basis (which needs to be paid for) then people may need to stay in alternative housing for a longer period of time while their home is rebuilt. All kinds of other indirect losses build up including longer commutes to work/school from alternate locations

101-123

Report on Comments — Copyright, NFPA NFPA 101 and replacement costs for items exceeding costs covered by insurance. The value of indirect losses that can be saved by sprinklers is estimated as $5000 per fire and is only taken for 90 percent of the fires, again in recognition that in some small percentage of fires sprinklers might not be so effective. VALUE OF INSURANCE SAVINGS - The NFSA received some criticism of the value used in the ROP in this column. Even though we stand behind the value used in the ROP, we have lowered the value used in this analysis to $75 per home per year. Actual discounts for fire sprinkler systems vary by insurance companies between 8 percent and 15 percent. If the average homeowner’s policy is $750 per year and the average savings is 10 percent, the average savings of $75 per year is extremely defendable, and most definitely lower than actual experience. VALUE OF CONSTRUCTION SAVINGS - The NFSA also received a great deal of criticism for the value we estimated that builders could take advantage of regarding construction savings. While it is true that there are limited construction savings in the Life Safety Code, it is also true that there are many opportunities for builders to take advantage of zoning and site development incentives to reduce the total cost of building and increase their profit while installing fire sprinklers. This analysis assumes that half of the homes built each year will not be able to find any savings. The other half will only save an average of $2500 per home, an incredibly low number considering the tremendous power of zoning and site development incentives. Such incentives include the savings of the infrastructure including the downsizing of underground mains and the separation of fire hydrants. VALUE OF FD ON SCENE - There are two types of savings available to fire departments that have been broken out into two separate columns in this analysis. This first category is the savings to the fire department when actually on the scene of a fire. Where fires occur in sprinklered buildings, fewer fire fighters are needed for a shorter duration. As such, firefighters are freed up to handle other tasks necessary of the fire department without having to employ additional personnel. Also included in this category are the savings in materials used to fight a fire such as fuel for fire trucks, which are left running during a fire event, and water, which costs the utility money to clean and make available at the hydrant. Fires in buildings with sprinkler systems use thousands of gallons of water less than fires that occur in nonsprinklered property. The value that we have used in this analysis of $10,000 per fire is extremely conservative given the value of labor, the number of fire fighters necessary to fight house fires and the value of materials like fuel and water. VALUE OF FD PLANNING - The second of the fire department savings comes from the ability to plan the development of fire stations. In communities with all new homes sprinklered, fewer fire stations will need to be built and staffed. In communities with all new homes sprinklered, fewer fire stations will need to be built and staffed. Buying the land for a fire station and building a station can easily cost several million dollars. Buying fire trucks for a new station can also cost more than $1 million. After that fire fighters have to be hired to staff the new vehicles, in multiple shifts. Clothing and protective gear needs to be purchased for all of the new fire fighters. This analysis assumes that there are approximately 3000 fire departments in the United States and that 1 percent of these departments will be able to save building a fire station each year. This saves $4 million in building and equipping the station each year as well as $75,000 for each of 13 fire fighters that would need to be hired (4 fire fighters per engine company with three shifts and one extra to cover for vacation and sick time) and $25,000 each year for building maintenance. The costs for fire fighters and maintenance continue each year for each new building. Once the building is 20 years old, additional costs are added for buying new equipment. INCOME TAX SAVINGS - The increase to the cost of the building for the fire sprinkler system is rolled into the cost of the mortgage. The interest on the mortgage is tax deductible at the income tax rate of the individual paying the mortgage. See the COST section of this analysis for the exact details of the mortgage assumptions. The tax bracket in this analysis is 28 percent. SAVINGS OF SPRINKLERS - The total of all of the savings columns for each year. COST OF SPRINKLER SYSTEMS - The average home is 2500 sq ft according to the NAHB. Sprinkler systems average less than $2.00 per sq ft, but we will use $2.00 per sq ft in this analysis. But people don’t pay cash for homes. Instead, the home is financed over a period of time. This analysis is based on someone putting 10 percent of the cost of the system down and paying the rest over a 30 year period at an interest rate of 6 percent. In addition, this analysis assumes that people don’t hang onto their homes for 30 years. Instead this analysis assumes that after 15 years, the person has sold their home at a profit and paid off the original mortgage. The new buyer does not pay specifically for the sprinkler system in the existing house since it is rolled into the general value of the property. NET COST - The total cost of the sprinkler systems minus the savings for each year. CUMULATIVE NET COST - The net cost added from year to year to show that the total money spent on sprinkler systems is recouped by a community over time (approximately 46 years). See the table shown on the following page. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-312. COMMITTEE STATEMENT: The action on Comment 101-312 should meet the submitter’s intent.

NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 15 Negative: 6 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BELL: We concur with the Committee members ROP comments opposing this proposal. Further, this proposal fails to comport with the Standards Council’s admonition to Committees to consider the cost/benefit of changes to codes and standards. This proposal would have no impact on the existing stock of housing in the U.S.; would come at a high unit cost and would be present in housing that with other improvements in utilities, cooking appliances, interior finish, smoke alarms (multiple now required) and others which mitigate the incidence or fires and/or their outcome. The proposal fails to differentiate between the risks of one and two family housing which can differ drastically from a three story townhouse with limited means of egress to a one story residence with multiple means of egress. While buyers of newly constructed homes now have a choice with respect to sprinkler protection, this proposal would remove any choice. BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydrant spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units. Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems.

101-124


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101-125

Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-312 Log #62 SAF-RES FINAL ACTION: Accept in Principle (24.3.5.1 and 24.3.5.2) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be modified so the wording of new 24.3.5.1 reads: 24.3.5.1 All new buildings one- and two-family dwellings shall be protected throughout by an approved automatic sprinkler system in accordance with 24.3.5.2.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-502 RECOMMENDATION: Give consideration to the subject so as to make any needed changes given the subject failed ROP letter ballot. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Accept Proposal 101-502. COMMITTEE STATEMENT: The committee action followed a review of the public comments received and testimony by individuals and organizations, such as, the International Association of Fire Chiefs. The committee also notes the NFPA membership has twice previously recommended the addition of a mandatory sprinkler provision in new one- and two-family dwellings by way of floor votes at technical committee report sessions; previous recommendations were overturned by the Standards Council based on lack of consensus at the technical committee level. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 16 Negative: 5 Abstain: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: No proven cost-benefit over current fire-safety requirements. HAMMERMAN: I disagree with mandating sprinkler protection for new single family dwellings for the following reasons: 1. Historically, fires are likely to occur more often in the kitchen and dining areas. Therefore, why not simply sprinkler those areas with piping integrated with the domestic household system and not mandate sprinklers elsewhere? This would eliminate the added cost of larger meters, higher water bills, higher insurance costs and sprinkler system installation costs. Perhaps the Committee should peruse the Prince George’s County, Maryland fire experience and promote a simple, inexpensive, solution of a few sprinklers in the high risk areas of the home? 2. The full installation of single family dwelling sprinkler system will likely necessitate a larger water meter, a backflow device and costlier homeowners insurance for water damage coverage, in addition to the added cost of the sprinkler system; thus, making the dwelling less affordable. For some people with limited finances, this may prevent them from purchasing a new home and to remain in an older dwelling. As such, they will find themselves at a higher risk in a less safe environment merely because they were priced out of a new home. 3. As expressed by the Safety to Life Committee in previous advisory notes, local governments should be encouraged to promote the voluntary installation of residential sprinkler systems through incentives such as reducing property taxes. KLUVER: See my Explanation of Negative on Comment 101-300. NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. PUHLICK: This issue is better left to local jurisdictions based upon development configuration, water supply availability, local credits available, i.e., water rate incentives, hydran spacing, lot line separation, distances, etc. EXPLANATION OF ABSTENTION: FRANCIS: The American Forest & Paper Association supports and advocates the use of sprinkler systems whenever an objective analysis clearly and irrefutably substantiates the cost/benefit to society. In the ROP, the proponents developed an intriguing substantiation. However, there are benefits asserted in the analysis for which no substantiation can be developed. For example, it claims benefit for fire fighter safety, which the fire loss data do not support. The opponents of the proposal have produced an equally intriguing analysis which shows that the demographics and socioeconomic elements are far more important in fire safety than previously thought. Following that argument, it can be seen that the benefits of sprinklers only justify the system in specific cases. And finally, the analysis was performed with certain assumptions about costs. The 2002 editions of NFPA 13 and NFPA 13R have new requirements which result in greatly increased costs. These increases are not reflected in the analysis. Given the benefits achievable with mandatory sprinklering, I would be inclined to vote in the affirmative if these concerns were addressed. The comments received in this cycle fail to address the two most important issues I raised in my ROP Abstention: benefits with no data to support the claim and excessive but hidden costs not accounted for. Until the two respective cost/benefit analyses [which come to different conclusions], can be harmonized, I must abstain. Two well-thought out studies lead to different conclusions so I am compelled to abstain. COMMENT ON AFFIRMATIVE BRIESE: In casting an affirmative vote for the provision of automatic sprinkler protection in one and two family dwellings, it is noted that the measure addresses future dwelling units.

Proponents of this measure have presented emotional testimony to support their position, however the proposed change to the Code will have minimal impact on fire deaths and injuries for years to come. Sprinkler industry estimates show that less then 10 percent of dwelling units would be protected within 5 years of enactment; less then one-third within 20 years; and less then half within 40 years. Clearly, the fire scenarios presented by proponents to support their position will continue to occur well into the foreseeable future. It is hoped that proponents will display as fervent an interest in addressing current residential fire and life safety challenges as they have with perceived future problems. _______________________________________________________________101-313 Log #263 SAF-RES FINAL ACTION: Reject (26.1.2.2) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-504 RECOMMENDATION: Revise text as follows: 26.1.2.2 No lodging or rooming house shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 26.1.2.2.1 or 26.1.2.2.2. 26.1.2.2.1 in buildings that are protected by an automatic sprinkler system in accordance with Section 9.7. 26.1.2.2.1 Lodging or rooming houses shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: ( 1) The lodging or rooming house shall comply with Chapter 26. (2) The sole means of egress from the lodging or rooming house shall not pass through a high hazard content area as defined in 6.2.2.4 26.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, lodging or rooming house shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The sole means of egress from the lodging or rooming house to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The lodging or rooming house shall comply with Chapter 26 (3) The sole means of egress from the lodging or rooming house shall not pass through a high hazard content area as defined in 6.2.2.4 SUBSTANTIATION: The revisions we have proposed to this Committee Proposal eliminates the sprinkler trade-off that allows the 1-hour fire barrier separation of the sole means of egress which passes through a nonresidential occupancy to be omitted when the building is protected by an automatic sprinkler system. We believe that both automatic sprinkler protection and a 1-hour fire barrier separation are necessary in order to allow the sole means of egress to pass through a nonresidential occupancy. Traditionally, this code has required lodging and rooming houses to have their primary means of egress directly to the exterior of the building. Why should this requirement be lessened in order to allow the sole means of egress to pass through a nonresidential occupancy which would most likely be more hazardous than a residential occupancy? Redundant protection should be provided for the sole means of egress to better assure that it will be maintained sufficiently safe during a fire emergency to allow the occupants to escape safely. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The two options provided by Proposal 101-504 (automatic sprinkler protection or rated separation of the means of egress) afford a reasonable level of protection. No data has been submitted to substantiate the proposed requirement for both sprinkler protection and separation of the means of egress. It is noted the proposed revision could retrospectively impact existing buildings. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: See my Explanation of Negative on Comment 101-296. _______________________________________________________________101-314 Log #63 SAF-RES FINAL ACTION: Accept in Principle (26.3.3 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-505 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 26.3.3.1 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the action on Proposal 101-505 by renumbering the proposed 26.3.3.1 and deleting the proposed 26.3.3.2 and 26.3.3.3: 26.3.3 26.3.2.4 Contents and Furnishings. 26.3.3.1 Contents and furnishings shall not be required to comply with Section 10.3.

101-126

Report on Comments — Copyright, NFPA NFPA 101 26.3.3.2 Furnishings or decorations of an explosive or highly flammable character shall not be used. 26.3.3.3 Fire-retardant coatings shall be maintained to retain the effectiveness of the treatment under service conditions encountered in actual use. COMMITTEE STATEMENT: Given the state of flux of the provisions of Ch.10, the committee is maintaining the exemption of lodging or rooming houses from Section 10.3. In addition, it is deleting provisions regarding the use of explosive and highly flammable furnishings and decorations, and fire-retardant coatings because of the lack of enforcibility, and because such issues are better regulated by other national standards, such as those promulgated by the Consumer Product Safety Commission (CPSC) and the Upholstered Furniture Action Council (UFAC). NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: LATHROP: Although I concur with the action taken on this subject with regard to one- and two-family dwellings, I do not concur with this action on lodging and rooming houses. This will allow natural cut Christmas trees in such facilities and there is no justification for allowing this after decades of prohibition. _______________________________________________________________101-315 Log #129 SAF-RES FINAL ACTION: Reject (26.3.3.5) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-506 RECOMMENDATION: Accept Proposal 101-506. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. Reference is also made to the Explanation of Negative by Austin on Proposal 101-506. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The smoke alarm criteria, which has been proposed to be deleted by this comment, must be maintained in NFPA 101 because NFPA 72 addressed only new installations, whereas NFPA 101 addresses both new and existing conditions. The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document.

With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101.

_______________________________________________________________101-316 Log #212 SAF-RES FINAL ACTION: Reject (26.3.5.3.7) _______________________________________________________________ SUBMITTER: Ben Greene Davis, CA COMMENT ON PROPOSAL NO: 101-508 RECOMMENDATION: Request the committee reconsider their rejection of the proposal: Portable fire extinguishers shall be installed in Lodging and Rooming Houses in accordance with NFPA 1 UFC. SUBSTANTIATION: The UFCA Code Committee concurs with the reasoning in the explanation of negative. The committee is correct that NFPA 1 extracts provisions for extinguishers from NFPA 10 which alleviates any concern for conflicting provisions. The benefit to a reference to 1 UFC is the fire code provides the information needed for determination, location, sizing and spacing of portable fire extinguishers in a more concise way then digging through all of NFPA 10 for those requirements. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No new technical information has been presented by the submitter to support the proposal. The committee stands on its previous substantiation. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: As NFPA 1 already requires portable fire extinguishers n lodging and rooming houses, NFPA 101 should reflect this mandatory provision. Suggested NFPA 101 text as follows: “26.3.5.4 Portable Fire Extinguishers. Portable fire extinguishers shall be provided in lodging and rooming house occupancies in accordance with 9.7.4.1.” _______________________________________________________________101-317 Log #229 SAF-RES FINAL ACTION: Reject (28.1.1.2 and 29.1.1.2) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-510 RECOMMENDATION: Change TC action from reject to accept. SUBSTANTIATION: There are two protection issues that are currently inconsistent for college dorms that could have the same students in a “dorm” or “apartment”, drills in accordance with 28.7.3 and corridor smokes in 28.3.4.4. The use should make determine the protection, not the arrangement of the units. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No new technical information has been submitted to support the proposal. The committee stands on its previous substantiation. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-318 Log #228 SAF-RES FINAL ACTION: Reject (28.2.2.12) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-514 RECOMMENDATION: Change TC action from reject to accept. SUBSTANTIATION: 1. The 13R scope annexes and handbook say that a 13R system is for life safety protection and provides limited property protection. 2. The response conflicts with TC response to Proposal 101-86 which only reduces ratings for NFPA 13 systems. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: With respect to Item 1 in the submitter’s substantiation, the committee agrees NFPA 13R sprinkler systems are intended to provide for life safety; however, such systems inherently provide some degree of property protection in most fire scenarios. No data has been

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Report on Comments — Copyright, NFPA NFPA 101 submitted to indicate the current provision that allows vertical opening protection and exit stair enclosures to be reduced from 2 hours to 1 hour in 4-story buildings with NFPA 13R sprinkler systems is unsafe. With respect to Item 2 in the submitter’s substantiation, there is no conflict. The reduction of ratings permitted with NFPA 13 sprinkler systems referenced in Proposal 101-86 deals with fire barriers used to create separated occupancies, not vertical opening protection. The provisions are independent. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-319 Log #279 SAF-RES FINAL ACTION: Reject (28.2.2.13 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-515 RECOMMENDATION: Revise as follows: 28.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: Currently there is a European Standard (EN341) that addresses one type of device, the controlled descent device, for use in rescue operations. At the time of the ROP meeting, the Standard Institution of Israel was in the process of developing standards for escape devices and systems and is now nearing completion. Since the ROP meeting ASTM is actively developing standards, and has formed a subcommittee of the E06 Committee on Building Performance to develop standards for three types of equipment: platform systems, chutes and controlled descent devices. ASTM is looking to NFPA for code-level guidance as to how and where such equipment will be used. The Proposal 101-128 explicitly stated that such equipment was not a substitute for required means of egress and that it would only be recognized as a second means of egress where permitted by an occupancy chapter (11 through 42). Such recognition has been provided by Assembly Occupancy Committee for equipment as a part of a second means of egress from a catwalk and similar equipment platform. Additionally, based on a related comment submitted on Proposal 101-107, installation of an escape device, a coordinated group of devices or system that complies with 7.2.14. 2 will reduce the minimum stair width requirement in new construction to that of the 2003 LSC. One requirement of that allowance is that an occupancy chapter (11 through 42) permit the escape device/system to serve as a component in the means of egress. The revised text indicated in this comment will permit that stair width reduction for new construction. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and Double Exit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment is rejected based on the action taken by the TC on Means of Egress on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-319a Log #381 SAF-RES FINAL ACTION: Hold (28.2.12) _______________________________________________________________ SUBMITTER: Scott W. Adams, Park City Fire Service District COMMENT ON PROPOSAL NO: 101-155 RECOMMENDATION: Add new text to read as follows: NFPA 1 UFC 20.8.2.7 Floor proximity egress path marking shall be provided in accordance with 7.10.1.6 and 7.10.1.7 of NFPA 101. NFPA 101 28.2.12 Floor proximity egress path marking complying with Section 7.10.1.6 and 7.10.1.7 of NFPA 101 shall be provided in interior exit corridors of new hotel and dormitory occupancies. SUBSTANTIATION: NFPA 1 UFC Section 14.14 and NFPA 101 Section 7.10 require that the means of egress shall be marked by readily visible exit signs. This is typically accomplished with the use of internally illuminated exit signs located at a vertical distance of not more than 80 inches above the top edge of the egress opening. In essence, they are “ceiling proximity” exit signs as opposed to floor proximity exit signs. NFPA 1 UFC Section 14.14.6.4.1 and NFPA 101 Section 7.10.7.1 require internally illuminated exit signs be listed in accordance with UL 924, Standard for Emergency Lighting and Power Equipment. On October 24, 2003, Underwriters Laboratories announced that it is clarifying the scope of UL 924 with the following new language: “1.9 These requirements cover the performance of emergency lighting equipment (signs and luminaires) in clear air conditions only. These

requirements also do not attempt to compensate for human visual deficiencies such as near- or far-sightedness, color- or night-blindness, or astigmatism. Applications that require visibility through smoke or way-finding assistance to those with visual impairments are beyond the scope of this standard.” [Emphasis added] Smoke from a fire typically stacks from the ceiling downward. What this means is that internally illuminated exit signs listed to UL 924 located near the ceiling were never tested for visibility through smoke or intended to be visible in a fire. Occupancies with only ceiling proximity exit signs essentially have no marking of the means of egress that is tested and listed for use in fires. Floor proximity exit signs and egress path marking, however, are intended for use in fire by locating them within eighteen (18) inches above the floor. Floor proximity egress path marking provides continuous delineation of the egress system and terminates at the exit door which is marked with a floor proximity exit sign. This will greatly improve timely occupant evacuation and provide firefighters with vital information on the egress system for rescue and firefighting operations. NFPA 1 UFC & NFPA 101, Section A.7.10.1.2, states “The character of the occupancy has a practical effect on the need for signs. In any assembly occupancy, hotel, department store, or other building subject to transient occupancy, the need for signs will be greater than in a building subject to permanent or semipermanent occupancy by the same people.” Note: This proposal was submitted to the NFPA 1, Uniform Fire Code, as a proposal on extracted text from another NFPA code or standard. Since the text affected by the proposal is extracted from another NFPA document, it is being redirected to the appropriate responsible Technical Committee as a public comment. COMMITTEE MEETING ACTION: Hold COMMITTEE STATEMENT: The proposed requirement for floor proximity egress path marking in new hotels and dormitories is new information, and has not received public review. In accordance with the NFPA Regulations Governing Committee Projects, the comment is being held for further study, and will automatically be entered as a public proposal during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-320 Log #64 SAF-RES FINAL ACTION: Accept in Principle (28.3.3.4 and 29.3.3.4) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-517 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 28.3.3.4.1 and 29.3.3.4.1 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Accept Proposal 101-517. COMMITTEE STATEMENT: The committee action is intended to create no technical change from the 2003 edition of the Code. At the time of the committee’s Report on Comments meeting, it was unclear what the Chapter 10 requirements were going to actually be. However the Chapter 10 provisions work out, the committee requests the Technical Correlating Committee take whatever action is necessary so as to not technically change the contents and furnishings requirements of Chapters 28 and 29 from what was found in the 2003 edition of the Code. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-321 Log #143 SAF-RES FINAL ACTION: Accept (28.3.4.3.5) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-519 RECOMMENDATION: Modify proposal as written with last sentence to read: “Annunciation shall be provided at a location readily accessible from the primary point of entry for emergency response personnel” SUBSTANTIATION: The revised language clearly states the objective of the location is to be readily accessible to the emergency response personnel, and provides guidance in the code as opposed to simply deferring the decision to the AHJ. The AHJ always has the opportunity to modify the requirement, but as a baseline the code should identify the performance objective to achieve. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: The provision on the location of the annunciation should be under the asepses of the SAF-BSF TC and should be located in Section 9.6.7 o 9.6.8, or be determined by the SIG-FUN TC.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-322 Log #317 SAF-RES FINAL ACTION: Reject (28.3.4.4) _______________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 101-520 RECOMMENDATION: Revise to read: 28.3.4.4 Detection. A corridor smoke detection system in accordance with Section 9.6 shall be provided in buildings other than those protected throughout by an approved, supervised automatic sprinkler system in accordance with 28.3.5.3. SUBSTANTIATION: With all due respect to the committee’s reason for rejection, fire data on scenarios that would show the benefit of corridor smoke detection would be hard to produce. This data based on occurrences of fire incidents would be based on an occupant’s decision to stay in place or flee the building. Fire related human behavior doesn’t always fit normal practices or what we as fire professionals would think how building occupants may react. Building occupants will not stay in their rooms, just because they are directed to or because it may be best for them. Corridor smoke detection will allow occupants more time to evaluate what action needs to be taken upon alarm activation. Keeping in mind that this particular amendment is within Hotel and Dormitory requirements, occupants may be awoken in the middle of the night and may need additional time to process in their mind what danger from a potential fire there is. I proposed this amendment, not to eliminate fire sprinklers or lessen the importance of having them installed, but as an added benefit to those subjected to smoke spread within a structure. Data on smoke spread and occupant notification is dependent on a number of variables that may include doors being left open to the corridor, rate of rise of ambient air temperature from a fire, fire origin in relation to fire sprinklers and smoke detection devices, and smoke generated from materials being burned. There was one other reason why this proposal was submitted. I didn’t wish to base the code change on this alone, but NFPA 1 extracts this code section. Although the Technical Committee for Safety to Life shouldn’t be swayed this, the reality is that NFPA 1 is adopted by many jurisdictions, which use a building code that is not formulated under the NFPA process. Not only would this submittal provide for better correlation, it also provides for a higher level of occupant safety. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No new data has been submitted to support the proposed requirement for corridor smoke detection systems in sprinklered hotels and dormitories. The committee stands on its previous substantiation. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: Smoke detection will respond to a fire before the sprinklers activate, thereby allowing the greatest escape time for guests. This is particularly crucial in hotels, where occupants are not likely to be familiar with the escape routes. Every second of escape time is crucial. LATHROP: I concur with the proponent and commentor. This adds a level of protection that appears to be justified in new construction. _______________________________________________________________101-323 Log #130 SAF-RES FINAL ACTION: Reject (28.3.4.5) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-521 RECOMMENDATION: Accept Proposal 101-521. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of

potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document. With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101.

_______________________________________________________________101-324 Log #280 SAF-RES FINAL ACTION: Reject (29.2.2.13 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-527 RECOMMENDATION: Revise as follows: 29.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: Currently there is a European Standard (EN341) that addresses one type of device, the controlled descent device, for use in rescue operations. At the time of the ROP meeting, the Standard Institution of Israel was in the process of developing standards for escape devices and systems and is now nearing completion. Since the ROP meeting ASTM is actively developing standards, and has formed a subcommittee of the E06 Committee on Building Performance to develop standards for three types of equipment: platform systems, chutes and controlled descent devices. ASTM is looking to NFPA for code-level guidance as to how and where such equipment will be used. The Proposal 101-128 explicitly stated that such equipment was not a substitute for required means of egress and that it would only be recognized as a second means of egress where permitted by an occupancy chapter (11 through 42). Such recognition has been provided by Assembly Occupancy Committee for equipment as a part of a second means of egress from a catwalk and similar equipment platform. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and Double Exit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment is rejected based on the action taken by the TC on Means of Egress on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-325 Log #131 SAF-RES FINAL ACTION: Reject (29.3.4.5) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-531 RECOMMENDATION: Accept Proposal 101-531. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed.COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The smoke alarm criteria, which has been proposed to be deleted by this comment, must be maintained in NFPA 101 because NFPA 72 addressed only new installations, whereas NFPA 101 addresses both new and existing conditions. The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document. With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101.

_______________________________________________________________101-326 Log #65 SAF-RES FINAL ACTION: Accept in Principle (29.3.7.6 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-534 so as NOT to add 29.3.7.6. ROP Proposal 101-183 remains Rejected.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-534 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 29.3.7.6 given the Rejection of Proposal 101-183. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete the proposed 29.3.7.6 provided Proposal 101-183 is maintained as rejected. COMMITTEE STATEMENT: The committee requests the Technical Correlating Committee take whatever action is necessary to ensure existing hotels and dormitories are exempt from the requirements for smoke door assemblies if the action on Proposal 101-183 is revised to anything other than ‘reject’ at the completion of the Report on Comments process. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-327 Log #66 SAF-RES FINAL ACTION: Accept in Principle (30.1.2.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-536 RECOMMENDATION: Give consideration, so as to make any needed changes, to revising the words “dwelling units of a residential occupancy” to “dwelling units of an apartment building” in 8 places for consistency of terminology/formatting done in Proposals 101-504, 101-511, and 101-525. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the action on Proposal 101-536 as follows: 30.1.2.2 No dwelling unit of a residential occupancy an apartment building shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 30.1.2.2.1 or 30.1.2.2.2. 30.1.2.2.1 In buildings that are protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy an apartment building shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The dwelling unit of the residential occupancy apartment building shall comply with Chapter 30 (2) The sole means of egress from the dwelling unit of the residential occupancy apartment building shall not pass through a high hazard content area as defined in 6.2.2.4 30.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy an apartment building shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The sole means of egress from the dwelling unit of the residential occupancy apartment building to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The dwelling unit of the residential occupancy apartment building shall comply with Chapter 30 (3) The sole means of egress from the dwelling unit of the residential occupancy apartment building shall not pass through a high hazard content area as defined in 6.2.2.4 COMMITTEE STATEMENT: The committee action makes the revisions requested by the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-328 Log #265 SAF-RES FINAL ACTION: Reject (30.1.2.2) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-536 RECOMMENDATION: Revise text as follows: 30.1.2.2 No dwelling unit of a residential occupancy shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 30.1.2.2.1 or 30.1.2.2.2. 30.1.2.2.1 in buildings that are protected by an automatic sprinkler system in accordance with Section 9.7.

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Report on Comments — Copyright, NFPA NFPA 101 30.1.2.2.1 Dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The dwelling unit of the residential occupancy shall comply with Chapter 30. (2) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4 30.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The sole means of egress from the dwelling unit of the residential occupancy to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The dwelling unit of the residential occupancy shall comply with Chapter 30 (3) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4 SUBSTANTIATION: The revisions we have proposed to this Committee Proposal eliminates the sprinkler trade-off that allows the 1-hour fire barrier separation of the sole means of egress which passes through a nonresidential occupancy to be omitted when the building is protected by an automatic sprinkler system. We believe that both automatic sprinkler protection and a 1-hour fire barrier separation are necessary in order to allow the sole means of egress to pass through a nonresidential occupancy. Traditionally, this code has required dwelling units to have their primary means of egress directly to the exterior of the building or through a 1-hour corridor leading to an exit enclosure or directly to the exterior in buildings classified as residential occupancies. Why should this requirement be lessened in order to allow the sole means of egress to pass through a nonresidential occupancy which would most likely be more hazardous than a residential occupancy? Redundant protection should be provided for the sole means of egress to better assure that it will be maintained sufficiently safe during a fire emergency to allow the occupants to escape safely. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The two options provided by Proposal 101-536 (automatic sprinkler protection or rated separation of the means of egress) afford a reasonable level of protection. No data has been submitted to substantiate the proposed requirement for both sprinkler protection and separation of the means of egress. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: See my Explanation of Negative on Comment 101-296. _______________________________________________________________101-329 Log #281 SAF-RES FINAL ACTION: Reject (30.2.2.13 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-538 RECOMMENDATION: Revise as follows: 30.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: Currently there is a European Standard (EN341) that addresses one type of device, the controlled descent device, for use in rescue operations. At the time of the ROP meeting, the Standard Institution of Israel was in the process of developing standards for escape devices and systems and is now nearing completion. Since the ROP meeting ASTM is actively developing standards, and has formed a subcommittee of the E06 Committee on Building Performance to develop standards for three types of equipment: platform systems, chutes and controlled descent devices. ASTM is looking to NFPA for code-level guidance as to how and where such equipment will be used. The Proposal 101-128 explicitly stated that such equipment was not a substitute for required means of egress and that it would only be recognized as a second means of egress where permitted by an occupancy chapter (11 through 42). Such recognition has been provided by Assembly Occupancy Committee for equipment as a part of a second means of egress from a catwalk and similar equipment platform. Additionally, based on a related comment submitted on Proposal 101-107, installation of an escape device, a coordinated group of devices or system that complies with 7.2.14. 2 will reduce the minimum stair width requirement in new construction to that of the 2003 LSC. One requirement of that allowance is that an occupancy chapter (11 through 42) permit the escape device/system to serve as a component in the means of egress. The revised text indicated in this comment will permit that stair width reduction for new construction. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the

development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and Double Exit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment is rejected based on the action taken by the TC on Means of Egress on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM

_______________________________________________________________101-330 Log #67 SAF-RES FINAL ACTION: Accept in Principle (30.3.3.4 (New) and 31.3.3.4 (New)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-542 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 30.3.3.4.1 and 31.3.3.4.1 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the action on Proposal 101-542 as follows: 30.3.3.4 Contents and Furnishings. 30.3.3.4.1 Contents and furnishings shall not be required to comply with Section 10.3. 30.3.3.4.2 Furnishings or decorations of an explosive or highly flammable character shall not be used outside of dwelling units. 30.3.3.4.3 Fire-retardant coatings shall be maintained to retain the effectiveness of the treatment under service conditions encountered in actual use. 31.3.3.4 Contents and Furnishings. 31.3.3.4.1 Contents and furnishings shall not be required to comply with Section 10.3. 31.3.3.4.2 Furnishings or decorations of an explosive or highly flammable character shall not be used outside of dwelling units. 31.3.3.4.3 Fire-retardant coatings shall be maintained to retain the effectiveness of the treatment under service conditions encountered in actual use. COMMITTEE STATEMENT: Given the state of flux of the provisions of Ch.10, the committee is maintaining the exemption of apartment buildings from Section 10.3. In addition, it is clarifying that only explosive or highly flammable furnishings and decorations located outside dwelling units are intended to be regulated due to limits on enforceability. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-331 Log #144 SAF-RES FINAL ACTION: Accept (30.3.4.3.2) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-543 RECOMMENDATION: Modify proposal as written with last sentence to read: “Annunciation shall be provided at a location readily accessible from the primary point of entry for emergency response personnel” SUBSTANTIATION: The revised language clearly states the objective of the location is to be readily accessible to the emergency response personnel, and provides guidance in the code as opposed to simply deferring the decision to the AHJ. The AHJ always has the opportunity to modify the requirement, but as a baseline the code should identify the performance objective to achieve. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: The provision on the location of the annunciation should be under the asepses of the SAF-BSF TC and should be located in Section 9.6.7 or 9.6.8, or be determined by the SIG-FUN TC. _______________________________________________________________101-332 Log #132 SAF-RES FINAL ACTION: Reject (30.3.4.5) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-544 RECOMMENDATION: Accept Proposal 101-544. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings,

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Report on Comments — Copyright, NFPA NFPA 101 and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document. With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101. _______________________________________________________________101-333 Log #68 SAF-RES FINAL ACTION: Accept in Principle (30.3.4.5.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-545 RECOMMENDATION: Give consideration to the subject of consistency as addressed in Lathrop’s Explanation of Negative so as to make any needed changes. LATHROP: Not requiring smoke detection in each sleeping room in new construction of apartment buildings makes no sense. We require this in new one- and two-family dwellings, why not apartment buildings. Recent studies on the ability, or more accurately the inability, of smoke detectors in the corridor to wake children, further justifies interconnecting the detectors and installing them within the sleeping rooms. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No action. COMMITTEE STATEMENT: The committee reviewed this comment in conjuction with Comment 101-334. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1

BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: The data presented showed that people are twice as likely to die or be injured in fires which start in the bedroom and that adding smoke alarms to sprinkler protection reduces the death rate by 42%. I find this compelling. _______________________________________________________________101-334 Log #151 SAF-RES FINAL ACTION: Reject (30.3.4.5.2) _______________________________________________________________ SUBMITTER: Wendy B. Gifford, National Electrical Manufacturers Association COMMENT ON PROPOSAL NO: 101-545 RECOMMENDATION: Accept Proposal 101-545. SUBSTANTIATION: According to “The U.S. Experience with Sprinklers,” a report of the NFPA Fire Analysis and Research Division, a National Institute of Standards and Technology study showed “sprinklers and smoke alarms both have an essential role to play in providing life safety from fires in homes.” Adding smoke alarms where only sprinklers existed reduces the death rate by an additional 42 percent (or 13 percent of the original total.) While the numbers are not directly comparable to adding smoke alarms specifically in bedrooms, the report concludes “smoke alarms will save many people who would not be saved by sprinklers.” This was reinforced by the most recent NIST study which concluded again that smoke alarms “will activate faster than sprinklers.” (Press release has been submitted. Full results at http://smokealarm.nist.gov/) According to the NFPA’s U.S. Fire Problem Overview (NFPA Report, June 2003), only 12.3 percent of apartment fires start in the bedroom, but these fires account for 24.2 percent of deaths and 26.4 percent of injuries. In bedrooms where sleeping people are particularly vulnerable, it seems particularly important to provide the fullest protection possible. Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: New apartment buildings will be provided with automatic sprinkler protection. No data has been submitted to indicate occupants are dying in sprinklered apartment building fires because of a lack of smoke alarms in sleeping rooms. Lacking such evidence, the comment must be rejected. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: See my Explanation of Negative on Comment 101-333. LATHROP: There does not appear to be any technical reason for smoke detection with an apartment to be different from the smoke detection requirements within a single-family dwelling. _______________________________________________________________101-335 Log #69 SAF-RES FINAL ACTION: Accept in Principle (31.1.2.2) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-550 RECOMMENDATION: Give consideration, so as to make any needed changes, to revising the words “dwelling units of a residential occupancy” to “dwelling units of an apartment building” in 8 places for consistency of terminology/formatting done in Proposals 101-504, 101-511, and 101-525. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Revise the action on Proposal 101-550 as follows: 31.1.2.2 No dwelling unit of a residential occupancy an apartment building shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 31.1.2.2.1 or 31.1.2.2.2. 31.1.2.2.1 In buildings that are protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy an apartment building shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The dwelling unit of the residential occupancy apartment building shall comply with Chapter 31 (2) The sole means of egress from the dwelling unit of the residential occupancy apartment building shall not pass through a high hazard content area as defined in 6.2.2.4 31.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy an apartment building shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The sole means of egress from the dwelling unit of the residential occupancy apartment building to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The dwelling unit of the residential occupancy apartment building shall comply with Chapter 31

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Report on Comments — Copyright, NFPA NFPA 101 (3) The sole means of egress from the dwelling unit of the residential occupancy apartment building shall not pass through a high hazard content area as defined in 6.2.2.4 COMMITTEE STATEMENT: The committee action makes the revisions requested by the Technical Correlating Committee. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-336 Log #266 SAF-RES FINAL ACTION: Reject (31.1.2.2.1) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-550 RECOMMENDATION: Revise text as follows: 31.1.2.2 No dwelling unit of a residential occupancy shall have its sole means of egress pass through any nonresidential occupancy in the same building unless otherwise permitted by 31.1.2.2.1 or 31.1.2.2.2. 31.1.2.2.1 in buildings that are protected by an automatic sprinkler system in accordance with Section 9.7. 31.1.2.2.1 Dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The dwelling unit of the residential occupancy shall comply with Chapter 31. (2) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4 31.1.2.2.2 In buildings that are not protected by an automatic sprinkler system in accordance with Section 9.7, dwelling units of a residential occupancy shall be permitted to have their sole means of egress pass through a nonresidential occupancy in the same building where the following conditions are met: (1) The sole means of egress from the dwelling unit of the residential occupancy to the exterior shall be separated from the remainder of the building by fire barriers having a fire resistance rating of not less than one hour (2) The dwelling unit of the residential occupancy shall comply with Chapter 31 (3) The sole means of egress from the dwelling unit of the residential occupancy shall not pass through a high hazard content area as defined in 6.2.2.4 SUBSTANTIATION: The revisions we have proposed to this Committee Proposal eliminates the sprinkler trade-off that allows the 1-hour fire barrier separation of the sole means of egress which passes through a nonresidential occupancy to be omitted when the building is protected by an automatic sprinkler system. We believe that both automatic sprinkler protection and a 1-hour fire barrier separation are necessary in order to allow the sole means of egress to pass through a nonresidential occupancy. Traditionally, this code has required dwelling units to have their primary means of egress directly to the exterior of the building or through a 1-hour corridor leading to an exit enclosure or directly to the exterior in buildings classified as residential occupancies. Why should this requirement be lessened in order to allow the sole means of egress to pass through a nonresidential occupancy which would most likely be more hazardous than a residential occupancy? Redundant protection should be provided for the sole means of egress to better assure that it will be maintained sufficiently safe during a fire emergency to allow the occupants to escape safely. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The two options provided by Proposal 101-550 (automatic sprinkler protection or rated separation of the means of egress) afford a reasonable level of protection. No data has been submitted to substantiate the proposed requirement for both sprinkler protection and separation of the means of egress. It is noted the proposed revision could retrospectively impact existing buildings. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: See my Explanation of Negative on Comment 101-296.

_______________________________________________________________101-337 Log #282 SAF-RES FINAL ACTION: Reject (31.2.2.13 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-551 RECOMMENDATION: Revise text to read as follows: 31.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: Currently there is a European Standard (EN341) that addresses one type of device, the controlled descent device, for use in rescue

operations. At the time of the ROP meeting, the Standards Institution of Israel was in the process of developing standards for escape devices and systems and is now nearing completion. Since the ROP meeting, ASTM is actively developing standards for three types of equipment: platform systems, chutes and controlled descent devices. ASTM is looking to NFPA for code-level guidance as to how and where such equipment will be used. The Proposal 101-128 explicitly stated that such equipment was not a substitute for required means of egress and that it would only be recognized as a second means of egress where permitted by an occupancy chapter (11 through 42). Such recognition has been provided by Assembly Occupancy Committee for equipment as a part of a second means of egress from a catwalk and similar equipment platform. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The comment is rejected based on the action taken by the TC on Means of Egress on Comment 101-78. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM

_______________________________________________________________101-338 Log #133 SAF-RES FINAL ACTION: Reject (31.3.4.5) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-556 RECOMMENDATION: Accept Proposal 101-556. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The smoke alarm criteria, which has been proposed to be deleted by this comment, must be maintained in NFPA 101 because NFPA 72 addresses only new installations, whereas NFPA 101 addresses both new and existing conditions. The committee notes a joint task group between it and the NFPA 72 technical committee is in the process of being established to coordinate requirements of the two documents and identify provisions that one should extract from the other. The committee intends to revisit this issue during the next code revision cycle. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: BROWN: It is unfortunate this occupancy TC believes it has oversight on the installation of a system that already has oversight by another TC that is charged with the requirements for installation. As for the Committee Statement addressing “new” and “existing” installations, up until this point I believe the smoke alarm location in NFPA 72 were extracted out of NFPA 101. This matter was appealed to the NFPA Standards Council, who determined jurisdictional concerns are guided under Annex A-9 of the NFPA Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the

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Report on Comments — Copyright, NFPA NFPA 101 requirements set by the installation committee, the rationale for the change is to be placed in the annex of the occupancy document. With the ever-changing technical advances n smoke and fire detection and signaling equipment, the TC’s of the National Fire Alarm Code have the expertise on the type of installation and equipment needed to address the hazards identified by the occupancy TC’s. It should be the responsibility of the occupancy committees to address their concerns to the respective NFPA 72 TC as to efficacy of the smoke alarm or fire alarm systems required to specifically address the identified hazards. If the occupancy TC believes the text on location, etc. is important information and needs to also be located in their document it should be an extract from NFPA 72. It should be considered that NFPA 72 is a standard referenced in other codes and standards, and is adopted on its own. The most “current” provisions for fire and smoke detection and alarm should be developed and located in NFPA 72, not lagging behind in adoption because these important provisions are developed in another NFPA standard. PUHLICK: This issue is better left to the jurisdiction of NFPA 72 when required by NFPA 101. _______________________________________________________________101-339 Log #150 SAF-RES FINAL ACTION: Reject (31.3.4.5.3) _______________________________________________________________ SUBMITTER: Wendy B. Gifford, National Electrical Manufacturers Association COMMENT ON PROPOSAL NO: 101-558 RECOMMENDATION: Accept Proposal 101-558. SUBSTANTIATION: The Committee rejects this proposal by stating there is “no technical justification” provided to “support a retroactive requirement for smoke alarms in sleeping rooms of existing apartment buildings.” We believe there is technical justification, as follows: 1) Wiring fires in residences are directly correlated to the age of the dwelling, according to a CPSC-sponsored study reported in the Fire Journal, January/February 1990. (What Causes Wiring Fires in Residences? Linda E. Smith and Dennis McCoskrie, p. 19-ff.) “Fire rate increased as the age of the dwelling increased.” According to the study, electrical fires have consistently represented about 8 percent of total residential fires. In buildings over 40 years of age, they would represent 1.64 times the average, or over 13 percent. A copy of the article has been submitted and is available via the CPSC website at http://www.cpsc.gov/LIBRARY/FOIA/FOIA04/os/firejournal.pdf. Note that apartment buildings were included only if they were individually metered, but there is no reason to believe the conclusions would be different for apartment buildings. 2) “House Fire Deaths” by Elliot F. Eisenberg, reported in Housing Economics, (p. 11-13) November 2002, concludes “Lastly, older residential structures were shown to have much higher fire death rates than newer ones.” The conclusion was based on two surveys, a national study by the NAHB (1987) and one examining all residential fire deaths in California (1986-91). The death rate for older housing stock (five years+ or 15 years+ depending on the study) was five to ten times higher than that of new housing. There may be myriad reasons for this, but one, surely, is that new construction requires more complete fire protection than grandfathered existing residences. (Full article at http://www.nahb.org/fileUpload_details.aspx?contentID-4097. 3) There is new information which adds urgency to the case for thorough protection in existing structures. New smoke alarm studies released by the National Institute of Standards and Testing concluded that since the last comprehensive tests were conducted thirty years ago, anticipated escape time from flaming fires has dropped from 17 minutes to 3 minutes. This represents a dramatic decrease in the escape window for a family to get out alive. (Full report is available at http://smokealarm.nist.gov/.) Considering these facts, and the fact that deaths and injuries are twice as likely to occur in fires originating in bedrooms (U.S. Fire Problem Overview, NFPA Report, June 2003), the less than $15 cost of a typical smoke alarm seems nominal, not significant. There seems no technical justification for leaving existing residential sleeping rooms unprotected. Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: None of the data submitted supports the notion that occupants of existing apartment buildings are dying in fires due to the lack of sleeping room smoke alarms where working smoke alarms are provided outside the sleeping rooms. The committee must be provided with compelling evidence that something in the Code is “broken” (i.e. the currently prescribed level of protection is inadequate) prior to approving new, retroactive requirements for existing buildings. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 20 Negative: 2 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: GIFFORD: The data presented clearly shows that the fire danger is higher in older buildings, that escape time has plummeted, and that deaths are more likely in bedrooms. I do not understand the committee’s reluctance to protect the millions of existing apartment dwellers in the U.S. HOWE: As a result of numerous NFPA studies and reports it is commonly understood that the broad use of smoke alarms in residential occupancies has led to a drop in fire deaths over the last few decades. By installing additional

smoke alarms in all sleeping rooms the critical time needed to escape a fire will be improved under most fire scenarios, resulting in fewer fire deaths and injuries. At the cost of between $15 and $90 for a three bedroom dwelling the cost implications are not significant and are likely less of a cost factor than compiling with any other section in Chapter 24 or Chapter 34. _______________________________________________________________101-340 Log #213 SAF-RES FINAL ACTION: Reject (31.3.5.1) _______________________________________________________________ SUBMITTER: Ben Greene Davis, CA COMMENT ON PROPOSAL NO: 101-559 RECOMMENDATION: The UFCA Code Committee requests the committee to reconsider their action on this item. We request that this item be referred to the NFPA 5000 TC responsible for Chapter 15 (Building Rehabilitation) of NFPA 5000. We feel it is a requirement better suited for the building code requirements for renovations and remodels. There is a point in which a building is renovated to the point where requiring sprinkler protection is warranted.SUBSTANTIATION: This issue is better suited for discussion and determination by the TC responsible for Chapter 15 (Building Rehabilitation) of NFPA 5000. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Proposal 101-559 addresses a mandatory, retroactive automatic sprinkler system requirement for existing apartment buildings. This comment addresses building renovation which is a separate issue. The submitter is directed to the proposed Chapter 43 on building rehabilitation. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 21 Negative: 1 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM EXPLANATION OF NEGATIVE: NICKSON: Many of the items considered in the cost effective justification are issues that cannot and are not addressed or covered in NFPA 101. These issues have to be addressed at the local level with decision at the local level to allow design or trade-offs based on the installation of sprinklers. _______________________________________________________________101-341 Log #70 SAF-RES FINAL ACTION: Accept in Principle (31.3.7.4) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-563 so as NOT to add 31.3.7.4. ROP Proposal 101-183 remains Rejected.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-563 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 31.3.7.4 given the Rejection of Proposal 101-183. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete the proposed 31.3.7.4, provided the action on Proposal 101-183 is maintained as rejected. COMMITTEE STATEMENT: The committee requests the Technical Correlating Committee take whatever action is necessary to ensure existing apartment buildings are exempt from the requirements for smoke door assemblies if the action on Proposal 101-183 is revised to anything other than ‘Reject’ at the completion of the Report on Comments process. NUMBER ELIGIBLE TO VOTE: 25 BALLOT RESULTS: Affirmative: 22 BALLOT NOT RETURNED: 3 BONISCH, CONVERY, ONEISOM _______________________________________________________________101-342 Log #134 SAF-BCF FINAL ACTION: Reject (32.2.3.4.3) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-569 RECOMMENDATION: Accept Proposal 101-569. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those

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Report on Comments — Copyright, NFPA NFPA 101 occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. Reference is also made to the Explanation of Negative by Austin on Proposal 101-569. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is maintaining the smoke alarm provisions in the Code for this edition, recognizing that a task group is being established between NFPA 72 and the Life Safety TC on Residential Occupancies to coordinate requirements between NFPA 72, NFPA 101, and NFPA 5000, and extract material where appropriate. The TC on Board and Care Facilities intends to request to participate on the task group as its smoke alarm requirements are similar, but not identical, to those for residential occupancies. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-343 Log #244 SAF-BCF FINAL ACTION: Accept in Principle (32.2.3.5.7) _______________________________________________________________ SUBMITTER: Kenneth E. Isman, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-570 RECOMMENDATION: Insert a new section 32.2.3.5.7 for inspection, testing and maintenance of systems installed in accordance with NFPA 13D as well as an explanation in the annex as follows: “32.2.3.5.7 Systems installed in accordance with NFPA 13D shall be inspected, tested and maintained in accordance with this section, which references specific sections of NFPA 25. The frequency of the inspection, test or maintenance shall be in accordance with this code where as the purpose and procedure shall be from NFPA 25. 32.2.3.5.7.1 Control valves shall be inspected monthly in accordance with Section 12.3.2 of NFPA 25. 32.2.3.5.7.2 Gages shall be inspected monthly in accordance with Section 12.2.8.1 32.2.3.5.7.3 Alarm devices shall be inspected quarterly in accordance with Section 5.2.6 of NFPA 25. 32.2.3.5.7.4 Alarm devices shall be tested semiannually in accordance with Section 5.3.3 of NFPA 25. 32.2.3.5.7.5 Valve supervisory switches shall be tested semiannually in accordance with Section 12.3.3.5 of NFPA 25. 32.2.3.5.7.6 Visible sprinklers shall be inspected annually in accordance with Section 5.2.1 of NFPA 25. 32.2.3.5.7.7 Visible pipe shall be inspected annually in accordance with Section 5.2.2 of NFPA 25. 32.2.3.5.7.8 Visible pipe hangers shall be inspected annually in accordance with Section 5.2.3 of NFPA 25. 32.2.3.5.7.9 Builds shall be inspected annually (prior to the onset of freezing weather to insure that there is adequate heat everywhere that water-filled piping is run in accordance with Section 5.2.5 of NFPA 25. 32.2.3.5.7.10 A representative sample of fast response sprinklers shall be tested once the sprinklers in the system are 20 years old in accordance with Section 5.3.1.1.1.2 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in 10 years. 32.2.3.5.7.11 A representative sample of dry-pendent sprinklers shall be tested once the sprinklers in the system are 10 years old in accordance with Section 5.3.1.1.1.5 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in 10 years. 32.2.3.5.7.12 Antifreeze solutions shall be tested annually in accordance with Section 5.3.4 of NFPA 25. 32.3.5.7.13 Control valves shall be operated through their full range and returned to normal annually in accordance with 12.3.3.1 of NFPA 25. 32.2.3.5.7.14 Operating stems of OS&Y valves shall be lubricated annually in accordance with Section 12.3.4 of NFPA 25. 32.2.3.5.7.15 Dry-pipe systems that extend into the unheated portions of the building shall be inspected, tested and maintained in accordance with 12.4.4 of NFPA 25. A.32.2.3.5. All sprinkler systems installed in accordance with NFPA 13 and NFPA 13R are required to be inspected, tested and maintained in accordance with NFPA 25. However, systems installed in accordance with NFPA 13D are historically exempt from applying NFPA 25. While there is a great deal of information in NFPA 25 that is not appropriate for NFPA 13D sprinkler systems, there are some basic concepts of inspection, testing and maintenance that are critical to system performance and smut be performed when a NFPA 13D sprinkler system is installed in a Board and Care occupancy. The

frequencies mandated by this code are slightly different from those required by NFPA 25. It is the intent of this code to utilize the frequencies stated in Chapter 32, but to reference the purpose and the procedures for running the inspections, tests and maintenance from NFPA 25. SUBSTANTIATION: NFPA 13D systems need to be maintained. Currently, there is no standard that directs the owner of a Board and Care facility as to the minimum requirements for such maintenance. Such maintenance needs to include regular inspection and testing of equipment. This comment identifies the minimum procedures that need to be performed. This comment was developed by a Task Group consisting of Ken Isman, David Kiely and Warren Bonisch for the purposes of facilitating committee discussion. COMMITTEE MEETING ACTION: Accept in Principle Revise the submitter’s recommendation as follows: 32.2.3.5.7 Systems installed in accordance with NFPA 13D shall be inspected, tested and maintained in accordance with this section, which references specific sections of NFPA 25. The frequency of the inspection, test or maintenance shall be in accordance with this code where as the purpose and procedure shall be from NFPA 25. 32.2.3.5.7.1 Control valves shall be inspected monthly in accordance with Section 12.3.2 of NFPA 25. 32.2.3.5.7.2 Gages shall be inspected monthly in accordance with Section 12.2.8.1 of NFPA 25. 32.2.3.5.7.3 Alarm devices shall be inspected quarterly in accordance with Section 5.2.6 of NFPA 25. 32.2.3.5.7.4 Alarm devices shall be tested semiannually in accordance with Section 5.3.3 of NFPA 25. 32.2.3.5.7.5 Valve supervisory switches shall be tested semiannually in accordance with Section 12.3.3.5 of NFPA 25. 32.2.3.5.7.6 Visible sprinklers shall be inspected annually in accordance with Section 5.2.1 of NFPA 25. 32.2.3.5.7.7 Visible pipe shall be inspected annually in accordance with Section 5.2.2 of NFPA 25. 32.2.3.5.7.8 Visible pipe hangers shall be inspected annually in accordance with Section 5.2.3 of NFPA 25. 32.2.3.5.7.9 Buildings shall be inspected annually (prior to the onset of freezing weather) to insure that there is adequate heat everywhere that water-filled piping is run in accordance with Section 5.2.5 of NFPA 25. 32.2.3.5.7.10 A representative sample of fast response sprinklers shall be tested once the sprinklers in the system are 20 years old in accordance with Section 5.3.1.1.1.2 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in every 10 years thereafter. 32.2.3.5.7.11 A representative sample of dry-pendent sprinklers shall be tested once the sprinklers in the system are 10 years old in accordance with Section 5.3.1.1.1.5 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in every 10 years thereafter . 32.2.3.5.7.12 Antifreeze solutions shall be tested annually in accordance with Section 5.3.4 of NFPA 25. 32. 2. 3.5.7.13 Control valves shall be operated through their full range and returned to normal annually in accordance with 12.3.3.1 of NFPA 25. 32.2.3.5.7.14 Operating stems of OS&Y valves shall be lubricated annually in accordance with Section 12.3.4 of NFPA 25. 32.2.3.5.7.15 Dry-pipe systems that extend into the unheated portions of the building shall be inspected, tested and maintained in accordance with 12.4.4 of NFPA 25. A.32.2.3.5. All sprinkler systems installed in accordance with NFPA 13 and NFPA 13R are required to be inspected, tested and maintained in accordance with NFPA 25. However, systems installed in accordance with NFPA 13D are historically exempt from applying NFPA 25. While there is a great deal of information in NFPA 25 that is not appropriate for NFPA 13D sprinkler systems, there are some basic concepts of inspection, testing and maintenance that are critical to system performance and smut must be performed when a NFPA 13D sprinkler system is installed in a Board and Care occupancy. The frequencies mandated by this code are slightly different from those required by NFPA 25. It is the intent of this code to utilize the frequencies stated in Chapter 32, but to reference the purpose and the procedures for running the inspections, tests and maintenance from NFPA 25. COMMITTEE STATEMENT: The revisions in the committee action are editorial and should meet the submitter’s intent. The committee notes it intends to submit these criteria to NFPA 25 pending approval and publication in NFPA 101. If accepted in NFPA 25, the provisions could be removed from NFPA 101, and a direct reference to NFPA 25 provided in their place. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-344 Log #145 SAF-BCF FINAL ACTION: Accept in Principle (32.3.3.4.3) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-571 RECOMMENDATION: Modify proposal as written with last sentence to read: “Annunciation shall be provided at a location readily accessible from the primary point of entry for emergency response personnel” SUBSTANTIATION: The revised language clearly states the objective of the location is to be readily accessible to the emergency response personnel, and provides guidance in the code as opposed to simply deferring the decision to the AHJ. The AHJ always has the opportunity to modify the requirement, but as a baseline the code should identify the performance objective to achieve. COMMITTEE MEETING ACTION: Accept in Principle Revise the submitter’s recommendation as follows: Annunciation An annunciator panel, connected to the fire alarm system, shall be provided at a location readily accessible from the primary point of entry for emergency response personnel. COMMITTEE STATEMENT: The committee action intends to clarify its intent. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-345 Log #387 SAF-BCF FINAL ACTION: Reject (32.3.3.4.6(2)) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes, in response to Austin’s comment, that the NFPA procedure calling for annex text to be added to explain the reason for deviating from another NFPA document’s requirements applies only when a committee add/changes text to create a new deviation. The text in question has been in NFPA 101 for many years.SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-573 RECOMMENDATION: Accept Proposal 101-573. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The changes made by the Committee Meeting Action are incorrect and are in conflict with NFPA 72, National Fire Alarm Code®. The new annex material contained in the committee action is not a proper discussion on positive alarm sequence. The correct sequence is for the system to have a notification at a constantly attended location, provide an initial acknowledgment phase of a maximum of 15 seconds prior to the alarm investigation phase, and then to allow for an investigation not to exceed 180 seconds. There is no activation of general notification appliances or emergency forces notification until the system goes into full alarm. If there is a second activation of the system during the 180-second investigation, or if the system is not reset during this time period, the system goes into an alarm state - effecting both occupant notification and emergency forces notification. Refer to NFPA 72-2002 Section 6.8.1.3. The subject of Section 32.3.3.4.6 is emergency forces notification. This notification will not occur until positive alarm sequence or alarm verification (where used) is complete. If positive alarm sequence is specified, location in another section would be more appropriate, and the timing for this sequence should be consistent with that addressed in NFPA 72. (The proposed language does not reflect this two-phase sequence terminology and will cause confusion in implementation.) Note that Section 55.2.3.4 addresses positive alarm sequence under occupant notification. The acknowledgment period of 180-seconds that is within NFPA 72 should be the same within NFPA 5000. (If a different timing of the investigation phase is specified, the rationale for the different timing should be addressed and provided as annex material for the related code section in accordance with Annex A-9 of the NFPA Committee Officer’s Guide.) COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: A 180-second emergency forces notification delay is excessive for an occupancy where the population might be incapable of self-preservation. A 120-second delay, as provided in Proposal 101-573, is reasonable. Occupant notification needs to occur immediately. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 11 Negative: 1 BALLOT NOT RETURNED: 1 HOFFMAN EXPLANATION OF NEGATIVE: AUSTIN: Disagree with committee action. Committee action to “Reject” makes it in conflict with NFPA 72. Committee action should be either to “Accept” or add Annex material to explain the need to deviate from NFPA 72 for this chapter.

_______________________________________________________________101-346 Log #135 SAF-BCF FINAL ACTION: Reject (32.3.3.4.7) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-574 RECOMMENDATION: Accept Proposal 101-574. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. Reference is also made to the Explanation of Negative by Austin on Proposal 101-574. With regard to the differences in siting requirements between NFPA 101, 32.3.3.4.7 and NFPA 72, 11.5.10.1 noted in the Committee Statement, requirements are being developed for the next edition of NFPA 72. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is maintaining the smoke alarm provisions in the Code for this edition, recognizing that a task group is being established between NFPA 72 and the Life Safety TC on Residential Occupancies to coordinate requirements between NFPA 72, NFPA 101, and NFPA 5000, and extract material where appropriate. The TC on Board and Care Facilities intends to request to participate on the task group as its smoke alarm requirements are similar, but not identical, to those for residential occupancies. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-347 Log #319 SAF-BCF FINAL ACTION: Reject (32.7.3.6) _______________________________________________________________ SUBMITTER: Ignatius Kapalczynski, Connecticut Office of State Fire Marshal COMMENT ON PROPOSAL NO: 101-578 RECOMMENDATION: Reconsider - Facilities with residents who cannot participate in their own evacuation frequently leave those residents in their rooms rather than moving them to a point of safety. Board and Care facilities are not designed for defend in place, as are Limited Care facilities. SUBSTANTIATION: 32.7.3.6 Substantiation: Residents in Board and Care can receive very extensive care while some residents in Health Care can receive minimal care. This overlap has blurred the definition of impractical Board and Care to be virtually indistinguishable from Health Care. The difference in life safety with respect to evacuation philosophy is significant. Resolution of inappropriate placement of residents frequently results in forced relocation that can be traumatic to the elderly. It is absurd that a resident in a sprinklered impractical Board and Care could be moved to an unsprinklered Health Care when their care needs are greater. Until the Board and Care and the Health Care technical committees coordinate the distinctions between the populations they serve and provide a synchronous approach to fire protection, residents requiring transitional levels of care may still receive inconsistent levels of protection between these two occupancies. Note Logs 225, 225a, and 225b. The proposed definition, taken from the International Building Code, makes the distinction between the occupancies clear, easily understood, and enforceable. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Proposal 101-578 is essentially a “clean-up” item from the previous cycle where all references to evacuation capability were removed from Chapter 32. The proposal permits residents who are incapable of self-preservation to not take part in evacuation drills.

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Report on Comments — Copyright, NFPA NFPA 101 NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-348 Log #136 SAF-BCF FINAL ACTION: Reject (33.2.3.4.1) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-581 RECOMMENDATION: Accept Proposal 101-581 in full. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed. Reference is also made to the Explanation of Negative by Austin on Proposal 101-581. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is maintaining the smoke alarm provisions in the Code for this edition, recognizing that a task group is being established between NFPA 72 and the Life Safety TC on Residential Occupancies to coordinate requirements between NFPA 72, NFPA 101, and NFPA 5000, and extract material where appropriate. The TC on Board and Care Facilities intends to request to participate on the task group as its smoke alarm requirements are similar, but not identical, to those for residential occupancies. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN

_______________________________________________________________101-349 Log #245 SAF-BCF FINAL ACTION: Accept in Principle (33.2.3.5.7) _______________________________________________________________ SUBMITTER: Kenneth E. Isman, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-570 RECOMMENDATION: Insert a new section 33.2.3.5.7 for inspection, testing and maintenance of systems installed in accordance with NFPA 13D as well as an explanation in the annex as follows: “33.2.3.5.7 Systems installed in accordance with NFPA 13D shall be inspected, tested and maintained in accordance with this section, which references specific sections of NFPA 25. The frequency of the inspection, test or maintenance shall be in accordance with this code where as the purpose and procedure shall be from NFPA 25. 33.2.3.5.7.1 Control valves shall be inspected monthly in accordance with Section 12.3.2 of NFPA 25. 33.2.3.5.7.2 Gages shall be inspected monthly in accordance with Section 12.2.8.1 33.2.3.5.7.3 Alarm devices shall be inspected quarterly in accordance with Section 5.2.6 of NFPA 25. 33.2.3.5.7.4 Alarm devices shall be tested semiannually in accordance with Section 5.3.3 of NFPA 25. 33.2.3.5.7.5 Valve supervisory switches shall be tested semiannually in accordance with Section 12.3.3.5 of NFPA 25. 33.2.3.5.7.6 Visible sprinklers shall be inspected annually in accordance with Section 5.2.1 of NFPA 25. 33.2.3.5.7.7 Visible pipe shall be inspected annually in accordance with Section 5.2.2 of NFPA 25. 33.2.3.5.7.8 Visible pipe hangars shall be inspected annually in accordance with Section 5.2.3 of NFPA 25.

33.2.3.5.7.9 Builds shall be inspected annually (prior to the onset of freezing weather to insure that there is adequate heat everywhere that water-filled piping is run in accordance with Section 5.2.5 of NFPA 25. 33.2.3.5.7.10 A representative sample of fast response sprinklers shall be tested once the sprinklers in the system are 20 years old in accordance with Section 5.3.1.1.1.2 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in 10 years. 33.2.3.5.7.11 A representative sample of dry-pendent sprinklers shall be tested once the sprinklers in the system are 10 years old in accordance with Section 5.3.1.1.1.5 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in 10 years. 33.2.3.5.7.12 Antifreeze solutions shall be tested annually in accordance with Section 5.3.4 of NFPA 25. 33.3.5.7.13 Control valves shall be operated through their full range and returned to normal annually in accordance with 12.3.3.1 of NFPA 25. 33.2.3.5.7.14 Operating stems of OS&Y valves shall be lubricated annually in accordance with Section 12.3.4 of NFPA 25. 33.2.3.5.7.15 Dry-pipe systems that extend into the unheated portions of the building shall be inspected, tested and maintained in accordance with 12.4.4 of NFPA 25. A.33.2.3.5. All sprinkler systems installed in accordance with NFPA 13 and NFPA 13R are required to be inspected, tested and maintained in accordance with NFPA 25. However, systems installed in accordance with NFPA 13D are historically exempt from applying NFPA 25. While there is a great deal of information in NFPA 25 that is not appropriate for NFPA 13D sprinkler systems, there are some basic concepts of inspection, testing and maintenance that are critical to system performance and smut be performed when a NFPA 13D sprinkler system is installed in a Board and Care occupancy. The frequencies mandated by this code are slightly different from those required by NFPA 25. It is the intent of this code to utilize the frequencies stated in Chapter 32, but to reference the purpose and the procedures for running the inspections, tests and maintenance from NFPA 25. SUBSTANTIATION: NFPA 13D systems need to be maintained. Currently, there is no standard that directs the owner of a Board and Care facility as to the minimum requirements for such maintenance. Such maintenance needs to include regular inspection and testing of equipment. This comment identifies the minimum procedures that need to be performed. This comment was developed by a Task Group consisting of Ken Isman, David Kiely and Warren Bonisch for the purposes of facilitating committee discussion.COMMITTEE MEETING ACTION: Accept in Principle Revise the submitter’s recommendation as follows: 33.2.3.5.7 Systems installed in accordance with NFPA 13D shall be inspected, tested and maintained in accordance with this section, which references specific sections of NFPA 25. The frequency of the inspection, test or maintenance shall be in accordance with this code where as the purpose and procedure shall be from NFPA 25. 33.2.3.5.7.1 Control valves shall be inspected monthly in accordance with Section 12.3.2 of NFPA 25. 33.2.3.5.7.2 Gages shall be inspected monthly in accordance with Section 12.2.8.1 of NFPA 25. 33.2.3.5.7.3 Alarm devices shall be inspected quarterly in accordance with Section 5.2.6 of NFPA 25. 33.2.3.5.7.4 Alarm devices shall be tested semiannually in accordance with Section 5.3.3 of NFPA 25. 33.2.3.5.7.5 Valve supervisory switches shall be tested semiannually in accordance with Section 12.3.3.5 of NFPA 25. 33.2.3.5.7.6 Visible sprinklers shall be inspected annually in accordance with Section 5.2.1 of NFPA 25. 33.2.3.5.7.7 Visible pipe shall be inspected annually in accordance with Section 5.2.2 of NFPA 25. 33.2.3.5.7.8 Visible pipe hangers shall be inspected annually in accordance with Section 5.2.3 of NFPA 25. 33.2.3.5.7.9 Buildings shall be inspected annually (prior to the onset of freezing weather) to insure that there is adequate heat everywhere that water-filled piping is run in accordance with Section 5.2.5 of NFPA 25. 33.2.3.5.7.10 A representative sample of fast response sprinklers shall be tested once the sprinklers in the system are 20 years old in accordance with Section 5.3.1.1.1.2 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in every 10 years thereafter. 33.2.3.5.7.11 A representative sample of dry-pendent sprinklers shall be tested once the sprinklers in the system are 10 years old in accordance with Section 5.3.1.1.1.5 of NFPA 25. If the sample fails the test, all of the sprinklers represented by that sample shall be replaced. If the sprinklers pass the test, the test shall be repeated in every 10 years thereafter. 33.2.3.5.7.12 Antifreeze solutions shall be tested annually in accordance with Section 5.3.4 of NFPA 25. 33. 2. 3.5.7.13 Control valves shall be operated through their full range and returned to normal annually in accordance with 12.3.3.1 of NFPA 25. 33.2.3.5.7.14 Operating stems of OS&Y valves shall be lubricated annually in accordance with Section 12.3.4 of NFPA 25.

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Report on Comments — Copyright, NFPA NFPA 101 33.2.3.5.7.15 Dry-pipe systems that extend into the unheated portions of the building shall be inspected, tested and maintained in accordance with 12.4.4 of NFPA 25. A.33.2.3.5. All sprinkler systems installed in accordance with NFPA 13 and NFPA 13R are required to be inspected, tested and maintained in accordance with NFPA 25. However, systems installed in accordance with NFPA 13D are historically exempt from applying NFPA 25. While there is a great deal of information in NFPA 25 that is not appropriate for NFPA 13D sprinkler systems, there are some basic concepts of inspection, testing and maintenance that are critical to system performance and smut must be performed when a NFPA 13D sprinkler system is installed in a Board and Care occupancy. The frequencies mandated by this code are slightly different from those required by NFPA 25. It is the intent of this code to utilize the frequencies stated in Chapter 32, but to reference the purpose and the procedures for running the inspections, tests and maintenance from NFPA 25. COMMITTEE STATEMENT: The revisions in the committee action are editorial and should meet the submitter’s intent. The committee notes it intends to submit these criteria to NFPA 25 pending approval and publication in NFPA 101. If accepted in NFPA 25, the provisions could be removed from NFPA 101, and a direct reference to NFPA 25 provided in their place. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN

_______________________________________________________________101-350 Log #124 SAF-BCF FINAL ACTION: Reject (33.3.2.4.1) _______________________________________________________________ SUBMITTER: Jon Nisja, MN State Fire Marshal’s Office COMMENT ON PROPOSAL NO: 101-583 RECOMMENDATION: Reconsider the original proposal and accept. SUBSTANTIATION: We would like the committee to reconsider its original action. We are also interested in the information obtained during the research to know if the omission was intended or an oversight. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee reviewed the history of a lack of a requirement for secondary means of escape from sleeping rooms in existing large board and care facilities. The board and care facility chapters first appeared in the 1985 edition of the Code. They were adapted from the requirements for hotels and dormitories. Prior to the 1985 edition, hotels and dormitories had no secondary means of escape requirements for guest rooms, therefore, no requirement carried over to board and care facilities. This has apparently gone unnoticed for nearly 20 years. For that reason, the lack of a requirement does not appear to be causing a significant fire problem. Lacking any data to support adding a retroactive requirement for secondary means of escape, the committee is maintaining the current provisions. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-351 Log #137 SAF-BCF FINAL ACTION: Reject (33.3.3.4.7) _______________________________________________________________ SUBMITTER: Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-584 RECOMMENDATION: Accept Proposal 101-584. SUBSTANTIATION: The Technical Committee on Single- and Multiple-Station Alarms and Household Fire Alarm Systems disagrees with the statement “Siting locations, as referenced in the NFPA 72 committee scope, should be limited to location with respect to distances from walls, ceilings, and obstructions.” Per the Committee Scope of the Technical Correlating Committee on Signaling Systems for the Protection of Life and Property, NFPA 72 technical committees have jurisdiction over requirements on the “installation, performance, maintenance, testing and use” of fire warning equipment. As such, NFPA 72 technical committees are uniquely qualified and have the expertise and jurisdiction for all siting requirements that are integral to the successful performance of fire warning equipment. This can only be accomplished by including room-specific siting requirements within occupancies (i.e., where devices are to be located in such occupancies). Reference is made to Annex A-9 of the Committee Officer’s Guide on Potential Jurisdictional Scope Issues. These guidelines indicate that it is the occupancy committee’s responsibility to define the hazards common to those occupancies, and it is the installation committee’s responsibility to address the hazards identified by the occupancy committee. While the guidelines allow the occupancy committee to modify the requirements set by the installation committee, these modifications are to be implemented under the conditions set forth in the annex. The guidance in Annex A-9 requires that when changes are made, the rationale for the change be placed in the annex of the occupancy document. The Standards Council has recently considered the subject of potential jurisdictional scope issues and has stated that the guidance provided by Annex A-9 is appropriate and should be followed.

Reference is also made to the Explanation of Negative by Austin on Proposal 101-584. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee is maintaining the smoke alarm provisions in the Code for this edition, recognizing that a task group is being established between NFPA 72 and the Life Safety TC on Residential Occupancies to coordinate requirements between NFPA 72, NFPA 101, and NFPA 5000, and extract material where appropriate. The TC on Board and Care Facilities intends to request to participate on the task group as its smoke alarm requirements are similar, but not identical, to those for residential occupancies. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-352 Log #71 SAF-BCF FINAL ACTION: Accept in Principle (33.3.3.7.7 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Reject ROP Proposal 101-587 so as NOT to add 33.3.3.7.7. ROP Proposal 101-183 remains Rejected.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-587 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed 33.3.3.7.7 given the Rejection of Proposal 101-183. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Delete the proposed 33.3.3.7.7 provided the action on Proposal 101-183 is maintained as REJECT. COMMITTEE STATEMENT: The committee requests the Technical Correlating Committee take whatever action is necessary to ensure existing board and care facilities are exempt from any potential new requirement in Chapter 8 for smoke doors. As long as Proposal 101-183 is rejected, the proposed 33.3.3.7.7 can be deleted. NUMBER ELIGIBLE TO VOTE: 13 BALLOT RESULTS: Affirmative: 12 BALLOT NOT RETURNED: 1 HOFFMAN _______________________________________________________________101-353 Log #210 SAF-MER FINAL ACTION: Accept in Principle (36.2.2.3 and 38.2.2.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See TCC Note on Comment 101-355. Also see Comment 101-354.SUBMITTER: Jake Pauls, Jake Pauls Consulting Services COMMENT ON PROPOSAL NO: 101-591 RECOMMENDATION: Suggest revised text as shown below: 36.2.2.3 Stairs. 36.2.2.3.1 Stairs complying with 7.2.2 shall be permitted except as modified by 36.2.2.3.2. 36.2.2.3.2 Section 7.2.x shall not apply. Minimum width clear of all obstructions, except projections not more than 4 1/2 in. (11.4 cm) at or below handrail height on each side shall be as follows: 44 in. (112 cm), 36 in. (91 cm) where total occupant load of all stories served by stairways is fewer than 50. 36.2.2.3.2.3 Spiral stairs complying with 7.2.2.2.3 shall be permitted. 38.2.2.3 Stairs. 38.2.2.3.1 Stairs complying with 7.2.2 shall be permitted except as modified by 38.2.2.3.2. 38.2.2.3.2 Section 7.2.x shall not apply. Minimum width clear of all obstructions, except projections not more than 4 1/2 in. (11.4 cm) at or below handrail height on each side shall be as follows: 44 in. (112 cm), 36 in. (91 cm) where total occupant load of all stories served by stairways is fewer than 50. 38.2.2.3.2.3 Spiral stairs complying with 7.2.2.2.3 shall be permitted. SUBSTANTIATION: If accepted, this comment has the effect of overturning the Mercantile TC action on its Committee Proposal 101-591 and reverting to prior text. The following remarks come from my lengthy Technical Correlating Committee negative ballot comment in relation to the Mercantile Technical Committee’s counter proposal, 101-591. To facilitate the Mercantile TC’s consideration of my comment, that negative ballot comment should be read in conjunction with this comment. The first paragraph of that negative ballot comment is reproduced below and the remainder of the comment—consisting of my written response to earlier negative ballots from David Frable and Edward Fixen, in relation to the Means of Egress TC acceptance of my proposal 101-107—is appended to this comment. The Mercantile TC has not justified a special exemption applying to occupancies under its purview (Mercantile and Business). The substantiations provided for accepting the proposals are not only poorly founded or incorrect;

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Report on Comments — Copyright, NFPA NFPA 101 they are of a general nature—dealing with factors that have been taken into account by the Means of Egress TC in accepting proposals NFPA 101-107 and NFPA 5000-526 and intended to apply to all occupancies for the high- population stair widths. (For example, the phrase “ served by the stairway” is current code language on the minimum stair width issue; moreover, the comment about low-rise buildings of high occupant load is mistaken because such buildings—for example, serving an assembly occupancy—would already be likely to have wider stairs for their large populations.) The Mercantile TC has not provided justification for exempting particular Mercantile and Business occupancies that are the subject of its proposals. I believe that the Mercantile TC would not have accepted its proposals if committee members had been aware of my extensive responses (reproduced below) to negative ballot comments from Means of Egress TC members, David Frable and Edward Fixen. My responses were shared with Means of Egress TC members during their balloting of the original proposal applying to the Means of Egress chapter and setting out the basic requirement for all occupancies. It should also be noted that I had the opportunity to discuss these issues and share the following responses with the Industrial Technical Committee when it was contemplating exempting high-rise buildings from the new requirement; after this the Industrial TC did not accept an exemption similar to what has been proposed for Mercantile and Business occupancies by the Mercantile TC. There was not similar opportunity to discuss the matter with the Mercantile TC, a fact that I believe resulted in its badly flawed justification for Proposals NFPA 5000-781 and NFPA 101-591. Given the problems with the Mercantile TC proposals, I do not believe that the TCC notes are responsive enough to the proposal’s problems or the need for different action on them. The Mercantile TC should be aware that comments have been submitted to the Means of Egress TC that respond directly to the “Lack of Clarity,” “Cumulative Basis,” and “Horizontal Exits” portions of the Mercantile TC’s substantiation of its proposal 101-591. By the time the Mercantile TC meets to consider this comment, clarifications should have been made by the Means of Egress TC on proposal 101-107 to deal with the Mercantile TC’s concerns on these issues and the result of that work should be available to the Mercantile TC. I believe that, as I understand, the somewhat vague criticism under the label, “Egress via upper levels,” is also dealt with in the clarifications. If not (on this or other criticisms), I would appreciate an audience with the Mercantile TC when it meets in San Diego to deliberate on this matter. (I will be in an adjoining meeting room for either the Assembly Occupancies or Residential Occupancies TC meetings where I serve as a Principal Member.) My comment to the Means of Egress TC also takes into account the need to scope the requirement for wider minimum stairway width at even lower total occupancy limits. Some of the impetus for this comes from GSA’s representative, Mr. Frable, in his negative ballot comment, where he stated, “it appears the proponent has not taken into consideration when determining these arbitrary thresholds that 40% of the population in North America is seriously overweight.” This is addressed at length below (as in my comment on proposal 101-107). Regarding possible lack of clarity on how occupant load is handled, the comment being processed by the Means of Egress TC adds the language, “the total occupant load being, for downward egress travel, the total number of occupants from stories above the level where the width is measured and, in the case of upward egress travel, the total number of occupants from stories below the level where the width is measured. Where multiple stairways serve the total occupant load, the “Total Occupant Load Served by the Stairway” shall be that stairway’s prorated share of the total occupant load, calculated in proportion to the stairway width as measured clear between handrails.” The foregoing clarification addresses criticism that the entire height of stairway of a high-rise building, for example, would need to be sized at the width applicable to the total occupant load of all stories rather than only that portion of the stairway height actually subjected to the occupant load during a total evacuation. A complementary change is clarification of how the occupant load would be apportioned between or among multiple stairways. For example, if three equal-width stairways were provided to serve a total occupant load of 3x above some level of the building, then each of the three stairways below that level would be assumed to serve a total occupant load of x. If one of the three stairways had a width, clear between handrails, of 60 inches and the other two had a width, clear between handrails, of 48 inches, the apportioned total occupant load per stairway would be, respectively, 1.154x, 0.923x and 0.923x. The cleanest way of handling horizontal exits, in relation to the minimum width issue addressed here, is simply to ignore them. This is because, in case of total evacuation of the building, the benefit of the horizontal exits is relatively localized and thus moot; the performance of the exit stairways will largely determine the speed and duration of the evacuation. In other words, there should be neither a credit or a penalty for use of horizontal exits as far as total building evacuation is concerned. Regarding the last of the Mercantile TC’s criticisms—“Use of Additional Exit Stairs”—there is not necessarily a penalty applied if, for design reasons, additional stairs are provided. Because the total occupant load, above the level below which the wider minimum stair width applies, is apportioned among all the stairs, this reduces the likelihood that the stairs might serve occupant loads high enough to trigger the wider minimum width. For example, in a mercantile occupancy with relatively large floor areas but a relatively small number of stories, the number of occupants using any one stair in a total

evacuation is much less than would be the case in many high-rise office buildings. Moreover, at least in the past, mercantile occupancy stairs have been of a more generous width generally than is the case in office buildings so the required-minimum width issue is moot. Demographics and Total Evacuation of Buildings Here we should turn to the significant issue raised by GSA’s representative, Mr. Frable, in his negative ballot comment on 101-107, where he stated, “it appears the proponent has not taken into consideration when determining these arbitrary thresholds that 40% of the population in North America is seriously overweight.” In my comment to the Means of Egress TC on 101-107, I suggest a broadened scoping of the minimum stairway width requirement based on the changed—and changing—demographics of building occupants in two respects. First relative to the research studies described by the proponent of proposal 101-107, these were performed decades ago at a time and in mostly in a country (Canada) when and where people were both thinner and more physically fit than are typical US residents today. Being overweight or obese has become a national health problem in the US among adults and children—the very people who will occupy, and might need to evacuate, buildings for decades to come. Irrefutable evidence for this is in the statistics from the US Centers for Disease Control (CDC), which along with other health organizations, has documented the major increases in overall body mass index (BMI) for US residents with these data being presented on a state-by-state, year-to-year basis on the web site http://www.cdc.gov/nccdphp/dnpa/obesity/resources.htm. The occurrence of obesity (BMI greater than or equal to 30) has approximately doubled from about 15 percent to 31 percent between the early 1970s to 2000 among adults aged 20 to 74 in the US. (See appended two-page tables of data from CDC, downloaded in pdf format from http://www.cdc.gov/nchs/products/pubs/pubd/hestats/obese/obse99.htm.) The Surgeon General for the US (at http://www.surgeongeneral.gov/topics/obesity/calltoaction/fact_glance.htm) notes that:

• 61% of adults in the United States were overweight or obese (BMI> 25) in 1999.

• 13% of children aged 6 to 11 years and 14% of adolescents aged 12 to 19 years were overweight in 1999. This prevalence has nearly tripled for adolescents in the past 2 decades.

• The increases in overweight and obesity cut across all ages, racial and ethnic groups, and both genders.

Notably, most of the Canadian office building evacuation studies—a major input for current US means of egress formulas on egress width and capacity—were already completed by the early 1970s. The same is true for the landmark studies of John Fruin whose book, Pedestrian Planning and Design, was based on field studies (for his PhD) in the New York area before 1970. People, today—and even more so in the coming decades—are larger than those studied for these studies of a few decades ago in Canada and the US. Moreover, it is likely that the differences between today’s (tomorrow’s) building populations and those of several decades ago, when building code requirements for means of egress were formulated in North America and the UK, are even more pronounced. (These earlier deliberations, resulting for example in the once-standard 22-inch unit of exit width—which is still the basis of the current 44-inch nominal, minimum egress stairway width, have been described in critical reviews by Pauls, published in the journal Fire Technology, in 1984 and referenced at the end of proposal 101-107.) In addition to people getting larger, they are becoming so because of reduced fitness generally. This affects people’s ability to cope with the physical demands of evacuation on stairs. One indication of this trend is the estimate of how many people would (or did) have difficulty evacuating down multiple stories of stairs in evacuation of office buildings. Pauls’ estimate of 3 percent of typical Canadian office workers, at about 1970, not being good candidates for using stairs for evacuation with a crowd of other descending persons, can be compared with more-recent US estimates about twice as large. Appendix O of the preliminary report issued by NIST in June 2004, on the World Trade Center evacuation, included the following finding, “Some 6 percent (n=52) reported having a limitation which impacted their ability to evacuate. These limitations included obesity, heart condition, needing assistance to walk, pregnancy, asthma, elderly, chronic condition, recent surgery or injury, and other.” This is also reflected in lower-than expected speeds of movement down the WTC exit stairs, and longer than expected evacuation times, estimated in both US and UK studies so far of the WTC evacuation (as described, for example, in Proceedings of the 3rd International Symposium on Human Behaviour in Fires, 1994). Generally, there are multiple indications that people are not able to evacuate as quickly and efficiently as assumed in drawing up the current means of egress requirements. Finally, we have an aging population generally. Increasingly, people are going to have to work longer than has been the case. Thus we must begin now to design for an older population generally. This means providing more-generous, easier-to-use egress facilities. Of course, this factor is an even larger one for mercantile occupancies. People are living longer and shopping longer. We should not be basing stairway design on demographics of the past. All of the above factors point to wider minimum width for egress stairways. Note that there has been a separate comment submitted to the Means of Egress TC addressing a possible need to address the minimum width of exit discharge doorways (or additional doorways) from the wider stairways resulting from proposal 101-107.

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Report on Comments — Copyright, NFPA NFPA 101 There was substantial discussion in the proposal on the code-related bases for the “triggers.” This dealt with how the code has addressed “Smoke-Protected Assembly Seating.” Admittedly all scoping requirements are based, ultimately, on judgment calls by committees and all the other participants in the code-making process—especially NFPA’s—as nobody has come up with some comprehensive, alternative model for doing this. However, in terms of improvements to certain aspects of safety, the proposal justification did note various benefits of the wider stairways. Generally, in terms of evacuation efficiency alone, with each step in the width table, the larger-population stairways function more efficiently—than current code capacity rules give credit—due to the “effective-width” phenomenon as discussed at length in referenced chapter of the SFPE Handbook of Fire Protection Engineering. The relative egress flow performance of the four widths in the reproduced table is: 1.00, 1.17, 1.33 and 1.50. Surely, with larger populations needing to use stairs for egress, there should be some greater conservatism in their performance such as accomplished with the scoping proposed in the reproduced table. Currently, the 2003 Life Safety Code requires that new stairs (where the occupant load is 50 or greater) to have a nominal 44-inch wide stair with a 35 inch clear width between handrails (takes into consideration projections not more than 4 1/2 inches at or below handrail height). [Please also note that in the 2000 edition of the Life Safety Code new stairs were required (where the occupant load is 50 or greater) to have a nominal 44 – inch wide stair with a 37 inch clear width between handrails (takes into consideration projections not more than 3 1/2 inches at or below handrail height).] I do concur with the proponent’s evacuation data that adult’s rarely decent (sic) side by side in a nominal 44-inch wide stair (i.e., 35 inch clear width between handrails). However, the data also suggests that the stairs would need to be substantially wider than proposed. Also, it appears the proponent has not taken into consideration when determining these arbitrary thresholds that 40% of the population in North America is seriously overweight. Is Mr. Frable arguing here that my proposal did not go far enough? Would GSA fund and support research into the changing demographics of U.S. government workers, for example, and the impact on egress capacity rules and egress performance generally (including the reduced physical capability of “seriously overweight” persons to even move significant distances in an evacuation)? Generally, my proposal offered scope to the Technical Committee to make the wider minimum stair width apply even more generally. Will Mr. Frable now support one of the two more-conservative options for scoping that were noted at the end of the proposal substantiation? Note also that the Canadian research (admittedly from a few decades ago from a more-fit nation than the USA) established that maximum widths between handrails should be reduced from the traditionally permitted 66 or 88 inches to 60 inches so that everyone on the stairway in a crowd condition could reach at least one handrail. Is Mr. Frable now prepared to say—and technically document—that the most effective stairway widths are in an even smaller range than the 12 inches between 48 and 60 inches? The proponent also has hypothesized that this proposal would address counter-flow issues of evacuees and emergency responders. I do agree in concept with the proponent that we need to look closer at this issue, however, whether or not it’s 40 inches, 44 inches, 48 inches or some other value is a sufficient width to accommodate the expected stairway capacity needs to be determined quantitatively. I believe that choosing these arbitrary threshold triggers is still too premature prior to a final report being issued on the World Trade Center. More additional work is required to develop such methods and to revise minimum Code requirements such that an integrated systematic approach to fire protection and egress movement is the norm. Mr. Frable’s reference to a “final report on the World Trade Center” has been seen before but there is not—to my knowledge as a close observer of the post-911 research—going to be any “final report” in the near future and I really doubt whether anyone involved with codes and standards today will live to see a “final report on the World Trade Center.” The journalistic, research and litigation investigations will go on for decades. As noted in the proposal, from what is known about the studies being performed now, there is not the kind of ergonomic detail forthcoming that is comparable to the studies of Fruin, Templer, Pauls and others dealing with crowd dynamics on stairways. Again, if GSA is really concerned about this, it could do a lot more than it is doing right now to actually fund additional studies that should not be restricted to learning what happened in the World Trade Center. The studies controlled by NIST—under the extraordinary, temporary (and inadequate) funding for the World Trade Center—will, in any event, be available in the fall of 2004, thus giving Mr. Frable and others ample opportunity to challenge the acceptance of this proposal on wider minimum stairway widths at the May 2005 meeting of the NFPA and the subsequent Standards Council appeal process in July of 2005. Last but not least, the proponent has not provided any answers to the fundamental questions below that I believe the Technical Committee needs answers to prior to accepting this proposal:• What will be the sociological, economical, and political impact of widening exit stairs by these arbitrary dimensions? First, the dimensions are not arbitrary! Read the substantiation again. Regarding “sociological, economical, and political impact,” does GSA have the base information about such impacts from current minimum stair width requirements that would be compared with the suggested new information?

Appendix 1. Comments from Jake Pauls on the Negative Ballot Comments of, respectively, Edward Fixen (Schirmer Engineering Corporation) and David Frable (GSA) as included in Pauls’ Technical Correlating Committee negative ballot on 101-591. Pauls’ responses are shown in bold italics font below, interspersed with the Negative Ballot Comments, first from Mr. Fixen and then from Mr. Frable. Fixen Neg: While the technical substantiation merits consideration, it appears that the fundamental driver for this substantiation is the complete and uncontrolled evacuation of very tall buildings, as opposed to staged evacuation currently contemplated by Code. It is premature to make changes that are not anchored to corresponding fundamental changes in the Code such as complete evacuation of very tall buildings. To my knowledge there is no committee consensus on fundamentally changing the underlying evacuation philosophy of tall buildings from staged to complete. This is not a fundamental change as the NFPA codes—and all other model codes—have always regulated minimum stair widths. The changes proposed simply improve the alignment of the minimum width requirements to longstanding assumptions about a certain stair widths facilitating certain kinds of crowd movement, both unidirectionally and with counterflow. The 44-inch nominal stair width was based on a mistaken assumption that two files or columns of people could use the stair in a shoulder-to-shoulder fashion. This was long enshrined in the concept of 22-inch units of exit width that NFPA and other code groups began rejecting in the 1980s. See the substantiation provided with the proposal for full background on this matter. Regarding Mr. Fixen’s contention that there is no committee consensus, the Means of Egress Technical Committee has now repeatedly voted (when there were not procedural complications as happened last cycle with the comment on NFPA 101), supported by NFPA members, in favor of realigning the minimum width to take account of the traditional misconception about the 44-inch stair width and this addresses both staged and complete evacuations recognizing that both occur in real events—fires, bombs and bomb scares—in large buildings. Mr. Fixen would have a very difficult job selling a code to professionals and the public today if he argued that the codes were solely based on a staged evacuation concept to the exclusion of other evacuation scenarios. What the codes do implicitly is to cater to evacuation of certain portions of a building in an implicitly-assumed time but they certainly do not rule out evacuation of larger portions or the total building in a longer time. See my full justification, with the proposal, on the benefit of improved egress flow—and hence evacuation time—performance due to the fact that, because of the greater effective width, the increased stair widths will actually be an additional safety benefit beyond enhancing two-abreast movement and counterflow. Although my proposal justification refers to “a fundamental re-examination of minimum egress stair width criteria,” it is not a fundamental re-examination of egress generally and it is merely one of the simplest ergonomic aspects of the egress issue—minimum stair width. Perhaps my proposal clouded matters slightly by permitting a few population-based, width steps between the traditional 44-inch nominal width and the widely recommended nominal width of about 55 inches, specified more clearly as 48 inches clear between handrails. However, I clearly stated that I would consider—within the scope of my proposal—a code revision applying the wider minimum width (of 48 inches clear between handrails) even more generally, for example, such as the Fire Safety Directors Association of Greater New York have advocated for all high-rise buildings. Frable Neg: At the December meeting the Technical Committee voted to accept the subject proposal. However, it is my opinion that the proponent has not provided sufficient technical substantiation to justify the new proposed occupant load threshold triggers for the proposed new stairway width clearances between handrails. Hence this proposal would not coincide with other quality documents published by NFPA that are based on sound technical documentation. It is remarkable that Mr. Frable can characterize a substantiation of over 2,700 words, plus a few figures and four citations to peer-reviewed literature as not being “sound technical documentation” especially as the vast majority of accepted proposals for NFPA documents are not equally justified with technical information based on decades of study. What does Mr. Frable offer to counter the proponent’s substantiation? His “opinion” and nothing more. Surely, if the justification were incorrect, a huge organization like the U.S. General Services Administration and a highly-placed GSA fire safety official like Mr. Frable could refute it in similar detail or, at a minimum, would fund and support a similarly intensive program of research into evacuation and crowd movement generally such as was described in the proposal justification. The proponent also has not provided any substantiation how these new threshold “triggers” will improve the overall building safety. The threshold “triggers” I am referring to are as follows: Total Occupant Load Served by the Stairway Stairway width clear between handrails 50 to 149 36 inches 150 to 999 40 inches 1000 to 1999 44 inches 2000 and more 48 inches

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Report on Comments — Copyright, NFPA NFPA 101 Is it prepared to fund such research? Is GSA interested also in what the “sociological, economical, and political impact,” would be if the actual 9-11 population of the World Trade Center had been significantly higher—as would have been the case had the 9-11 attacks occurred somewhat later that day—than the relatively small population of about 7,000 persons per tower? Imagine several thousand additional people trying to utilize the two conventionally narrow, 44-inch nominal width exit stairs (provided along with a third 55-inch nominal width stair) while having to stop or drastically slow down because of the counterflow from first responders? Imagine a death toll a few times higher than the 2,749 now confirmed in the WTC attack. Imagine that higher death toll attributed, in significant part, directly to inadequate exit width. GSA representative, please explain to members of the Skyscraper Safety Campaign or any of the other post-9-11 family groups why you suggest that a “sociological, economical, and political impact” study now be required of the proponent of the wider stair width requirement. Regarding economic impact, this was dealt with in the prior cycle’s comments and NFPA Standards Council appeal process when GSA challenged the NFPA committee and membership acceptance of a requirement for wider exit stairway width. The economic impact (or area increase impact) was not challenged in detail at that time by GSA. For those not seeing those comments a year ago, it was noted (by Pauls) that: “For example, a 20-story building [with a 29,400 sq ft floor area per story] would have the wider, 56-inch nominal-width stairs (with 48 inches between handrails) only on the lowest 6 stories and the impact on the building area would be only about 400 sq ft or about 0.07 percent of total (above-grade) floor area of about 600,000 sq ft subject to the occupant load calculation. (This calculation is based on minimum floor-to-floor heights of 9 feet; more-typical, 10-ft floor-to-floor heights would have an area impact of about 0.08 percent with the wider stairs.) However, this calculation assumes that the building size remains unchanged for the six lowest floors. In actuality the wider stairs for the six lowest above-grade floors permit an additional 80 persons occupant load on each of these lower floors. Thus the permissible floor area of each of these lower floors could be increased by 8,000 sq ft to about 37,400 sq ft subject to the occupant load calculation. Thus the adjusted percentage impact of the wider stairs on total building area is only about 0.06 percent.” • Will widening new exit stairs to these arbitrary dimensions improve safety significantly? Characterizing new exit stair dimensions as “arbitrary” does not make it so! See comments above regarding significant benefits to stairway usability and thus safety. • By accepting this proposal, will this lead to a “false” perception of improved safety by the occupants of a building? With what technical justification does GSA refer to “false” perception? From what I already know of people’s perceptions of the narrow stair width provided with two of the three World Trade Center exits (as well as other typical office building exits now) they do perceive them as narrow and inadequate. The John Labriola photographs taken in one of the narrower WTC exit stairs on 9-11 clearly depict what ordinary people can readily perceive; people had to stop and twist to the side to let the firefighter pass. (The photographs are available in John Labriola’s book, Walking Forward, Looking Back, Hyper Publishing, 2003.) What basis does GSA have for even suggesting that people’s perception of improved safety with the wider stairs is “false?” • Is this proposal only a “band-aid” that ignores the larger issue of the building evacuation philosophy? Band-aids do a useful job even if applied temporarily. Wider stairs are much more effective as they serve permanently and they improve building evacuation regardless of the evacuation philosophy employed. The proposal does not ignore the larger issue; I believe it clearly pointed out its scope as dealing with one of the relatively simple aspects of design for evacuation—based on traditional expectations of performance with two-unit stairs. Again, what has GSA done and what is it prepared to do to support and fund research on “the larger issue of building evacuation philosophy?” • In lieu of requiring wider stairs, would additional protection of the stairs or requiring additional stairs be more effective in the overall goal? The proposal-specified benefits of the wider stairs are not achieved with “additional protection of the stairs” or simply providing more of them (unless organizations like GSA are prepared to install stairways that are explicitly not intended for evacuation and are for use by first responders only). However, if the overall goal—and the means to reliably achieve it—are to not have any evacuation of a building, then the benefits of wider stairs would be unneeded. Does GSA have the confidence in “additional protection,” for example, to go this route? More important, do the occupants of GSA’s buildings share this confidence? • In lieu of requiring wider stairs, should the expected evacuation capabilities be revised and the associated time required to egress a building? Yes! See all the reasons stated above. Based on the above concerns, the appropriate action on this comment should have been “Reject”. No! The concerns expressed by the two negative balloters, Fixen and Frable, clearly do not justify rejection of the proposal.

Appendix 2 follows on the next two pages. The tables are downloadable as pdf files from http://www.cdc.gov/nchs/products/pubs/pubd/hestats/obese/obse99.htm Note: Supporting material is available for review at NFPA Headquarters.COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: While the committee agrees that perceived safety and egress concerns associated with high rise buildings exist, the committee is not convinced that the proposed provisions adequately address the relevant issues and believes that the proposed revisions only offer a potential partial intermediate step that will require revision in the future. The committee believes a more holistic approach is required and that other safeguards or a combination of other safeguards with the wider stairs have not been sufficiently studied. In addition, the committee notes that a gap exists in the application of the proposed provisions for the 36-inch minimum width. The defend in place concept, i.e. use of horizontal exits, which is allowed by current requirements has not been properly considered in the application of the wider stair provisions, nor has the impact of ground floor exits on upper floors been thoroughly considered. Members of the committee expressed willingness in serving on a task group to further study the issues and develop proposed language if such a task group is appointed by the Technical Correlating Committee. In acting on this comment the committee also took into consideration the action of SAF-MEA on comment 101-46. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: BUSH: The original submission provides sufficient technical justification for this change. The actual Committee Statement issued as a part of this Rejection affirms that the Committee recognizes that this proposal offers a partial solution to the existing concerns with high rise buildings. The design of wider stairs to serve larger building populations, and, in turn larger and taller buildings, would provide a benefit for occupant evacuation and to emergency responders attempting to enter the building alike. For the limited application of conditions where larger stairs would be required, the benefits for the construction of these stairs now warrant their requirement in the model codes. It should also be noted that further action by other Occupancy Technical Committees, which were scheduled after this meeting, have adequately addressed the concerns regarding the application of the proposed provisions for the 36-inch minimum width stair, and regarding the presence of horizontal exits and ground floor exits on upper floors. I do still support the formation of a Task Group to further study and refine these issues. However, I also support the adoption of this proposal as a sound beginning to address the unique hazards of evacuating large numbers of building occupants and the mode of entry for emergency responders. GAUVIN: NEMA commends the exemplary efforts by the submitter to provide a very detailed substantiation and supports the SAF-MER TC suggestion to the TCC, that recommends a task group to investigate a more holistic approach to resolving the perceived safety and egress concerns in high rise buildings. We also feel additional consideration should be given to the comments from Mr. Bush regarding action taken by other Technical Committees. _______________________________________________________________101-354 Log #72a SAF-MEA FINAL ACTION: Accept in Principle (36.2.2.3.1 and 38.2.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that it is permitting the action to go forward as it is Rejecting Comment 101-355.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-591 RECOMMENDATION: Give consideration, so as to make any needed changes, to whether there is adequate technical justification for the new stair width provisions to apply to all occupancies. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-591. COMMITTEE STATEMENT: The committee action on Comment 101-46 is based on recognition that the extra width is needed where counterflow is expected (that is, where occupants are moving downward on a stair while emergency responders are moving upward on the stair at the same time). The revised threshold (that is, the 2000 cumulative person criterion) for the provision was established in recognition that in buildings more than approximately 14 stories in height, emergency responders will be on site before all occupants have evacuated the building. Where a high-rise building does not use full evacuation, but - for example - practices staged evacuation, the extra stair width is needed to help assure safe counterflow in cases where it becomes necessary to go to a full evacuation mode in response to changing fire condition. The subject is related to counterflow as explained in the preceding paragraph. It is not occupancy specific. Proposal 101-591 needs to be rejected. The ROP action by SAF-MER to exempt mercantile and business occupancies from the stair width requirement is unjustified. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-355 Log #72b SAF-MER FINAL ACTION: Reject (36.2.2.3.1 and 38.2.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT – See Comment 101-354.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-591 RECOMMENDATION: (a) Create correlation exemptions for placement in 7.2.xx where SAF-MER exempts mercantile and business occupancies from the stair width provision of the means of egress chapter. (b) Give consideration, so as to make any needed changes, to the method of measuring stair width (for example, between handrails vs. wall-to-wall) for correlation with the methods in Chapter 7. (c) Create/address, in the future, separate proposals for mercantile and business occupancies as the reviewer of the ROP should not be expected to study the mercantile occupancies proposals to find a proposal that affects business occupancies. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle In the proposed section 7.2.2.2.1.1(1) as indicated in the committee action to comment 101-46, make the following modification: 7.2.2.2.1.1(1) New stairs shall be in accordance with Table 7.2.2.2.1(a) and 7.2.2.2.1.2 except as otherwise specified in 36.2.2.3.1 for mercantile occupancies and 38.2.2.3.1 for business occupancies. COMMITTEE STATEMENT: Meets the intent of the submitter. Also, see Committee Action and Statement on Comment 101-353. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: BUSH: The original submission provides sufficient technical justification for this change. The actual Committee Statement issued as a part of this Rejection affirms that the Committee recognizes that this proposal offers a partial solution to the existing concerns with high rise buildings. The design of wider stairs to serve larger building populations, and, in turn larger and taller buildings, would provide a benefit for occupant evacuation and to emergency responders attempting to enter the building alike. For the limited application of conditions where larger stairs would be required, the benefits for the construction of these stairs now warrant their requirement in the model codes. It should also be noted that further action by other Occupancy Technical Committees, which were scheduled after this meeting, have adequately addressed the concerns regarding the application of the proposed provisions for the 36-inch minimum width stair, and regarding the presence of horizontal exits and ground floor exits on upper floors. I do still support the formation of a Task Group to further study and refine these issues. However, I also support the adoption of this proposal as a sound beginning to address the unique hazards of evacuating large numbers of building occupants and the mode of entry for emergency responders. GAUVIN: NEMA commends the exemplary efforts by the submitter to provide a very detailed substantiation and supports the SAF-MER TC suggestion to the TCC, that recommends a task group to investigate a more holistic approach to resolving the perceived safety and egress concerns in high rise buildings. We also feel additional consideration should be given to the comments from Mr. Bush regarding action taken by other Technical Committees. _______________________________________________________________101-356 Log #287 SAF-MER FINAL ACTION: Reject (36.2.2.3.1 and 38.2.2.3.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to REJECT – See Comment 101-354 and 101-355.SUBMITTER: David Frable, U.S. General Services Administration COMMENT ON PROPOSAL NO: 101-591 RECOMMENDATION: We concur with the action taken by the Technical Committee to retain the current minimum exit stair width criteria. SUBSTANTIATION: We concur with the action taken by the Technical Committee to retain the current minimum exit stair width criteria. Therefore, we have provided below, for informational purposes only, the comments we provided on Proposal NFPA 101-107, Log #413. We concur with the negative ballot comments submitted by Mr. Fixen that the fundamental driver for this proposal is proponent’s belief that the only reasonable evacuation strategy to consider for any building is for a complete and total evacuation as opposed to other evacuation strategies (e.g., selective evacuation strategies, horizontal exiting, additional exit stairs, etc.) currently recognized by the code. In addition, the proponent has failed to realize that in some cases, an egress system that relies strictly on total evacuation to the exterior of a building is not practical. For example, health care occupancy, total building evacuation might expose patients to conditions more dangerous than those encountered in relocating the patients from a fire compartment to a safe smoke compartment on the same floor. It is also the proponent’s belief that increasing the widths of exit stairs is the only viable solution to address the need to totally evacuate multistory buildings

as well as addressing counter-flow problems on exit stairs encountered by first responders and evacuees in multistoried buildings. However, the proponent has failed to acknowledge the use of elevators as a viable alternative strategy to be utilized for occupant evacuation and/or relocation in a multistoried building, other than to state “the prospects for this are not good”. There is an ongoing research initiative for the development of performance requirements for the use of elevators for occupant egress and fire department access is currently being conducted by the National Institute of Standards and Technology (NIST). NIST has received positive feedback on this initiative from by many organizations across the world. Organizations such as the American Society of Mechanical Engineers, KONE Elevators, OTIS Canada Elevators, United Technologies Research Center, International Association of Fire Fighters, just to name a few. Should this research initiative be successful, the use of elevators by occupants in an emergency situation would provide the option to both increase the speed of the evacuation and also provide a means of evacuation of individuals unable to negotiate the stairs. Last but not least, the proponent has not provided any calculations to quantitatively access the impact of widening the exit stairs on evacuation movement nor has the proponent provided any comparison to the current exit stair width or the impact of providing more exit stairs meeting the current stair width requirements. We do however feel that it may be prudent to reexamine the entire concept of occupant evacuation in multistoried building (e.g., all evacuation strategies currently recognized by the Codes for all individuals). Based on the above concerns, we feel this proposal is just too premature and has not been fully thought out by the proponent to be considered at this time. Therefore, the only prudent action to take is to refrain the current minimum stair width criteria. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-355 and 101-353. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-355 and 101-353. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: BUSH: The original submission provides sufficient technical justification for this change. The actual Committee Statement issued as a part of this Rejection affirms that the Committee recognizes that this proposal offers a partial solution to the existing concerns with high rise buildings. The design of wider stairs to serve larger building populations, and, in turn larger and taller buildings, would provide a benefit for occupant evacuation and to emergency responders attempting to enter the building alike. For the limited application of conditions where larger stairs would be required, the benefits for the construction of these stairs now warrant their requirement in the model codes. It should also be noted that further action by other Occupancy Technical Committees, which were scheduled after this meeting, have adequately addressed the concerns regarding the application of the proposed provisions for the 36-inch minimum width stair, and regarding the presence of horizontal exits and ground floor exits on upper floors. I do still support the formation of a Task Group to further study and refine these issues. However, I also support the adoption of this proposal as a sound beginning to address the unique hazards of evacuating large numbers of building occupants and the mode of entry for emergency responders. GAUVIN: NEMA commends the exemplary efforts by the submitter to provide a very detailed substantiation and supports the SAF-MER TC suggestion to the TCC, that recommends a task group to investigate a more holistic approach to resolving the perceived safety and egress concerns in high rise buildings. We also feel additional consideration should be given to the comments from Mr. Bush regarding action taken by other Technical Committees.

_______________________________________________________________101-357 Log #73 SAF-MER FINAL ACTION: Accept in Principle (36.2.4(1)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-593 RECOMMENDATION: Give consideration, so as to make any needed changes, to the verbiage of 36.2.4.1 which per errata and second printing of NFPA 101-2003 is different from that addressed by the submitter. The corrected 36.2.4.1 has 3 subparts and retains the concept from earlier editions that not only is access required to two exits, but both of the required exits must be ON the floor (that is, unenclosed exit access stairs cannot be used to satisfy the minimum number of means of egress for floors required to have 2 means of egress). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action required. Section 36.2.4.1 will read as follows: 36.2.4.1 Exits shall comply with the following, except as otherwise permitted by 36.2.4.2 through 36.2.4.5. (1) the number of means of egress shall be in accordance with Section 7.4. (2) Not less than two separate exists shall be provided on every story.

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Report on Comments — Copyright, NFPA NFPA 101 (3) Not less than two separate exits shall be accessible from every part of every story. Sections 36.2.4.2, 36.2.4.3, 36.2.4.4 and 36.2.4.5 also to remain as indicated in the errata no. 101-03-1. COMMITTEE STATEMENT: Committee’s intent with regard to the requirements for the number of exits in new mercantile occupancies has been met. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-358 Log #74 SAF-MER FINAL ACTION: Accept in Principle (36.2.5.7 and 37.2.5.7) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-594 RECOMMENDATION: Give consideration to Schultz’s Explanation of Negative and Perry’s Comment on Affirmative, so as to make any needed changes. SCHULTZ: The Committee action indicated is not correct. The Committee action was “Reject”. The Committee proposal was created to achieve public comment and justification regarding the 50 percent vs. 67 percent of the exit capacity being provided out the front elevation of the store. The Committee wanted more input before it considered a change to the current code text. PERRY: The committee may need to revisit this at the ROC phase. My recollection was that the intent was to modify two things: first, to reduce the required exit capacity on the main entry wall from 2/3 to 1/2 of the total, and second, to not require placement of exits from upper or lower floors to be tied to the building entrance wall location on another floor. The resulting text incorporates a third change: in a multiple-story retail building (other than bulk merchandising), there is no longer any requirement for locating any percentage of the egress width for the entry floor on the exterior wall with the building entrance. This isn’t reflected in the substantiation, and I don’t recall it being discussed. If this was intended, the committee should provide substantiation. If it was not intended, either adding a second sentence to address floors with ‘customer entrances via one exterior wall’, or revising the first sentence to cover any story with ‘the only means of customer entrance through one exterior wall” would re-instate the requirement for multi-story buildings. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Further revise sections 36.2.5.7 and 37.2.5.7 as indicated in proposal 101-594 to read as follows: “In one story retail buildings other than bulk merchandising retail buildings, if the only means of customer entrance is through one exterior wall of the building, one half of the required egress width f rom the street floor shall be located in such wall. Means of egress from floors above or below the street floor shall be arranged in accordance with section 7.5. ” COMMITTEE STATEMENT: This meets the intent of the submitter, expands upon the concepts introduced during the ROP stage and addresses concerns raised during ROP balloting. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-359 Log #75 SAF-MER FINAL ACTION: Accept in Principle (36.3.3.3) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-596 RECOMMENDATION: Give consideration to the proposal, so as to make any needed changes, for purposes of achieving consistency with other occupancy chapters. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-360. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-360. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees in part with the comments from Mr. Humble. However we see this change not as redundant but as conflicting and confusing. It is not clear what the actual requirement is – to comply with the entire section of Section 10.2 (per 36.3.3.3.1) or only to comply with the requirements of 10.2.7.1 or 10.2.8.2 (per 36.3.3.3.3)? HUMBLE: It remains unclear the necessity to adopt provisions for the sake of consistency when in this case the provisions are duplicative within the

proposal itself. In this case 36.3.3.3.1 states that compliance must be made with Section 10.6. Duplicating that provision is the other part of the proposal to add 36.3.3.3.3 that states the floor finish must comply with 10.6.1 and 10.6.2, but that has been done since that is required in 36.3.3.3.1 which references Section 10.6 in its entirety. In regard to the phase “as applicable”, this emphasis currently applies to the entire document anyway. I would respectfully submit that the proposal requires the incorporation of 36.3.3.3.1 and 36.3.3.3.2 only. _______________________________________________________________101-360 Log #303 SAF-MER FINAL ACTION: Accept in Principle (36.3.3.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-596 RECOMMENDATION: Revise 36.3.3.3 to read: 36.3.3.3 Interior Floor Finish. 36.3.3.3.1 Interior floor finish shall comply with Section 10.2. 36.3.3.3.2 Interior floor finish in exit enclosures shall be Class I or Class II. 36.3.3.3.3 Interior finish shall comply with 10.2.7.1 or 10.2.8.2 as applicable. SUBSTANTIATION: As directed by the NFPA 101 TCC, this proposal achieves consistency with the other occupancy chapters, as such the committee statement on rejecting the proposal makes no sense. COMMITTEE MEETING ACTION: Accept in Principle Editorially revise the submitter’s proposed section 36.3.3.3.3 to read as follows: “36.3.3.3.3 Interior floor finish shall comply with 10.2.7.1 or 10.2. 8 7. 2 as applicable.” COMMITTEE STATEMENT: Editorial corrections. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees in part with the comments from Mr. Humble. However we see this change not as redundant but as conflicting and confusing. What is the requirement – to comply with the entire section of Section 10.2 (per 36.3.3.3.1) or only to comply with the requirements of 10.2.7.1 or 10.2.8.2 (per 36.3.3.3.3)? HUMBLE: It remains unclear the necessity to adopt provisions for the sake of consistency when in this case the provisions are duplicative within the proposal itself. In this case 36.3.3.3.1 states that compliance must be made with Section 10.6. Duplicating that provision is the other part of the proposal to add 36.3.3.3.3 that states the floor finish must comply with 10.6.1 and 10.6.2, but that has been done since that is required in 36.3.3.3.1 which references Section 10.6 in its entirety. In regard to the phase “as applicable”, this emphasis currently applies to the entire document anyway. I would respectfully submit that the proposal requires the incorporation of 36.3.3.3.1 and 36.3.3.3.2 only. _______________________________________________________________101-361 Log #76 SAF-MER FINAL ACTION: Accept in Principle (36.3.4 and 37.3.4) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-597 RECOMMENDATION: (a) Give consideration, so as to make any needed changes, to deleting proposed 36.3.4 and 37.3.4 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. (b) Include future provisions for contents and furnishings either as part of the xx.3.3 or xx.7 sections. The xx.3.4 is reserved for alarms; xx.3.5 is for extinguishing systems, and xx.3.6 is for corridors so as to keep the numbering of the occupancy chapters consistent. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Renumber proposed sections 36.3.4 and 37.3.4 as indicated in proposal 101-597 of the ROP as sections 36.7.4 and 37.7.4 and revise to read as follows: “Upholstered furniture and mattresses. The provisions of section 10.3.2 shall not apply.” COMMITTEE STATEMENT: SAF-MER considered the action by SAF-FUR on comment 101-175 and 101-176 in preparing their response to this public comment. SAF-MER believes that there are significant differences between newly introduced and newly manufactured furnishings and contents. After-market furnishings and contents are often introduced into new and existing facilities. SAF-MER believes the provisions of section 10.3.2 as proposed by comments 101-175 and 101-176 would present significant application and enforcement issues. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-362 Log #388 SAF-MER FINAL ACTION: Reject (36.3.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-598 RECOMMENDATION: Accept Proposal 101-598. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee intends that at a minimum one manual fire alarm box be provided, and does not have concerns with being redundant in this regard. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-363 Log #96 SAF-MER FINAL ACTION: Reject (36.3.4.3.1) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-599 RECOMMENDATION: Revise 36.3.4.3.1 as originally proposed, i.e., 36.3.4.3.1 Occupant Notification. During all times that the mercantile occupancy is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate an alarm in accordance with 9.6.3 throughout the mercantile occupancy. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies, as follows: (a) Emergency action shall be initiated by means of live voice public address system announcements occupant notification in accordance with 9.6.3 originating from the attended location where the alarm signal is received. (b) The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72 Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code. − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72. If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards.

3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example; - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No demonstrated need for the proposed type of occupant notification system has been provided. Additionally, no data has been presented indicating that the used of a live voice public address system has been problematic or insufficient. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the submitter. _______________________________________________________________101-364 Log #146 SAF-MER FINAL ACTION: Reject (36.3.4.3.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-599 RECOMMENDATION: Revise 36.3.4.3.1 as originally proposed, i.e., 36.3.4.3.1 Occupant Notification. During all times that the mercantile occupancy is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate an alarm in accordance with 9.6.3 throughout the mercantile occupancy. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action, by personnel trained to respond to emergencies, as follows: (a) Emergency action shall be initiated by means of live voice public address system announcements occupant notification in accordance with 9.6.3 originating from the attended location where the alarm signal is received. (b) The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72, Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code.

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Report on Comments — Copyright, NFPA NFPA 101 - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections maybe applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMESEXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the Technical Committee on Fundamentals of Fire Alarm Systems. _______________________________________________________________101-365 Log #77 SAF-AXM FINAL ACTION: Accept in Principle (36.4.4.3.2 (New) ) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-603 RECOMMENDATION: Review and take any action needed on the subject of the proposed change by SAF-MER to 36.4.4.3.2, given that SAF-AXM has primary responsibility for assembly occupancies and egress from such.

SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No further action needed by SAF-AXM. COMMITTEE STATEMENT: The SAF-AXM committee does not take issue with the action on ROP Proposal 101-603. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 23 Negative: 1 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: ROETHER: I agree that assembly occupancy of 500 people or more that is separate from the mall should have at least half of its means of egress independent of the mall. However, there are many instances where an assembly is within the mall, such as a food court. Any means of egress from such an assembly is itself an exit of the mall and not independent. Therefore, I vote negative on the committee’s action since an assembly within a mall requires its entire means of egress from the mall. _______________________________________________________________101-366 Log #97 SAF-MER FINAL ACTION: Reject (36.4.4.4.3.1) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-604 RECOMMENDATION: Revise 36.4.4.4.3.1 as originally proposed, i.e., 36.4.4.4.3.1 Occupant Notification. During all times that the mall is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate a general alarm in accordance with 9.6.3 throughout the mall. (2) Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (3) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies. Emergency action Occupant Notification in accordance with 9.6.3 shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72 Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code. − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72. If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards. 3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example;

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Report on Comments — Copyright, NFPA NFPA 101 - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the submitter.

_______________________________________________________________101-367 Log #147 SAF-MER FINAL ACTION: Reject (36.4.4.4.3.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-604 RECOMMENDATION: Revise 36.4.4.4.3.1 as originally proposed, i.e., 36.4.4.4.3.1 Occupant Notification. During all times that the mall is occupied, the required fire alarm system, once initiated, shall perform one of the following functions. (1) It shall activate a general alarm in accordance with 9.6.3 throughout the mall. (2) Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (3) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies. Emergency action Occupant notification in accordance with 9.6.3 shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72, Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code. - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows:

In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections maybe applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the Technical Committee on Fundamentals of Fire Alarm Systems.

_______________________________________________________________101-368 Log #194 SAF-MER FINAL ACTION: Accept (36.4.4.8) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-607 RECOMMENDATION: Accept this proposal in principle with the following language: 36.4.4.8 Kiosks. Kiosks and similar structures (temporary or permanent) shall not be considered as tenant spaces and shall meet the following requirements: (1) Combustible kiosks and similar structures shall be constructed of any of the following materials: (a) Fire retardant-treated wood complying with the requirements for fire retardant-impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials

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Report on Comments — Copyright, NFPA NFPA 101 (b) Light-transmitting plastics complying with Chapter 47 of the NFPA 5000 ™, Building Construction and Safety Code™ (c) Foam plastics having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) having a Class A rating as specified in Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films meeting the fire flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films SUBSTANTIATION: I made a mistake in the proposal. The correct language from NFPA 701 is “flame propagation performance criteria”, as was correctly adopted by acceptance in principle of proposal 101-252, 101-293 and others. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-369 Log #195a SAF-MER FINAL ACTION: Reject (36.4.4.8 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9* Children’s Playground Structures. Stand-alone structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in Section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). A.36.4.4.9 Children’s playground structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m 2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of children’s playground structures should be

regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. SUBSTANTIATION: I will not repeat all the information provided in the proposal, but highlight some areas and provide added information, as well as respond to the issues raised by the technical committee in its statement regarding proposal 101-608. During the full scale fire test conducted on a mini structure (with a simple small cigarette lighter on a bit of newspaper) the following was found: (1) the temperature at all locations measured within the structure exceeded 100EC within less than 1 min from the beginning of the test, and did not return below 100EC at all for 5 of the 6 thermocouples used (and only did so for a period of time in the other thermocouple, while still remaining above 65EC, before rising again); (2) the temperatures measured in the structure exceeded 700EC in every thermocouple; (3) the total smoke released exceeded 1,000 m2 during the test (before the fire was extinguished); (4) the optical density measured in the duct exceeded a value of 1 (in units of inverse metres) and (5) the structure reached flashover before being manually extinguished (over 5 megawatts of heat released). This means that a child caught inside such a structure would be incapacitated within 1-2 min of a fire starting. A parent trying to rescue the child may need several minutes to wind his or her way through the structure to reach the child. The structures.are built to make it challenging for the children to exit. The dimensions and separation recommended in the comment are identical to those the code requires for kiosks. To have some idea of the size of these playground structures, a few offered for sale at present have the following dimensions: 16 ft x 20 ft, 8 ft x 25 ft, 20 ft x 20 ft and up to 28 ft x 12 ft. Five figures (a photograph of the commercial mini test structure, and two photographs and two designs of commercial structures) show examples. The Centers for Disease Control found that each year in the United States, more than 200,000 children 14 years of age and younger are treated in emergency departments for playground-related injuries (although fire is not yet a large fraction) The “National Program for Playground Safety, School of Health, Physical Education & Leisure Services, WRC 205, University of Northern Iowa, Cedar Falls, IA 50614-0618 (NPPS)” has made a survey of children’s playgrounds and has found problems with safety, especially indoors. One of the areas highlighted has been the typical surfacing provided for under the playground to protect children using this equipment. Such surfacing are carpet, mats or safety tiles. In order to ensure that children are safe from falls inside as well as outside, NPPS undertook a study of community used surfaces found under indoor playground equipment. Twenty-four different products were obtained from 20 national suppliers and manufacturers of child care and exercise/tumbling/gymnastic equipment (see: Mack, M., Sacks, J., Hudson, S., and Thompson, D. (2001). “The impact attenuation performance of materials used under indoor playground equipment at child care centers.” Injury Control and Safety Prevention, Vol 8, No. 1). Such surfacing is needed to provide protection from falls by children using such equipment, and neither normal carpet, nor ordinary floor tiles offer the appropriate safety. Thus, such children’s playgrounds need special types of floor surfacing equipment, placed between the mall floor and the children’s playground. The recommended types of surfaces for proper fall protection are: rubber mats, rubber tiles and poured-in-place rubber composition materials, which typically have poor fire performance. This is why floor surfacing materials need fire test requirements. Typical materials used for the exterior surfaces of the structures are materials in vivid and attaractive colors and which have little probability of causing splinters or other such problems. Thus, the exterior materials are typically rigid plastics (more often than not polyethylene), foamed plastics, rubbers and textiles. Instead of abdicating the responsibility to ASTM F15 (issuer of ASTM F1918 recommended in the proposal), this comment incorporates them all into the code. This comment uses the following requirements for fire performance of chilldren’s playground materials, which are an upgrade over what ASTM F 1918 has. The comment upgrades the requirements for rigid plastics, to meet

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Report on Comments — Copyright, NFPA NFPA 101 UL 94 V2 (instead of the milder UL 94 HB) and for textiles, to meet NFPA 701 for textiles (instead of the milder CA TB 117). NFPA 701 is, of course, already widely referenced in the code and UL 94 is used by UL (and all other nationally recognized testing labs running fire tests) for listing plastic materials. A long list of fire retarded polyethylene materials meeting UL 94 V2 is attached for information after a search of the UL data base, showing that it can be met easily. UL 1975 is already required in the codes for foam plastic displays, for plastic signs and for foam plastic displays in kiosks in malls (in NFPA 5000) and for all foam plastic displays in assembly and mercantile occupancies (in NFPA 101). Light-transmitting plastics used for windows and the like (glass would not be used to prevent injuries) need to meet the same requirements that such materials need to meet in kiosks. The structural materials to be used (whether non combustible, limited combustible or fire retardant treated wood) are the same as those for other mall structures. Finally, ACM materials might be used to offer certain added visual impacts, and the same requirement is placed for them as for them when used in kiosks. If rigid plastics such as polyethylene are used without fire retardance (as would be the case if requirements are not included) they can cause very severe fires on their own. As an example, a typical waste basket (22.4 lb) made of non FR polyethylene has been shown to emit > 1 megawatt on its own when ignited. Polyethylene materials should not be allowed into malls unless properly fire retarded. Requirements for suppressions and detection were also added, in response to the committee concerns for context. This comment also adds an Annex note, for information, to the code text added to new section 36.4.4.9, as additional help to the user (compared with the other comment to proposal 101-608). Equivalent comments have also been made for Chapter 37 (proposal 101-624). Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The committee does not believe that a fire and life safety problem has been demonstrated. The play structures are typically located in highly visible areas. The activities of children on and around these structures is associated with supervision by adults. Ignition sources on and around these play structures are considered to be minimal. The committee also notes that the terminology associated with the proposed requirements are not sufficiently defined and the requirements are ambiguous. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. _______________________________________________________________101-370 Log #195b SAF-AXM FINAL ACTION: Reject (36.4.4.8 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9* Children’s Playground Structures. Stand-alone structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36

in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in Section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). A.36.4.4.9 Children’s playground structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m 2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of children’s playground structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. SUBSTANTIATION: I will not repeat all the information provided in the proposal, but highlight some areas and provide added information, as well as respond to the issues raised by the technical committee in its statement regarding proposal 101-608. During the full scale fire test conducted on a mini structure (with a simple small cigarette lighter on a bit of newspaper) the following was found: (1) the temperature at all locations measured within the structure exceeded 100EC within less than 1 min from the beginning of the test, and did not return below 100EC at all for 5 of the 6 thermocouples used (and only did so for a period of time in the other thermocouple, while still remaining above 65EC, before rising again); (2) the temperatures measured in the structure exceeded 700EC in every thermocouple; (3) the total smoke released exceeded 1,000 m2 during the test (before the fire was extinguished); (4) the optical density measured in the duct exceeded a value of 1 (in units of inverse metres) and (5) the structure reached flashover before being manually extinguished (over 5 megawatts of heat released). This means that a child caught inside such a structure would be incapacitated within 1-2 min of a fire starting. A parent trying to rescue the child may need several minutes to wind his or her way through the structure to reach the child. The structures.are built to make it challenging for the children to exit. The dimensions and separation recommended in the comment are identical to those the code requires for kiosks. To have some idea of the size of these playground structures, a few offered for sale at present have the following dimensions: 16 ft x 20 ft, 8 ft x 25 ft, 20 ft x 20 ft and up to 28 ft x 12 ft. Five figures (a photograph of the commercial mini test structure, and two photographs and two designs of commercial structures) show examples. The Centers for Disease Control found that each year in the United States, more than 200,000 children 14 years of age and younger are treated in emergency departments for playground-related injuries (although fire is not yet a large fraction) The “National Program for Playground Safety, School of Health, Physical Education & Leisure Services, WRC 205, University of Northern Iowa, Cedar Falls, IA 50614-0618 (NPPS)” has made a survey of children’s playgrounds

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Report on Comments — Copyright, NFPA NFPA 101 and has found problems with safety, especially indoors. One of the areas highlighted has been the typical surfacing provided for under the playground to protect children using this equipment. Such surfacing are carpet, mats or safety tiles. In order to ensure that children are safe from falls inside as well as outside, NPPS undertook a study of community used surfaces found under indoor playground equipment. Twenty-four different products were obtained from 20 national suppliers and manufacturers of child care and exercise/tumbling/gymnastic equipment (see: Mack, M., Sacks, J., Hudson, S., and Thompson, D. (2001). “The impact attenuation performance of materials used under indoor playground equipment at child care centers.” Injury Control and Safety Prevention, Vol 8, No. 1). Such surfacing is needed to provide protection from falls by children using such equipment, and neither normal carpet, nor ordinary floor tiles offer the appropriate safety. Thus, such children’s playgrounds need special types of floor surfacing equipment, placed between the mall floor and the children’s playground. The recommended types of surfaces for proper fall protection are: rubber mats, rubber tiles and poured-in-place rubber composition materials, which typically have poor fire performance. This is why floor surfacing materials need fire test requirements. Typical materials used for the exterior surfaces of the structures are materials in vivid and attaractive colors and which have little probability of causing splinters or other such problems. Thus, the exterior materials are typically rigid plastics (more often than not polyethylene), foamed plastics, rubbers and textiles. Instead of abdicating the responsibility to ASTM F15 (issuer of ASTM F1918 recommended in the proposal), this comment incorporates them all into the code. This comment uses the following requirements for fire performance of chilldren’s playground materials, which are an upgrade over what ASTM F 1918 has. The comment upgrades the requirements for rigid plastics, to meet UL 94 V2 (instead of the milder UL 94 HB) and for textiles, to meet NFPA 701 for textiles (instead of the milder CA TB 117). NFPA 701 is, of course, already widely referenced in the code and UL 94 is used by UL (and all other nationally recognized testing labs running fire tests) for listing plastic materials. A long list of fire retarded polyethylene materials meeting UL 94 V2 is attached for information after a search of the UL data base, showing that it can be met easily. UL 1975 is already required in the codes for foam plastic displays, for plastic signs and for foam plastic displays in kiosks in malls (in NFPA 5000) and for all foam plastic displays in assembly and mercantile occupancies (in NFPA 101). Light-transmitting plastics used for windows and the like (glass would not be used to prevent injuries) need to meet the same requirements that such materials need to meet in kiosks. The structural materials to be used (whether non combustible, limited combustible or fire retardant treated wood) are the same as those for other mall structures. Finally, ACM materials might be used to offer certain added visual impacts, and the same requirement is placed for them as for them when used in kiosks. If rigid plastics such as polyethylene are used without fire retardance (as would be the case if requirements are not included) they can cause very severe fires on their own. As an example, a typical waste basket (22.4 lb) made of non FR polyethylene has been shown to emit > 1 megawatt on its own when ignited. Polyethylene materials should not be allowed into malls unless properly fire retarded. Requirements for suppressions and detection were also added, in response to the committee concerns for context. This comment also adds an Annex note, for information, to the code text added to new section 36.4.4.9, as additional help to the user (compared with the other comment to proposal 101-608). Equivalent comments have also been made for Chapter 37 (proposal 101-624). Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-371 Log #248a SAF-MER FINAL ACTION: Reject (36.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9 Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code

(c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of multilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-608, with different terminology. In this comment, and in the one adding also an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 37, on proposal 101-624. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The application, context and terminology of the proposed requirements are not clear. Distinction between the proposed requirements and that for special amusement needs to be provided. Also see committee statement for comment 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. _______________________________________________________________101-372 Log #248b SAF-AXM FINAL ACTION: Reject (36.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9 Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films

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Report on Comments — Copyright, NFPA NFPA 101 (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of multilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-608, with different terminology. In this comment, and in the one adding also an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 37, on proposal 101-624. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-373 Log #249a SAF-MER FINAL ACTION: Reject (36.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9* Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253.

(2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of muiltilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). A.36.4.4.9 Multilevel play structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of multilevel play structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. Also add ASTM F 1918 to the list of ASTM informational references. SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-608, with different terminology. In this comment, and in the one not including an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 37, on proposal 101-624. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-371 and 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. _______________________________________________________________101-374 Log #249b SAF-AXM FINAL ACTION: Reject (36.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9* Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code

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Report on Comments — Copyright, NFPA NFPA 101 (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of muiltilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). A.36.4.4.9 Multilevel play structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of multilevel play structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. Also add ASTM F 1918 to the list of ASTM informational references.SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-608, with different terminology. In this comment, and in the one not including an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 37, on proposal 101-624. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30

BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-375 Log #267 SAF-MER FINAL ACTION: Reject (36.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-609 RECOMMENDATION: Revise text as follows: 36.4.4.9* Smoke Control. A smoke control system complying with 8.6.7(5) shall be provided in a mall with floor openings connecting more than two or more levels. SUBSTANTIATION: The purpose of this proposed revision is to require the smoke control system for malls having two or more levels connected by floor openings. We believe the same fire safety issues exist for 2 level malls, as well as 3 level malls. At least two nationally recognized model building codes have also required smoke control systems for 2 level malls. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: No data has been provided indicating that the current provisions of the code present an unacceptable risk. The code permits vertical openings in Class A and Class B mercantile occupancies. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment which I submitted on behalf of one of my clients, the Alliance for Fire and Smoke Containment and Control (AFSCC), I would vote negative on the Committee Action to reject the comment which requires smoke control systems to be provided in malls having floor openings connecting two or more levels. I believe the substantiation provided is adequate in order that a reasonable acceptable level of life safety can be achieved in multi-level covered mall buildings. _______________________________________________________________101-376 Log #196a SAF-MER FINAL ACTION: Reject (36.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9 Children’s Playground Structures. Stand-alone structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films.

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Report on Comments — Copyright, NFPA NFPA 101 (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in Section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal, but highlight some areas and provide added information, as well as respond to the issues raised by the technical committee in its statement regarding proposal 101-608. During the full scale fire test conducted on a mini structure (with a simple small cigarette lighter on a bit of newspaper) the following was found: (1) the temperature at all locations measured within the structure exceeded 100EC within less than 1 min from the beginning of the test, and did not return below 100EC at all for 5 of the 6 thermocouples used (and only did so for a period of time in the other thermocouple, while still remaining above 65EC, before rising again); (2) the temperatures measured in the structure exceeded 700EC in every thermocouple; (3) the total smoke released exceeded 1,000 m2 during the test (before the fire was extinguished); (4) the optical density measured in the duct exceeded a value of 1 (in units of inverse metres) and (5) the structure reached flashover before being manually extinguished (over 5 megawatts of heat released). This means that a child caught inside such a structure would be incapacitated within 1-2 min of a fire starting. A parent trying to rescue the child may need several minutes to wind his or her way through the structure to reach the child. The structures.are built to make it challenging for the children to exit. The dimensions and separation recommended in the comment are identical to those the code requires for kiosks. To have some idea of the size of these playground structures, a few offered for sale at present have the following dimensions: 16 ft x 20 ft, 8 ft x 25 ft, 20 ft x 20 ft and up to 28 ft x 12 ft. Five figures (a photograph of the commercial mini test structure, and two photographs and two designs of commercial structures) show examples. The Centers for Disease Control found that each year in the United States, more than 200,000 children 14 years of age and younger are treated in emergency departments for playground-related injuries (although fire is not yet a large fraction) The “National Program for Playground Safety, School of Health, Physical Education & Leisure Services, WRC 205, University of Northern Iowa, Cedar Falls, IA 50614-0618 (NPPS)” has made a survey of children’s playgrounds and has found problems with safety, especially indoors. One of the areas highlighted has been the typical surfacing provided for under the playground to protect children using this equipment. Such surfacing are carpet, mats or safety tiles. In order to ensure that children are safe from falls inside as well as outside, NPPS undertook a study of community used surfaces found under indoor playground equipment. Twenty-four different products were obtained from 20 national suppliers and manufacturers of child care and exercise/tumbling/gymnastic equipment (see: Mack, M., Sacks, J., Hudson, S., and Thompson, D. (2001). “The impact attenuation performance of materials used under indoor playground equipment at child care centers.” Injury Control and Safety Prevention, Vol 8, No. 1). Such surfacing is needed to provide protection from falls by children using such equipment, and neither normal carpet, nor ordinary floor tiles offer the appropriate safety. Thus, such children’s playgrounds need special types of floor surfacing equipment, placed between the mall floor and the children’s playground. The recommended types of surfaces for proper fall protection are: rubber mats, rubber tiles and poured-in-place rubber composition materials, which typically have poor fire performance. This is why floor surfacing materials need fire test requirements. Typical materials used for the exterior surfaces of the structures are materials in vivid and attaractive colors and which have little probability of causing splinters or other such problems. Thus, the exterior materials are typically rigid plastics (more often than not polyethylene), foamed plastics, rubbers and textiles. Instead of abdicating the responsibility to ASTM F15 (issuer of ASTM F1918 recommended in the proposal), this comment incorporates them all into the code. This comment uses the following requirements for fire performance of chilldren’s playground materials, which are an upgrade over what ASTM F 1918 has. The comment upgrades the requirements for rigid plastics, to meet UL 94 V2 (instead of the milder UL 94 HB) and for textiles, to meet NFPA 701 for textiles (instead of the milder CA TB 117). NFPA 701 is, of course, already widely referenced in the code and UL 94 is used by UL (and all other nationally recognized testing labs running fire tests) for listing plastic materials. A long list of fire retarded polyethylene materials meeting UL 94 V2 is attached for information after a search of the UL data base, showing that it can be met easily. UL 1975 is already required in the codes for foam plastic displays, for plastic signs and for foam plastic displays in kiosks in malls (in NFPA 5000) and for all foam plastic displays in assembly and mercantile occupancies (in NFPA 101). Light-transmitting plastics used for windows and the like (glass would not be used to prevent injuries) need to meet the same requirements that such materials need to meet in kiosks. The structural materials to be used (whether non combustible, limited combustible or fire

retardant treated wood) are the same as those for other mall structures. Finally, ACM materials might be used to offer certain added visual impacts, and the same requirement is placed for them as for them when used in kiosks. If rigid plastics such as polyethylene are used without fire retardance (as would be the case if requirements are not included) they can cause very severe fires on their own. As an example, a typical waste basket (22.4 lb) made of non FR polyethylene has been shown to emit > 1 megawatt on its own when ignited. Polyethylene materials should not be allowed into malls unless properly fire retarded. Requirements for suppressions and detection were also added, in response to the committee concerns for context. This comment does not contain an Annex note to the code text which was added to new section 36.4.4.9, as additional help to the user by my other comment to proposal 101-608. Equivalent comments have also been made for Chapter 37 (proposal 101-624). Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting.

_______________________________________________________________101-377 Log #196b SAF-AXM FINAL ACTION: Reject (36.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 36.4.4.9 Children’s Playground Structures. Stand-alone structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in Section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal, but highlight some areas and provide added information, as well

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Report on Comments — Copyright, NFPA NFPA 101 as respond to the issues raised by the technical committee in its statement regarding proposal 101-608. During the full scale fire test conducted on a mini structure (with a simple small cigarette lighter on a bit of newspaper) the following was found: (1) the temperature at all locations measured within the structure exceeded 100EC within less than 1 min from the beginning of the test, and did not return below 100EC at all for 5 of the 6 thermocouples used (and only did so for a period of time in the other thermocouple, while still remaining above 65EC, before rising again); (2) the temperatures measured in the structure exceeded 700EC in every thermocouple; (3) the total smoke released exceeded 1,000 m2 during the test (before the fire was extinguished); (4) the optical density measured in the duct exceeded a value of 1 (in units of inverse metres) and (5) the structure reached flashover before being manually extinguished (over 5 megawatts of heat released). This means that a child caught inside such a structure would be incapacitated within 1-2 min of a fire starting. A parent trying to rescue the child may need several minutes to wind his or her way through the structure to reach the child. The structures.are built to make it challenging for the children to exit. The dimensions and separation recommended in the comment are identical to those the code requires for kiosks. To have some idea of the size of these playground structures, a few offered for sale at present have the following dimensions: 16 ft x 20 ft, 8 ft x 25 ft, 20 ft x 20 ft and up to 28 ft x 12 ft. Five figures (a photograph of the commercial mini test structure, and two photographs and two designs of commercial structures) show examples. The Centers for Disease Control found that each year in the United States, more than 200,000 children 14 years of age and younger are treated in emergency departments for playground-related injuries (although fire is not yet a large fraction) The “National Program for Playground Safety, School of Health, Physical Education & Leisure Services, WRC 205, University of Northern Iowa, Cedar Falls, IA 50614-0618 (NPPS)” has made a survey of children’s playgrounds and has found problems with safety, especially indoors. One of the areas highlighted has been the typical surfacing provided for under the playground to protect children using this equipment. Such surfacing are carpet, mats or safety tiles. In order to ensure that children are safe from falls inside as well as outside, NPPS undertook a study of community used surfaces found under indoor playground equipment. Twenty-four different products were obtained from 20 national suppliers and manufacturers of child care and exercise/tumbling/gymnastic equipment (see: Mack, M., Sacks, J., Hudson, S., and Thompson, D. (2001). “The impact attenuation performance of materials used under indoor playground equipment at child care centers.” Injury Control and Safety Prevention, Vol 8, No. 1). Such surfacing is needed to provide protection from falls by children using such equipment, and neither normal carpet, nor ordinary floor tiles offer the appropriate safety. Thus, such children’s playgrounds need special types of floor surfacing equipment, placed between the mall floor and the children’s playground. The recommended types of surfaces for proper fall protection are: rubber mats, rubber tiles and poured-in-place rubber composition materials, which typically have poor fire performance. This is why floor surfacing materials need fire test requirements. Typical materials used for the exterior surfaces of the structures are materials in vivid and attaractive colors and which have little probability of causing splinters or other such problems. Thus, the exterior materials are typically rigid plastics (more often than not polyethylene), foamed plastics, rubbers and textiles. Instead of abdicating the responsibility to ASTM F15 (issuer of ASTM F1918 recommended in the proposal), this comment incorporates them all into the code. This comment uses the following requirements for fire performance of chilldren’s playground materials, which are an upgrade over what ASTM F 1918 has. The comment upgrades the requirements for rigid plastics, to meet UL 94 V2 (instead of the milder UL 94 HB) and for textiles, to meet NFPA 701 for textiles (instead of the milder CA TB 117). NFPA 701 is, of course, already widely referenced in the code and UL 94 is used by UL (and all other nationally recognized testing labs running fire tests) for listing plastic materials. A long list of fire retarded polyethylene materials meeting UL 94 V2 is attached for information after a search of the UL data base, showing that it can be met easily. UL 1975 is already required in the codes for foam plastic displays, for plastic signs and for foam plastic displays in kiosks in malls (in NFPA 5000) and for all foam plastic displays in assembly and mercantile occupancies (in NFPA 101). Light-transmitting plastics used for windows and the like (glass would not be used to prevent injuries) need to meet the same requirements that such materials need to meet in kiosks. The structural materials to be used (whether non combustible, limited combustible or fire retardant treated wood) are the same as those for other mall structures. Finally, ACM materials might be used to offer certain added visual impacts, and the same requirement is placed for them as for them when used in kiosks. If rigid plastics such as polyethylene are used without fire retardance (as would be the case if requirements are not included) they can cause very severe fires on their own. As an example, a typical waste basket (22.4 lb) made of non FR polyethylene has been shown to emit > 1 megawatt on its own when ignited. Polyethylene materials should not be allowed into malls unless properly fire retarded. Requirements for suppressions and detection were also added, in response to the committee concerns for context.

This comment does not contain an Annex note to the code text which was added to new section 36.4.4.9, as additional help to the user by my other comment to proposal 101-608. Equivalent comments have also been made for Chapter 37 (proposal 101-624). Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-377a Log #CC426 SAF-MER FINAL ACTION: Accept (36.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Technical Committee on Mercantile and Business Occupancies COMMENT ON PROPOSAL NO: 101-169 RECOMMENDATION: Revise the proposed new section 36.4.4.9 as indicated in proposal 101-609 of the ROP to read as follows: Smoke Control. A Smoke control system complying with 8.6.7(5) shall be provided in a mall with floor openings connecting more than two levels. SUBSTANTIATION: Editorial correction. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-378 Log #299a SAF-MER FINAL ACTION: Reject (36.4.4.9, 36.4.4.9.1 and 36.4.4.9.2) _______________________________________________________________ SUBMITTER: Catherine L. Stashak Des Plaines, IL COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Provide new language as follows: 36.4.4.9 Multilevel Play Structures. 36.4.4.9.1 Multilevel play structures shall comply with the requirements of 12.4.7. 36.4.4.9.2 Multilevel play structures shall comply with the requirements of ASTM 1918, Standard safety Performance Specification for Soft Container Play Equipment. SUBSTANTIATION: There has been an increasing number of multilevel play structures in malls for the purpose of entertaining children while their parents go shopping. Originally these structures were found in assembly occupancies such as McDonald’s. Chuckie Cheese, Discovery Zone, and Odyssey Fun World. During the developmental cycle for the 1997 edition of NFPA 101, the Assembly TC proactively perceived a risk with these structures, as they were growing in size to as tall as 30 ft and covering floor area of 900 sq ft. The Assembly TC established a task group, for which I chaired, and that task group visited facilities housing multilevel play structures evaluating the hazard and how expected behavior of the occupants (children) interfaces with the hazard. There frequently exists large numbers of children ranging from toddlers and young children who probably have no evacuation training, to older children and teenagers, playing within these structures. The structure provides various climbing experiences (tubes, slides, ladders, ropes, and nets) which confounds egress. Combine the inexperienced evacuee + confounded egress + unfamiliarity with way out of structure + heavy thick black smoke created by the burning plastic = casualties. My own experience was myself crawling through tubes to get at my (then) 6 year old daughter who was caught in a remote section of the structure, unable to climb the rope that was her only way out. Recognizing the greater challenge for occupants of multilevel play structures, the Assembly TC defined multilevel play structures as a Special Amusement Building, (see 3.3.27.10/A.3.3.27.10) requiring special consideration. During the development of this language the Assembly TC was unaware that a standard providing requirements for fire resistance directly related to these structures existed. Now that there is knowledge that a standard exists that will improve the equation, the Mercantile/Business TC should extend the existing protection to multilevel play structures located within malls, and improve that protection as provided by ASTM 1918. The combination of the sprinklers and ASTM 1918 will provide a structure that is consistent with the rest of the code that would not permit these plastics as interior finish, and in some cases furnishings. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action on Comment 101-369 and 101-371. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-379 Log #299b SAF-AXM FINAL ACTION: Reject (36.4.4.9, 36.4.4.9.1 and 36.4.4.9.2) _______________________________________________________________ SUBMITTER: Catherine L. Stashak Des Plaines, IL COMMENT ON PROPOSAL NO: 101-608 RECOMMENDATION: Provide new language as follows: 36.4.4.9 Multilevel Play Structures. 36.4.4.9.1 Multilevel play structures shall comply with the requirements of 12.4.7. 36.4.4.9.2 Multilevel play structures shall comply with the requirements of ASTM 1918, Standard safety Performance Specification for Soft Container Play Equipment. SUBSTANTIATION: There has been an increasing number of multilevel play structures in malls for the purpose of entertaining children while their parents go shopping. Originally these structures were found in assembly occupancies such as McDonald’s. Chuckie Cheese, Discovery Zone, and Odyssey Fun World. During the developmental cycle for the 1997 edition of NFPA 101, the Assembly TC proactively perceived a risk with these structures, as they were growing in size to as tall as 30 ft and covering floor area of 900 sq ft. The Assembly TC established a task group, for which I chaired, and that task group visited facilities housing multilevel play structures evaluating the hazard and how expected behavior of the occupants (children) interfaces with the hazard. There frequently exists large numbers of children ranging from toddlers and young children who probably have no evacuation training, to older children and teenagers, playing within these structures. The structure provides various climbing experiences (tubes, slides, ladders, ropes, and nets) which confounds egress. Combine the inexperienced evacuee + confounded egress + unfamiliarity with way out of structure + heavy thick black smoke created by the burning plastic = casualties. My own experience was myself crawling through tubes to get at my (then) 6 year old daughter who was caught in a remote section of the structure, unable to climb the rope that was her only way out. Recognizing the greater challenge for occupants of multilevel play structures, the Assembly TC defined multilevel play structures as a Special Amusement Building, (see 3.3.27.10/A.3.3.27.10) requiring special consideration. During the development of this language the Assembly TC was unaware that a standard providing requirements for fire resistance directly related to these structures existed. Now that there is knowledge that a standard exists that will improve the equation, the Mercantile/Business TC should extend the existing protection to multilevel play structures located within malls, and improve that protection as provided by ASTM 1918. The combination of the sprinklers and ASTM 1918 will provide a structure that is consistent with the rest of the code that would not permit these plastics as interior finish, and in some cases furnishings. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 22 Negative: 2 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER EXPLANATION OF NEGATIVE: HAYES: Festival Seating by nature offers issues with over crowding. No exemption should apply here regarding a fire suppression system. A perfect example would be the West Warwick Fire, people were stepping on each other to get away from the fire. The crowd crush that ensued actually stopped people from getting out. A fire suppression system would have aided in the exiting of the building. LAKE: The provisions presented by the proponent would provide a reasonable degree of safety for children in these types of structures. Bear in mind that in most cases these facilities are being used by small children, who in many cases do not have the skills to self preserve. The facilities are set up with limited ingress and egress and plastic materials are used both in bumper protection and access control that would never be allowed in any area where limited ingress and egress restrictions are present. The plastics used within these structures should be required to meet the proposed testing requirements.

_______________________________________________________________101-380 Log #98 SAF-MER FINAL ACTION: Reject (36.4.5.4.3) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-614 RECOMMENDATION: Revise 36.4.5.4.3 as originally proposed, i.e., 36.4.5.4.3 Occupant Notification. During all times that the mercantile occupancy is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate a general alarm in accordance with 9.6.3 throughout the mercantile occupancy. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to

emergencies. Emergency action Occupant notification in accordance with 9.6.3 shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72 Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code. − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72. If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards. 3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example; - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF

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Report on Comments — Copyright, NFPA NFPA 101 FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the submitter. _______________________________________________________________101-381 Log #148 SAF-MER FINAL ACTION: Reject (36.4.5.4.3) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-614 RECOMMENDATION: Revise 36.4.5.4.3 as originally proposed, i.e., 36.4.5.4.3 Occupant Notification. During all times that the mercantile occupancy is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate an alarm in accordance with 9.6.3 throughout the mercantile occupancy. Positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies. Emergency action Occupant notification in accordance with 9.6.3 shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72, 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code. - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer

NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections maybe applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the Technical Committee on Fundamentals of Fire Alarm Systems. _______________________________________________________________101-382 Log #78 SAF-MER FINAL ACTION: Accept in Principle (37.2.4(1)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-617 RECOMMENDATION: (a) Correct the Committee Action which was recorded incorrectly but was meant to accomplish the same change as done on Proposal 101-593. See Bush’s and Gauvin’s Explanation of Negative. (b) Give consideration, so as to make any needed changes, to the verbiage of 37.2.4.1 which per errata and second printing of NFPA 101-2003 is different from that addressed by the submitter. The corrected 37.2.4.1 has 3 subparts and retains the concept from earlier editions that not only is access required to two exits, but both of the required exits must be ON the floor (that is, unenclosed exit access stairs cannot be used to satisfy the minimum number of means of egress for floors required to have 2 means of egress). BUSH: The Committee language for this proposal is not consistent with the original proposal which was accepted in principle by the Technical Committee. It appears that the final wording should apply to a different paragraph of the Code. GAUVIN: The committee action at the ROP was to see action on 101-593 (Log #43). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action required. Section 37.2.4. 1 will read as follows: 37.2.4.1 Exits shall comply with the following, except as otherwise permitted by 37.2.4.2 through 37.2.4.5. (1) the number of means of egress shall be in accordance with Section 7.4. (2) Not less than two separate exists shall be provided on every story. (3) Not less than two separate exits shall be accessible from every part of every story. Sections 37.2.4.2, 37.2.4.3, 37.2.4.4 and 37.2.4.5 also to remain as indicated in the errata no. 101-03-1. COMMITTEE STATEMENT: Committee’s intent with regard to the requirements for the number of exits in existing mercantile occupancies is indicated. The committee also notes that the wording in the committee meeting action on proposal 101-617 in the ROP is not correct. The committee action on this comment supersedes the committee action on proposal 101-617. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-383 Log #389 SAF-MER FINAL ACTION: Reject (37.3.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-619 RECOMMENDATION: Accept Proposal 101-619. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected

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Report on Comments — Copyright, NFPA NFPA 101 premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-362. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-384 Log #199 SAF-MER FINAL ACTION: Accept (37.4.4.8) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-623 RECOMMENDATION: Accept this proposal in principle with the following language: 37.4.4.8 Kiosks. Kiosks and similar structures (temporary or permanent) shall not be considered as tenant spaces and shall meet the following requirements: (1) Combustible kiosks and similar structures shall be constructed of any of the following materials: (a) Fire retardant-treated wood complying with the requirements for fire retardant-impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 47 of the NFPA 5000 ™, Building Construction and Safety Code™ (c) Foam plastics having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) having a Class A rating as specified in Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films meeting the fire flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films SUBSTANTIATION: I made a mistake in the proposal. The correct language from NFPA 701 is “flame propagation performance criteria”, as was correctly adopted by acceptance in principle of proposal 101-252, 101-293 and others. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-385 Log #250a SAF-MER FINAL ACTION: Reject (37.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9 Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance

with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of multilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-624, with different terminology. In this comment, and in the one adding also an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 36, on proposal 101-608. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-371 and 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. _______________________________________________________________101-386 Log #250b SAF-AXM FINAL ACTION: Reject (37.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9 Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices.

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Report on Comments — Copyright, NFPA NFPA 101 (3) The minimum horizontal separation between multilevel play structures or groups of multilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-624, with different terminology. In this comment, and in the one adding also an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 36, on proposal 101-608. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-387 Log #251a SAF-MER FINAL ACTION: Reject (37.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in a new section: 37.4.4.9* Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of muiltilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). A.37.4.4.9 Multilevel play structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures,

FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of multilevel play structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. Also, add ASTM F 1918 to the list of ASTM informational references. SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-624, with different terminology. In this comment, and in the one not including an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 36, on proposal 101-608. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-371 and 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting.

_______________________________________________________________101-388 Log #251b SAF-AXM FINAL ACTION: Reject (37.4.4.9) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in a new section: 37.4.4.9* Multilevel Play Structures. Stand-alone multilevel play structures contained within shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Multilevel play structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh

101-157

Report on Comments — Copyright, NFPA NFPA 101 (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the multilevel play structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Multilevel play structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between multilevel play structures or groups of muiltilevel play structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each multilevel play structure shall have a maximum area of 27.8 m2 (300 ft2). A.37.4.4.9 Multilevel play structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of multilevel play structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. Also, add ASTM F 1918 to the list of ASTM informational references. SUBSTANTIATION: I will not repeat all the information provided in the proposal or in other comments regarding proposals 101-608 or 101-624. I am submitting two companion comments to the comments I submitted to proposal 101-624, with different terminology. In this comment, and in the one not including an annex note, I call the structures “multilevel play structures” (as defined in NFPA 101 in 3.3.217.5) instead of children’s playground structures. Two other comments are being submitted to Chapter 36, on proposal 101-608. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-389 Log #197a SAF-MER FINAL ACTION: Reject (37.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9 Children’s Playground Structures. Stand-alone structures contained withing shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials

(b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: This comment is identical to one of those made to 101-608 for Chapter 36 (new mercantile occupancies) but for Chapter 37 (existing mercantile occupancies), which contains the substantiation. There is also a companion comment to this one, which adds an annex note. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting.

_______________________________________________________________101-390 Log #197b SAF-AXM FINAL ACTION: Reject (37.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9 Children’s Playground Structures. Stand-alone structures contained withing shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes,

101-158

Report on Comments — Copyright, NFPA NFPA 101 pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). SUBSTANTIATION: This comment is identical to one of those made to 101-608 for Chapter 36 (new mercantile occupancies) but for Chapter 37 (existing mercantile occupancies), which contains the substantiation. There is also a companion comment to this one, which adds an annex note. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER

_______________________________________________________________101-391 Log #198a SAF-MER FINAL ACTION: Reject (37.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9* Children’s Playground Structures. Stand-alone structures contained withing shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices.

(3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). A.37.4.4.9 Children’s playground structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of children’s playground structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. SUBSTANTIATION: This comment is identical to one of those made to 101-608 for Chapter 36 (new mercantile occupancies) but for Chapter 37 (existing mercantile occupancies), which contains the substantiation. There is also a companion comment to this one, which does not contain the annex note proposed here. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-369. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. _______________________________________________________________101-392 Log #198b SAF-AXM FINAL ACTION: Reject (37.4.4.9 (New) ) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International / Rep. American Fire Safety Council COMMENT ON PROPOSAL NO: 101-624 RECOMMENDATION: Accept the proposal in part in principle with the following language in anew section: 37.4.4.9* Children’s Playground Structures. Stand-alone structures contained withing shopping malls and intended as children’s playgrounds shall not be considered as tenant spaces and shall meet the following requirements: (1) Children’s playground structures shall be constructed of noncombustible materials, of limited combustible materials or of combustible materials that comply with the following: (a) Fire retardant–treated wood complying with the requirements for fire retardant–impregnated wood in NFPA 703, Standard for Fire Retardant Impregnated Wood and Fire Retardant Coatings for Building Materials (b) Light-transmitting plastics complying with Chapter 48 of NFPA 5000, Building Construction and Safety Code (c) Foam plastics (including the pipe foam used in soft-contained play equipment structures) having a maximum heat-release rate not greater than 100 kW when tested in accordance with UL 1975 (d) Aluminum composite material (ACM) meeting the requirements of Class A interior finish in accordance with Chapter 10 when tested as an assembly in the maximum thickness intended for use

101-159

Report on Comments — Copyright, NFPA NFPA 101 (e) Textiles and films complying with the flame propagation performance criteria contained in NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films (f) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, window, panels, junction boxes, pipes, slides, and decks) meeting the UL 94 V-2 classification when tested in accordance with UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances. (g) Ball pool balls, used in soft-contained play equipment structures, having a maximum heat release rate not greater than 100 kW when tested in accordance with UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes. The minimum specimen test size shall be 910 mm by 910 mm (36 in. by 36 in.) by an average of 560 mm (21 in.) deep, and the balls shall be held in a box constructed of galvanized steel poultry netting wire mesh (h) Foam plastics shall be covered by a fabric, coating, or film meeting the flame propagation performance criteria of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. (i) The floor surfacing placed under the children’s playground structure shall exhibit a Class I interior floor finish classification, as described in section 10.6, when tested in accordance with NFPA 253. (2) Children’s playground structures located within the mall shall be protected with approved fire suppression and detection devices. (3) The minimum horizontal separation between children’s playground structures or groups of children’s playground structures and other structures within the mall shall be 6100 mm (240 in.). (4) Each children’s playground structure shall have a maximum area of 27.8 m2 (300 ft2). A.37.4.4.9 Children’s playground structures are commonly present inside shopping malls. Such structures are not classified as interior finish, as decorative objects, as plastic signs, as kiosks, or as exhibit booths, for all of which there are requirements in the Life Safety Code, NFPA 101, or in the Building Construction and Safety Code, NFPA 5000. A fire test was conducted on a small version of a soft-contained play equipment structure, constructed of materials complying with the flammability section of ASTM F 1918, Standard Safety Performance Specification for Soft Contained Play Equipment, which is a specification for such structures. The structure generated a very severe fire (exceeding 5 MW of heat release rate, and 1,000 m2 of smoke released, before extinction; M.M. Hirschler: Fire Safety of Children’s Playground Structures, FPRF Fire Risk and Fire Hazard Symposium, June 2004). Therefore, the materials of construction of children’s playground structures should be regulated and should also be either non combustible, limited combustible, constructed of materials permitted for kiosks in malls (such as fire retardant treated wood) or exceed the materials requirements of the flammability section of ASTM F 1918. ASTM F 1918 requires: (1) plastic materials used for rigid components to comply with a UL 94 HB classification when tested to UL 94, Test for Flammability of Plastic Materials for Parts, Devices, and Appliances; (2) materials used for foam padding (excluding pipe foam) to comply with the requirements of California Technical Bulletin 117, Section A, Requirements, Test Procedure and Apparatus for Testing the Flame Retardance of Resilient Filling Materials Used in Upholstered Furniture; (3) materials used for foam padding to be covered by a fabric, coating, or film that meets the requirements of NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films; (4) materials used for pipe foam padding to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW; (5) materials used for ball pool balls to comply with the requirements of UL 1975, Fire Tests for Foamed Plastics Used for Decorative Purposes, with a peak heat release rate not exceeding 100 kW and (6) knitted and woven fabrics, whether coated or uncoated, to comply with the requirements of NFPA 701, Standard Methods of Fire Test for Flame Resistant Textiles and Films. The requirements of this section exceed those of the flammability section of ASTM F 1918 for both rigid plastics and textiles, and permit the use of other materials, similar to those permitted for use in kiosks and other mall structures. SUBSTANTIATION: This comment is identical to one of those made to 101-608 for Chapter 36 (new mercantile occupancies) but for Chapter 37 (existing mercantile occupancies), which contains the substantiation. There is also a companion comment to this one, which does not contain the annex note proposed here. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Play structures are assembly occupancies regardless of occupant load based on 6.1.2.1(2). The submitter has not adequately substantiated the need for regulating such equipment. NUMBER ELIGIBLE TO VOTE: 30 BALLOT RESULTS: Affirmative: 24 BALLOT NOT RETURNED: 6 BACON, BARTLETT, FITCH, PERKINS, PRITCHETT, WERTHEIMER _______________________________________________________________101-393 Log #227 SAF-MER FINAL ACTION: Accept in Principle (38.1.5.2, 39.1.5.2) _______________________________________________________________ SUBMITTER: David Stringfield, University of Minnesota COMMENT ON PROPOSAL NO: 101-629 RECOMMENDATION: Change TC action from reject to accept in part. 38.1.5.2 For purposes...classified as a light hazard occupancy in...systems. 39.1.5.2 For purposes...classified as a light hazard occupancy in...systems.

SUBSTANTIATION: The business occupancy TC is the only TC that has chosen the sprinkler design. (Compare other XX.1.5.X sections). Also, the instructional labs listed in A.3.3.252.3 would not be light hazard. Usually business occupancies have mechanical or storage rooms that exceed light hazard. COMMITTEE MEETING ACTION: Accept in Principle Delete 38.1.5.2 and 39.1.5.2 in their entirety. COMMITTEE STATEMENT: The current language introduces confusion and is not necessary. Occupancy classifications with regard to sprinkler system design and installation are addressed by NFPA 13. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-394 Log #283 SAF-MER FINAL ACTION: Reject (38.2.2.13) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-632 RECOMMENDATION: Revise text to read as follows: 38.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: The benefit from installation of escape device(s) or system(s) is apparent: the equipment, in conjunction with the required evacuation plan and training provides a controlled and reasonably safe alternative for evacuation when the required means of egress have been compromised. Additionally, based on a related comment submitted on Proposal 101-107, installation of an escape device, a coordinated group of devices or system that complies with 7.2.14.2 will reduce the minimum stair width requirements in new construction to that of the 2003 LSC. One requirement of that allowance is that an occupancy chapter (11 through 42) permit the escape device/system to serve as a component in the means of egress. The revised text indicated in this comment will permit that stair width reduction for new construction. The risks are addressed by the criteria in 7.2.14 and the evaluation, if one is required by the AHJ, as indicated in Proposal 101-128, 7.2.14.1(2). Because building owners and occupants of buildings are purchasing and installing various types of escape of devices and systems, whether required or not, guidance on appropriate selection and use is important. Since the ROP meetings, ASTM is actively developing standards and has formed a subcommittee of the E06 Committee on Building Performance to develop standards for the certification, installation, testing and maintenance of three types of escape device/system products. Installations are now complete in numerous locations with three products successfully completed field trials and one has been completed the certification requirements for installation by the Standards Institution of Israel who is following NFPA and ASTM’s actions closely. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The recommendation as proposed by the submitter to Chapter 7 regarding escape devices and systems was not accepted by SAF-MEA and therefore the appropriate action on this comment as recommended by the submitter at the ROC meeting is reject. See action by SAF-MEA on comment 101-78. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-395 Log #79 SAF-MER FINAL ACTION: Accept in Principle (38.2.4.2(1)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-633 RECOMMENDATION: Give consideration, so as to make any needed changes, to the verbiage of 38.2.4.1 which per errata and second printing of NFPA 101-2003 is different from that addressed by the submitter. The corrected 38.2.4.1 has 3 subparts and retains the concept from earlier editions that not only is access required to two exits, but both of the required exits must be ON the floor (that is, unenclosed exit access stairs cannot be used to satisfy the minimum number of means of egress for floors required to have 2 means of egress). SUBSTANTIATION: See the above recommendation.

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept in Principle No specific action required. Section 38.2.4. 1 will read as follows: 38.2.4.1 Exits shall comply with the following, except as otherwise permitted by 38.2.4.2 through 38.2.4.5. (1) the number of means of egress shall be in accordance with Section 7.4. (2) Not less than two separate exists shall be provided on every story. (3) Not less than two separate exits shall be accessible from every part of every story. Sections 38.2.4.2, 38.2.4.3, 38.2.4.4, 38.2.4.5 and 38.2.4.6 also to remain as indicated in the errata no. 101-03-1. COMMITTEE STATEMENT: Committee’s intent with regard to the requirements for the number of exits in new business occupancies is indicated. The committee also notes that the wording in the committee meeting action on proposal 101-633 in the ROP is not correct. The committee action on this comment supersedes the committee action on proposal 101-633. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-396 Log #80 SAF-MER FINAL ACTION: Accept in Principle (38.3.3.3) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-636 RECOMMENDATION: Give consideration to the proposal, so as to make any needed changes, for purposes of achieving consistency with other occupancy chapters. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-397. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-397. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees in part with the comments from Mr. Humble. However we see this change not as redundant but as conflicting and confusing. It is not clear what the actual requirement is – to comply with the entire section of Section 10.2 (per 36.3.3.3.1) or only to comply with the requirements of 10.2.7.1 or 10.2.8.2 (per 36.3.3.3.3)? HUMBLE: It remains unclear the necessity to adopt provisions for the sake of consistency when in this case the provisions are duplicative within the proposal itself. In this case 38.3.3.3.1 states that compliance must be made with Section 10.6. Duplicating that provision is the other part of the proposal to add 38.3.3.3.3 that states the floor finish must comply with 10.6.1 and 10.6.2, but that has been done since that is required in 38.3.3.3.1 which references Section 10.6 in its entirety. In regard to the phase “as applicable”, this emphasis currently applies to the entire document anyway. I would respectfully submit that the proposal requires the incorporation of 38.3.3.3.1 and 38.3.3.3.2 only. ______________________________________________________________101-397 Log #300 SAF-MER FINAL ACTION: Accept in Principle (38.3.3.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-636 RECOMMENDATION: Revise 38.3.3.3 to read: 38.3.3.3 Interior Floor Finish. 38.3.3.3.1 Interior floor finish shall comply with Section 10.2. 38.3.3.3.2 Interior floor finish in exit enclosures shall be Class I or Class II. 38.3.3.3.3 Interior finish shall comply with 10.2.7.1 or 10.2.7.2 as applicable. SUBSTANTIATION: As directed by the NFPA 101 TCC, this proposal achieves consistency with the other occupancy chapters, as such the committee statement on rejecting the proposal makes no sense. COMMITTEE MEETING ACTION: Accept in Principle Editorially revise the submitter’s proposed section 38.3.3.3.3 to read as follows: “36.3.3.3.3 Interior floor finish shall comply with 10.2.7.1 or 10.2.7.2 as applicable.” COMMITTEE STATEMENT: Editorial correction. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 2 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees in part with the comments from Mr. Humble. However we see this change not as redundant but as conflicting and confusing. It is not clear what the actual requirement is – to comply with the entire section of Section 10.2 (per 36.3.3.3.1) or only to comply with the requirements of 10.2.7.1 or 10.2.8.2 (per 36.3.3.3.3)?

HUMBLE: It remains unclear the necessity to adopt provisions for the sake of consistency when in this case the provisions are duplicative within the proposal itself. In this case 38.3.3.3.1 states that compliance must be made with Section 10.6. Duplicating that provision is the other part of the proposal to add 38.3.3.3.3 that states the floor finish must comply with 10.6.1 and 10.6.2, but that has been done since that is required in 38.3.3.3.1 which references Section 10.6 in its entirety. In regard to the phase “as applicable”, this emphasis currently applies to the entire document anyway. I would respectfully submit that the proposal requires the incorporation of 38.3.3.3.1 and 38.3.3.3.2 only. _______________________________________________________________101-398 Log #81 SAF-MER FINAL ACTION: Accept in Principle (38.3.4 and 39.3.4) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-637 RECOMMENDATION: (a) Give consideration, so as to make any needed changes, to deleting proposed 38.3.4 and 39.3.4 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. (b) Include future provisions for contents and furnishings either as part of the xx.3.3 or xx.7 sections. The xx.3.4 is reserved for alarms; xx.3.5 is for extinguishing systems, and xx.3.6 is for corridors so as to keep the numbering of the occupancy chapters consistent. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Renumber proposed sections 38.3.4 and 38.3.4 as indicated in proposal 101-637 of the ROP as sections 38.7.4 and 38.7.4 and revise to read as follows: “Upholstered furniture and mattresses. The provisions of section 10.3.2 shall not apply.” COMMITTEE STATEMENT: SAF-MER considered the action by SAF-FUR on comment 101-175 and 101-176 in preparing their response to this public comment. SAF-MER believes that there are significant differences between newly introduced and newly manufactured furnishings and contents. After-market furnishings and contents are often introduced into new and existing facilities. SAF-MER believes the provisions of section 10.3.2 as proposed by comments 101-175 and 101-176 would present significant application and enforcement issues. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-399 Log #99 SAF-MER FINAL ACTION: Reject (38.3.4.3) _______________________________________________________________ SUBMITTER: Daniel J. Gauvin, Tyco/Simplex Grinnell COMMENT ON PROPOSAL NO: 101-638 RECOMMENDATION: Revise 38.3.4.3 as originally proposed, i.e., 38.3.4.3 Occupant Notification. During all times that the building is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate a general alarm in accordance with 9.6.3 throughout the building; positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies. Occupant notification in accordance with 9.6.3 Emergency action shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72 Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: 1. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with the Guide for Committee Officers of Technical Committees and Technical Correlating Committees of National Fire Protection Association, Annex A-9, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved in accordance with applicable NFPA standards. When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope for the installation and performance of the fire alarm system lies with the NFPA 72 Fire Alarm Code. − The Building and Life Safety Codes identify when and where fire alarm systems and features are required. − NFPA 72 is the installation standard that identifies how the fire alarm system and associated fire alarm system features required by the Building and/or Life Safety Codes must perform, be installed, and tested. If NFPA 101 or 5000 requires occupants to be notified of a fire condition then the requirements for the Occupant Notification of the fire condition must comply with NFPA 72.

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Report on Comments — Copyright, NFPA NFPA 101 If an NFPA 101 and/or 5000 Technical Committee does not agree with the requirements of NFPA 72 for occupant notification then the NFPA 101 and/or 5000 Technical Committee should submit a proposal to NFPA 72. 2. Other Building Codes and Jurisdictions may begin to question whether the requirements of NFPA Codes and Standards should be adopted as minimum regulatory requirements knowing that its own Building and Life Safety Codes are taking exception to the minimum requirements of the NFPA 72 Fire Alarm Code. If the NFPA Building and Life Safety Codes take exception the minimum requirements for Fire Alarm Occupant Notification Systems in accordance with NFPA 72, it sets a precedent that has the potential to cast doubt on the integrity of all NFPA Codes and Standards. 3. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example; - In a fire emergency it is not uncommon to experience a loss of primary power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. 4. There are no installation standards or performance requirements applicable to Public Address systems. AHJ’s do not have any standards to ensure and enforce the reliability and minimum performance requirements for public address systems are met. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification in their areas. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. 5. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: In accordance with NFPA 72 section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicate systems. Where sophisticated public address audio systems are required the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. 6. The option also currently exists for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1-4 and NFPA 101 Chapter 5 respectively. These sections may be applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72 National Fire Alarm Code for any occupancy. In some venues, PA Systems may be a preferred and valid approach. However, because PA systems are not required to meet the minimum performance criteria of any standards, THE USE OF PUBLIC ADDRESS SYSTEMS NOT LISTED FOR THE PURPOSE OF FIRE ALARM OCCUPANT NOTIFICATION SHOULD ONLY BE APPLIED USING THE PERFORMANCE BASED PROVISIONS IN THE CODE. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the submitter. _______________________________________________________________101-400 Log #149 SAF-MER FINAL ACTION: Reject (38.3.4.3) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals of Fire Alarm Systems COMMENT ON PROPOSAL NO: 101-638 RECOMMENDATION: Revise 38.3.4.3 as originally proposed, i.e., 38.3.4.3 Occupant Notification. During all times that the building is occupied, the required fire alarm system, once initiated, shall perform one of the following functions: (1) It shall activate a general alarm in accordance with 9.6.3 throughout the building; positive alarm sequence in accordance with 9.6.3.4 shall be permitted. (2) It shall activate an alarm signal in a continuously attended location for the purpose of initiating emergency action by personnel trained to respond to emergencies. Occupant notification in accordance with 9.6.3 Emergency action shall be initiated by means of live voice public address system announcements originating from the attended location where the alarm signal is received. The

emergency voice/alarm communication live voice public address system shall be permitted to be used for other announcements in accordance with NFPA 72, Section 6.8.4, provided that the emergency action use takes precedence over any other use. SUBSTANTIATION: When the Building and Life Safety Code require a fire alarm system feature such as occupant notification of a fire condition the scope of the installation and performance of the fire alarm system lies with the NFPA 72, National Fire Alarm Code. - The Building and Life Safety Codes identify when and where fire alarm systems and features are required. - NFPA 72 is the installation standard that identifies how the fire alarm system required by the Building and/or Life Safety Code must perform, be installed, and tested. The Codes and the Code Making Process currently addresses the assignment of scope as follows: In accordance with Annex A-9 guidelines on potential jurisdictional (scope) issues between committees developing occupancy standards and committees developing installation standards, an Occupancy Committee should wherever possible reference the requirements by an installation standard. NFPA 101 Section 4.5.6 states, Any fire protection system, building service equipment, feature of protection, or safeguard provided for life safety shall be designed, installed, and approved, in accordance with applicable NFPA standards. NFPA 72 has specific minimum performance requirements for Occupant Notification such as performance levels for: - Secondary power, - Monitoring integrity (circuit supervision), - Survivability, - Audible and visible characteristics, - Testing, maintenance, record keeping, etc. These are minimum fundamental requirements of NFPA 72 occupant notification systems. For example: - In a fire emergency it is not uncommon for the cause of the fire condition to also result in a loss of power. Often the fire alarm system is the only reliable emergency notification system due to NFPA 72 secondary power requirements. - In today’s environment the monitoring and integrity requirements of NFPA 72 are necessary to ensure the system wiring is not altered or tampered with due to building maintenance, acts of vandalism, arson, or terror. There are no installation standards or performance requirements applicable to Public Address systems. Some Public Address systems provide speaker volume controls accessible to occupants that may be used to completely turn off the means of notification n their areas. We also share the concerns associated with the use of public address systems as provided in the explanation of negative vote from Mr. Bartlett. The allowed use of public address systems in the NFPA Building and Life Safety Codes without including the installation and performance requirements for an NFPA 72 Emergency Voice/Alarm Communications system does not provide the minimum requirements for fire alarm occupant notification. NFPA 72 and NFPA 101 also address the desire to eliminate the cost of requiring duplicative similar systems: - In accordance with NFPA 72 Section 6.8.4, Fire Alarm systems are allowed to be used as Combination Systems that share components, circuitry, and installation wiring with non-fire alarm systems. Several manufacturers offer NFPA 72 Emergency Voice/Alarm Communication systems that are also listed for paging applications - eliminating the need for duplicative systems. Where sophisticated public address audio systems are required, the technology exists for system manufacturers to design and manufacture systems that also comply with the requirements of NFPA 72 as combination systems. - The option also exist for Equivalency and Performance Based Options in accordance with NFPA 101 Section 1.4 and NFPA 101 Chapter 5 respectively. These sections maybe applied to allow use of alternative systems and performance methods. The NFPA Building and Life Safety Code must not circumvent the prescriptive performance requirements of its own NFPA 72, National Fire Alarm Code for any occupancy. The prescriptive requirements of NFPA 72 occupant notification systems must be included as the basis for determining performance based options when desired. It is the position of the NFPA 72 Technical Committee on Fundamentals of Fire Alarm Systems that systems used for the purpose of occupant notification of fire conditions falls within the scope of NFPA 72. This appears to be a correlation issue that needs to be addressed to determine which committee’s purview notification of occupants of a fire alarm condition resides. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-363. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Negative: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA agrees with the substantiation provided by the Technical Committee on Fundamentals of Fire Alarm Systems.

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-400a Log #CC427 SAF-MER FINAL ACTION: Accept (38.3.6.2) _______________________________________________________________ SUBMITTER: Technical Committee on Mercantile and Business Occupancies COMMENT ON PROPOSAL NO: 101-633 RECOMMENDATION: Delete 38.3.6.2 as follows: 38.3.6 Corridors. 38.3.6.1* Where access to exits is provided by corridors, such corridors shall be separated from use areas by walls having a fire resistance rating of not less than 1 hour in accordance with Section 8.3, unless one of the following conditions exists: (1)* Where exits are available from an open floor area (2)* Within a space occupied by a single tenant (3) Within buildings protected throughout by an approved, supervised automatic sprinkler system in accordance with 9.7.1.1(1) 38.3.6.2 Unenclosed exits available from an open floor area, or unenclosed exits that serve a space occupied by a single tenant, shall not be required to be protected in accordance with 38.3.6.1. SUBSTANTIATION: This comment has been tied to Proposal 101-633 on 38.2.4.2 because there is no ROP proposal directly addressing 38.3.6. Proposal 101-633 deals with Exits and this comment deals with deleting a paragraph that mistakenly uses the term “Unenclosed Exits.” In the ROP for the 2003 edition, Proposal 101-658 recommended retiring the exceptions in Chapter 38 by reformatting the text. At the ROC stage for the 2003 edition, Comment 101-377 took what eventually became 38.3.6.2 and worked its subject into what became 38.3.6.1(1) and (2) but failed to mention that proposed 38.3.6.2 needed to be deleted. All three exceptions (open plan, single tenant, and sprinklered buildings) are adequately covered in 38.3.6.1 so as to permit 38.3.6.2 to be deleted. The term “unenclosed exits” as used in 38.3.6.2 is a misnomer and another reason why 38.3.6.2 needs to be deleted. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 14 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting.

_______________________________________________________________101-401 Log #284 SAF-MER FINAL ACTION: Reject (39.2.2.13 (New) ) _______________________________________________________________ SUBMITTER: David deVries, Firetech Engineering Incorporated / Rep. Safe Evacuation Coalition COMMENT ON PROPOSAL NO: 101-639 RECOMMENDATION: Revise text to read as follows: 39.2.2.13 Escape Devices or Systems. Escape devices or systems complying with 7.2.14. 2 shall be permitted. SUBSTANTIATION: The benefit from installation of escape device(s) or system(s) is apparent: the equipment, in conjunction with the required evacuation plan and training provides a controlled and reasonably safe alternative for evacuation when the required means of egress have been compromised. The risks are addressed by the criteria in 7.2.14 and the evaluation, if one is required by the AHJ, as indicated in Proposal 101-128, 7.2.14.1(2). Because building owners and occupants of buildings are purchasing and installing various types of escape of devices and systems, whether required or not, guidance on appropriate selection and use is important. Since the ROP meetings, ASTM is actively developing standards and has formed a subcommittee of the E06 Committee on Building Performance to develop standards for the certification, installation, testing and maintenance of three types of escape device/system products. Installations are now complete in numerous locations with three products successfully completed field trials and one has been completed the certification requirements for installation by the Standards Institution of Israel who is following NFPA and ASTM’s actions closely. The Safe Evacuation Coalition (SEvacC) is a newly formed group of manufacturers of escape devices and systems organized to support the development of criteria for the selection, installation and safe use of such equipment in both new and existing buildings. The current members include Escape Rescue Systems Ltd., Moseroth Ltd. (Spider Rescue System) and DoublExit Ltd. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-394. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES

_______________________________________________________________101-402 Log #82 SAF-MER FINAL ACTION: Accept in Principle (39.2.4.2(1)) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-640 RECOMMENDATION: Give consideration, so as to make any needed changes, to the verbiage of 39.2.4.1 which per errata and second printing of NFPA 101-2003 is different from that addressed by the submitter. The corrected 39.2.4.1 has 3 subparts and retains the concept from earlier editions that not only is access required to two exits, but both of the required exits must be ON the floor (that is, unenclosed exit access stairs cannot be used to satisfy the minimum number of means of egress for floors required to have 2 means of egress). SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle No specific action required. Section 39.2.4. 1 will read as follows: 39.2.4.1 Exits shall comply with the following, except as otherwise permitted by 39.2.4.2 through 39.2.4.5. (1) the number of means of egress shall be in accordance with Section 7.4. (2) Not less than two separate exists shall be provided on every story. (3) Not less than two separate exits shall be accessible from every part of every story. Sections 39.2.4.2, 39.2.4.3, 39.2.4.4, 39.2.4.5 and 39.2.4.6 also to remain as indicated in the errata no. 101-03-1. COMMITTEE STATEMENT: Committee’s intent with regard to the requirements for the number of exits in existing business occupancies is indicated. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 15 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES _______________________________________________________________101-403 Log #83 SAF-IND FINAL ACTION: Accept (40.2.5.2.1 and Table 40.2.5.2.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-646 RECOMMENDATION: Give consideration, so as to make any needed changes, to changing the lead-in to read: “Industrial equipment access doors, walkways, platforms, ramps, and stairs…” as the proposed text is difficult to read and comprehend. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept Revise 40.2.5.2.1 as recommended by the submitter. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-404 Log #84 SAF-IND FINAL ACTION: Accept in Principle (40.3.3.3) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-652 RECOMMENDATION: Give consideration, to the submitter’s Substantiation, so as to make any needed changes: The proposal makes industrial chapter of NFPA 101 consistent with NFPA 5000. It also corrects an error in NFPA 101. What is printed in the Code is technically wrong and misleading. Chapter 7 regulates the floor finish in exit enclosures and requires that they be Class I or Class II. By saying no requirements, it implies that the Industrial Occupancies chapter is overriding Chapter 7, but this has never been formally proposed or documented. There is no justification for it. With regard to 40.3.3.3.3 this makes it more user friendly. With the exception of the chapters written by the Mercantile and Business Committee and the Industrial and Storage Committee (NFPA 101 only) all other occupancy chapters use this format. It is important that the provisions for interior finish be consistent within the occupancy chapters so as to not imply that something different is intended. Although it could be argued as extraneous it is needed for consistency. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-405. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-405. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 24 Negative: 1 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: HOLMES: The statement by the proponent not withstanding, the Association action in 1991, 1994, 1997, 2000, and 2003 for NFPA 101 upheld that Industrial Occupancies are exempt from floor finish requirements. The subject was deliberated by the TC in subsequent editions of the codes and the TC

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Report on Comments — Copyright, NFPA NFPA 101 decided that there is no need to regulate floor finish in Industrial Occupancies. The statement in the codes that there are no requirements for floor finish in Industrial Occupancies was not inadvertent but purposeful. This was upheld by Association actions on previous editions of the code. For the type of spaces, type of hazards, and geometry of industrial facilities, floor finish is not a significant contributor the level of hazard or risk to occupants. The statement in 40.3.3.3 that there are no requirements for floor finish for Industrial Occupancies is not a change but is a continuation of a longstanding statement in the code. There is no justification to make the proposed change in the code to include floor finish requirements for Industrial Occupancies. As indicated in the Committee Substantiation in Comment 101-405, there is no demonstrated hazard with the current requirements (No Requirements) and no justification to introduce a floor finish requirement for industrial occupancies. _______________________________________________________________101-405 Log #301 SAF-IND FINAL ACTION: Accept in Principle in Part (40.3.3.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. / Rep. Carpet & Rug Institute COMMENT ON PROPOSAL NO: 101-652 RECOMMENDATION: Revise 40.3.3.3 to read: 40.3.3.3 Interior Floor Finish ( no requirements ) 40.3.3.3.1 Interior floor finish shall comply with Section 10.2 40.3.3.3.2 Interior floor finish in exit enclosures and in exit access corridors shall be not less than Class II 40.3.3.3.3 Interior finish shall comply with 10.2.7.1 or 10.2.7.2 as applicable. SUBSTANTIATION: Based on the original proposal, along with the TCC action, this proposal should be acepted as originally submitted. COMMITTEE MEETING ACTION: Accept in Principle in Part Revise 40.3.3.3 to read as follows: 40.3.3.3 Interior Floor Finish ( no requirements ) 40.3.3.3.1 Interior floor finish shall comply with Section 10.2 40.3.3.3. 2 1 Interior floor finish in exit enclosures and in exit access corridors shall be not less than Class II 40.3.3.3. 3 2 Interior floor finish in other areas shall not be required to comply with 10.2.7.1 or 10.2.7.2 as applicable section 10.2. COMMITTEE STATEMENT: SAF-IND does not intend that all floor coverings be regulated. Traditional floor covering have not been regulated in Industrial occupancies. Impact of the proposed change on Industrial floor coverings such as epoxy and other chemical reactant coatings is not unknown. Furthermore, the committee notes that no demonstrated hazard with the current requirements has been indicated. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 24 Negative: 1 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: HOLMES: The statement by the proponent not withstanding, the Association action in 1991, 1994, 1997, 2000, and 2003 for NFPA 101 upheld that Industrial Occupancies are exempt from floor finish requirements. The subject was deliberated by the TC in subsequent editions of the codes and the TC decided that there is no need to regulate floor finish in Industrial Occupancies. The statement in the codes that there are no requirements for floor finish in Industrial Occupancies was not inadvertent but purposeful. This was upheld by Association actions on previous editions of the code. For the type of spaces, type of hazards, and geometry of industrial facilities, floor finish is not a significant contributor the level of hazard or risk to occupants. The statement in 40.3.3.3 that there are no requirements for floor finish for Industrial Occupancies is not a change but is a continuation of a longstanding statement in the code. There is no justification to make the proposed change in the code to include floor finish requirements for Industrial Occupancies. As indicated in the Committee Substantiation in Comment 101-405, there is no demonstrated hazard with the current requirements (No Requirements) and no justification to introduce a floor finish requirement for industrial occupancies. COMMENT ON AFFIRMATIVE SHAPIRO: In addition to the reason shown for the committee action, it should also be noted that the comment was rejected because the format is confusing. The first section requires compliance with Section 10.2, then subsections require compliance with 10.2.7.1 or 10.2.7.2 as appropriate. Once compliance with the entirety of Section 10.2 is required, it is unclear why it should be necessary to subsequently reference individual subsections thereof.

_______________________________________________________________101-406 Log #85 SAF-IND FINAL ACTION: Accept in Principle (40.3.4 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Create a 40.7 to read: 40.7 Operating Features – Upholstered Furniture and Mattresses. The provisions of 10.3.2 shall not apply. The TCC action should meet the intent of SAF-IND which misunderstood the effect of Comment 101-175SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-653 RECOMMENDATION: (a) Give consideration, so as to make any needed changes, to deleting proposed 40.3.4 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. (b) Include future provisions for contents and furnishings either as part of the xx.3.3 or xx.7 sections. The xx.3.4 is reserved for alarms; xx.3.5 is for extinguishing systems, and xx.3.6 is for corridors so as to keep the numbering of the occupancy chapters consistent. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject proposal 101-653. COMMITTEE STATEMENT: Proposed 40.3.4 is not needed based upon action taken by SAF-FUR on comment 101-175. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-407 Log #390 SAF-IND FINAL ACTION: Reject (40.3.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-654 RECOMMENDATION: Accept Proposal 101-654. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: It is the committee’s understanding that section 9.6.2.5 was not deleted. In addition, it is the committee’s intent to require at least one manual fire alarm pull box. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-408 Log #304 SAF-IND FINAL ACTION: Accept in Principle (42.3.3.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Revise text as follows: 42.3.3.3 Interior Floor Finish. (No requirements.) 42.3.3.3.1 Interior Floor finish in exit enclosures shall be not less than Class II. 42.3.3.3.2 Interior floor finish in other areas shall not be required to comply with Section 10.2. 42.8.3.3.3 Interior Floor Finish. (No requirements.) 42.8.3.3.3.1 Interior Floor finish in exit enclosures shall be not less than Class II. 42.8.3.3.3.2 Interior floor finish in other areas shall not be required to comply with Section 10.2. The committee meeting action does not show for Chapter 42 any text change, and none would have automatically been created based on the committee meeting action having referenced Comment 101-405. The missing text has been added by the TCC.SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-659 RECOMMENDATION: Revise 42.3.3.3 to read: 42.3.3.3 Inerior Floor Finish ( no reqirements) 42.3.3.3.1 Interior floor finish shall comply with Section 10.2 43.3.3.3.2 Interior floor finish in exit enclosures and in exit access corridors shall be not less than Class II. 43.3.3.3.3 Interior finish shall comply with 10.2.7.1 or 10.2.7.2 as applicable. Revise 42.8.3.3.3 to read: 42.8.3.3.3 Interior Floor Finish ( no requirements)

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Report on Comments — Copyright, NFPA NFPA 101 42.8.3.3.3.1 Interior floor finish shall comply with Section 10.2 42.8.3.3.3.2 Interior floor finish in exit enclosures and in exit access corridors shall be not less than Class II 42.8.3.3.3.3 Interior finish shall comply with 10.2.7.1 or 10.2.7.2 as applicable SUBSTANTIATION: Based on the original proposal and the TCC action, there is no justification to reject the original proposal. COMMITTEE MEETING ACTION: Accept in Principle in Part See Committee Action to Comment 101-405. COMMITTEE STATEMENT: See Committee Action to Comment 101-405. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 24 Negative: 1 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: HOLMES: The statement by the proponent not withstanding, the Association action in 1991, 1994, 1997, 2000, and 2003 for NFPA 101 upheld that Storage Occupancies are exempt from floor finish requirements. The subject was deliberated by the TC in subsequent editions of the codes and the TC decided that there is no need to regulate floor finish in Storage Occupancies. The statement in the codes that there are no requirements for floor finish in Storage Occupancies was not inadvertent but purposeful. This was upheld by Association actions on previous editions of the code. For the type of spaces, type of hazards, and geometry of storage facilities, floor finish is not a significant contributor the level of hazard or risk to occupants. The statement in 42.3.3.3 that there are no requirements for floor finish for Storage Occupancies is not a change but is a continuation of a longstanding statement in the code. There is no justification to make the proposed change in the code to include floor finish requirements for Storage Occupancies. As indicated in the Committee Substantiation in Comment 101-405, there is no demonstrated hazard with the current requirements (No Requirements) and no justification to introduce a floor finish requirement for Storage Occupancies. COMMENT ON AFFIRMATIVE SHAPIRO: In addition to the reason shown for the committee action, it should also be noted that the comment was rejected because the format is confusing. The first section requires compliance with Section 10.2, then subsections require compliance with 10.2.7.1 or 10.2.7.2 as appropriate. Once compliance with the entirety of Section 10.2 is required, it is unclear why it should be necessary to subsequently reference individual subsections thereof.

_______________________________________________________________101-409 Log #86 SAF-IND FINAL ACTION: Accept in Principle (42.3.3.3 and 42.8.3.3.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – See TCC Note on Comment 101-408.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-659 RECOMMENDATION: Give consideration, to the submitter’s Substantiation, so as to make any needed changes: The proposal makes the industrial chapter of NFPA 101 consistent with NFPA 5000. It also corrects an error in NFPA 101. What is printed in the Code is technically wrong and misleading. Chapter 7 regulates the floor finish in exit enclosures and requires that they be Class I or Class II. By saying no requirements, it implies that the Industrial Occupancies chapter is overriding Chapter 7, but this has never been formally proposed or documented. There is no justification for it. With regard to 42.3.3.3.3 and 42.8.3.3.3 this makes it more user friendly. With the exception of the chapters written by the Mercantile and Business Committee and the Industrial and Storage Committee (NFPA 101 only) all other occupancy chapters use this format. It is important that the provisions for interior finish be consistent within the occupancy chapters so as to not imply that something different is intended. Although it could be argued as extraneous it is needed for consistency. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action to Comment 101-405. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-405 and 101-408. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 24 Negative: 1 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: HOLMES: The statement by the proponent not withstanding, the Association action in 1991, 1994, 1997, 2000, and 2003 for NFPA 101 upheld that Storage Occupancies are exempt from floor finish requirements. The subject was deliberated by the TC in subsequent editions of the codes and the TC decided that there is no need to regulate floor finish in Storage Occupancies. The statement in the codes that there are no requirements for floor finish in Storage Occupancies was not inadvertent but purposeful. This was upheld by Association actions on previous editions of the code. For the type of spaces, type of hazards, and geometry of storage facilities, floor finish is not a significant contributor the level of hazard or risk to occupants. The statement in 42.3.3.3 that there are no requirements for floor finish for Storage Occupancies is not a change but is a continuation of a longstanding

statement in the code. There is no justification to make the proposed change in the code to include floor finish requirements for Storage Occupancies. As indicated in the Committee Substantiation in Comment 101-405, there is no demonstrated hazard with the current requirements (No Requirements) and no justification to introduce a floor finish requirement for Storage Occupancies. _______________________________________________________________101-410 Log #87 SAF-IND FINAL ACTION: Accept in Principle (42.3.4 (New) ) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed to Accept in Principle – Create a 42.9 to read: 42.9 Operating Features – Upholstered Furniture and Mattresses. The provisions of 10.3.2 shall not apply. The TCC action should meet the intent of SAF-IND which misunderstood the effect of Comment 101-175.SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-660 RECOMMENDATION: (a) Give consideration, so as to make any needed changes, to deleting proposed 42.3.4 given the Rejection of Proposals 101-253, 101-260, 101-269, 101-274, and 101-331. (b) Include future provisions for contents and furnishings either as part of the xx.3.3 or xx.7 sections. The xx.3.4 is reserved for alarms; xx.3.5 is for extinguishing systems, and xx.3.6 is for corridors so as to keep the numbering of the occupancy chapters consistent. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject proposal 101-660. COMMITTEE STATEMENT: Proposed 42.3.4 is not needed based upon action taken by SAF-FUR on comment 101-175. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

_______________________________________________________________101-411 Log #391 SAF-IND FINAL ACTION: Reject (42.3.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-672 RECOMMENDATION: Accept Proposal 101-672. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: It is the committee’s understanding that section 9.6.2.5 was not deleted. In addition, it is the committee’s intent to require at least one manual fire alarm pull box. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-412 Log #88 SAF-IND FINAL ACTION: Accept in Principle (42.7) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-661 RECOMMENDATION: Give consideration to Allison’s Explanation of Negative, so as to make any needed changes. ALLISON: Grain handling, processing, milling and other bulk storage facilities will typically fall under the high hazard content category per 6.2.2.4 due to the combustible dust hazard. They would therefore require a maximum common path of travel of 25 ft. There is no justification provided that would support this to 50 ft. Section 7.11.4 allows 1 exit if: 200 sq ft or less; 3 people or less; and 25 ft or less travel distance to the door. The proposal violates this requirement with no technical justification. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle The committee gave consideration to the submitter’s recommendation and reaffirms its action of Accept-in-Principal on proposal 101-661. COMMITTEE STATEMENT: The proposed provisions of 42.7.4.1 only apply to normally unoccupied spaces. The committee does not believe that a decrease in travel distance would notably reduce the associated hazard. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 24 Negative: 1

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Report on Comments — Copyright, NFPA NFPA 101 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: ALLISON: The original proposal provided no justification for providing greater travel distances than normally required for similar high hazard situations. The areas in question could include the tunnel and catwalks under and above grain bins that typically get a layer of grain dust built up on equipment and structures. The proposal would permit a single means of egress if the travel distance is less than 50 ft and would only require a means of escape (not a qualified means of egress) as the second means of egress if the distance is greater. This places the occupants at greater risk. Grain dust is known to have the potential for a rapidly developing fire or explosion and is clearly a high hazard occupancy. Section 7.11.4 permits such areas to have a single exit only if the area is less than/equal to 200 sq ft, the occupant load is not greater than 3 persons, and the maximum travel is not greater than 25 ft. The Life Safety Code should not be driven to change, without providing historical justification or technical merit for the change, simply because NFPA 61 feels it is sufficient. Although the committee felt the areas in question are normally unoccupied, they are actually visited frequently by the occupants during operation of the facility and during routine maintenance/housekeeping activities and the occupants would be at no less risk while they are there.

_______________________________________________________________101-412a Log #CC479 SAF-IND FINAL ACTION: Accept in Principle (42.8.3) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) directs that the action be changed, per Holmes’ comment, to Accept in Principle – Replace 42.8.3.1 with the following: 42.8.3.1 Protection of Vertical Openings. 42.8.3.1.1 Vertical Openings in Enclosed Parking Structures. 42.8.3.1.1.1 Vertical openings through floors in buildings four stories or more in height shall be enclosed with walls or partitions having a fire resistance rating of not less than 2 hours. [88A: 4.6.1] 42.8.3.1.1 2 For buildings less than four stories, the walls or partitions required by 42.8.3.1.1.1 shall have a fire resistance rating of not less than 1 hour. [88A: 4.6.2] 42.8.3.1.1.3 Ramps in enclosed parking structures shall not be required to be enclosed when one of the following safeguards is provided: (1) An approved, automatic sprinkler system fully protecting the enclosed parking structure. [88A: 4.6.3] (2) An approved, automatic, supervised fire detection system installed throughout the enclosed parking structure, and a mechanical ventilation system capable of providing a minimum of 1 ft3/min per ft2 of floor area (300 L/min per m2 of floor area) during hours of normal operation. [88A: 4.6.4, 5.3.2] (3)* Where a parking structure consists of sprinklered enclosed parking levels, and sprinklered or non-sprinklered open parking levels. 42.8.3.1.1.4 Sprinkler systems provided in accordance with 42.8.3.1.1.3(1) or 42.8.3.1.1.3(3) shall be supervised in accordance with 9.7.2. 42.8.3.1.2 Open Parking Structures. Unprotected vertical openings through floors in open parking structures shall be permitted. [88A:4.7.4] A.42.8.3.1.1.3(3) It is common practice to construct a parking structure that consists of open parking levels aboveground meeting the opening requirements for an “open parking structure, but also having enclosed parking levels below grade that would need to comply with the requirements for an “enclosed parking structure”. It is impractical to have enclosed ramps between the enclosed level(s) and the open level(s) of such a parking structure. The TCC also notes that the new 42.8.3.1.1.4 requires electrical supervision as this is not a requirement of NFPA 88A.SUBMITTER: Technical Committee on Industrial, Storage, and Miscellaneous Occupancies COMMENT ON PROPOSAL NO: 101-667 RECOMMENDATION: 1. Revise 42.8.3 to read as follows: 42.8.3 Protection. 42.8.3.1 Protection of Vertical Openings. (A) Vertical openings through floors in buildings four stories or more in height shall be enclosed with walls or partitions having a fire resistance rating of not less than 2 hours. [88A:3.6] (B) For buildings less than four stories, such walls or partitions shall have a fire resistance rating of not less than 1 hour. [88A:3.6] (C) Ramps in enclosed parking structures shall not be required to be enclosed when an approved, automatic sprinkler system is provided throughout the enclosed parking structure, in accordance with Section 55.3 [88A:3.6, Exception, subpart (a) only] ( D) Ramps in enclosed parking structures shall not be required to be enclosed where the enclosed parking structure is protected throughout by an approved, supervised, automatic fire detection system, and a mechanical ventilation system in accordance with Chapter 50 that is capable of providing a minimum of 1 ft3 /min per ft2 of floor area (300 L/min per m2 of floor area) during hours of normal operation. [88A:5.3.2] (E) *Ramps shall not be required to be enclosed where a parking structure consists of sprinklered enclosed parking levels, and sprinklered or non-sprinklered open parking levels. 42.8.3.1.2 Open Parking Structures. Unprotected vertical openings through floors in open parking structures shall be permitted [88A:4.7.4]

2. Add new annex material to read as follows: A.42.8.3.1(E). It is common practice to construct a parking structure that consists of open parking levels aboveground meeting the opening requirements for an “open parking structure”, but also having enclosed parking levels below grade that would need to comply with the requirements for an “enclosed parking structure”. It is impractical to have enclosed ramps between the enclosed level(s) and the open level(s) of such a parking structure. SUBSTANTIATION: This action provides for coordination with NFPA 88A with regard to enclosed and open parking structures. A companion comment has been submitted to NFPA 5000. See comment 5000-568. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 23 Negative: 2 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN EXPLANATION OF NEGATIVE: FLUER: The comments from Mr. Humble as indicated in an email sent by M. Puchovsky of January 4, 2005 should be used. I am in favor of using the wording as suggested by Mr. Humble. HOLMES: Based on the circulation of ballots for the SAF-IND ROC ballot, please change my vote to NEGATIVE with the following comment: The original SAF-IND ROC ballot contained an inadvertent transcription error that resulted in the incorrect committee meeting action being balloted. Jonathan Humble’s Comment on Affirmative, while correcting formatting errors, also failed to capture the correct action or intent of action taken at the SAF-IND ROC meeting. It was the intent of SAF/BLD-IND to take the same action on 101-42.8.3.1, Protection of Vertical Openings, (Comment 101-412a) in NFPA 101 as the same committee did on 5000-30.8.3.1, Protection of Vertical Openings (Comment 5000-842) in NFPA 5000. It was proposed in NFPA 5000 to require both fire detection AND mechanical ventilation for unenclosed ramps in enclosed parking structures. To correlate with NFPA 5000, it was the committee’s intent to have the same requirements in 101-42.8.3.1.1 3 (2). Neither the original ballot nor Humble’s Comment on Affirmative captured this intent. As proposed by the committee at its ROC meeting, the proposed 42.8.3.1.1.3 (2) should read: “(2) An approved, automatic, supervised fire detection system installed throughout the enclosed parking structure using detectors sensing products of combustion other than heat and mechanical ventilation system, and a mechanical ventilation system capable of providing a minimum of 300 L/min per m2 of floor area (1 ft3/min per ft2 of floor area) during hours of normal operation. [88A: 4.6.4]” The Technical Correlating Committee on Safety to Life should consider this correction to correct an error in the ROC ballot and to correlate with a similar action taken by the same technical committee (SAF/BLD-IND) on this same issue in NFPA 5000. COMMENT ON AFFIRMATIVE HUMBLE: The published 101-412a (Log #CC479) is not printed as was voted on at the SAF-IND ROC meeting held on 10 November 2004 in San Diego, CA. Apparently what has happened is that the proposal for NFPA 5000 (5000-568 (Log #151)) was re-printed as the ballot item 101-412a. Therefore, the proposal should read as that voted by the committee, and which is consistent with NFPA 101 format, which is shown below: 42.8.3 Protection. 42.8.3.1 Protection of Vertical Openings. 42.8.3.1.1 Vertical Openings in Enclosed Parking Structures. 42.8.3.1.1.1 Vertical openings through floors in buildings four stories or more in height shall be enclosed with walls or partitions having a fire resistance rating of not less than 2 hours. 42.8.3.1.1.2 For buildings less than four stories, the walls or partitions required by 42.8.3.1.1.1 shall have a fire resistance rating of not less than 1 hour. 42.8.3.1.1.3 Ramps in enclosed parking structures shall not be required to be enclosed when either one of the following safeguards is provided: (1) An approved, automatic sprinkler system fully protecting the enclosed parking structure. (2) An approved, automatic, supervised fire detection system installed throughout the enclosed parking structure using detectors sensing products of combustion other than heat and mechanical ventilation system. (3) * Where a parking structure consists of sprinklered enclosed parking levels, and sprinklered or non-sprinklered open parking levels. 42.8.3.1.2 Open Parking Structures. Unprotected vertical openings through floors in open parking structures shall be permitted [88A:4.7.4]. (Add new annex note) 42.8.3.1.1.3(3). It is common practice to construct a parking structure that consists of open parking levels aboveground meeting the opening requirements for an “open parking structure”, but also having enclosed parking levels below grade that would need to comply with the requirements for an “enclosed parking structure”. It is impractical to have enclosed ramps between the enclosed level(s) and the open level(s) of such a parking structure. Upon recirculation Mr. Humble provided the following comments: My original “accept with comment” was directed at establishing the proposal as read, and voted on, by the BLD/SAF-IND committee at the TC meeting on

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Report on Comments — Copyright, NFPA NFPA 101 10 November 2004. Subsequent to that I have found an error to the original task group proposal. Vacant are the ventilation requirements that should read identical for all three documents (e.g. NFPA 5000, NFPA 101, and NFPA 88A). Therefore, Section 42.8.3.1.1.3 (2) should read, or have read, as follows: “(2) An approved, automatic, supervised fire detection system installed throughout the enclosed parking structure using detectors sensing products of combustion other than heat and mechanical ventilation system, and a mechanical ventilation system capable of providing a minimum of 300 L/min per m 2 of floor area (1 ft 3 /min per ft 2 of floor area) during hours of normal operation. [88A: 4.6.4]” I would therefore respectfully submit to the NFPA 101 Technical Correlating Committee that they act to correct the error in order to establish consistency with the three NFPA documents. KRANTZ: I agree with the correct wording for Proposal 101-412a as indicated in Jonathan Humble’s affirmative comment. _______________________________________________________________101-413 Log #392 SAF-IND FINAL ACTION: Reject (42.8.3.4.2) _______________________________________________________________ SUBMITTER: J. Jeffrey Moore, Hughes Associates, Inc. COMMENT ON PROPOSAL NO: 101-668 RECOMMENDATION: Accept Proposal 101-668. SUBSTANTIATION: This comment is based on the work of a task group of the Technical Committee on Protected Premises Fire Alarm Systems. The requirement in NFPA 72, 6.8.5.1.2 for a single manual fire alarm box is a performance requirements of this Standard to provide a manual means to activate the system, regardless of the occupancy classification of the protected premise. This is to provide a means to activate the alarm should the system be down for testing or maintenance. This requirement is within the purview of the Signaling Systems for the Protection of Life and Property project. The original proposal was sent to the technical committee as part of the Standards Council directive to all technical committees regarding scoping between NFPA 101 and other NFPA codes and standards. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: It is the committee’s understanding that section 9.6.2.5 was not deleted. In addition, it is the committee’s intent to require at least one manual fire alarm pull box. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-414 Log #364 SAF-FUN FINAL ACTION: Reject (Chapter 43) _______________________________________________________________ SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Reject the new Chapter 43. SUBSTANTIATION: Although a Chapter 43 may be appropriate for a building code, it is not for the Life Safety Code. The Life Safety Code addresses the requirements for both existing and new buildings. This in itself provides guidance for rehabilitation work. If Chapter 43 is included in the Life Safety Code, it will result in three different levels of protection, new, existing and rehabilitation. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The NFPA 5000 building code has its Chapter 15 on existing building rehabilitation. NFPA 101 Chapter 43 is needed so the existing building rehabilitation requirements are better coordinated between NFPA 1 UFC and NFPA 5000. It will help the C3 codes set to work together. The requirements for existing buildings are applied to existing situations where no rehabilitation is taking place. Such requirements are reasonable given the situation already exists. The requirements for new construction are reasonable because they apply at the time of initial construction when it is feasible to meet such requirements. The Code currently requires rehabilitation to be performed per the requirements for new construction and this is not easily done. It is too much of a penalty that operators of existing buildings choose instead not to perform any rehabilitation. Yet, if they choose to rehabilitate a building, it is fair for the Code to force the building features to be modified to meet requirements that are somewhere between those for new buildings and those for existing situations. Note that proposed 43.1.2.1 sets a baseline where the building undergoing rehabilitation must meet the requirements of the applicable existing occupancy chapter and the specialized requirements of Chapter 43. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 20 Negative: 1 BALLOT NOT RETURNED: 2 ALLEN, WATTS EXPLANATION OF NEGATIVE: CARSON: Chapter 43 is appropriate for the Building Code but not for NFPA 101. Including Chapter 43 now provides a third level of protection in addition to the traditional new and existing levels of protection provided in the code. Existing Section 1.4 allows equivalency and has worked well in the past for historic buildings and renovations. In addition, section 4.6.8 recognizes

the potential problems with renovation and permits alternatives. Also, 4.6.3 specifically addresses historic buildings. The “scope” of this proposed new chapter states that it applies to “buildings identified and classified as historic”. What about the renovation of old buildings that have not been classified as “historic”, which there are many. This new Chapter allows considerable weakening of the egress provisions and presents confusion in the application of requirements such as: 1. Section 43.5.3.2 requires that where the renovation work area exceeds 50 percent of the total area of the building it must comply with this section. If it is less than 50 percent it than complies with existing provisions. This in reality provides two different layers of protection for “historic’ buildings without justification. 2. Section 43.6.2.2(1) allowing a basically unenforceable provision on limiting occupant load. 3. Section 43.6.2.4.2 could be interpreted to mean that if the rehabilitation is less than 50 percent, no work needs to be performed, not even meeting requirements for existing. 4. Section 43.6.4.1 again provides two different levels of protection for buildings undergoing renovation. This section could conflict with requirements for sprinklers in new construction such as 28.3.5 where the renovation is less than 50 percent of the building area. This new section is not needed in the Life Safety Code, and at best is not ready for “prime time”. _______________________________________________________________101-415 Log #175 SAF-FUN FINAL ACTION: Accept (43.1.2.1) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: In part (2) change the first reference to Section 43.4 to read 43.3. (2) the requirements of the applicable section of this chapter. (See Sections 43. 4 3, 43.4, 43.5, and 43.6). SUBSTANTIATION: Editorial error. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-415a Log #CC7 SAF-FUN FINAL ACTION: Accept (43.1.2.5) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Insert a new 43.1.2.5 as follows: 43.1.2.5 Nothing in this chapter shall be interpreted as excluding the use of the performance-based option of Chapter 5. SUBSTANTIATION: Clarification that the performance-based option of Chapter 5 can be utilized in rehabilitation projects. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-415b Log #CC8 SAF-FUN FINAL ACTION: Accept (43.2.2.1.2 and 43.2.2.1.3) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.2.2.1.2 Renovation. Renovation shall be defined as the replacement in kind change, or strengthening or addition of load bearing elements; or the refinishing, replacement, bracing, strengthening, upgrading of existing materials, elements, equipment or fixtures; all without involving the reconfiguration of spaces. 43.2.2.1.3 Modification. Modification shall be defined as the reconfiguration of any space; the addition, relocation or elimination of any door or window; the addition or elimination of load bearing elements; the reconfiguration or extension of any system; or the installation of any additional equipment. SUBSTANTIATION: For renovation work, the only changes to load bearing elements should be replacement in kind. Under renovation, no other system can be changed or added to, so this is comparable with the requirements for these other systems. The addition or elimination of load bearing elements should be categorized as a modification, and not a renovation. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-415c Log #CC2 SAF-FUN FINAL ACTION: Accept (43.3.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.3.1.1 Repairs, as defined in 43.2.2.1.1, in other than historic buildings shall comply with the requirements of Section 43.3, except as otherwise specified in Section 43.9 for historic buildings. 43.3.1.2 Repairs in historic buildings shall comply with the requirements of one of the following: (1) Section 43.3 (2) Section 43.3 as modified by Section 43.10 43.3.1.3 43.3.1.2 The work shall be done using like materials, or materials permitted by other sections of this Code. 43.3.1.4 43.3.1.3 The work shall not make the building less conforming with the other sections of this Code or with any previously approved alternative arrangements, than it was before the repair was undertaken. SUBSTANTIATION: Clarification of intent so as to use language more easily understood. Note that the reference to Section 43.10 is meant to be the renumbered section on historic buildings which in the ROP appeared as Section 43.9. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-415d Log #CC3 SAF-FUN FINAL ACTION: Accept (43.4.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.4.1.1 Renovations, as defined in 43.2.2.1.2, in other than historic buildings shall comply with the requirements of Section 43.4, except as otherwise specified in Section 43.9 for historic buildings. 43.4.1.2 Renovations in historic buildings shall comply with the requirements of one of the following: (1) Section 43.4 (2) Section 43.4 as modified by Section 43.10 43.4.1.3 43.4.1.2 All new work shall comply with the requirements of this Code applicable to existing buildings. 43.4.1.4 43.4.1.3 The work shall not make the building less conforming with other sections of this Code, or with any previous approved alternative arrangements, than it was before the renovation was undertaken unless otherwise specified in 43.4.1.5 43.4.1.4. 43.4.1.5 43.4.1.4 Minor reductions in the clear opening dimensions of replacement doors and windows that result from the use of different materials shall be allowed, unless such reductions are prohibited. SUBSTANTIATION: Clarification of intent so as to use language more easily understood. Note that the reference to Section 43.10 is meant to be the renumbered section on historic buildings which in the ROP appeared as Section 43.9. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-416 Log #176 SAF-FUN FINAL ACTION: Accept (43.4.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Add a new paragraph to read: 43.4.3 The reconfiguration or extension of any system, or the installation of any additional equipment shall comply with Section 43.5. SUBSTANTIATION: The definition of renovation appears to include installations of new building equipment as long as the space involved is not reconfigured. However, this is covered under Modification. To help prevent confusion this paragraph will clearly send the user to Modification. This wording is directly from 43.2.2.1.2, the definition of Renovation. The Life Safety Code has required for decades that the installations of new equipment comply with the requirements for new, to the extent practical. There has been no technical justification given for eliminating this requirement. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

_______________________________________________________________101-416a Log #CC4 SAF-FUN FINAL ACTION: Accept (43.5.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.5.1.1 Modifications, as defined in 43.2.2.1.3, in other than historic buildings shall comply with both of the following: (1) the requirements of Section 43.5, except as otherwise specified in Section 43.9 for historic buildings (2) the requirements of Section 43.4 43.5.1.2 Modifications in historic buildings shall comply with the requirements of one of the following: (1) 43.5.1.1(1) and (2) (2) 43.5.1.1(1) and (2) as modified by Section 43.10 43.5.1.3 43.5.1.2 Newly constructed elements, components and systems shall comply with the requirements of other sections of this Code applicable to new construction. SUBSTANTIATION: Clarification of intent so as to use language more easily understood. Note that the reference to Section 43.10 is meant to be the renumbered section on historic buildings which in the ROP appeared as Section 43.9. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-416b Log #CC5 SAF-FUN FINAL ACTION: Accept (43.6.1) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.6.1.1 Reconstruction work, as defined in 43.2.2.1.4, in other than historic buildings shall comply with all of the following: (1) the requirements of Section 43.6, except as otherwise specified in Section 43.9 for historic buildings (2) the requirements Section 43.5, except that any stairway replacing an existing stairway shall be permitted to comply with 7.2.2.2.1(3). (3) the requirements of Section 43.4 43.6.1.2 Reconstruction work in historic buildings shall comply with the requirements of one of the following: (1) 43.6.1.1(1), (2) and (3) (2) 43.6.1.1(1), (2) and (3) as modified by Section 43.10 43.6.1.3 43.6.1.2 Wherever the term “rehabilitation work area” is used in Section 43.6, it shall include only the area affected by reconstruction work, and areas covered by 43.5.2. 43.6.1.4 43.6.1.3 Other rehabilitation work areas affected exclusively by renovation or modification work shall not be included in the rehabilitation work area required to comply with Section 43.6. SUBSTANTIATION: Clarification of intent so as to use language more easily understood. Note that the reference to Section 43.10 is meant to be the renumbered section on historic buildings which in the ROP appeared as Section 43.9. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-417 Log #178 SAF-FUN FINAL ACTION: Accept in Principle (43.6.2.6.3) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise text to read as follows: 43.6.2.6.3 Exit s S tair way s with a required egress width of more than 6 5 6 in. ( 1680 mm) shall have handrails on both sides. SUBSTANTIATION: The Life Safety Code requires a handrail within 44 in. reach at any point in the required width in existing buildings. If a stair is greater than 56 in. wide you can not reach a handrail within 44 in. This applies to all stairs in the means of egress, not just exit stairs. COMMITTEE MEETING ACTION: Accept in Principle Delete 43.6.2.6.3. COMMITTEE STATEMENT: Paragraph 43.1.2.1(1) requires the building undergoing rehabilitation to meet the requirements of the applicable existing occupancy chapter. The 56-in. criterion (that is, 44 in. plus two 4 1/2 in. encroachments for handrails) proposed by the submitter is already a requirement applicable to the existing building. It need not be restated. The 66-in. criterion proposed in the ROP would permit the building to be less compliant than an existing building not undergoing rehabilitation and that would violate the requirement of 43.1.2.1(1). So, the provision needs to be deleted.

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Report on Comments — Copyright, NFPA NFPA 101 NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-418 Log #174 SAF-FUN FINAL ACTION: Accept in Principle (43.6.4.2 (New) ) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Add a new paragraph to read: 43.6.4.2 On any story with rehabilitation work areas involving over 50 percent of the area of the story, a sprinkler system shall be provided throughout the story in accordance with the requirements of other sections of this Code applicable to new construction for the occupancy. (See Chapters 12, 14, 18, 20, 22, 24, 26, 28, 30, 32, 36, 38, 40, and 42). SUBSTANTIATION: The provisions of 43.6.4.1 can be easily avoided by staging reconstruction work. This would at least mandate a story by story installation of sprinklers where such would be required for new construction. With 43.6.4.1 a large building could have extensive reconstruction without providing automatic sprinklers, even though they are required in new construction. COMMITTEE MEETING ACTION: Accept in Principle Add the commenter’s first sentence, but not the second sentence as follows: 43.6.4.2 On any story with rehabilitation work areas involving over 50 percent of the area of the story, a sprinkler system shall be provided throughout the story in accordance with the requirements of other sections of this Code applicable to new construction for the occupancy. COMMITTEE STATEMENT: The committee action adopts the technical portion of the commenter’s recommendation. The parenthetical reference sentence does not fit the format used in Section 43.6. Introduction here would create inconsistency with paragraphs 43.6.2.3, 43.6.2.4.1, 43.6.2.4.2, 43.6.2.4.3, 43.6.2.4.4, 43.6.2.5.1, 43.6.2.5.2, and 7 other occurrences. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-419 Log #177 SAF-FUN FINAL ACTION: Accept in Principle (43.6.5.1.2) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise 43.6.5.1.2 as follows: 43.6.5.1.2 Where the rehabilitation work area is in residential board and care occupancies and one- and two-family dwellings, smoke alarms complying with the requirements of other sections of this Code applicable to new construction for the occupancy, shall be provided throughout the dwelling unit at each level and outside each sleeping area. SUBSTANTIATION: The Code requires more than just every level and outside each sleeping area in new construction and therefore just referring back to the requirements for new construction would be clearer and more accurate. COMMITTEE MEETING ACTION: Accept in Principle Revise 43.6.5.1.2 as follows: 43.6.5.1.2 Where the rehabilitation work area is located in residential board and care occupancies or and one- and two-family dwellings dwelling units, smoke alarms complying with the requirements of other sections of this Code applicable to new construction for the occupancy, occupancy shall be provided throughout the dwelling unit at each level and outside each sleeping area. COMMITTEE STATEMENT: The committee action does what the submitter requested, but also editorially revises the sentence for correlation with the draft of Chapter 43 prepared by NFPA staff after the ROP was published. The action by SAF-FUN also deletes the words “throughout the dwelling unit” because the phrase confuses rather than clarifies. The smoke alarm installation details are found elsewhere, not in Chapter 43. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-420 Log #179 SAF-FUN FINAL ACTION: Accept (43.6.6) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise 43.6.6 as follows: 43.6.6 Elevators. 43.6.6.1 Elevators shall be provided with Phase I and Phase II emergency operations in accordance with 9.4.3.2. 43.6.6.2 Elevators iIn Hhigh-Rrise Bbuildings., Wwhere the rehabilitation work area is one entire floor or where the rehabilitation work area is 20 percent or more of the occupied floor area of the building, the elevators in the building shall be equipped with the following emergency control devices in accordance with ASME A17.1, Safety Code for Elevators and Escalators.

(1) Automatic, NON-designated attendant elevators having a travel of 25 ft (7.6 m) or more above or below the designated level shall be equipped with Phase I Emergency Recall Operations. (2) A a ll floors shall be accessible by at least one elevator equipped with Phase I Emergency Recall Operation. (3) Designated attendant elevators having a travel of 25 ft (7.6 m) or more above or below the designated level shall be equipped with emergency controls. SUBSTANTIATION: The Life Safety Code requires, and has required this for almost two decades, that all elevators in existing buildings, regardless or rehabilitation, have Phase I and Phase II fire fighter service when the elevators travel 25 ft above or below the designated level. NO justification has been provided to reduce this requirement due to rehabilitation. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-420a Log #CC6 SAF-FUN FINAL ACTION: Accept (43.7.2) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise as follows: 43.7.2 Change of Occupancy. Where the occupancy classification of an existing building or portion of an existing building is changed in other than historic buildings, the building shall meet the requirements of 43.7.2.1 or 43.7.2.2, except as otherwise provided in 43.7.2.5 43.7.2.3. 43.7.2.1 Where a change of occupancy classification occurs within the same hazard classification category or to an occupancy classification in a lesser hazard classification category (that is, a higher number) as addressed by Table 43.7.3.1, the building shall meet both of the following: (1) the requirements of the applicable existing occupancy chapters for the occupancy created by the change. (See Chapters 13, 15, 17, 19, 21, 23, 24, 26, 29, 31, 33, 37, 39, 40 and 42.) (2) any automatic sprinkler requirements applicable to new construction for the occupancy created by the change. (See Chapters 12, 14, 16, 18, 20, 22, 24, 26, 28, 30, 32, 36, 38, 40 and 42.) 43.7.2.2 Where a change of occupancy classification occurs to an occupancy classification in a higher hazard classification category (that is, a lower number) as addressed by Table 43.7.3.1, the building shall comply with the requirements of the occupancy chapters applicable to new construction for the occupancy created by the change. (See Chapters 12, 14, 16, 18, 20, 22, 24, 26, 28, 30, 32, 36, 38, 40 and 42.) 43.7.2.3 In historic buildings where a change of occupancy classification occurs within the same hazard classification category or to an occupancy classification in a lesser hazard classification category (that is, a higher number) as addressed by Table 43.7.3.1, the building shall meet the requirements one of the following: (1) 43.7.2.1(1) and (2) (2) 43.7.2.1(1) and (2) as modified by Section 43.10 43.7.2.4 In historic buildings where a change of occupancy classification occurs to an occupancy classification in a higher hazard classification category (that is, a lower number) as addressed by Table 43.7.3.1, the building shall meet the requirements one of the following: (1) 43.7.2.2 (2) 43.7.2.2 as modified by Section 43.10 43.7.2.5 43.7.2.3 Portions of the building in which the occupancy classification is not changed shall be permitted to comply with the requirements of the applicable existing occupancy chapters provided one of the following is met: (1) the occupancies are separated as required by 6.1.14.4 (2) the occupancies are separated via approved compliance alternatives SUBSTANTIATION: Clarification of intent so as to use language more easily understood. Note that the reference to Section 43.10 is meant to be the renumbered section on historic buildings which in the ROP appeared as Section 43.9. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-421 Log #173 SAF-FUN FINAL ACTION: Accept (43.7.2.1) _______________________________________________________________ SUBMITTER: James K. Lathrop, Koffel Assoc., Inc. COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: Revise 43.7.2.1(2) as follows: (2) any automatic sprinkler and detection, alarm and communication system requirements applicable to new construction... (no further changes) SUBSTANTIATION: Although 43.6.5 addresses smoke alarms in residential occupancies, there are many fire alarm system features that are critical. This section would apply to a mercantile changed to a residential or to an assembly

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Report on Comments — Copyright, NFPA NFPA 101 or educational occupancy. Due to this the fire alarm system requirements for new should be required. This has been required by the Life Safety Code for decades and no justification has been provided to eliminate it. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-421a Log #CC1 SAF-FUN FINAL ACTION: Accept (43.9 (New) ) _______________________________________________________________ SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-70 RECOMMENDATION: 1. Insert a new Section 43.9 as follows: Section 43.9 (Reserved) 2. Renumber Section 43.9 to become Section 43.10 as follows: - Section 43.9 43.10 Historic Buildings - Change paragraph numbers and text references from 43.9 to 43.10 as needed throughout new Section 43.10. 3. Revise 43.1.2.4 as follows: 43.1.2.4 Historic buildings undergoing rehabilitation shall comply with the requirements of Section 43.9 43.10. SUBSTANTIATION: NFPA 5000 Chapter 15 is being revised to insert a new Section 15.9 on damaged or unsafe buildings. A corresponding section in NFPA 101 is not needed. However, for consistency in numbering, the Historic Buildings section should be section x.10 in both NFPA 5000 and NFPA 101. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-422 Log #89 SAF-FUN FINAL ACTION: Accept in Principle (A.1.3) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-672A RECOMMENDATION: Give consideration to the proposal so as to make any needed changes given the TCC developed the proposal after FUN had completed its ROP. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle See action on Comment 101-424. COMMITTEE STATEMENT: The action on the referenced comment should meet the submitter’s intent. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-423 Log #271 SAF-FUN FINAL ACTION: Reject (A.1.3) _______________________________________________________________ SUBMITTER: Eugene A. Cable, U.S. Department of Veterans Affairs COMMENT ON PROPOSAL NO: 101-672A RECOMMENDATION: (Reject proposal to delete first paragraph) Revert to 2003 Code language. SUBSTANTIATION: A.1.3 was my proposal as a Committee Alternate member for the 1997 Code. The Fundamentals Committee labored over the concept of new vs. existing and placed this in the Code Annex in 1997 for very good reason. Without this paragraph the overriding Code intent to maintain features once they are installed according to the NEW chapter could be lost. Many users see the Existing Chapter as the only Chapter to apply when inspecting an existing building. If it was constructed according to the 1991 Code than those features should be maintained. For example, 1991 requires sprinklers in New Health Care space, the 2003 Code for existing does not. If one inspects the building according to the 2003 Existing Chapter alone, you might miss the important problem that a section of the new construction is not sprinkler protected. My. Jay Woodward, committee member at the time representing ICBO, said it best “without this statement somewhere in the Code we have relegated the Life Safety Code to an “EXISTING BUILDINGS CODE”. I HOPE THAT IS NOT THE INTENT. Without this statement, clearly giving intent that a building built new must stay in compliance with new, the features could slowly degrade to the safety level as required for existing. Other action is need to fix the problem as described in Committee Action. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The deletion of the annex paragraph, as proposed in the ROP, remains appropriate as the text confuses more than helps. See new 4.6.8.4 and retained 4.6.8.5 as shown in Proposal 101-70 in the ROP which provide guidance to the user on the concept promoted by the submitter. Also, see action on Comment 101-424 which relocates the remaining annex text so as to help clarify the issue. NUMBER ELIGIBLE TO VOTE: 23

BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-424 Log #367 SAF-FUN FINAL ACTION: Accept in Principle (A.1.3) _______________________________________________________________ SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-672A RECOMMENDATION: Accept the TCC proposal to delete the first paragraph of A.1.3. SUBSTANTIATION: The American Health Care Association is the national trade association for nursing homes. On September 11, 2003, all 17,000 existing nursing homes in the United States were required to comply with the 2000 Life Safety Code (LSC). The language in Section A.1.3 is also in the 200 LSC. The language in both the 2000 and 2003 editions are either being misinterpreted or misused by the states. In addition to the example cited by the T.C.C in its substantiation, there are other examples. The one that most concerns the nursing home industry has to do with retrofitting sprinklers into existing nursing homes. The nursing home industry submitted a proposal to mandate sprinklers in all existing nursing homes. In the next few years, 2500 existing nursing homes will have sprinklers retrofitted. This is a very positive life safety improvement. However, the industry is being told in some states that the language in A.1.3 would not allow the facilities to take the tradeoffs for sprinkles, e.g., the one-hour rated corridor partitions must be maintained because it was required by previous editions of the code. This is true for the 1967 edition, which required a one-hour rated corridor wall even in a sprinkled building. Approximately 43 percent of existing nursing homes complied prior to September 11, 2003, with the 1967 edition. Without going into a lot of details, the cited example would require the owner of an existing building in which sprinklers were retrofitted to provide a higher level of safety in the 2003 and 2006 Codes than would be required for a new building. Because the requirements in the LSC for existing buildings do change over time, if we allow the states to misinterpret the intent of the Life Safety Code, we would end up with existing buildings being required to comply with a composite of the most restrictive requirements in the Code for the current edition and all previous editions. This is absurd. If the SAF-FUN does not accept deletion of the first paragraph, please at least change the language to provide relief to those industries that have the LSC retroactively applied. COMMITTEE MEETING ACTION: Accept in Principle 1. Retain the acceptance of Proposal 101-672a which deletes the first paragraph of A.1.3. 2. Move the remaining, second paragraph of A.1.3 to the A.4.6.8.4 shown in Proposal 101-70 as follows: A.4.6.8.4 In some cases, the requirements for new construction are less restrictive, and it might be justified to permit an existing building to use the less restrictive requirements. However, extreme care needs to be exercised when granting such permission, because the less restrictive provision might be the result of a new requirement elsewhere in the Code. For example, in editions of the Code prior to 1991, corridors in new health care occupancies were required to have a 1-hour fire resistance rating. Since 1991, these corridors have been required only to resist the passage of smoke. However, this provision is based on the new requirement that all new health care facilities be protected throughout by automatic sprinklers. See A.4.6.8.5. COMMITTEE STATEMENT: The deletion of the annex paragraph, as proposed in the ROP, remains appropriate as the text confuses more than helps. The repostioning of the remaining annex text will make it easier for the user to find it in relation to the new 4.6.8.4 being added by Proposal 101-70. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-425 Log #90 SAF-MER FINAL ACTION: Accept in Principle (A.3.3.27.9 Mall Building) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-673 RECOMMENDATION: Give consideration to Thornberry’s Explanation of Abstention, so as to make any needed changes. THORNBERRY: I have voted to abstain on the following proposals: 101-28 (Log #CP1508), 101-43 (Log #CP1518), 101-601 (Log #202), 101-606 (Log #CP1516), 101-609 (Log #CP1515), 101-615 (Log #435), and 101-673 (Log #CP1511). I am required to abstain based on the NFPA rules for operating technical committees since I am classified as a special expert and have client interests in those particular proposals. As indicated above, I have voted to abstain on this proposal. However, if I could vote, I would vote to reject this Committee Proposal which greatly expands the definition of mall buildings by including transportation facilities.

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Report on Comments — Copyright, NFPA NFPA 101 No technical justification was provided to include transportation facilities as part of the mall building concept. This is especially critical regarding exiting arrangements which are based on more traditional malls where surveys were conducted of various mall building sites around the country to determine a method for calculating occupant load. Those traditional malls did not contain transportation facilities which could significantly alter the occupant load determination if incorporated in mall buildings. Transportation facilities should not be allowed in mall buildings until such time as adequate egress studies, as well as other fire and life safety related evaluations, have been conducted to determine if, in fact, they would be suitable in mall buildings without challenging or reducing the level of fire and life safety provided by the mall building provisions of this code. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Do not accept the proposed revisions to the annex material for the term mall building as indicated in proposal 101-673. Instead, revise the annex material in the existing code to read as follows: A.3.3.27.9 Mall Building. A mall building may enclose one or more uses such as retail and wholesale stores, drinking and dining establishments, entertainment and amusement facilities, transportation facilities, offices and other similar uses. COMMITTEE STATEMENT: This better satisfies the committee’s intent with regard to mall buildings. Wholesale stores and dining establishments were added for completeness. The addition of the term “transportation facilities” is consistent with the committee statement provided in the ROP on proposal 101-673. Also see committee action on comment 101-426. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 13 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA recognizes the concerns raised by Mr. Thornberry regarding the potential fire and life safety impacts (e.g., occupant loading and means of egress) resulting from the inclusion of transportation facilities in mall buildings and is in support of Mr. Thornberry’s recommendation for egress studies to be conducted to address these concerns. EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment, I would vote negative to reject the Committee Action to revise the definition for “Mall Building” to expand it to include transportation facilities. Please see my additional comments on Comment 101-426. _______________________________________________________________101-426 Log #269 SAF-MER FINAL ACTION: Accept in Principle in Part (A.3.3.27.9 Mall Building) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-673 RECOMMENDATION: Revise text to read as follows: A.3.3.27.9 Mall Building. Mall buildings are occupied primarily by mercantile occupancies. However, they can include other occupancies such as drinking and dining establishments, entertainment and amusement facilities, offices, transportation facilities, and occupancies with similar uses that are incidental to the primary use of the building. A mall building may enclose one or more uses, such as retail stores, drinking establishments, entertainment and amusement facilities, offices, and other uses. SUBSTANTIATION: This Committee Proposal greatly expands the definition of mall building by including transportation facilities. No technical justification was provided to include transportation facilities as part of the mall building concept. This is especially critical regarding exiting arrangements which are based on more traditional malls where surveys were conducted of various mall building sites around the country to determine a method for calculating occupant load. Those traditional malls did not contain transportation facilities which could significantly alter the occupant load determination if incorporated in mall buildings. Transportation facilities should not be allowed in mall buildings until such time as adequate egress studies, as well as other fire and life safety related evaluations, have been conducted to determine if, in fact, they would be suitable in mall buildings without challenging or reducing the level of fire and life safety provided by the mall buildings provisions of this code. COMMITTEE MEETING ACTION: Accept in Principle in Part See Committee Action on Comment 101-425. COMMITTEE STATEMENT: The committee believes that transportation facilities posses many of the characteristics and hazards associated with traditional mall buildings. Also see Committee Statement on Comment 101-425. NUMBER ELIGIBLE TO VOTE: 21

BALLOT RESULTS: Affirmative: 13 Negative: 1 Abstain: 1 BALLOT NOT RETURNED: 6 BOCCI, DODGE, FRANCIS, MARTIN, MOON, TOMES EXPLANATION OF NEGATIVE: GAUVIN: NEMA recognizes the concerns raised by Mr. Thornberry regarding the potential fire and life safety impacts (e.g., occupant loading and means of egress) resulting from the inclusion of transportation facilities in mall buildings and is in support of Mr. Thornberry’s recommendation for egress studies to be conducted to address these concerns. EXPLANATION OF ABSTENTION: THORNBERRY: I have voted to abstain on the this Comment since I am a special expert on the Technical Committee and I have clients who may have specific interest in this Comment. Therefore, I am required by the NFPA Regulations Governing Committee Projects to abstain from voting. I also would like to offer the following comment: If I were allowed to vote on this Comment which I submitted on behalf of one of my clients, the Alliance for Fire and Smoke Containment and Control (AFSCC), I would vote to accept the Comment as originally submitted with an editorial correction. Please note that the editorial correction should show the entire first and second sentences lined through so that they are deleted in their entirety, Thus, the Annex note to “Mall Building” would read as follows: “A mall building may enclose one or more uses, such as retail stores, drinking establishments, entertainment and amusement facilities, offices, and other similar uses.” My main concern is with the Committee indicating that transportation facilities are suitable occupancies within mall buildings. The substantiation provided for the Public Comment clearly indicates why this is a problem, Thus, transportation facilities should not be included as part of the mall building concept without further analysis and study of the ramifications based on existing mall building requirements. It should also be noted that the definition proposed in Proposal 101-673 does not clearly indicate the revisions actually made to A.3.3.27.9 Mall Building. The proposal should show the first two sentences underlined which have been added based on a similar Annex Note in NFPA 5000 (without the reference to transportation facilities) as indicated in A.3.3.58.11 Mall Building. However, in order to maintain consistency between NFPA 101 and NFPA 5000, I would be willing to accept the proposed text identical to the text contained in NFPA 5000, which would not include the reference to transportation facilities as being an allowed occupancy within a mall building. But, all this Comment attempted to do was to reverse the Committee’s Action on the Proposal and retain the current Annex A language for “Mall Building” in NFPA 101. _______________________________________________________________101-427 Log #253 SAF-IND FINAL ACTION: Accept in Principle (A.3.3.152.8.2 High Hazard Industrial Occupancy) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-677 RECOMMENDATION: Accept this proposal in part in principle and use the following wording: A.3.3.152.8.2 High Hazard Industrial Occupancy. A high hazard occupancy includes occupancies where gasoline and other flammable liquids are handled, used, or stored under such conditions that involve possible release of flammable vapors; where grain dust, wood flour or plastic dusts, aluminum or magnesium dust, or other explosive dusts are produced; where hazardous chemicals or explosives are manufactured, stored, or handled; where cotton or other combustible fibers flammable solids are processed or handled under conditions that might produce flammable flyings; and where other situations of similar hazard exist. Chapter 40 and Chapter 42 include detailed provisions on high hazard industrial and storage occupancies. SUBSTANTIATION: This comment is associated with a set of four comments addressing proposals NFPA 5000-191, 5000-891, 5000-900 and 5000-1131. The basic objective of all the comments to NFPA 5000 is to eliminate “densely-packed cotton bales” from the restrictions associated with hazardous materials. There will be also a companion comment giving an alternative approach for the technical committee and two equivalent ones addressing proposal NFPA 101-688. In its statement when rejecting my proposal NFPA 101-677, the technical committee on Industrial, Storage and Miscellaneous Occupancies stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation.” This is similar to the technical committee’s statement when rejecting my proposal NFPA 5000-891, where it stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation, and that requirements for sprinkler systems are also triggered by building height and area.”

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Report on Comments — Copyright, NFPA NFPA 101 The technical committee is correct in stating that cotton (as densely-packed cotton bales) is not a flammable solid, but that it is a combustible fiber. The technical committee is also correct in talking about the requirements for sprinklers triggered by building height anda area. However, the technical committee is incorrect when talking about the fire hazard of densely-packed cotton bales; most of the information traditionally available is anecdotal evidence which is no longer valid for densely-packed cotton bales. The cotton industry has investigated the issue of “fire-packed cotton bales”. Several issues need to be presented to the committee:

(1) After repeated experiments, the cotton industry has found that it is not possible to get a sustained fire (either smoldering or flaming) inside a cotton bale, unless the bale has a density of less than 14 lb/ft3. If the density is 14 lb/ft3 or higher, there is insufficient oxygen to sustain combustion. For that reason, the compression for “densely-packed cotton bales” was set at 22 lb/ft3 (360 kg/m3), giving a safey factor of > 50%.(2) Fires, therefore, will not occur in a “densely-packed cotton bale” but will only occur during the ginning operation, when cotton bales are being created. Once the cotton bale has been compressed to a sufficient density to create a “densely-packed cotton bale” an internal fire can no longer exist within the bale.(3) The US Department of Agriculture (Agricultural Handbook Number 503, W.S. Anthony and W.D. Mayfield editors, 1994, front page and safety section attached as a pdf file) has issued the “Cotton Ginners Handbook”, which contains a safety section that describes the procedures for isolating cotton bales when fires occur within the bale (before it has been compressed properly). These instructions, for the “ginner”, the “press operator” and “other crew members” read as follows. “Procedures for Gin Fires: When a fire occurs, the ginner and press operator should do the following:Ginner:1. Sound the horn several times with many rapid blasts to alert the press man and the rest of the crew.2. Kick out the gin stands.3. Open all fire doors.4. Stop the flow of seed cotton from the feed control or module feeder.5. Shut off all heaters, V-trench conveyors, and seed conveyors.6. Kick in the fire door at the gin stands.7. Attach a tarp on each gin stand.8. Run cotton from the feeder apron out onto the floor. Gin all cotton before shutting the gin down.9. Wet down all burning cotton on the floor.10. Move all the burned cotton to the outside of the gin, and put the cotton next to a water supply.11. Shut down all gin equipment for cleanout.Press operator:1. Stay witth the press and battery condenser until the fire is out.2. Wait until all cotton is down the slide, and then turn the press and raise the bale out of the press.3. Keep the tramper running if cotton is burning in the lint slide4. If a fire is in the battery condenser, wet down the areas around the flashing and rollers, and avoid letting the fire burn on the lint belt or near the flashing.5. Isolate at least two bales before and after a suspected bale fire.

Other crew members:The lint cleaner operator should stay with the lint cleaners until the fire is completely out. The moteman/yard operator should move the mote trailer out from under the shed. The module feeder operator should move the module away from the spike rollers to stop feeding seed cotton into the gin. All other crew members should report to the ginner. Only water should be used to put out cotton fires. Chemical fire extinguishers should be used on oil, gas, and electrical fires only.” (4) In the ginning process the lint fiber is separated from the cotton seed by automated mechanical operations, involving heating of the lint fiber for drying purposes. During ginning, the three most common sources of ignition are: friction, sparks created by the machinery and high temperatures, usually from the process heater drying the lint fiber. Fire occurs during the ginning process when loose cotton fibers are ignited and included into the bale during compression. Once a fire-packed bale is discovered (or once any fire is discovered during the ginning process), the bales are all inspected individually (including checking their temperature to see if it is elevated). Any bale with a fire in it (either observed visually or identified through high temperature) is separated and quarantined in a clear space, at least 100 yards from any building.for a minimum of five days.(5) Therefore, fire packed cotton bales will not reach storage facilities. They will stay in the gin and be quarantined there while being properly cared for. After the quarantine, the fire-packed bale will usually be reworked, cotton will be added to it and it will be recompressed into a “densely-packed cotton bale”. Alternatively it will be shipped as a low density bale, which results in a large cost penalty to the seller.

The technical committee is also incorrect when discussing the fire tests conducted by the cotton industry: they were not small scale tests as most of the tests were conducted on full bales of cotton (500 pounds in weight and 55

in. long by 21 in. wide by 35 in. high). In fact, the cotton industry conducted significant fire research to demonstrate the low fire hazard associated with densely-packed baled cotton. ASTM E 1590 is a full scale heat release test that exposes a complete mattress to a significant flaming fire source, and in the cotton industry tests several complete cotton bales were exposed to the same flaming ignition source. Also as part of the same research conducted by the cotton industry, it was shown that placing a complete electric heater inside the cotton bale did not cause the cotton to burn because of lack of oxygen. The remainder of the details on the research has already been presented and is not presented again here. Moreover, fire-packed cotton bales (which are bales where fires have occurred, usually during the ginning process) are isolated and are never mixed with densely-packed cotton bales. Therefore, it should be made clear that densely-packed cotton bales are not hazardous materials. The NFPA 1/UFC technical committee analyzed this issue also at its ROP meeting and concluded that combustible fibers should not be considered “hazardous materials” (when it accepted in principle proposal NFPA 1-186). “The Committee agrees with the submitter’s proposal to delete combustible fibers from being included in the requirements of regulated hazardous materials in Chapter 60. The Committee upon reviewing the recommendation and substantiation agree that combustible fibers by themselves are not hazardous, but the physical state they are in may cause the hazard. This is a similar situation to dust producing processes. The Committee also noted that they do not agree that combustible fibers should be regulated as a hazardous material, but that precautions are needed for the safe storage of the product. The protection features need to be outlined in a separate chapter.The Committee is moving Chapter 62 Combustible Fibers out of Part VI, Hazardous Materials, and into Part IV, Processes as Chapter 45, since the Committee agrees that combustible fibers should not be considered hazardous materials.” The NFPA 1/UFC technical committee also believes that “densely-packed cotton bales” should be accepted as a special case, due to their good fire performance, and incorporated the definition into the code (see action on NFPA 1-34). “The Committee agreed with the submitter’s proposal and added the identified definitions to NFPA 1 UFC through its incorporation of the terms defined in NFPA 230 in this revision cycle. See Proposal 1-27 (Log #CP30). The terms were editorially revised to comply with the NFPA MOS format for definitions. The second sentence of 3.3.14.4 was not accepted as it appears to contradict the main definition.” The definitions incorporated into NFPA 1/UFC had the exact language contained in this comment. The NFPA 1/UFC technical committee also stated, when rejecting NFPA 1-176): “The Uniform Fire Code Committee is trying to maintain consistency with NFPA 5000 in this area. These requirements will need to be correlated with NFPA 5000 at the comment stage. The existing text is coordinated with NFPA 5000 for the regulation of hazardous materials and the 5000 BLD-IND TC rejected a similar proposal. The NFPA 1 UFC Committee believes that the actions taken on Proposals 1-186 (Log #160) and 1- 34 (Log#170) meet the submitter’s intent. This proposed code change would place a definition in a footnote, and this is not permitted in accordance with the NFPA MOS. This Committee is of the opinion, that cotton is more appropriately classified as a combustible fiber, rather than a flammable solid. This Committee further notes that baled cotton does present a fire hazard, and it is associated with deep-seated fires that are difficult to control and extinguish once ignited. The Committee also notes that the building height and area would trigger the requirement for a sprinkler system.” The best way to coordinate this is to make it clear that “densely-packed cotton bales” are much less hazardous than normal baled cotton. Unfortunately, the NFPA 1/UFC technical committee also restated the incorrect anecdotal assumption that cotton bales present a fire hazard. As stated before, densely-packed baled cotton (meeting the size and weight requirements of ISO 8115) is not a hazardous material. This concept was accepted by the US Department of Transportation (US Coast Guard), the International Maritime Organization (IMO) and the Uniform Fire Code committee. Currently, ninety-nine plus percent of all U.S. cotton is pressed and stored as densely-packed baled cotton. Those bales meet the weight and dimension requirements of ISO 8115 (Cotton Bales - Dimensions and Density). The definitions incorporated into NFPA 1/UFC were: “Baled Cotton Definitions Baled Cotton. A natural seed fiber wrapped and secured in industry-

accepted materials, usually consisting of burlap, woven polypropylene, or sheet polyethylene, and secured with steel, synthetic, or wire bands, or wire; also includes linters (lint removed from the cottonseed) and motes (residual materials from the ginning process),

Densely-Packed Baled Cotton. Cotton, made into banded bales, with a packing density of at least 360 kg/m3 (22 lb/ft3), and dimensions complying with the following: a length of 1400 ± 20 mm (ca. 55 in.), a width of 530 ± 20 mm (ca. 21 in.) and a height of 700-900 mm (27.6-35.4 in.).

Fire-Packed Baled Cotton. A cotton bale within which a fire has been packed as a result of a process, ginning being the most frequent cause.

Naked Cotton Bale. An unwrapped cotton bale secured with wire or steel straps.”

Acceptance of this comment would eliminate combustible fibers from the list of hazardous materials, and refer to “flammable solids or loose cotton” instead, consistent with what the NFPA 1/UFC technical committee recommended. An alternative wording, including also the term “loose cotton”, is being provided in a separate comment.

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Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept in Principle Accept the submitter’s proposed change but revise the term “flammable solids” to read “materials”. COMMITTEE STATEMENT: The committee prefers a more encompassing term. Flammable solids are not the only types of materials that could produce a flammable flying. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-428 Log #254 SAF-IND FINAL ACTION: Accept in Principle (A.3.3.152.8.2 High Hazard Industrial Occupancy) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-677 RECOMMENDATION: Accept this proposal in part in principle and use the following wording: A.3.3.152.8.2 High Hazard Industrial Occupancy. A high hazard occupancy includes occupancies where gasoline and other flammable liquids are handled, used, or stored under such conditions that involve possible release of flammable vapors; where grain dust, wood flour or plastic dusts, aluminum or magnesium dust, or other explosive dusts are produced; where hazardous chemicals or explosives are manufactured, stored, or handled; where cotton or other combustible fibers flammable solids or loose cotton are processed or handled under conditions that might produce flammable flyings; and where other situations of similar hazard exist. Chapter 40 and Chapter 42 include detailed provisions on high hazard industrial and storage occupancies. SUBSTANTIATION: This comment is associated with a set of four comments addressing proposals NFPA 5000-191, 5000-891, 5000-900 and 5000-1131. The basic objective of all the comments to NFPA 5000 is to eliminate “densely-packed cotton bales” from the restrictions associated with hazardous materials. There will be also a companion comment giving an alternative approach for the technical committee and two equivalent ones addressing proposal NFPA 101-677. In its statement when rejecting my proposal NFPA 101-677, the technical committee on Industrial, Storage and Miscellaneous Occupancies stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation.” This is similar to the technical committee’s statement when rejecting my proposal NFPA 5000-891, where it stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation, and that requirements for sprinkler systems are also triggered by building height and area.” The technical committee is correct in stating that cotton (as densely-packed cotton bales) is not a flammable solid, but that it is a combustible fiber. The technical committee is also correct in talking about the requirements for sprinklers triggered by building height anda area. However, the technical committee is incorrect when talking about the fire hazard of densely-packed cotton bales; most of the information traditionally available is anecdotal evidence which is no longer valid for densely-packed cotton bales. The cotton industry has investigated the issue of “fire-packed cotton bales”. Several issues need to be presented to the committee:

(1) After repeated experiments, the cotton industry has found that it is not possible to get a sustained fire (either smoldering or flaming) inside a cotton bale, unless the bale has a density of less than 14 lb/ft3. If the density is 14 lb/ft3 or higher, there is insufficient oxygen to sustain combustion. For that reason, the compression for “densely-packed cotton bales” was set at 22 lb/ft3 (360 kg/m3), giving a safey factor of > 50%.(2) Fires, therefore, will not occur in a “densely-packed cotton bale” but will only occur during the ginning operation, when cotton bales are being created. Once the cotton bale has been compressed to a sufficient density to create a “densely-packed cotton bale” an internal fire can no longer exist within the bale.(3) The US Department of Agriculture (Agricultural Handbook Number 503, W.S. Anthony and W.D. Mayfield editors, 1994, front page and safety section attached as a pdf file) has issued the “Cotton Ginners Handbook”, which contains a safety section that describes the procedures for isolating cotton bales when fires occur within the bale (before it has been compressed properly). These instructions, for the “ginner”, the “press operator” and “other crew members” read as follows. “Procedures for Gin Fires: When a fire occurs, the ginner and press operator should do the following:Ginner:1. Sound the horn several times with many rapid blasts to alert the press man and the rest of the crew.2. Kick out the gin stands.3. Open all fire doors.

4. Stop the flow of seed cotton from the feed control or module feeder.5. Shut off all heaters, V-trench conveyors, and seed conveyors.6. Kick in the fire door at the gin stands.7. Attach a tarp on each gin stand.8. Run cotton from the feeder apron out onto the floor. Gin all cotton before shutting the gin down.9. Wet down all burning cotton on the floor.10. Move all the burned cotton to the outside of the gin, and put the cotton next to a water supply.11. Shut down all gin equipment for cleanout.Press operator:1. Stay witth the press and battery condenser until the fire is out.2. Wait until all cotton is down the slide, and then turn the press and raise the bale out of the press.3. Keep the tramper running if cotton is burning in the lint slide4. If a fire is in the battery condenser, wet down the areas around the flashing and rollers, and avoid letting the fire burn on the lint belt or near the flashing.5. Isolate at least two bales before and after a suspected bale fire.

Other crew members:The lint cleaner operator should stay with the lint cleaners until the fire is completely out. The moteman/yard operator should move the mote trailer out from under the shed. The module feeder operator should move the module away from the spike rollers to stop feeding seed cotton into the gin. All other crew members should report to the ginner. Only water should be used to put out cotton fires. Chemical fire extinguishers should be used on oil, gas, and electrical fires only.”

(4) In the ginning process the lint fiber is separated from the cotton seed by automated mechanical operations, involving heating of the lint fiber for drying purposes. During ginning, the three most common sources of ignition are: friction, sparks created by the machinery and high temperatures, usually from the process heater drying the lint fiber. Fire occurs during the ginning process when loose cotton fibers are ignited and included into the bale during compression. Once a fire-packed bale is discovered (or once any fire is discovered during the ginning process), the bales are all inspected individually (including checking their temperature to see if it is elevated). Any bale with a fire in it (either observed visually or identified through high temperature) is separated and quarantined in a clear space, at least 100 yards from any building.for a minimum of five days.

(5) Therefore, fire packed cotton bales will not reach storage facilities. They will stay in the gin and be quarantined there while being properly cared for. After the quarantine, the fire-packed bale will usually be reworked, cotton will be added to it and it will be recompressed into a “densely-packed cotton bale”. Alternatively it will be shipped as a low density bale, which results in a large cost penalty to the seller.

The technical committee is also incorrect when discussing the fire tests conducted by the cotton industry: they were not small scale tests as most of the tests were conducted on full bales of cotton (500 pounds in weight and 55 in. long by 21 in. wide by 35 in. high). In fact, the cotton industry conducted significant fire research to demonstrate the low fire hazard associated with densely-packed baled cotton. ASTM E 1590 is a full scale heat release test that exposes a complete mattress to a significant flaming fire source, and in the cotton industry tests several complete cotton bales were exposed to the same flaming ignition source. Also as part of the same research conducted by the cotton industry, it was shown that placing a complete electric heater inside the cotton bale did not cause the cotton to burn because of lack of oxygen. The remainder of the details on the research has already been presented and is not presented again here. Moreover, fire-packed cotton bales (which are bales where fires have occurred, usually during the ginning process) are isolated and are never mixed with densely-packed cotton bales. Therefore, it should be made clear that densely-packed cotton bales are not hazardous materials. The NFPA 1/UFC technical committee analyzed this issue also at its ROP meeting and concluded that combustible fibers should not be considered “hazardous materials” (when it accepted in principle proposal NFPA 1-186). “The Committee agrees with the submitter’s proposal to delete combustible fibers from being included in the requirements of regulated hazardous materials in Chapter 60. The Committee upon reviewing the recommendation and substantiation agree that combustible fibers by themselves are not hazardous, but the physical state they are in may cause the hazard. This is a similar situation to dust producing processes. The Committee also noted that they do not agree that combustible fibers should be regulated as a hazardous material, but that precautions are needed for the safe storage of the product. The protection features need to be outlined in a separate chapter.The Committee is moving Chapter 62 Combustible Fibers out of Part VI, Hazardous Materials, and into Part IV, Processes as Chapter 45, since the Committee agrees that combustible fibers should not be considered hazardous materials.” The NFPA 1/UFC technical committee also believes that “densely-packed cotton bales” should be accepted as a special case, due to their good fire performance, and incorporated the definition into the code (see action on NFPA 1-34). “The Committee agreed with the submitter’s proposal and added the

101-173

Report on Comments — Copyright, NFPA NFPA 101 identified definitions to NFPA 1 UFC through its incorporation of the terms defined in NFPA 230 in this revision cycle. See Proposal 1-27 (Log #CP30). The terms were editorially revised to comply with the NFPA MOS format for definitions. The second sentence of 3.3.14.4 was not accepted as it appears to contradict the main definition.” The definitions incorporated into NFPA 1/UFC had the exact language contained in this comment. The NFPA 1/UFC technical committee also stated, when rejecting NFPA 1-176): “The Uniform Fire Code Committee is trying to maintain consistency with NFPA 5000 in this area. These requirements will need to be correlated with NFPA 5000 at the comment stage. The existing text is coordinated with NFPA 5000 for the regulation of hazardous materials and the 5000 BLD-IND TC rejected a similar proposal. The NFPA 1 UFC Committee believes that the actions taken on Proposals 1-186 (Log #160) and 1- 34 (Log#170) meet the submitter’s intent. This proposed code change would place a definition in a footnote, and this is not permitted in accordance with the NFPA MOS. This Committee is of the opinion, that cotton is more appropriately classified as a combustible fiber, rather than a flammable solid. This Committee further notes that baled cotton does present a fire hazard, and it is associated with deep-seated fires that are difficult to control and extinguish once ignited. The Committee also notes that the building height and area would trigger the requirement for a sprinkler system.” The best way to coordinate this is to make it clear that “densely-packed cotton bales” are much less hazardous than normal baled cotton. Unfortunately, the NFPA 1/UFC technical committee also restated the incorrect anecdotal assumption that cotton bales present a fire hazard. As stated before, densely-packed baled cotton (meeting the size and weight requirements of ISO 8115) is not a hazardous material. This concept was accepted by the US Department of Transportation (US Coast Guard), the International Maritime Organization (IMO) and the Uniform Fire Code committee. Currently, ninety-nine plus percent of all U.S. cotton is pressed and stored as densely-packed baled cotton. Those bales meet the weight and dimension requirements of ISO 8115 (Cotton Bales - Dimensions and Density).

The definitions incorporated into NFPA 1/UFC were: “Baled Cotton Definitions Baled Cotton. A natural seed fiber wrapped and secured in industry-accepted materials, usually consisting of burlap, woven polypropylene, or sheet polyethylene, and secured with steel, synthetic, or wire bands, or wire; also includes linters (lint removed from the cottonseed) and motes (residual materials from the ginning process), Densely-Packed Baled Cotton. Cotton, made into banded bales, with a packing density of at least 360 kg/m3 (22 lb/ft3), and dimensions complying with the following: a length of 1400 ± 20 mm (ca. 55 in.), a width of 530 ± 20 mm (ca. 21 in.)and a height of 700-900 mm (27.6-35.4 in.). Fire-Packed Baled Cotton. A cotton bale within which a fire has been packed as a result of a process, ginning being the most frequent cause. Naked Cotton Bale. An unwrapped cotton bale secured with wire or steel straps.”

Acceptance of this comment would eliminate combustible fibers from the list of hazardous materials, and refer to “flammable solids or loose cotton” instead, consistent with what the NFPA 1/UFC technical committee recommended. An alternative wording, without referring to “loose cotton”) is also being provided in a separate comment.COMMITTEE MEETING ACTION: Accept in Principle See Committee Action and Statement on Comment 101-427. COMMITTEE STATEMENT: See Committee Action and Statement on Comment 101-427. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN _______________________________________________________________101-429 Log #91 SAF-FUN FINAL ACTION: Accept in Principle (A.4.6.6) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-680A RECOMMENDATION: Give consideration to the proposal so as to make any needed changes given the TCC developed the proposal after FUN had completed its ROP. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Retain the acceptance of Proposal 101-680a. COMMITTEE STATEMENT: Acceptance of Proposal 101-680a remains appropriate. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS

_______________________________________________________________101-430 Log #366 SAF-FUN FINAL ACTION: Accept (A.4.6.6) _______________________________________________________________ SUBMITTER: Thomas W. Jaeger, Gage-Babcock & Assoc., Inc. / Rep. American Health Care Association COMMENT ON PROPOSAL NO: 101-680A RECOMMENDATION: Accept the TCC Proposal. SUBSTANTIATION: The language being proposed is verbatim from Section 2.1 of the 2000 Life Safety Code. This language was editorially removed from the 2003 Edition by the editor and was not removed by any Technical Committee as the result of any actions on a proposal or comment. The health care industry developed the language that was deleted because more than 30,000 existing hospitals and nursing homes in the United States have the Life Safety Code applied retroactively. The text that was lost in the 2003 Edition is very important to insure that adequate guidance is given as to how to apply newer editions of the referenced documents to existing buildings. COMMITTEE MEETING ACTION: Accept Retain the acceptance of Proposal 101-680a. COMMITTEE STATEMENT: Acceptance of Proposal 101-680a remains appropriate. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-431 Log #255 SAF-IND FINAL ACTION: Accept in Principle (A.6.2.2.4) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-688 RECOMMENDATION: Accept this proposal in part in principle and use the following wording: A.6.2.2.4 High hazard contents include occupancies where flammable liquids are handled or used or are stored under conditions involving possible release of flammable vapors; where grain dust, wood flour or plastic dust, aluminum or magnesium dust, or other explosive dusts are produced; where hazardous chemicals or explosives are manufactured, stored, or handled; where cotton or other combustible fibers flammable solids are processed or handled under conditions producing flammable flyings; and other situations of similar hazard. SUBSTANTIATION: This comment is associated with a set of four comments addressing proposals NFPA 5000-191, 5000-891, NFPA 900 and 5000-1131. The basic objective of all the comments to NFPA 5000 is to eliminate “densely-packed cotton bales” from the restrictions associated with hazardous materials. There will be also a companion comment giving an alternative approach for the technical committee and two equivalent ones addressing proposal NFPA 101-677. In its statement when rejecting my proposal NFPA 101-677, the technical committee on Industrial, Storage and Miscellaneous Occupancies stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation.” This is similar to the technical committee’s statement when rejecting my proposal NFPA 5000-891, where it stated that: “The committee is of the opinion that cotton is more appropriately classified as a combustible fiber rather than a flammable solid. The committee further notes that baled cotton does present a fire hazard, and is associated with deep seated fires that are difficult to control and extinguish once ignited. The committee also notes that only small scale tests are referenced in the substantiation, and that requirements for sprinkler systems are also triggered by building height and area.” The technical committee is correct in stating that cotton (as densely-packed cotton bales) is not a flammable solid, but that it is a combustible fiber. The technical committee is also correct in talking about the requirements for sprinklers triggered by building height anda area. However, the technical committee is incorrect when talking about the fire hazard of densely-packed cotton bales; most of the information traditionally available is anecdotal evidence which is no longer valid for densely-packed cotton bales. The cotton industry has investigated the issue of “fire-packed cotton bales”. Several issues need to be presented to the committee:

(1) After repeated experiments, the cotton industry has found that it is not possible to get a sustained fire (either smoldering or flaming) inside a cotton bale, unless the bale has a density of less than 14 lb/ft3. If the density is 14 lb/ft3 or higher, there is insufficient oxygen to sustain combustion. For that reason, the compression for “densely-packed cotton bales” was set at 22 lb/ft3 (360 kg/m3), giving a safey factor of > 50%.(2) Fires, therefore, will not occur in a “densely-packed cotton bale” but will only occur during the ginning operation, when cotton bales are being created. Once the cotton bale has been compressed to a sufficient density to create a “densely-packed cotton bale” an internal fire can no longer exist within the bale.

101-174

Report on Comments — Copyright, NFPA NFPA 101 (3) The US Department of Agriculture (Agricultural Handbook Number 503, W.S. Anthony and W.D. Mayfield editors, 1994, front page and safety section attached as a pdf file) has issued the “Cotton Ginners Handbook”, which contains a safety section that describes the procedures for isolating cotton bales when fires occur within the bale (before it has been compressed properly). These instructions, for the “ginner”, the “press operator” and “other crew members” read as follows. “Procedures for Gin Fires: When a fire occurs, the ginner and press operator should do the following:Ginner:1. Sound the horn several times with many rapid blasts to alert the press man and the rest of the crew.2. Kick out the gin stands.3. Open all fire doors.4. Stop the flow of seed cotton from the feed control or module feeder.5. Shut off all heaters, V-trench conveyors, and seed conveyors.6. Kick in the fire door at the gin stands.7. Attach a tarp on each gin stand.8. Run cotton from the feeder apron out onto the floor. Gin all cotton before shutting the gin down.9. Wet down all burning cotton on the floor.10. Move all the burned cotton to the outside of the gin, and put the cotton next to a water supply.11. Shut down all gin equipment for cleanout.Press operator:1. Stay witth the press and battery condenser until the fire is out.2. Wait until all cotton is down the slide, and then turn the press and raise the bale out of the press.3. Keep the tramper running if cotton is burning in the lint slide4. If a fire is in the battery condenser, wet down the areas around the flashing and rollers, and avoid letting the fire burn on the lint belt or near the flashing.5. Isolate at least two bales before and after a suspected bale fire.

Other crew members:The lint cleaner operator should stay with the lint cleaners until the fire is completely out. The moteman/yard operator should move the mote trailer out from under the shed. The module feeder operator should move the module away from the spike rollers to stop feeding seed cotton into the gin. All other crew members should report to the ginner. Only water should be used to put out cotton fires. Chemical fire extinguishers should be used on oil, gas, and electrical fires only.”(4) In the ginning process the lint fiber is separated from the cotton seed by automated mechanical operations, involving heating of the lint fiber for drying purposes. During ginning, the three most common sources of ignition are: friction, sparks created by the machinery and high temperatures, usually from the process heater drying the lint fiber. Fire occurs during the ginning process when loose cotton fibers are ignited and included into the bale during compression. Once a fire-packed bale is discovered (or once any fire is discovered during the ginning process), the bales are all inspected individually (including checking their temperature to see if it is elevated). Any bale with a fire in it (either observed visually or identified through high temperature) is separated and quarantined in a clear space, at least 100 yards from any building.for a minimum of five days.(5) Therefore, fire packed cotton bales will not reach storage facilities. They will stay in the gin and be quarantined there while being properly cared for. After the quarantine, the fire-packed bale will usually be reworked, cotton will be added to it and it will be recompressed into a “densely-packed cotton bale”. Alternatively it will be shipped as a low density bale, which results in a large cost penalty to the seller.

The technical committee is also incorrect when discussing the fire tests conducted by the cotton industry: they were not small scale tests as most of the tests were conducted on full bales of cotton (500 pounds in weight and 55 in. long by 21 in. wide by 35 in. high). In fact, the cotton industry conducted significant fire research to demonstrate the low fire hazard associated with densely-packed baled cotton. ASTM E 1590 is a full scale heat release test that exposes a complete mattress to a significant flaming fire source, and in the cotton industry tests several complete cotton bales were exposed to the same flaming ignition source. Also as part of the same research conducted by the cotton industry, it was shown that placing a complete electric heater inside the cotton bale did not cause the cotton to burn because of lack of oxygen. The remainder of the details on the research has already been presented and is not presented again here. Moreover, fire-packed cotton bales (which are bales where fires have occurred, usually during the ginning process) are isolated and are never mixed with densely-packed cotton bales. Therefore, it should be made clear that densely-packed cotton bales are not hazardous materials. The NFPA 1/UFC technical committee analyzed this issue also at its ROP meeting and concluded that combustible fibers should not be considered “hazardous materials” (when it accepted in principle proposal NFPA 1-186). “The Committee agrees with the submitter’s proposal to delete combustible fibers from being included in the requirements of regulated hazardous materials in Chapter 60. The Committee upon reviewing the recommendation and

substantiation agree that combustible fibers by themselves are not hazardous, but the physical state they are in may cause the hazard. This is a similar situation to dust producing processes. The Committee also noted that they do not agree that combustible fibers should be regulated as a hazardous material, but that precautions are needed for the safe storage of the product. The protection features need to be outlined in a separate chapter.The Committee is moving Chapter 62 Combustible Fibers out of Part VI, Hazardous Materials, and into Part IV, Processes as Chapter 45, since the Committee agrees that combustible fibers should not be considered hazardous materials.” The NFPA 1/UFC technical committee also believes that “densely-packed cotton bales” should be accepted as a special case, due to their good fire performance, and incorporated the definition into the code (see action on NFPA 1-34). “The Committee agreed with the submitter’s proposal and added the identified definitions to NFPA 1 UFC through its incorporation of the terms defined in NFPA 230 in this revision cycle. See Proposal 1-27 (Log #CP30). The terms were editorially revised to comply with the NFPA MOS format for definitions. The second sentence of 3.3.14.4 was not accepted as it appears to contradict the main definition.” The definitions incorporated into NFPA 1/UFC had the exact language contained in this comment. The NFPA 1/UFC technical committee also stated, when rejecting NFPA 1-176): “The Uniform Fire Code Committee is trying to maintain consistency with NFPA 5000 in this area. These requirements will need to be correlated with NFPA 5000 at the comment stage. The existing text is coordinated with NFPA 5000 for the regulation of hazardous materials and the 5000 BLD-IND TC rejected a similar proposal. The NFPA 1 UFC Committee believes that the actions taken on Proposals 1-186 (Log #160) and 1- 34 (Log#170) meet the submitter’s intent. This proposed code change would place a definition in a footnote, and this is not permitted in accordance with the NFPA MOS. This Committee is of the opinion, that cotton is more appropriately classified as a combustible fiber, rather than a flammable solid. This Committee further notes that baled cotton does present a fire hazard, and it is associated with deep-seated fires that are difficult to control and extinguish once ignited. The Committee also notes that the building height and area would trigger the requirement for a sprinkler system.” The best way to coordinate this is to make it clear that “densely-packed cotton bales” are much less hazardous than normal baled cotton. Unfortunately, the NFPA 1/UFC technical committee also restated the incorrect anecdotal assumption that cotton bales present a fire hazard. As stated before, densely-packed baled cotton (meeting the size and weight requirements of ISO 8115) is not a hazardous material. This concept was accepted by the US Department of Transportation (US Coast Guard), the International Maritime Organization (IMO) and the Uniform Fire Code committee. Currently, ninety-nine plus percent of all U.S. cotton is pressed and stored as densely-packed baled cotton. Those bales meet the weight and dimension requirements of ISO 8115 (Cotton Bales - Dimensions and Density).

The definitions incorporated into NFPA 1/UFC were: “Baled Cotton DefinitionsBaled Cotton. A natural seed fiber wrapped and secured in industry-accepted materials, usually consisting of burlap, woven polypropylene, or sheet polyethylene, and secured with steel, synthetic, or wire bands, or wire; also includes linters (lint removed from the cottonseed) and motes (residual materials from the ginning process), Densely-Packed Baled Cotton. Cotton, made into banded bales, with a packing density of at least 360 kg/m3 (22 lb/ft3), and dimensions complying with the following: a length of 1400 ± 20 mm (ca. 55 in.), a width of 530 ± 20 mm (ca. 21 in.)and a height of 700-900 mm (27.6-35.4 in.).Fire-Packed Baled Cotton. A cotton bale within which a fire has been packed as a result of a process, ginning being the most frequent cause. Naked Cotton Bale. An unwrapped cotton bale secured with wire or steel straps.”

Acceptance of this comment would eliminate cotton and combustible fibers from the list of hazardous materials, and refer to “flammable solids” isntead, consistent with what the NFPA 1/UFC technical committee recommended. An alternative wording, including also the term “loose cotton”, is being provided in a separate comment.COMMITTEE MEETING ACTION: Accept in Principle Accept the submitter’s proposed change but revise the term “flammable solids” to read “materials”. COMMITTEE STATEMENT: The committee prefers a more encompassing term. Flammable solids are not the only types of materials that could produce a flammable flying. NUMBER ELIGIBLE TO VOTE: 29 BALLOT RESULTS: Affirmative: 25 BALLOT NOT RETURNED: 4 DOODY, GARRETT, RAJ, WREN

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Report on Comments — Copyright, NFPA NFPA 101 _______________________________________________________________101-432 Log #92 SAF-MEA FINAL ACTION: Accept in Principle (A.7.1.1) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-689 RECOMMENDATION: Give consideration to Shulman’s Explanation of Negative and Koffel’s Comment on Affirmative (see also Proposal 101-128), so as to make any needed changes. SHULMAN: In alignment with our negative vote on 101-128 (Log #CP207), we do not support the proposed amendments to this section. While some of the proposed amendments are editorial and appropriate, others implicitly elevate these other devices/systems to the status of being approved “secondary” means of egress. The Code has requirements for means of egress, not for “primary” and “secondary” means of egress. We do not believe that the range of consequences associated with making such a distinction have been adequately analyzed or discussed. KOFFEL: See my Comment on Affirmative on 101-128 (Log #CP207): It is my understanding that some Committee members supported the proposed action on the basis that the Committee was seeking additional input from the public. Therefore, the record should clearly show that the Committee recognizes that additional work and consideration may be necessary and that Public Comment, both favorable and negative, should be encouraged. In 101-129 (Log #294) the Submitter justifies, in part, the proposal as a need to provide selection criteria. As an alternative to providing the material in this Code, a product standard may be a more appropriate method to accomplish this objective. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-689 so as NOT to revise A.7.1.1. COMMITTEE STATEMENT: The changes proposed to A.7.1.1 by Proposal 101-689 incorrectly refer to escape devices serving as secondary means or egress or escape. The action taken on Comment 101-78 moves the material to a new Section 7.13 and gives no credit for escape devices within the means of egress. The text is incorrect. It is necessary to revert to existing text. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 22 Abstain: 2 EXPLANATION OF ABSTENTION: DE VRIES: In accordance with Section 3-3 (e) of the Guide for the Conduct of Participants in the NFPA Codes and Standards Development Process, I hereby abstain from voting on this comment based on my retention by the Safe Evacuation Coalition to represent their interests on the subject of escape devices and systems. FAVRO: Please record me as abstaining on all issues relative to the “Supplemental Evacuation Equipment” on both the NFPA 101 and NFPA 5000 ballots. Not having been able to attend the meeting in San Diego, I am unfamiliar with the arguments made for and against the proposals and I am not comfortable with the information that I have seen in a recent CD-ROM and related material that was sent to me. COMMENT ON AFFIRMATIVE ELVOVE: The revisions made by the Technical Committee during the ROC meeting have certainly improved upon the original proposal text and therefore provide a minimum level of requirements should a building owner opt to install supplemental evacuation equipment and the local jurisdiction permit its installation. Therefore, all the revisions proposed to the 2005 edition of NFPA 101 related to supplemental evacuation systems should be accepted. However, should this comment be overturned via this ballot, then ensure the 2005 edition of NFPA 101 makes no mention of escape devices (i.e., delete all previously accepted proposals having to do with supplemental evacuation systems) as including nothing is better than including flawed code text (which would be the case should this particular comment be rejected and the original proposal remain). KOFFEL: This comment is one of many that deal with the issue of escape devices or systems. Please see my ballot comment regarding Comment 101-78. _______________________________________________________________101-433 Log #226 SAF-MEA FINAL ACTION: Accept in Principle (A.7.2.12.2.3(2)) _______________________________________________________________ SUBMITTER: Jake Pauls, Jake Pauls Consulting Services COMMENT ON PROPOSAL NO: 101-124 RECOMMENDATION: Revise text to read as follows: A.7.2.12.2.3(2) The stair descent device provides a safer, more effective option to carrying an occupied wheelchair or other chair, lifted off the stair, down the stairs. Such stair descent devices are recommended for use, regardless of the stair width. The design, manufacture, maintenance and operation of such devices should take into account the following factors: 1. Carrying capacity sufficient for the weight of individuals in the population served. 2. Descent speed readily controlled within a range comparable to that of ambulatory evacuees descending stairs, 1.5 to 2.5 ft per second (0.45 to 0.76 meter per second), measured along the slope of the stair flight and along the

level on landings. (This is based on conditions reported in the SFPE Handbook of Fire Protection Engineering chapter “Movement of People.”) 3. Fail-safe braking that will hold the device in place on any surface with a pitch or slope of less than 42° and that must be manually disengaged by the operator for the device to descend. 4. Transitions between stairway landings and stair flights should be accomplished without delaying, by more than 3 seconds per transition, the movement of other persons using the stairway in the vicinity of the device. 5. Operation by any trained, ambulatory adult for any transported person not exceeding 300 pounds in weight. 6. Stable, slip-free contact of the device, with the stair tread nosings, should be maintained on a minimum of three stair nosings of straight-flight stairs. Unless designed specifically for use on stairs with non-rectangular treads, the device shall not be operated on stairways with tapered treads, however, the device can be used on such stairways if it is designed and manufactured, with a weight not exceeding 50 pounds, so it can be transported over such stairways and if operators are trained and available for such operation. Secure, ergonomically configured carrying points should be provided for carrying by two or three persons. 7. Safe, reasonably comfortable support of the transported person along with sufficient restraints to maintain that person in the device in case of overturning or other disruption to normal operation. 8. Safe, convenient transfer of the transported person into and out of the device by reasonable trained and competent persons. 9. Device set-up time of no more than 10 seconds from the stored condition to readiness for transfer of the person to be transported. SUBSTANTIATION: For a device to be counted on for reasonable safe, efficient evacuation of persons otherwise unable to use stairs, especially if there is a relationship between such device provision and the buildings stairway design, some guidelines - if not mandatory standards - should be met for design, manufacture, maintenance and operation. This comment provides a draft of such guidelines which will be considered, and improved upon, by a Task Group of the Means of Egress Technical Committee prior to the TC’s deliberation on the comment. COMMITTEE MEETING ACTION: Accept in Principle Replace proposed A.7.2.12.2.3(2) as shown in ROP Proposal 101-433 with the text that follows: A.7.2.12.2.3(2) Stairway descent devices, using stair-bearing belted tracks for example, provide a safer, more effective evacuation option than carrying an occupied wheelchair or other carried device down the stairs and on landings. The use of stair descent devices is recommended even if egress stairway width satisfies a requirement for 48 in. (1220 mm) of minimum clear width between stairway handrails or between a handrail and a landing wall. The design, manufacture, selection, maintenance and operation of such devices should take into account the following recommendations and general guidance information: (1) Minimum carrying capacity of the device should be 300 pounds (136 kg) rated for the maximum permitted stair slope or pitch of 42 degrees or 1.0 unit vertical for 1.1 units horizontal. The rated maximum carrying capacity and maximum stair pitch should be labeled on the device and the device should only be operated within the labeled limits of load and stair slope or pitch. (2) Maximum descent speed, without undue restraint by the operator(s), should be limited by device design to 30 in./sec (760 mm/sec) measured along the slope of the stair. (3) When operated according to manufacturer’s instructions and loaded to its maximum stated capacity, the device should come reliably to a complete stop within a distance of 36 in. (910 mm), measured along the landing or stair slope, on a stair with a slope or pitch within the device’s maximum stated capability. Undue force should not be required to stop the device or, once stopped, to maintain it in a stationary position on the stairs. On walking surfaces other than stairs, the device should maintain a parked position, without rolling, so that the operator can attend to other activity including assisting the passenger to transfer from or to other mobility devices. (4) Slowing or delays when transitioning between stairway landings and stair flights should cause no more than minimal delay to the movement of pedestrians using the stairway in the vicinity of the device and, generally, should not significantly reduce the flow of evacuees using the stairway system. (5) When descending stairs, the device should be easily operable by one or two trained ambulatory adults. Above average weight or strength should not be required for proper operation. Lifting or carrying of the device, when occupied, should normally not be required for descent. (6) Unless designed specifically for use on stairs with non-rectangular treads, with operators trained for such use, the device should be operated only on stairways with straight flights having rectangular treads. On straight flights, the device should be designed to have supporting contact with at least two treads except during the transition between landings and stair flights. (7) The device should be equipped with restraining straps that securely hold the passenger, including arms and legs, to prevent injury. The length and quantity of straps should be designed to accommodate a range of passenger sizes and weights up to the maximum capacity of the device. (8) The seat or seat sling should have open sides and be positioned at an appropriate height to allow transfer with minimal operator assistance. The specific procedure used for a particular transfer should be determined through discussion between the passenger and the operators.

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Report on Comments — Copyright, NFPA NFPA 101 (9) Setup of the device should be described in procedures posted on the device, requiring no other tools or expertise beyond that of available operators, and taking approximately 10 seconds from its storage condition to being set up ready for transfer. (10) In addition to descending stairs, the device should be able to travel across ramped or horizontal surfaces, such as stair landings and hallways, so that it can follow an entire egress route to the exterior of the building. (11) The device’s seating system should provide adequate support of the passenger to minimize the potential for discomfort or injury or discomfort, recognizing also that people with physical disabilities, who will be the main occupants of the device, are often unusually susceptible to pressure related injuries and spasm while being unable to perceive the warning signs of pain. (12) Water on the stairways should have no adverse effect on the operation of the device. (13) If cabinets or storage covers are provided they should include signage or labeling that clearly identifies the device and its use. The device should be readily retrievable from storage without use of a key or special tool. (14) The building evacuation plan should include the location of the devices, a list of trained operators, a matching list of people with disabilities and other critical information as may be required for the building. (15) The manufacturer of the device should provide comprehensive training materials with each device. All designated operators should be trained in accordance with these instructions. Evacuation drills that involve actual use of the device by the designated operators, including transfer and transport of building occupants with disabilities, should occur at least quarterly. (16) The device should be inspected and tested annually in accordance with manufacturer’s recommendations. Preventive maintenance should be performed in accordance to the manufacturer’s recommendations. (17) Device capabilities differing significantly from those spelled out in the foregoing recommendations (such as carrying capacity, higher normal speed and fail-safe braking systems) should be disclosed by the manufacturer in a manner readily known to operators whose training should take this into account. (18) Limitations of the device based on stair nosing geometry and nature of stairway covering should be disclosed by the manufacturer in specifications, operating instructions and labeling. (19) Minimum stairway width requirements, especially at landings where turns occur, should be disclosed by the manufacturer and only devices appropriate to the building’s stairways should be provided in the building. (20) Carrying handles, if installed on the device, should provide secure gripping surfaces and adequate structural and geometric design to facilitate carrying by two or more operators. Carrying might be necessitated by damaged or otherwise irregular walking surfaces that do not facilitate rolling with the device’s wheels or tracks. Carrying might also be necessitated by the existence of an ascending stair along the means of egress, for example in the exit discharge path. (21) Unless specialized operator training is undertaken, use of a stairway descent device on stairways with unusually large treads and on escalators should only be attempted if the device is designed for extra long distance between the tread nosings ([or example, about 16 in. (405 mm) on escalators as opposed to about 12 in. to 13 in. (305 mm to 330 mm) on typical exit stairways]. Such specialized training might entail maintaining a downward force on the device operating handle. COMMITTEE STATEMENT: The expanded annex is a product of a task group of the Technical Committee on Means of Egress. The task group report was revised as needed by the technical committee and appears in the committee action field shown above. The members of the Task Group on Stairway Evacuation Devices are: Joseph Versteeg - Chair, Versteeg Associates, member of the SAF/BLD MEA committee Peter Axelson, Beneficial Designs, Inc. Norm Cooper, Garaventa Accessibility David Egen, EVAC+CHAIR Corp. Philip Favro, Philip C. Favro & Associates, member of the SAF/BLD MEA committee David Frable, US General Services Administration, member of the SAF/BLD MEA committee Edwina Juillet, Fire & Life Safety for People with Disabilities Marsha Mazz, U.S. Access Board Jake Pauls, Consulting Services in Building Use & Safety, member of the SAF/BLD MEA committee Michelle Wigley, Stryker NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-434 Log #296 SAF-MEA FINAL ACTION: Reject (A.7.2.2.5.4.8) _______________________________________________________________ SUBMITTER: Alan Carlson, Jessup Manufacturing Company COMMENT ON PROPOSAL NO: 101-117 RECOMMENDATION: Delete and add text as follows: 7.2.2.5.4.8* Where new contrasting marking is applied to stairs, such marking shall comply with the following:

(1) The marking shall include a continuous strip as a coating on, or a material integral with, the full width of the leading edge of each tread. (2) The marking shall include a continuous strip as a coating on, or as a material integral with, the full width of the leading edge of each landing nosing. (3) The marking strip width, measured horizontally from the leading vertical edge of the nosing shall be consistent at all nosing, (4) The marking strip width shall be 1 in. to 2 in. (25 mm to 51 mm). A.7.2.2.5.4.8 For stair nosing marking, surface applied material, such as adhesive backed tape and magnetic strips, should not be used as it is not durable under the scuffing from users feet and, in coming loose, it creates a tripping hazard. To avoid a potential tripping hazard on the stair nose marking; the use of adhesive backed marking stripes, contrasting color or photoluminescent material, that are manufactured and recommended for use on the specific walking surface. Make sure that they are applied in accordance with the manufacturer’s installation instructions. While a carefully applied and consistently maintained coating is acceptable, contrasting color or photoluminescent material integral with the nosings is preferred because of its permanence. See also 7.1.6.4 and 7.2.2.3.3 for slip resistance uniformity requirements as well as prohibition of projections on the treads. Guidance on the use of photoluminescent marking is provided by ASTM E2030, Guide for Recommended Uses of Photoluminescent (Phosphorescent) Safety Markings. Additional marking, for example, at the side boundaries of the stair, should be applied in accordance with the guidance provided therein. If photoluminescent marking is also provided for handrails, it should be on at least the upper surface of the handrail and should extend the full length of each handrail. SUBSTANTIATION: We wish to commend the committee for understanding the need for adequately marking stair treads for exit stairs. While we fully support the proposed regulation, we do not feel the appendix explanation is consistent with Section 2.3.8.2 of the Manual of Style for NFPA Technical Committee Documents which states: “Caution and warning statements shall only be permitted to be used within the mandatory text sections where a distinct hazard to the user, building, property, exposures, and so forth exists.” We understand the concerns of the committee and feel there is a more positive way in which to state the concern. We feel the attached new wording addresses the concern in a more positive and appropriate manner. Jessup Manufacturing Company has successfully manufactured safety grade non-slip tapes applied to walking surfaces for over 25 years. We use only solvent based industrial adhesives specifically formulated for use on walking surfaces/substrates to insure that the tapes will not be displaced by foot traffic. These non-slip tapes are specifically designed and manufactured for use on walking surfaces. When installed in accordance with the manufacturer’s installation instructions, they will not cause a tripping hazard. Any safety devise not properly installed in accordance with the manufacturers installation instructions can become a hazard. We do not outlaw safety devices simply because we may have seen an improper installation. That is why the authority having jurisdiction is responsible to see that all building safety devices and components are installed in full accordance with the manufacturer’s installation instructions. We must also point out that the committee has no data to support the statement “Tape should not be used as it is not durable under the scuffing from users feet and, in coming lose, it creates a tripping hazard.” Such statements by a fire safety organization without documented substantiation should be reviewed by legal staff. We wish to speak in support of this proposal. Removal of the proposed first sentence of the appendix section will maintain the factual basis and enable us to go forward in full support of this worthwhile proposal. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: See committee statement for the rejection of Comment 101-64. NUMBER ELIGIBLE TO VOTE: 24 BALLOT RESULTS: Affirmative: 24 _______________________________________________________________101-434a Log #CC10 SAF-FUN FINAL ACTION: Accept (A.7.5.2.1) _______________________________________________________________ TCC Action: The Technical Correlating Committee (TCC) notes that SAF-MEA, which has primary responsibility for Chapter 7 and its associated annex, was information balloted on the action by SAF-FUN with 22 in agreement and 1 in disagreement. The TCC permits the action by SAF-FUN to stand.SUBMITTER: Technical Committee on Fundamentals COMMENT ON PROPOSAL NO: 101-35 RECOMMENDATION: Add annex text as follows: A.7.5.2.1 It is not the intent that an area with equipment such as a beverage brewpot, microwave oven, and a toaster be considered a kitchen. SUBSTANTIATION: See Comment 101-16 and Proposal 101-35 which sought to add a definition of Kitchen. The proposed defnition confuses more than clarifies, but guidance is needed so spaces like employee break rooms are not prohibited as serving a means of egress paths. The anex text helps to clarify the issue.

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Report on Comments — Copyright, NFPA NFPA 101 The SAF-FUN committee prepared this comment although primary responsibility for Chapter 7 and its annex belongs to the SAF-MEA committee. The SAF-FUN committee also balloted the action on this comment because it held its meeting just prior to that of SAF-MEA. Staff was unable to prepare the necessary paperwork in time to allow SAF-MEA to act. Per the operating procedures, an informational ballot of the SAF-MEA committee will be conducted, and results reported to the Techncial Correlating Committee on Safety to Life to permit it to judge whether the action should go forward in the ROC. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-434b Log #CC151 SAF-BSF FINAL ACTION: Accept (A.9.6.2.5 (New) ) _______________________________________________________________ SUBMITTER: Technical Committee on Building Service and Fire Protection Equipment COMMENT ON PROPOSAL NO: 101-207 RECOMMENDATION: Add a new A.9.6.2.5 as follows: A.9.6.2.5 The manual fire alarm box required by 9.6.2.5 is intended to provide a means to manually activate the fire alarm system when the automatic fire detection system or waterflow devices are out of service due to maintenance or testing, or where human discovery of the fire precedes automatic sprinkler system or automatic detection system activation. Where the fire alarm system is connected to a monitoring facility, the manual fire alarm box required by 9.6.2.5 should be connected to a separate circuit that is not placed “on test” when the detection or sprinkler system is placed “on test.” The manual fire alarm box should be located in an area that is accessible to occupants of the building, not located in a locked location. SUBSTANTIATION: The proposed annex note is intended to clarify the intent of the fire alarm box required by 9.6.2.5. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 16 Negative: 1 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN EXPLANATION OF NEGATIVE: LARRIMER: If the manual pull station is required, the occupancy chapter should establish the requirement, not Chapter 9. If the fire detection system or water flow devices are out of service due to maintenance or testing, the manual pull station will also be out of service. If it is thought that human discovery of a fire will precede automatic sprinkler or detection activation, then it is the responsibility of the occupancy chapter to mandate manual stations. (Also see my negative comment on 101-141.) The second sentence (Where the fire alarm system is connected to a monitoring facility, the manual fire alarm box required by 9.6.2.5 should be connect to a separate circuit that is not place “on test” when the detection or sprinkler system is placed “on test”.) doesn’t appear to be very practical. My experience is that when you are testing flow switches or detection devices, you disconnect the system from the monitoring station. Adding this recommended design option in the annex will not make it happen. The last sentence identifies that it should be “located in an area accessible to occupants of the building not located in a locked location.” This is clearly a note that would imply that the manual fire alarm box is there for the use of the occupants of the building. Again, if the occupants need a manual fire alarm box to initiate an alarm signal, then the occupancy chapters of the Life Safety Code should (and do) require this to be the case. While I was in favor of identifying why the manual pull station was required, it appears to me that this annex note does not help identify that reason. Therefore, I believe it should be deleted. _______________________________________________________________101-435 Log #215 SAF-BSF FINAL ACTION: Reject (A.9.7.2.1) _______________________________________________________________ SUBMITTER: Kevin J. Kelly, National Fire Sprinkler Association COMMENT ON PROPOSAL NO: 101-232 RECOMMENDATION: Add a new annex note A.9.7.2.1 as follows: A.9.7.2.1 The code does not intend for supervision requirements to be applied to combination domestic/fire protection water tanks. Since if there is a problem with such a tank, it will be known relatively quickly due to the dependence on it for domestic water. SUBSTANTIATION: This is the intent of the tecnical committee as stated in the committee statement. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: Paragraph 9.7.2.1 is clear as written. The proposed annex text is unnecessary. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 15 Negative: 2 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

EXPLANATION OF NEGATIVE: KELLY: The committee statement from proposal 101-232 clarifies that it is not the intent of the code to require supervision requirements on combined domestic/fire protection water tanks. Stating this in the annex will clarify the intent of the committee and avoid confusion. LARRIMER: The paragraph is not clear as was evident during the committee discussions. The Department of Veterans Affairs campuses generally have water tanks that are used for both domestic and fire protection purposes. Based on the reading of NFPA 101, 9.7.2.1 as it is written, I am not sure if these tank levels and temperatures are required to be supervised or not. While I can go to the committee substantiation in the ROP and ROC and read the committee substantiation to see that it is not the intent to supervise combination tanks, accepting comment 101-152 or this comment would allow me to use the code without going to the ROP and ROC. See my negative vote on Comment 101-152. I am not sure why the committee doesn’t want to clarify the requirement in the code with an annex note that would actually be in line with the thoughts stated in the committee substantiation. _______________________________________________________________101-435a Log #CC527 SAF-FUR FINAL ACTION: Accept (A.10.2.4.3.1) _______________________________________________________________ SUBMITTER: Technical Committee on Furnishings and Contents COMMENT ON PROPOSAL NO: 101-247 RECOMMENDATION: Add an annex not to 10.2.4.3.1 to read as follows: A.10.2.4.3.1. Both NFPA 286 and UL 1715 contain smoke obscuration criteria. UL 1040 and FM 4880 do not. Smoke obscuration is an important component of the fire performance of cellular or foam plastic materials. SUBSTANTIATION: This provides advisory information on the test methods that are commonly used in evaluating cellular and foamed plastic materials, and clarifies that the four test methods are not equivalent and that smoke obscuration is a relevant measure of fire. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-436 Log #188 SAF-FUR FINAL ACTION: Accept in Principle (A.10.3.1) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: Revise text to read: A.10.3.1 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of this Code, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: This comment is a proposal that was sent to NFPA 1/UFC (as NFPA 1-137) and was rejected by the technical committee because the material is extracted from NFPA 101. It provides simple clarification, which is probably principally needed by the users of the extract material in the UFC, where the Annex to Sections 10.2 is not included. This language should help users of NFPA 1/UFC distinguish between the uses of NFPA 701 and those of NFPA 255 and NFPA 286. For information, this was the exact wording of 1-137 and 20.1.4.3.2 is shown in the UFC to be extract materials from NFPA 101 in section 10.3.1: “20.1.4.3.2* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the flame propagation performance criteria contained in be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. A.20.1.4.3.2 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame

101-178

Report on Comments — Copyright, NFPA NFPA 101 spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. “ By accepting proposal 101-252, the 101 FUR committee already accepted the terminology issue in the body of the standard. However, it did not consider the changes to the Annex. COMMITTEE MEETING ACTION: Accept in Principle See Committee Comment 101-174a (Log #CC526). COMMITTEE STATEMENT: See Committee Comment 101-174a (Log #CC526). NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11 _______________________________________________________________101-437 Log #252 SAF-FUR FINAL ACTION: Accept in Principle (A.10.3.1) _______________________________________________________________ SUBMITTER: Marcelo M. Hirschler, GBH International COMMENT ON PROPOSAL NO: 101-252 RECOMMENDATION: Revise text as follows: A.10.3.1 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of this Code, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. SUBSTANTIATION: This comment is a proposal that was sent to NFPA 1/UFC (as NFPA 1-137) and was rejected by the technical committee because the material is extracted from NFPA 101. It provides simple clarification, which is probably principally needed by the users of the extract material in the UFC, where the Annex to sections 10.2 is not included. This language should help users of NFPA 1/UFC distinguish between the uses of NFPA 701 and those of NFPA 255 and NFPA 286. For information, this was the exact wording of 1-137 and 20.1.4.3.2 is shown in the UFC to be extract materials from 101 in section 10.3.1: “20.1.4.3.2* Where required by the applicable provisions of this Code, draperies, curtains, and other similar loosely hanging furnishings and decorations shall meet the flame propagation performance criteria contained in be flame resistant as demonstrated by testing in accordance with NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films. A.20.1.4.3.2 Testing per NFPA 701, Standard Methods of Fire Tests for Flame Propagation of Textiles and Films, applies to textiles and films used in a hanging configuration. If the textiles and films are to be applied to surfaces of buildings or backing materials as interior finishes for use in buildings, they should be treated as interior wall and ceiling finishes in accordance with Section 10.2 of NFPA 101, and they should then be tested for flame spread rating index and smoke development developed index values in accordance with NFPA 255, Standard Method of Test of Surface Burning Characteristics of Building Materials (with the appropriate use of sprinklers), or for flame spread and flashover in accordance with NFPA 265, Standard Methods of Fire Tests for Evaluating Room Fire Growth Contribution of Textile Coverings on Full Height Panels and Walls. Films and other materials used as interior finish applied to surfaces of buildings should be tested for flame spread index and smoke developed index values in accordance with NFPA 255 or for heat and smoke release and flashover in accordance with NFPA 286, Standard Methods of Fire Tests for Evaluating Contribution of Wall and Ceiling Interior Finish to Room Fire Growth. “ By accepting proposal 101-252, the 101 FUR committee already accepted the terminology issue in the body of the standard. However, it did not consider the changes to the Annex. COMMITTEE MEETING ACTION: Accept in Principle See Committee Comment 101-174a (Log #CC526). COMMITTEE STATEMENT: See Committee Comment 101-174a (Log #CC526). NUMBER ELIGIBLE TO VOTE: 11 BALLOT RESULTS: Affirmative: 11

_______________________________________________________________101-438 Log #104 SAF-HEA FINAL ACTION: Accept in Principle (A.18.3.2.6) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-410 RECOMMENDATION: Delete existing Annex Note and replace with the following: Extensive research, including fire modeling, has indicated that alcohol-based hand rub solutions can be safely installed in corridors of health care facilities with certain other precautions. The total quantities of flammable liquids in any area should comply with the provisions of other recognized Codes, including NFPA 1 and NFPA 30. In addition, special consideration should be given to the obstructions created by the installation of these dispensers to location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially when mounted on combustible wall construction; to the requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment; and to the amount and location of such flammable gels both in use and in storage, particularly due to leakage or failure of the container. SUBSTANTIATION: While this proposed section has addressed many of the original concerns regarding the installation of these alcohol-based hand sanitizer dispensers, the proposal, as written, contains too many technical errors to be published and enacted as printed. Much, if not all, of the proposed Annex material speaks more to the justification of this proposal and should not be included as a part of the text to be inserted into the Code. While it may serve as useful background information, there is no need to include the history of clinical studies concerning the effectiveness of hand hygiene facilities, the background and results of fire modeling studies, or recommendations made for infection control. There are also assumptions and indications of acceptable test results, threshold limits, tenability values, engineering judgments, field conditions, and needs for further studies that are stated by persons other than the Technical Committee responsible for the document that should not be included without proper source identification and clarification. The last paragraph of the Annex Note also contains an incomplete sentence. Rather, the Annex should be reserved for material that would be useful in the application of Code requirements and further state means and explanation of the requirements written in the Code text. What is missing from the Annex is guidance for the definition of what qualifies as an alcohol-based hand rub solution. In addition, consideration should be given to add Annex material to further explain the total quantities of solution which would be permitted by this section of the Code; that the total amount of flammable liquids, including the alcohol-based hand rub solutions, should not exceed the maximum amounts permitted by other Codes, including NFPA 1; that dispensers would be permitted to be installed only in corridors having a clear width of at least 72 in.; and that dispensers installed in locations with combustible wall or floor coverings should be permitted only in smoke compartments provided with complete automatic sprinkler protection. Additional wording should be included in the Annex which would indicate that dispensers should be located such that flammables cannot be ignited from any external ignition source with consideration to possible container failure or leakage which may permit liquids or gels to come in contact with wall or floor mounted electrical contacts or other equipment or other potential sources of ignition. This proposal still contains no indication of the total amount of flammable liquids that are permitted to be used or stored within a health care facility, and is somewhat misleading to the Code user by ignoring other amounts of such flammable liquids which may be present for reasons other than sanitizing purposes. The amounts of alcohol-based hand rub solution permitted to be present should be included in, and not in addition to, the overall total of flammable liquids present in any fire area. Currently, there are provisions to limit the installation of containers in locations with carpeted floor coverings, however there is no restriction for the installation of containers on wall surfaces that may be of combustible construction or have combustible surfaces. Such surfaces may include wood paneling, vinyl coverings, or even carpet, and seem to pose as significant, if not more of a hazard due to container leakage or other failure. In addition, the requirement for the restriction of dispensers to sprinklered areas of new health care facilities where carpeted floors are present is not necessary since sprinkler protection is required throughout all such facilities. Several new paragraphs also permit the restriction of corridor widths for only the installation of handrub dispensing units. It is unclear why such restrictions can be permitted for these specific devices, and not address other obstructions, such as fire alarm system components, decorations, and lighting fixtures, which are permitted and routinely found as projections into clear corridor widths. This proposal has made great strides in the acceptable means for the installation and protection of alcohol-based hand rub dispensers, however the technical inconsistencies and details which still are not addressed, as well as the unnecessary Annex material included as a part of this proposal requires further work and modifications before being processed. The proposed background material presents compelling evidence that, with certain precautions, this material may be safe and effective to use. However, to reduce this wording to appear in Code text for fire and life safety issues is not proper, and deserves further consideration before being moved forward at this time.

101-179

Report on Comments — Copyright, NFPA NFPA 101 COMMITTEE MEETING ACTION: Accept in Principle Replace the annex text of ROP Proposal 101-410 with the following: A.18.3.2.6 Extensive research, including fire modeling, has indicated that alcohol-based hand-rub solutions can be safely installed in corridors of health care facilities provided certain other precautions are taken. The total quantities of flammable liquids in any area should comply with the provisions of other recognized codes, including NFPA 1, Uniform Fire Code, and NFPA 30, Flammable and Combustible Liquids Code. In addition, special consideration should be given to the following: (1) obstructions created by the installation of such dispensers (2) location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially where containers are mounted on walls of combustible construction (3) requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment (4) amount and location of such flammable solutions both in use and in storage, particularly with respect to potential for leakage or failure of the container COMMITTEE STATEMENT: The action does what the submitter requested, but reformats the material editorially. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-439 Log #105 SAF-HEA FINAL ACTION: Accept in Principle (A.19.3.2(6)) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-445 RECOMMENDATION: Delete existing Annex Note and replace with the following: Extensive research, including fire modeling, has indicated that alcohol-based hand rub solutions can be safely installed in corridors of health care facilities with certain other precautions. The total quantities of flammable liquids in any area should comply with the provisions of other recognized Codes, including NFPA 1 and NFPA 30. In addition, special consideration should be given to the obstructions created by the installation of these dispensers to location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially when mounted on combustible wall construction; to the requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment; and to the amount and location of such flammable gels both in use and in storage, particularly due to leakage or failure of the container. SUBSTANTIATION: While this proposed section has addressed many of the original concerns regarding the installation of these alcohol-based hand sanitizer dispensers, the proposal, as written, contains too many technical errors to be published and enacted as printed. Much, if not all, of the proposed Annex material speaks more to the justification of this proposal and should not be included as a part of the text to be inserted into the Code. While it may serve as useful background information, there is no need to include the history of clinical studies concerning the effectiveness of hand hygiene facilities, the background and results of fire modeling studies, or recommendations made for infection control. There are also assumptions and indications of acceptable test results, threshold limits, tenability values, engineering judgments, field conditions, and needs for further studies that are stated by persons other than the Technical Committee responsible for the document that should not be included without proper source identification and clarification. The last paragraph of the Annex Note also contains an incomplete sentence. Rather, the Annex should be reserved for material that would be useful in the application of Code requirements and further state means and explanation of the requirements written in the Code text. What is missing from the Annex is guidance for the definition of what qualifies as an alcohol-based hand rub solution. In addition, consideration should be given to add Annex material to further explain the total quantities of solution which would be permitted by this section of the Code; that the total amount of flammable liquids, including the alcohol-based hand rub solutions, should not exceed the maximum amounts permitted by other Codes, including NFPA 1; that dispensers would be permitted to be installed only in corridors having a clear width of at least 72 in.; and that dispensers installed in locations with combustible wall or floor coverings should be permitted only in smoke compartments provided with complete automatic sprinkler protection. Additional wording should be included in the Annex which would indicate that dispensers should be located such that flammables cannot be ignited from any external ignition source with consideration to possible container failure or leakage which may permit liquids or gels to come in contact with wall or floor mounted electrical contacts or other equipment or other potential sources of ignition. This proposal still contains no indication of the total amount of flammable liquids that are permitted to be used or stored within a health care facility, and is somewhat misleading to the Code user by ignoring other amounts of such

flammable liquids which may be present for reasons other than sanitizing purposes. The amounts of alcohol-based hand rub solution permitted to be present should be included in, and not in addition to, the overall total of flammable liquids present in any fire area. Currently, there are provisions to limit the installation of containers in locations with carpeted floor coverings, however there is no restriction for the installation of containers on wall surfaces that may be of combustible construction or have combustible surfaces. Such surfaces may include wood paneling, vinyl coverings, or even carpet, and seem to pose as significant, if not more of a hazard due to container leakage or other failure. In addition, the requirement for the restriction of dispensers to sprinklered areas of new health care facilities where carpeted floors are present is not necessary since sprinkler protection is required throughout all such facilities. Several new paragraphs also permit the restriction of corridor widths for only the installation of hand-rub dispensing units. It is unclear why such restrictions can be permitted for these specific devices, and not address other obstructions, such as fire alarm system components, decorations, and lighting fixtures, which are permitted and routinely found as projections into clear corridor widths. This proposal has made great strides in the acceptable means for the installation and protection of alcohol-based hand rub dispensers, however the technical inconsistencies and details which still are not addressed, as well as the unnecessary Annex material included as a part of this proposal requires further work and modifications before being processed. The proposed background material presents compelling evidence that, with certain precautions, this material may be safe and effective to use. However, to reduce this wording to appear in Code text for fire and life safety issues is not proper, and deserves further consideration before being moved forward at this time. COMMITTEE MEETING ACTION: Accept in Principle Replace the annex text of ROP Proposal 101-445 with the following: A.19.3.2.6 Extensive research, including fire modeling, has indicated that alcohol-based hand-rub solutions can be safely installed in corridors of health care facilities provided certain other precautions are taken. The total quantities of flammable liquids in any area should comply with the provisions of other recognized codes, including NFPA 1, Uniform Fire Code, and NFPA 30, Flammable and Combustible Liquids Code. In addition, special consideration should be given to the following: (1) obstructions created by the installation of such dispensers (2) location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially where containers are mounted on walls of combustible construction (3) requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment (4) amount and location of such flammable solutions both in use and in storage, particularly with respect to potential for leakage or failure of the container COMMITTEE STATEMENT: The action does what the submitter requested, but reformats the material editorially. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-440 Log #106 SAF-HEA FINAL ACTION: Accept in Principle (A.20.3.2.6) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-464 RECOMMENDATION: Delete existing Annex Note and replace with the following: Extensive research, including fire modeling, has indicated that alcohol-based hand rub solutions can be safely installed in corridors of health care facilities with certain other precautions. The total quantities of flammable liquids in any area should comply with the provisions of other recognized Codes, including NFPA 1 and NFPA 30. In addition, special consideration should be given to the obstructions created by the installation of these dispensers to location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially when mounted on combustible wall construction; to the requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment; and to the amount and location of such flammable gels both in use and in storage, particularly due to leakage or failure of the container. SUBSTANTIATION: While this proposed section has addressed many of the original concerns regarding the installation of these alcohol-based hand sanitizer dispensers, the proposal, as written, contains too many technical errors to be published and enacted as printed. Much, if not all, of the proposed Annex material speaks more to the justification of this proposal and should not be included as a part of the text to be inserted into the Code. While it may serve as useful background information, there is no need to include the history of clinical studies concerning the effectiveness of hand hygiene facilities, the background and results of fire modeling studies, or recommendations made for infection control. There are also assumptions and indications of acceptable test results, threshold limits, tenability values, engineering judgments, field conditions, and

101-180

Report on Comments — Copyright, NFPA NFPA 101 needs for further studies that are stated by persons other than the Technical Committee responsible for the document that should not be included without proper source identification and clarification. The last paragraph of the Annex Note also contains an incomplete sentence. Rather, the Annex should be reserved for material that would be useful in the application of Code requirements and further state means and explanation of the requirements written in the Code text. What is missing from the Annex is guidance for the definition of what qualifies as an alcohol-based hand rub solution. In addition, consideration should be given to add Annex material to further explain the total quantities of solution which would be permitted by this section of the Code; that the total amount of flammable liquids, including the alcohol-based hand rub solutions, should not exceed the maximum amounts permitted by other Codes, including NFPA 1; that dispensers would be permitted to be installed only in corridors having a clear width of at least 72 in.; and that dispensers installed in locations with combustible wall or floor coverings should be permitted only in smoke compartments provided with complete automatic sprinkler protection. Additional wording should be included in the Annex which would indicate that dispensers should be located such that flammables cannot be ignited from any external ignition source with consideration to possible container failure or leakage which may permit liquids or gels to come in contact with wall or floor mounted electrical contacts or other equipment or other potential sources of ignition. This proposal still contains no indication of the total amount of flammable liquids that are permitted to be used or stored within a health care facility, and is somewhat misleading to the Code user by ignoring other amounts of such flammable liquids which may be present for reasons other than sanitizing purposes. The amounts of alcohol-based hand rub solution permitted to be present should be included in, and not in addition to, the overall total of flammable liquids present in any fire area. Currently, there are provisions to limit the installation of containers in locations with carpeted floor coverings, however there is no restriction for the installation of containers on wall surfaces that may be of combustible construction or have combustible surfaces. Such surfaces may include wood paneling, vinyl coverings, or even carpet, and seem to pose as significant, if not more of a hazard due to container leakage or other failure. In addition, the requirement for the restriction of dispensers to sprinklered areas of new health care facilities where carpeted floors are present is not necessary since sprinkler protection is required throughout all such facilities. Several new paragraphs also permit the restriction of corridor widths for only the installation of hand-rub dispensing units. It is unclear why such restrictions can be permitted for these specific devices, and not address other obstructions, such as fire alarm system components, decorations, and lighting fixtures, which are permitted and routinely found as projections into clear corridor widths. This proposal has made great strides in the acceptable means for the installation and protection of alcohol-based hand rub dispensers, however the technical inconsistencies and details which still are not addressed, as well as the unnecessary Annex material included as a part of this proposal requires further work and modifications before being processed. The proposed background material presents compelling evidence that, with certain precautions, this material may be safe and effective to use. However, to reduce this wording to appear in Code text for fire and life safety issues is not proper, and deserves further consideration before being moved forward at this time. COMMITTEE MEETING ACTION: Accept in Principle Replace the annex text of ROP Proposal 101-464 with the following: A.20.3.2.6 Extensive research, including fire modeling, has indicated that alcohol-based hand-rub solutions can be safely installed in corridors of health care facilities provided certain other precautions are taken. The total quantities of flammable liquids in any area should comply with the provisions of other recognized codes, including NFPA 1, Uniform Fire Code, and NFPA 30, Flammable and Combustible Liquids Code. In addition, special consideration should be given to the following: (1) obstructions created by the installation of such dispensers (2) location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially where containers are mounted on walls of combustible construction (3) requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment (4) amount and location of such flammable solutions both in use and in storage, particularly with respect to potential for leakage or failure of the container COMMITTEE STATEMENT: The action does what the submitter requested, but reformats the material editorially. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR

_______________________________________________________________101-441 Log #107 SAF-HEA FINAL ACTION: Accept in Principle (A.21.3.2.6) _______________________________________________________________ SUBMITTER: Kenneth E. Bush, Office of the Maryland State Fire Marshal COMMENT ON PROPOSAL NO: 101-472 RECOMMENDATION: Delete existing Annex Note and replace with the following: Extensive research, including fire modeling, has indicated that alcohol-based hand rub solutions can be safely installed in corridors of health care facilities with certain other precautions. The total quantities of flammable liquids in any area should comply with the provisions of other recognized Codes, including NFPA 1 and NFPA 30. In addition, special consideration should be given to the obstructions created by the installation of these dispensers to location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially when mounted on combustible wall construction; to the requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment; and to the amount and location of such flammable gels both in use and in storage, particularly due to leakage or failure of the container. SUBSTANTIATION: While this proposed section has addressed many of the original concerns regarding the installation of these alcohol-based hand sanitizer dispensers, the proposal, as written, contains too many technical errors to be published and enacted as printed. Much, if not all, of the proposed Annex material speaks more to the justification of this proposal and should not be included as a part of the text to be inserted into the Code. While it may serve as useful background information, there is no need to include the history of clinical studies concerning the effectiveness of hand hygiene facilities, the background and results of fire modeling studies, or recommendations made for infection control. There are also assumptions and indications of acceptable test results, threshold limits, tenability values, engineering judgments, field conditions, and needs for further studies that are stated by persons other than the Technical Committee responsible for the document that should not be included without proper source identification and clarification. The last paragraph of the Annex Note also contains an incomplete sentence. Rather, the Annex should be reserved for material that would be useful in the application of Code requirements and further state means and explanation of the requirements written in the Code text. What is missing from the Annex is guidance for the definition of what qualifies as an alcohol-based hand rub solution. In addition, consideration should be given to add Annex material to further explain the total quantities of solution which would be permitted by this section of the Code; that the total amount of flammable liquids, including the alcohol-based hand rub solutions, should not exceed the maximum amounts permitted by other Codes, including NFPA 1; that dispensers would be permitted to be installed only in corridors having a clear width of at least 72 in.; and that dispensers installed in locations with combustible wall or floor coverings should be permitted only in smoke compartments provided with complete automatic sprinkler protection. Additional wording should be included in the Annex which would indicate that dispensers should be located such that flammables cannot be ignited from any external ignition source with consideration to possible container failure or leakage which may permit liquids or gels to come in contact with wall or floor mounted electrical contacts or other equipment or other potential sources of ignition. This proposal still contains no indication of the total amount of flammable liquids that are permitted to be used or stored within a health care facility, and is somewhat misleading to the Code user by ignoring other amounts of such flammable liquids which may be present for reasons other than sanitizing purposes. The amounts of alcohol-based hand rub solution permitted to be present should be included in, and not in addition to, the overall total of flammable liquids present in any fire area. Currently, there are provisions to limit the installation of containers in locations with carpeted floor coverings, however there is no restriction for the installation of containers on wall surfaces that may be of combustible construction or have combustible surfaces. Such surfaces may include wood paneling, vinyl coverings, or even carpet, and seem to pose as significant, if not more of a hazard due to container leakage or other failure. In addition, the requirement for the restriction of dispensers to sprinklered areas of new health care facilities where carpeted floors are present is not necessary since sprinkler protection is required throughout all such facilities. Several new paragraphs also permit the restriction of corridor widths for only the installation of hand-rub dispensing units. It is unclear why such restrictions can be permitted for these specific devices, and not address other obstructions, such as fire alarm system components, decorations, and lighting fixtures, which are permitted and routinely found as projections into clear corridor widths. This proposal has made great strides in the acceptable means for the installation and protection of alcohol-based hand rub dispensers, however the technical inconsistencies and details which still are not addressed, as well as the unnecessary Annex material included as a part of this proposal

101-181

Report on Comments — Copyright, NFPA NFPA 101 requires further work and modifications before being processed. The proposed background material presents compelling evidence that, with certain precautions, this material may be safe and effective to use. However, to reduce this wording to appear in Code text for fire and life safety issues is not proper, and deserves further consideration before being moved forward at this time. COMMITTEE MEETING ACTION: Accept in Principle Replace the annex text of ROP Proposal 101-472 with the following: A.21.3.2.6 Extensive research, including fire modeling, has indicated that alcohol-based hand-rub solutions can be safely installed in corridors of health care facilities provided certain other precautions are taken. The total quantities of flammable liquids in any area should comply with the provisions of other recognized codes, including NFPA 1, Uniform Fire Code, and NFPA 30, Flammable and Combustible Liquids Code. In addition, special consideration should be given to the following: (1) obstructions created by the installation of such dispensers (2) location of such dispensers with regard to adjacent combustible materials and potential sources of ignition, especially where containers are mounted on walls of combustible construction (3) requirements for other fire protection features, including complete automatic sprinkler protection, to be installed throughout the compartment (4) amount and location of such flammable solutions both in use and in storage, particularly with respect to potential for leakage or failure of the container COMMITTEE STATEMENT: The action does what the submitter requested, but reformats the material editorially. NUMBER ELIGIBLE TO VOTE: 22 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 5 BROOKS, FREIRE, HARRIS, MILLS, TAYLOR _______________________________________________________________101-442 Log #93 SAF-BSF FINAL ACTION: Accept in Principle (Annex B) _______________________________________________________________ SUBMITTER: Technical Correlating Committee on Safety to Life COMMENT ON PROPOSAL NO: 101-711 RECOMMENDATION: Give consideration, so as to make any needed changes, to deleting proposed A.9.6.3.6.2 given the occupancy chapter technical committees’ Rejection of Proposal 101-712, 101-713, 101-714, 101-715, and 101-716. SUBSTANTIATION: See the above recommendation. COMMITTEE MEETING ACTION: Accept in Principle In the committee action on Proposal 101-711, delete the proposed A.9.6.3.6.2. COMMITTEE STATEMENT: The committee concurs with the occupancy chapters’ rejections of Proposals 101-712, 101-713, 101-714, 101-715, and 101-716. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN

_______________________________________________________________101-443 Log #270a SAF-FUN FINAL ACTION: Accept in Principle (Annex B) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-711 RECOMMENDATION: Delete the fourth sentence from the end of the Committee Meeting Action as follows: In sprinklered buildings, the area of refuge or safe rooms should be separated from each other and adjacent spaces by smoke-resisting partitions. SUBSTANTIATION: This sentence is not consistent with 7.2.13.3.4 of NFPA 101 from which some of this text is extracted. The separations provided for an area of refuge need to have some minimum degree of fire resistance even in a sprinklered building. As noted in the sentence above this one, the minimum fire resistance rating for such barriers in existing buildings is 30 minutes. Otherwise, the fire resistance rating is required to have a minimum of one hour fire resistance. Furthermore, the term “smoke-resisting” is not consistent with terminology used elsewhere in NFPA 101 nor is it defined. COMMITTEE MEETING ACTION: Accept in Principle Reject Proposal 101-711 so as to NOT add the new A.9.6.3.6.2. COMMITTEE STATEMENT: As noted in Comment 101-442 from the Technical Correlating Committee to SAF-BSF, the new annex should not be adopted because the occupancy technical committees rejected the proposal. NUMBER ELIGIBLE TO VOTE: 23 BALLOT RESULTS: Affirmative: 21 BALLOT NOT RETURNED: 2 ALLEN, WATTS _______________________________________________________________101-444 Log #270b SAF-BSF FINAL ACTION: Accept in Principle (Annex B) _______________________________________________________________ SUBMITTER: Rick Thornberry, The Code Consortium, Inc. / Rep. Alliance for Fire and Smoke Containment and Control COMMENT ON PROPOSAL NO: 101-711 RECOMMENDATION: Delete the fourth sentence from the end of the Committee Meeting Action as follows: In sprinklered buildings, the area of refuge or safe rooms should be separated from each other and adjacent spaces by smoke-resisting partitions. SUBSTANTIATION: This sentence is not consistent with 7.2.13.3.4 of NFPA 101 from which some of this text is extracted. The separations provided for an area of refuge need to have some minimum degree of fire resistance even in a sprinklered building. As noted in the sentence above this one, the minimum fire resistance rating for such barriers in existing buildings is 30 minutes. Otherwise, the fire resistance rating is required to have a minimum of one hour fire resistance. Furthermore, the term “smoke-resisting” is not consistent with terminology used elsewhere in NFPA 101 nor is it defined. COMMITTEE MEETING ACTION: Accept in Principle See the action on Comment 101-442. COMMITTEE STATEMENT: A.9.6.3.6.2 is deleted in its entirety by the action on Comment 101-442. NUMBER ELIGIBLE TO VOTE: 20 BALLOT RESULTS: Affirmative: 17 BALLOT NOT RETURNED: 3 BROWN, MCDANIEL, WREN