Yes, that's it in a nutshell, Jeff- none of the others apply. The AHJ should
NOT go to the NRC guidelines for pipe protection to apply to our apt
building.

Also, the UCC section chief at L&I in Harrisburg agrees with me, also. 
We sized the nail plates by buying em from Caddy.

glc

From: Balson, Jon [mailto:[email protected]] 
Sent: Friday, April 17, 2009 11:01 AM
To: '[email protected]'
Subject: RE: UCC, IPC, IMC and spkrs

George:
 
We would say that he/she is wrongly interpreting/applying the code, but if
he/she persists, the only statutorily provided means of resolving this is to
file an appeal with the local appeals board (L&I was given no authority to
render binding interpretations, except where the Department has
jurisdiction.)
 
We base our position on the following:
 
The IPC-2006 scoping section says the following at section 101.2:
 
The provisions of this code shall apply to the erection, installation,
alteration, repairs, relocation, replacement, addition to, use or
maintenance of plumbing systems within this jurisdiction. This code shall
also regulate nonflammable medical gas, inhalation anesthetic, vacuum
piping, nonmedical oxygen systems and sanitary and condensate vacuum
collection systems. The installation of fuel gas distribution piping and
equipment, fuel-gas-fired water heaters and water heater venting systems
shall be regulated by the International Fuel Gas Code. Provisions in the
appendices shall not apply unless specifically adopted. [Note: no mention of
sprinkler systems or fire-protection systems, etc.]
 
 
Further, Chapter 3 of the IPC-2006 defines "plumbing" as:
 
The practice, materials and fixtures utilized in the installation,
maintenance, extension and alteration of all piping, fixtures, plumbing
appliances and plumbing appurtenances, within or adjacent to any structure,
in connection with sanitary drainage or storm drainage facilities; venting
systems; and public or private water supply systems. [Note: no mention of
sprinkler systems or fire-protection systems, etc.]
 
 
The scope of the IMC-2006 is defined at section 101.2 as:
 
This code shall regulate the design, installation, maintenance, alteration
and inspection of mechanical systems that are permanently installed and
utilized to provide control of environmental conditions and related
processes within buildings. This code shall also regulate those mechanical
systems, system components, equipment and appliances specifically addressed
herein. [Underlining added for emphasis.  Note also that the IMC does not
address sprinkler systems.]
 
 
 
Jon C. Balson | Chief, UCC Division
Bureau of Occupational & Industrial Safety
PA Department of Labor & Industry
651 Boas Street | Harrisburg, PA 17121
Phone: 717.346.2729 | Fax: 717.787.8363
www.dli.state.pa.us/codes
Auxiliary aids and services are available on request to individuals with
disabilities.
Equal Opportunity Employer/Program
-----Original Message-----
From: George Church [mailto:[email protected]] 
Sent: Friday, April 17, 2009 9:57 AM
To: Balson, Jon
Subject: UCC, IPC, IMC and spkrs
Jon:
Is it the intent of the PA UCC that the IPC and IMC apply to sprinkler
piping in a building?

I could understand the backflow and in some cases, the incoming service
coming under the IPC. 

But I have a 3rd party AHJ that is attempting to invoke 305.8 from the IPC
and 301.8 from the IMC, and I'm quite surprised that if these codes applied
to our work, I'd know about it by now.

I'd think that at some point- the control valve isolating the sprinkler
system from a combined service, for example- the rules and regs of the IPC
and/or IMC would no longer apply and the IFC and applicable NFPA
installation standard- in this case NFPA #13R- would apply. 

Am I correct it is NOT the intent of the PA UCC to apply the IMC and IPC to
sprinkler piping in buildings?

George L. Church, Jr.
President
Rowe Sprinkler Systems, Inc.
7993 US Hwy 522
PO Box 407
Middleburg, PA 17842
570-837-7647
570-837-6335 fax
[email protected]

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Jeff Hewitt
Sent: Friday, April 17, 2009 11:40 AM
To: [email protected]
Subject: RE: IMC, IPC and nail plates

I think you are missing the point.

You have found the references within each Code, but do the Codes apply to
Fire Suppression piping?

Read the SCOPE of each document and you will find that it does NOT include
Fire Suppression piping.

Jeff Hewitt, PE, SET, SFPE (Professional Member)
Corporate Engineer
Bi-State Fire Protection Corporation
241 Hughes Lane
St. Charles, MO  63301

636-946-0011
636-946-5172 (fax)
314-574-6989 (cell)

Fire Sprinklers Save lives.
Can You Live Without Them?

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Thom McMahon
Sent: Friday, April 17, 2009 10:28 AM
To: [email protected]
Subject: RE: IMC, IPC and nail plates


IPC 2006
305.8 Protection against physical damage. In concealed
locations where piping, other than cast-iron or galvanized steel,
is installed through holes or notches in studs, joists, rafters or
similar members less than 1.5 inches (38 mm) from the nearest
edge of the member, the pipe shall be protected by shield plates.
Protective shield plates shall be a minimum of
0.062-inch-thick (1.6 mm) steel, shall cover the area of the pipe
where the member is notched or bored, and shall extend a minimum
of 2 inches (51 mm) above sole plates and below top
plates.

IMC 2006
305.5 Protection against physical damage. In concealed
locations where piping, other than cast-iron or steel, is installed
through holes or notches in studs, joists, rafters or similar members
less than 1.5 inches (38 mm) from the nearest edge of the
member, the pipe shall be protected by shield plates. Protective
shield plates shall be a minimum of 0.062-inch-thick (1.6 mm)
steel, shall cover the area of the pipe where the member is
notched or bored, and shall extend a minimum of 2 inches (51 mm) above 
sole plates and below top plates.

Here's how we deal with this. 
We nail plate the sole plates(one or up to 3 depending on the construction,
houses with gypcrete floors typically have an extra plate or two depending
upon how thick the gyp is.) and slip a steel sleeve around the riser coming
thru the plate.(We find we have enough scrap pipe around to keep a constant
supply of 8" sleeves. We use 8" because we have base moldings here that go
to 10" high on occasion.)

Most walls we see are double plates at the top. Only the upper plate is the
actual "Top Plate" the second plate has a name I forget right now. Any way
we nail plate both plates and have our "Nominal" 2" below the top plate.
We've never had any problem with doing this from any inspector.


Thom McMahon, SET
Firetech, Inc.
2560 Copper Ridge Dr
P.O. Box 882136
Steamboat Springs, CO 80488
Tel:  970-879-7952
Fax: 970-879-7926



-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of George Church
Sent: Friday, April 17, 2009 7:59 AM
To: [email protected]
Subject: IMC, IPC and nail plates

Had an interesting encounter with an AHJ this week.
He stopped by a jobsite where we're installing CPVC in walls, and found
fault with the nail plates we're using.
I called to follow up on why he didn't like them, and asked for a code
reference. He replied even if it wasn't in the code, he'd enforce nailplates
extending further than ours as a safety issue. So I reminded him that his
authority was to enforce the PA UCC as adopted, not safety issues he took a
personal liking to. 

His code reference arrived by USPS this AM. He cited the IPC and IMC as
applicable to sprinkler piping, which I disagree with.

Any thoughts or previous rulings by other AHJs?

George Church
Rowe Sprinkler

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