Rather than agree or disagree, I'll ask you to step away from #13 and come
over to #13R, the venue where this is being played out. It's a 3-story apt
building under #13R, so #13 only applies as it is brought in by #13R.
Protection of piping from #13 is NOT brought into #13R anywhere (we're in
#13R 2002 edition, BTW) so the #13 requirements for protection of piping are
as applicable to a #13R installation as the #13 requirements for protecting
an attic- they simply do not apply.

If there is NO requirement for protecting our piping from mechanical injury
(drywall screw) then we're not bound to provide them. Do I think it is
important to protect against them? Yes. Are we taking reasonable steps to do
so, at our own option and exceeding the code? Yes. Does this mean I have to
invoke how to protect the piping from a non-referenced standard? No.

If we decided to toss a head at the top of the trash chute on the 4th floor
of a #13R hotel, despite the lack of a requirement to provide protection in
building service chutes, simply because we want to do so, does this mean we
HAVE to install one on the 2nd floor as well, since #13 would have us start
at the top and provide them on alternate floors? I don't see how, any more
than providing something like this head per #13 at the top level means the
corridor protection would have to be delivered at .1 instead of per the
residential head requirements, or providing attic protection above that 4th
floor trash chute head.

Understand the AHJ stated that "even if it isn't in the code, I'm going to
require them because I think it is a safety issue". Sorry, the PA UCC
doesn't have a list of safety issues AHJs can enforce and he doesn't have a
local amendment either. So I pointed out that as a BCO he can enforce the
adopted law and that is all he can do.

Naturally this is one of two projects we have in this jurisdiction, the
other is a new FD station. Ironically the chief was arguing with Ken about
the need for protection of a walk-in cooler and freezer that are outside the
building, but entered at the common wall. We're installing a 2-head AF loop
for it, he's arguing no protection is required for a storage area. Holy role
reversal!

It will be interesting to see if I need to drive down for an appeal mtg.

glc

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Chris Cahill
Sent: Friday, April 17, 2009 1:39 PM
To: [email protected]
Subject: RE: IMC, IPC and nail plates

Well then we agree we disagree, not a problem.  Would be a better world if
every agreed with me (mwahahahaha) but it would also be boring, lol.  

Right or wrong I did something similar once as an AHJ and for my life can't
recall the specifics. I did win in that in the end the issue was resolved my
way.  Never got to a judge I'll admit.  I only lost once as an AHJ on a
standpipe issue and a man of God representing the Cathedral was on the other
side of the table.  Up against God I knew I didn't really have a chance.  

My full code path is from the '02 NFPA 13 3.5.5 definition of a riser to
8.15.4 requirement to protect risers by...other approved means.  No place in
13 describes how to protect so I look in the Code that adopts the standard
and find nothing.  Which then invokes 102.7 and off to the IPC/FM/other NFPA
documents/listings.  

I believe the reliability of the sprinkler system does fit into the overall
scope of the IFC.  But the use of those sections can be more specific.  Even
if you don't like the IFC sections the AHJ still has George by the short
hairs with 8.15.4 other approved means.  He's saying the other approved
means is IPC/IMC.  Think the judge is going to overrule.  I don't. Certainly
seems reasonable to use another reference on how to that has the exact same
purpose - to protect pipe from damage.  It would be up to George to come up
with something within our family of codes and standards to refute going
outside.  Sorry George but if it gets to court I don't see you winning.  I
promise I'm not for hire to the AHJ or his legal team.  

Don't get me wrong a simple nail plate from the average home improvement
store is sufficient for nearly all applications IMHO.  Going to the
specificity of the IPC/IMC seems a little ridiculous.        

Chris Cahill, P.E.
Fire Protection Engineer
Sentry Fire Protection, Inc.
 
763-658-4483
763-658-4921 fax
 
Email: [email protected]
 
Mail: P.O. Box 69
        Waverly, MN 55390
 
Location: 4439 Hwy 12 SW
              Waverly, MN 55390

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Jeff Hewitt
Sent: Friday, April 17, 2009 11:59 AM
To: [email protected]
Subject: RE: IMC, IPC and nail plates

Chris,

I respectfully disagree,

IFC 2006 102.7 and 102.8 can only be applied within the overall SCOPE of the
entire IFC document which is limited to Fire Suppression conditions, not
Mechanical, and not Plumbing.  The Scope is found in IFC 2006 101.2

Also, according to IFC 2006 102.6 Referenced Codes and Standards, 

        "the codes and standards referenced in this code shall be those that
are listed in Chapter 45 and such codes and standards shall     be
considered part of the requirements of this code to the prescribed extent of
each such reference."

The commentary to IFC 2206 102.6 states: 

        "the application of referenced standards is limited to those
portions of the standards that are specifically identified."

Please note that in IFC 2006 Chapter 45, where the reference standards and
codes are listed, IPC 2006 305.8, and IMC 2006 305.5 are NOT specifically
listed/referenced.  


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 Chris Cahill
Sent: Friday, April 17, 2009 10:53 AM
To: [email protected]
Subject: RE: IMC, IPC and nail plates

Does our family of codes go into this level of detail?  If not and I don't
think it does, the authority for the AHJ to use what Thom quoted is IFC
102.7 or IFC 102.8.   

Chris Cahill, P.E.
Fire Protection Engineer
Sentry Fire Protection, Inc.
 
763-658-4483
763-658-4921 fax
 
Email: [email protected]
 
Mail: P.O. Box 69
        Waverly, MN 55390
 
Location: 4439 Hwy 12 SW
              Waverly, MN 55390

-----Original Message-----
From: [email protected]
[mailto:[email protected]] On Behalf Of Jeff Hewitt
Sent: Friday, April 17, 2009 10:40 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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