I'm close to going postal. It's been over a year since I posed a question to PA's departments of Health and Labor & Industry, and we've still yet to receive other than conflicting direction. I'm sure this occurs in other jurisdictions throughout the US and maybe someone has solved this, it certainly is not unique to PA.
Summary: PA DOH enforces compliance with the 1999 edition of NFPA 13 because it is the referenced edition in the 2000 Life Safety Code used by the Centers for Medicare and Medicaid Services (Federal Health and Human Services). Both PA DOH and CMS itself have reiterated clearly that they will accept ONLY compliance with the 1999 edition; they really don't care if a newer code is deemed equal or better protection by NFPA, or what edition of NFPA 13 is referenced by the applicable local building code. PA's Dept of Labor and Industry is charged with administration and enforcement of the PA Uniform Construction Code, now based on the 2009 I-Codes, so NFPA 13-2007 edition is now our standard. Under Pennsylvania law, all facilities that are regulated by the Health Care Facilities Act must also comply with the requirements of the Pennsylvania Construction Code Act and its regulations. Quandry: So- how do we design a system to simultaneously comply with both 1999 and (for now) 2007 editions of NFPA 13? We cannot comply simply with the more recent standard as equal or better, that'd be too easy. CMS and DOH have both stated this is unacceptable. Now we're certainly not the only sprinkler contractor doing work in health care and nursing homes where CMS mandates apply- i.e., anywhere reimbursement for services is covered by Medicare and/or Medicaid. And PA is not the only state adopting a code with post-1999 #13 as the adopted standard. What are the rest of you doing to comply? George Church Rowe Sprinkler _______________________________________________ Sprinklerforum mailing list [email protected] http://fireball.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)
