I want to be able to design a system to ONE edition of NFPA 13. Is that an unreasonable request? Otherwise rather than designing, we're cross-referencing our way thru a layout, applicable code line by line.
Have you EVER seen a system with multiple editions of the same code referenced in your life? If not, then it would be "unusual". Plus, we'd have to answer the same question posed by different AHJs with different code references.... Understand at one point it sounded as if the DOH would accept the most STRINGENT of both editions. When I pointed out that a registered design professional, hopefully an FPE, would have to go thru both codes and itemize the differences and point to which one to use in each case, a herculean task I doubted DOH had the internal horsepower to do- and then he said No, we have no intention of doing that- YOU'D have to do that. Ok, my response was then the applicable code for health care on this particular project isn't written in black and white where we can refer to it, it exists only as a hybrid of two editions and is based on the OPINION of the RDP making the determination. I've got about zero interest in assuming the responsibility of determining which sentences are most stringent in two different editions simply because two AHJs can't agree on ONE requirement for A building. Does it seem odd that a hybrid opinion would be the state law as applied to a building? And that it might change depending upon whose analysis we use? And how many FPEs want to assume such a role, how much would it cost? Bill B, you've been around the DOH and VA systems a bit, and have seen #13 progress over a few decades, and have worked with us on some projects. Would this be something you'd like to estimate a cost on, and is it a duty you'd want to assume? I think Roland would refer to this opportunity as RLH (run like heck!). glc -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Thom McMahon Sent: Thursday, January 28, 2010 11:22 AM To: [email protected] Subject: RE: Quandry-design to two editions of 13? G: Is there a specific issue of conflict? 90% of 99 is still the same in 2007 as it would apply to healthcare facilities. Storage is a lot different, but not room design, Area Density or residential design/light hazard. What exactly do you want to do that 2007 would allow, that 99 won't? 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 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? George Church _______________________________________________ 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) _______________________________________________ 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)
