George, Your discussion reminds me very much of a couple of extremely troubling episodes here in California.
With the advent of the 2007 edition of NFPA-13 one local jurisdiction adopted it immediately, and had as an effective date 01/01/08. Unfortunately the fire marshal in one district decided that such an adoption meant that project which were not "signed off" and issued a c/o, even if they had been fully permitted and approved under the '02, must now be upgraded to comply with the provisions of the '07 edition. This manifested itself in a "ban" on the use of other than schedule 40 or schedule 10 pipe for mains in a sprinkler system as the tables in 9.3.5.3.2 (a) and (b) only covered those types of pipe. His interpretation was that it was an "implied" requirement from NFPA-13 that only those types be allowed for mains. He took the extraordinary (in my view) action of both advising the regional distributor for Dyna-Flow not to ship it to his jurisdiction and refusing to issue a c/o to any project underway unless Dyna-flow mains were removed and replaced with either schedule 40 or schedule 10. In the face of letters from several individuals from NFPA, AFSA, and OSHPD he was unmoved. Another example of this was a situation that developed here in March. The agency responsible for oversight of construction of public schools here has four separate regional offices, and unfortunately there is a wide range of criteria which are above and beyond those established by NFPA-13, and very little consistency between the offices. A decision was made at the San Diego office in March which had huge repercussions, in the middle of a project, and quite out of the blue. When it was learned that the individual making the requirement had the backing of the San Diego office manager, the information was incorporated into an email notice and sent to every local organization of contractors and vendors who might be able to spread the word. As a courtesy, that message was also sent to the headquarters office of that agency. Twenty-four hours later that policy was rescinded, and another release was emailed out, explaining that the original decision was made without consideration of the parameters of the design criteria for sprinkler systems, and that on this particular topic a strict adherence to NFPA-13 requirements was acceptable by this agency. Both are classic examples of the same kind of thinking you're describing with the individual you're dealing with there in PA. He couldn't find a specific requirement in the applicable documents to support his position, yet was willing to attempt to enforce it because he thought it was a safety issue. Most of the contractors I deal with here and in other parts of the country don't have any real problem following the requirements of the adopted standard, and local or state modifications, provided they are clearly indicated during the bid process. It is the "out of the blue" criteria which costs us dearly, and delays project completion, particularly in the vise-like economic times we're currently experiencing. Please keep us informed as to how this turns out. PARSLEY CONSULTING Ken Wagoner, SET 760.745.6181 voice 760.745.0537 fax [email protected] <mailto:[email protected]> e-mail www.ParsleyConsulting.com <http://www.ParsleyConsulting.com> website George Church wrote: > 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 > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > _______________________________________________ > Sprinklerforum mailing list > http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum > For Technical Assistance, send an email to: [email protected] > > To Unsubscribe, send an email to:[email protected] > (Put the word unsubscribe in the subject field) > > > _______________________________________________ Sprinklerforum mailing list http://lists.firesprinkler.org/mailman/listinfo/sprinklerforum For Technical Assistance, send an email to: [email protected] To Unsubscribe, send an email to:[email protected] (Put the word unsubscribe in the subject field)
