From:

Subject: CTC VO SG

Date: May 8, 2008 11:53:15 PM PDT

To: , , , , , , ,

Cc: , , ,

Hello All:

With only four hours to discuss matters in Baltimore, I thought that I would respond to comments offered by various parties in opposition to FS162, as modified. Hopefully, I can clarify some of the points raised and save us some time at our upcoming meeting.

Response to Intercode Incorporated letter, dated May 1, 2008:

A number of individuals volunteered to serve on this Study Group, which as it turns out, represented a polarity of opinions as to what the code actually says today, and what are the intent of the code requirements.

I believe that the fact that several experience practitioners differ as to what the current code says and intends, speaks to the need to improve the provisions.

The new concept was the maximum 4-floor, 50 foot high, interconnecting fire zone.

The initial, progressive approach was an absolute maximum four story, 50 foot high fire zone based on active sprinklering and smoke control was replaced with migration limits that virtually parallel what are currently contained in the IBC.

I believe the CTC should re-direct the Study Group to abandon the work on FS 162 and proceed with working on the existing IBC format, clean it up editorially, identify the problems, such as omissions, do-loops, contradictions, and offer solutions for the 2012 IBC.

Given the overwhelming lack of editorial and technical continuity of current opening protective requirements, it is questionable whether or not an editorial clean up of the existing IBC format, omissions, do-loops and contradictions will achieve any improvement in understandability and comprehensiveness of design.

I am still uncomfortable with the fire zone concept and how the subtle distinctions between the use of the new fire zone, currently understood fire areas, control areas, smoke compartment, and the word “compartment” in the existing code is going to be interpreted and integrated into one another.

The distinctions between the various terms are not subtle. Each is defined an delineates a prescribed area. Fire area refers to an unsprinklered floor area. Control area refers to the maximum amount of hazardous materials permitted within a non-H occupancy building area. Fire zone establishes vertical fire migration limits in stories. Each term addresses a specific concern in objective building design. Additionally, the applicable text requirements clarify the differences between the various building areas or zones.

I do not agree that this format is a significant improvement to the format of the current Chapter 7.

The FS 162 achieves no less than three significant format improvements. The general section organization places fire-resistance rating and testing requirements in a logical order. Section 715 is organized such that various building element opening protection requirements are stated in one location, Sections 715.3 though 715.5. Opening protective assembly provisions are organized in a consistent fashion regardless of the specific assembly required: Rating, testing, labeling and installation. Enclosure construction requirements are similarly uniformly organized: Materials, construction, rating and openings. That is to say that the same fundamental system is exercised regardless of the assembly or opening protection method employed. In fact, FS 162 represents a quantum improvement in the IBC as it creates a system for requirement determination purposes.

Even if the big picture items in FS 162 were unanimously and enthusiastically supported by the majority of the Study Group members (which they are not), there are still a number of other problems with the draft that need more work before offering FS 162 to the ICC membership.

During its most recent teleconference, a majority of Study Group members, in fact, voted in favor of the "big picture" items (orgaization, terminology and technical format) contained in FS 162. There was no vote on the migration limits proposed at that time. At the Northbrook meeting, there was considerable compromise offered to address virtually every concern voiced by the opposition. I think that considerable work was accomplished in preparation for the offering of FS 162 to the ICC membership.

I do not support the combining of all types of openings into one big catch-all definition. Joints are different than atria, penetrations are different that doors, which includes testing, protection requirements, and function. They are more dis similar than alike in many respects and require separation in the code.

At its first meeting in Atlanta, the Study Group agreed that "a hole in the floor was a hole in the floor" and decided for purposes of simplicity to address any breach as an "opening." The issue is not what you call the breach; but rather, how you remedy it. To that end, you are correct the joints, atria, doors, etc. are each distinctly different remedies. Their similarities and dissimilarities are described in the various opening protective assembly and enclosure construction sections which can be compared due to the common format.

I do not support changing the existing understanding of element or assemblies. Current IBC adequately addresses the use of those terms. Need to return to commonly understood terms throughout this document.

"Building element" is the term currently used and defined in the IBC. Based on discussion in Northbrook, the term "building assembly" has been changed to "building element" throughout FS 162.

1.

Horizontal assembly and horizontal barrier are terms that will be mis-used in the field and are too similar as definitions. Non fire resistance rated horizontal assembly, or fire resistance rated horizontal assembly is easier to understand and use.

This comment makes an excellent case for the need for two definitions. One is not a non rated horizontal assembly while the other is a fire-resistance-rated horizontal assembly. In fact, both are fire-resistance-rated assemblies. One is largely intended to perform a given structural function while the other confines a fire (please see the current IBC definition of "fire-resistance rating"). Creating this technical hierarchy somewhat parallels what presently occurs with vertical assemblies (fire wall, fire barrier, fire partition). Similar to vertical assemblies, one size does not fit all with horizontal construction. I suspect that the distinction will actually assist persons in the field.

1.

Agreethat the requirements for nonlisted materials used in the code now (defined herein as flamestops and in the code as fireblocks) are messy and inconsistent. I prepared a worksheet to identify code sections where such generic or unlisted material is required in code, and in what context. Needs more work.

Again, this comment makes an excellent case for the need for proposed definitions. FS 162 does not replace the term "fireblock" with "flamestop." Fireblock is a term that addresses concealed spaces in combustible construction. The new term "flamestop" refers to nonlisted or generic opening protection methods in unconcealed spaces. Currently there are several different descriptions for this typical construction. The proposed definition will provide clarification by making the necessary distinction.

Term"opening protective assembly” is too general and is inconsistent with how products are currently listed by UL (and other labs) and the manufacturers who test their products for listing. UL uses the terms “fire resistance rated assemblies” to include beams, floors, roofs, columns, and walls and partitions. The term “system” is used to categorize joint systems, through-penetration firestop systems, and electrical circuit protective systems and duct assemblies. The term “opening protective” refers to dampers, fire doors, glazing and related equipment. Forthe most part, the current IBC accurately conveys those same meanings, and to change that arbitrarily is creating un-needed busy work for all stakeholders in those fields – change for the sake of change is not an advantage. On page 10, penetrations (715.2.2.4) and joints (715.5.2.2.5) and opening protective assemblies (715.6) are terms that are used interchangeably to describe a penetration and a joint – but that creates questions, not answers. Call it what it is.

"Opening protective assembly" is a term that is currently used in the IBC(please see the current IBC definition of "fire protection rating"). Nothing has been changed arbitrarily, if anything has been changed at all. Rich Walke, Kurt Roeper and myself made a conscious attempt to tie all opening protection remedies to the individual UL tests and terminology. In the reference to Page 10, the comment is out of context. There is a direct correlation between the charging language for various types of openings in various building elements (Sections 715.3 through 715.5) and the specific manner of compliance prescribed in Section 715.6 based on the opening protection method employed. This proposal calls things precisely what they are and reduces confusion due to its consistent format and terminology.

Why was opening allowance in 707.8 and in Exception 2 changed from 120 sq.ft in IBC to 156 sq. ft. ? 15 m2 is 161 sq. ft., not 156 sq. ft.

My recollection is that RIch and I found an inconsistency in the current code and resolved it for purposes of continuity of technical provisions. 15 m2 is the current SI conversion factor currently used for 156 sq. ft. (Please see Section 706.7, Exception 1, for example).

Exception 1. What section does this point to? 707.1.1 in IBC? Or in this draft? Either way, may be wrong numbers ?? Confusing.

Section 707.8, Exception 1 is a exact duplication of current IBC Section 705.8, Exception 1 with proper FS 162 cross-reference to Section 707.1.1. If this provision is confusing, then the same must be said for the current IBC.

The statement has been made that the formatting of FS 162 is easier to use than the current IBC. To test this idea, I started with trying to find the firestopping requirements for fire barriers. Section 708.7 in Fire Barriers sends me to Section 715.5.2.2 (1 hop). Section 715.5.2.2 sends me to read through this section to find Section 715.5.2.2.4 (2 hops), which sends me to Section 715.6.6 (3 hops). Once in Section 715.6.6, the section lays out the requirements for through penetrations, but I then have to hop to 715.6.5.1 through 715.6.5.11 (this may be a typo – shouldn’t this be 715.6.6.1 through 715.6.11??) to find the exceptions permitted for generic annular space materials (4 hops), and then continue on to 715.6.9 to find the requirements for wall membrane penetrations (5 hops). I would not say that the IBC is any less complicated than this, but I cannot agree that, at least on this topic, that the current draft is less complicated than the current chapter 7 of the IBC. Without belaboring the point, I found other topics to require about the same level of hopping around.

It may be true that the same number of "hops" are required in FS 162 as opposed to the current IBC. However, there is one major improvement with FS 162. That is, the process or "hops" are the same in all cases regardless of the type of assembly or opening protection method. With the current IBC, there is no "system" for requirement determination purposes. Each protection method has a different set of "hops" whether it be an opening protective assembly or enclosure construction. The present lack of a requirement determination system lends to confusion and often leads to the provision of non-required protectives when a building designer or code enforcement official is in doubt as to the actual code requirement. I find it difficult to understand why some are not necessarily in favor of needed clarification.

Section 715.6.5.4 needs more numbering. The paragraphs run on.

This may be a valid comment. Some are concerned about the number of subsections and attendant decimal points. This is something that we can discuss in Baltimore. This is an editorial issue.

On page 19, Exception 1 regarding the sprinkler trade off for smoke dampers is not clear that it only applies to corridors and it not a building wide trade off.

I could not locate the provision in question. Perhaps the next question is the one being asked.

On page 19, the sentence “A listed smoke damper designed to resist the passage of smoke….” is not clear whether it applies to corridors that are smoke barriers, or is a building wide requirement. This should have been more logically located in with the other smoke damper requirements. Again, lots of hops to get all the info on smoke dampers…

This provision is virtually verbatim with current IBC Section 716.5.4.1. It is no more or less clear than the current code.It was offered that this provision should be located with other smoke damper requirements. The provision is located in Section 715.6.5 which is titled, "Smoke dampers." No hops. All smoke damper technical information is found in the same section.

This section 715 is massive with many subsections.

This is the nature of the one-stop shop. Less "hops."

Section 715.2. Needs more subsection numbers throughout. 715.2 does not really clearly explain or define the purpose, function, or boundaries of the fire zone. Exceptions 1 and 2 would be meaningless as written to someone who has not had the benefit of the numerous task group discussions.

Section 715.2 only contains three paragraphs. The purpose and function of the fire zone are contained within the definition of "fire zone" in Section 702.1. The boundaries of the fire zone are contained in the very first sentence of Section 715.2. I think that "meaningless" does not necessarily give proper credit to the intelligence of code users. It must be noted that with a new system of fire zone compartmentation, education will be a necessary component of technical transition.

The last paragraph on page 6 “Fire zones shall be permitted to extend vertically…” is incomprehensible to me, especially when combined with the reference to 715.3.2. When is protection required and when isn’t it? Can’t tell from these sections. I believe that this was an effort to incorporate some of the comments and compromises from the second day of meetings in Northbrook, but I don’t think what we discussed is clearly stated here.

I am having trouble seeing where a more or less absolute system of vertical migration with six exceptions found in a single location is incomprehensible when compared to the current 30 plus exceptions found in countless locations. When protection is required in any building element is concisely contained in Sections 715.3 through 715.5.

Section 715.2.1 and 715.3.1. What and where is a “portion” of a fire zone?

Section 715.3.1 and 715.3.2 refer to a portion of a fire zone "envelope" which is sufficiently clear. Section 715.2.1 should also read "envelope."

Section 715.3.2. This section is nonsensical to me. What are the “other openings” in horizontal assemblies that are not required to be enclosed?

As previously explained, the term opening refers to any breach. Since the first paragraph refers to "penetrations, joints and ducts," other openings would refer to those normally mitigated by enclosure such as shafts, exit enclosures and atriums.

715.5.2.1. This is a presumption that goes beyond the IBC. It doesn’t say that protection in non rated walls is not required - ever. The IBC is silent. There is a difference.

As was confirmed by staff during our Atlanta meeting, there is no inherent opening protection requirement associated with nonrated wall construction, bearing or non. Silence can lead to confusion. The provision is positively stated. Please provide an example of where an opening would be required to be protected in a nonrated wall. If any exist, perhaps language such as, "unless required by other provisions of this code" would be in order.

715.5.2.1 protection is not required; but it may be, unless it isn’t.

This appears to be a restatement of the previous question.

715.6.6 Last numbers. Where and what is Section 910.6? Can't find it.

With coordination with Rich Walke, his has been corrected.

715.6.6.1 First sentence is not grammatically correct. Something is missing. Also, I have a problem starting with 715.6.6.1. All the alternative methods permitted appear to be stand alone section that looks like they are the only applicable requirements for these conditions and specific assemblies.

Section 715.6.6.1 has been rewritten. I agree that the multitude of alternative methods are cumbersome. Perhaps the solution is to create a new Section 715.6.6.2, "Alternative Methods," and list them there. We should discuss this in Baltimore.

715.6.7.1 Joints are tested to fire resistant ratings, not fire protection ratings.

Corrected in current draft.

715.6.7.4 and 715.6.7.5 sends user to 706.9 (1 hop) which send user to 713 (presumably to a new section on joints (2 hops)). Existing text from IBC send user to 704.9, (3 hops) or possibly back to 713.4 (4 hops??) After that long trip, not much information has been obtained related to height and fire resistance requirements for curtain wall spandrels, which was promised in 715.6.7.4 in the first place…. In fairness, the problem is also in the current IBC. But this draft did not fix it either. Also a typo in 715.6.7.5. Should be 715.6.7.4, not 716.6.7.4, I think.

You are correct, it is a similar problem in the current IBC. Typo will be corrected.

715.8.1 titled Utility Openings is really about shaft enclosures. Again, I think the user is better served by calling it what it is.

As has been previously explained, the system of designation of the various types of openings has been changed. The various remedies, however, have remained the same. Shaft enclosures protect utility openings, exit enclosures protect egress openings, atrium enclosures protect architectural openings, etc. The user will be better served by the use of conventional terminology.

Within 715.8.1 Utility Openings are sub sections called Openings. ( 715.8.1.4, 715.8.2.4)) What thing are we talking about and why do we need different terms if we are talking about the same thing?

We are not talking about the same thing. Where utility openings require protection, they are protected with properly constructed shaft enclosures. Openings occurring within the shaft enclosure must also be protected, hence the cited provisions.

Section 715.8.3. I presumed that we are talking about aria here, but this draft has specifically included escalators, and the IBC does not include escalator requirements in with the atrium provisions. I think combining the requirements for these features this is asking for a problem in design and enforcement and in the field by not adding clarity. It is doing the opposite.

Escalators and non-egress stairway openings are currently addressed under the shaft provisions. Arguably, their function more closely relates to egress or architectural uses. Clearly, there is a similarity in the construction requirements for each. That being said, it is probably a moot point since the Northbrook meeting because Exception 2 to the second paragraph of Section 715.2 exempts the enclosure of escalators under prescribed conditions, identical to the current code.