Excellent code analysis/decision tree formation Duane. And I still think we need to work hard to put this idea of code versus standard, where the one trumps the other because of a word in the title, even when the one given the greater weight references the other as part of itself. I once had an AHJ tell me there was no such thing as limited combustibility because some unrelated chapter in IBC only mentioned non-combustibility so that the silence in that section on limited combustibility trumped the rules in 13 (and 13 was an adopted reference) because 13 was "only a standard." This is the kind of stuff I have bad dreams about. And Curtis, funny comment, but often analysis of the simplest thing provides a platform for clearly seeing much larger issues. I'm not saying this closet issue is a big deal but Galileo gazed at the heavens with his "looking tube" and saw four moons orbiting Jupiter. The direct result was Copernicus, Kepler, Newton and a totally new world.
On Fri, Oct 5, 2012 at 6:54 AM, Curtis Tower < cur...@centralfireprotection.net> wrote: > I don't think anyone could ever foresee just how much discussion could be > generated from a space barely large enough to store a vacuum cleaner > in...[chuckles under breath]. > > ----- Original Message ----- From: "Johnson, Duane (NIH/OD/ORS) [C]" < > johnson...@mail.nih.gov> > To: <sprinklerforum@firesprinkler.**org <sprinklerforum@firesprinkler.org> > > > Sent: Friday, October 05, 2012 8:24 AM > Subject: RE: Stupid closet question... > > > > Based on NFPA 13, 2010 edition and NFPA 101, 2009 edition. > > Annex D is not part of the enforceable section of NFPA 13, unless a > jurisdiction specifically adopts it (see section heading). In this case, > Annex D is copied from NFPA 101, so if a jurisdiction adopts NFPA 101, it > is enforceable from that perspective, but I would go do NFPA 101 directly, > not Annex D of NFPA 13. > > As for the differences in requirements, per NFPA 101:1.2 the purpose of > this code is to provide safety to life from fire while NFPA 13:1.2 has a > purpose to provide a reasonable degree of protection for life and property. > The two codes have slightly different purposes, hence they may have > different design requirements for sprinklers. The committee agreed in the > 2009 ROP to move NFPA 101 requirements to the Annex (see proposal 13-444). > > More importantly, the paragraphs you mention are for different > occupancies. The exception from NFPA 13:8.15.8.2 to eliminate sprinklers in > closets not exceeding 24 sq. ft. is for Hotels and Motels only. The > exception from Annex D or NFPA 101:30.3.5.4 to exclude sprinklers in > closets 12 sq. ft. or less is for New Apartments only. Interestingly, NFPA > 101:31.3.5.4 permits the exclusion of sprinklers in closets not exceeding > 24 sq. ft. for Existing Apartments. So, in reality, the NFPA 13 and Annex D > references you cited do not contradict because they are for different > occupancies. However, if you look at NFPA 101:29.3.5.5, Existing hotels and > Dorms have the exception to exclude sprinklers in closets not exceeding 24 > sq. ft. But this is for Existing Hotels and Dorms only, there is not an > exception in NFPA 101 for New Hotels and Dorms. This is arguably a > difference from NFPA 13 to NFPA 101. > > Duane Johnson, PE > Program Manager > Division of the Fire Marshal (Support Contractor) > Office of Research Services > National Institutes of Health > 301-496-0487 > > "Protecting Science - One Sprinkler at a Time" > > > -----Original Message----- > From: Curtis Tower > [mailto:curtis@**centralfireprotection.net<cur...@centralfireprotection.net> > ] > Sent: Monday, October 01, 2012 2:49 PM > To: sprinklerforum@firesprinkler.**org <sprinklerforum@firesprinkler.org> > Subject: Re: Stupid closet question... > > Of course, I was only speaking of "adopted" codes. I'm not familiar with > all of the various code sets available for a jurisdiction to consider; > however, the prevalent code set in Texas is IFC. IFC references NFPA 13 > and > 13R specifically for its installation requirements. What I was ultimately > alluding to was that if a jurisdiction had adopted NFPA 101, then it > appeared that closets < 12s.f. could be omitted. This question came up > from > a chapter contained in NFPA 2007, Special Occupancy Requirements, Section > 21.20.13.2.1. At the end of the sub-section NFPA 101, 30.3.5.4 was > bracketed. It is my understanding that a fair amount within that chapter > was erroneously included in the 2007 standard. Fast forward to the 2010 > Edition, and it was moved to a new Annex D. I think this was to try to > alleviate any confusion on what was required. Annex D was titled Sprinkler > System Information from the 2009 Edition of the Life Safety Code. My > understanding is that if the adopted code is anything other than NFPA 101, > then the exceptions and omissions stated withing Annex D may and probably > do > not apply. Of course, I'm always open to debate. > > Curtis > > > ----- Original Message ----- From: "Ron Greenman" <rongreen...@gmail.com> > To: <sprinklerforum@firesprinkler.**org <sprinklerforum@firesprinkler.org> > > > Sent: Thursday, September 27, 2012 6:26 PM > Subject: Re: Stupid closet question... > > > This is the conventional wisdom Curtis but I disagree. All model codes and > standards are simply books until adopted, no matter what they are called. > I'll use Washington as an example: The Revised Code of Washington (RCW) > stipulates there will be a building code. The Building Code itself derives > from the International Building Code (currently the 2009 edition) and all > the references and amendments as proposed by the State Building Code > Council as submitted to the governor and adopted by the legislature. In its > final form it is called the Washington Administrative Code (WAC) Chapter > 51-50, although we'll refer to it as the IBC in conversation. In the end > though, before adoption it has no power of enforcement and after after > adoption a referenced standard is a part of the WAC. So when chapter 9 of > IBC references NFPA 13 and is adopted that way then NFPA 13 is a very long > part of WAC 51-50, not some child of a lesser god. Had the legislature > decided to not adopt the chapter 9 reference to NFPA 13 in IBC, but instead > had replaced it with Hop On Pop or Cat In the Hat then that would be the > sprinkler rules and criterion within 51-50. That a "code" tells you when > and a "standard" tells you how is essentially a correct statement that only > applies as separate and hierarchical as long as they are co-joined as one > thing under the Law. Once adopted chapter 9, section X (I forget the number > off-hand) is the code and, if sprinklers are required per Chapters 3 & 6, > contains the how rules for installation. NFPA 101 unadopted is merely a > very boring book and has no force of law no matter what the title may say > about code, standard, what have you. > > > On Thu, Sep 27, 2012 at 2:13 PM, Curtis Tower < > curtis@centralfireprotection.**net <cur...@centralfireprotection.net>> > wrote: > > I believe that the root of the confusion stems from semantics. NFPA 101 >> is referred to as a code, where NFPA 13, 13R, etc., is referred to as a >> standard. Many times, I have heard those of us in the business use the >> term 'code' interchangeably with the term 'standard'. This is technically >> incorrect. >> >> Gov't entities have a plethora of code sets to choose from when deciding >> what to adopt. Most incorporated cities in Texas have adopted one version >> or another of IFC, most with local amendments. Tarrant County, which >> oversees the unincorporated sections surrounding the Fort Wort area, has >> adopted NFPA 101. >> >> To simplify things a bit... >> >> Code says WHAT gets sprinklered. >> >> The Standard says HOW. >> >> Example: NFPA 13R does not require balconies to be sprinklered; however, >> if the adopted code is IFC 2006, for example, then the balconies will be >> sprinklered. >> >> In summation, your honor. >> >> If a jurisdiction has adopted NFPA 101, then it appears that the 12 s.f. >> closet can be omitted. By most other codes that I'm aware of, under NFPA >> 13, the closets will be sprinklered regardless of size, with the exception >> of hotels and motels under the stated criteria. >> >> >> >> ----- Original Message ----- From: "C&H Fire - Mike Gallello" < >> mgalle...@chfireinc.com> >> To: <sprinklerforum@firesprinkler.****org <sprinklerforum@firesprinkler.* >> *org <sprinklerforum@firesprinkler.org>> >> > >> Sent: Wednesday, September 26, 2012 3:25 PM >> Subject: Stupid closet question... >> >> >> It's likely been asked before, but I don't recall - so please excuse my >> possible ignorance! >> >> NFPA 13, 2010 - 8.15.8.2 Dwelling units, closets - hotels and motels >> they can be deleted, conditionally regarding the 24sf and 3ft rule. >> >> Annex D (Pulled from NFPA 101) in two separate areas (D1.1.6.1 & >> D2.19.2.1) states that closets under 12sf in dwelling units shall not be >> required to be sprinklered. The referenced 101 code is stated there as >> well... >> >> I'm looking at it that the paragraphs of 101 referencing closets under >> 12sf in dwelling units permits the omitting of sprinklers within these >> closets. (Not any with equipment of course). There are some others >> here that disagree, stating that since 13 addresses it, 101 isn't >> applicable and that heads are required in the closets period. >> >> Anyone else have this kind of throw down in your offices? >> >> >> >> ______________________________****_________________ >> Sprinklerforum mailing list >> Sprinklerforum@firesprinkler.****org >> <Sprinklerforum@firesprinkler.**org<Sprinklerforum@firesprinkler.org> >> > >> http://fireball.firesprinkler.****org/mailman/listinfo/**** >> sprinklerforum<http://**fireball.firesprinkler.org/**mailman/listinfo/** >> sprinklerforum<http://fireball.firesprinkler.org/mailman/listinfo/sprinklerforum> >> > >> >> > > > -- > Ron Greenman > Instructor > Fire Protection Engineering Technology > Bates Technical College > 1101 So. Yakima Ave. > Tacoma, WA 98405 > > rgreen...@bates.ctc.edu > > http://www.bates.ctc.edu/**fireprotection/<http://www.bates.ctc.edu/fireprotection/> > > 253.680.7346 > 253.576.9700 (cell) > > Member: > ASEE, SFPE, ASCET, NFPA, AFSA, NFSA, AFAA, NIBS, WSAFM, WFC, WFSC > > They are happy men whose natures sort with their vocations. -Francis Bacon, > essayist, philosopher, and statesman (1561-1626) > -------------- next part -------------- > An HTML attachment was scrubbed... > URL: > <http://fireball.**firesprinkler.org/mailman/**private/sprinklerforum/** > attachments/20120927/a28e453c/**attachment.html<http://fireball.firesprinkler.org/mailman/private/sprinklerforum/attachments/20120927/a28e453c/attachment.html> > > > > > ______________________________**_________________ > Sprinklerforum mailing list > Sprinklerforum@firesprinkler.**org <Sprinklerforum@firesprinkler.org> > http://fireball.firesprinkler.**org/mailman/listinfo/**sprinklerforum<http://fireball.firesprinkler.org/mailman/listinfo/sprinklerforum> > > > ______________________________**_________________ > Sprinklerforum mailing list > Sprinklerforum@firesprinkler.**org <Sprinklerforum@firesprinkler.org> > http://fireball.firesprinkler.**org/mailman/listinfo/**sprinklerforum<http://fireball.firesprinkler.org/mailman/listinfo/sprinklerforum> > -- Ron Greenman Instructor Fire Protection Engineering Technology Bates Technical College 1101 So. 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