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Insights Category: Technical Information

NFPA 3, Recommended Practice for Commissioning and Integrated Testing of Fire Protection and Life Safety Systems, and NFPA 4, Standard for Integrated Fire Protection and Life Safety System Testing, are two NFPA documents that everyone should become familiar with. NFPA 3 is a recommended guide intended to address the administrative and procedural concepts of commissioning fire protection systems while NFPA 4 addresses testing the performance of the interconnection between multiple fire protection and life safety systems.

NFPA 3 and 4 are neither adopted nor referenced by 780 CMR, Massachusetts State Building Code; however, the concepts contained within these documents have already been embraced and implemented by many building owners. It’s for good reason too. The fire alarm, fire protection and other life safety systems of today are complicated and often require integration with building automation, audio/visual and security systems, to name a few. Implementing NFPA 3 and 4 allows building owners have confidence that the life safety systems they are purchasing will work beyond the initial acceptance test of the fire department.

With 527 CMR, Massachusetts Comprehensive Fire Safety Code, requiring existing smoke control systems to be tested semi-annually if dedicated, annually if non-dedicated, the need for NFPA 3 and 4 to become adopted standards is more apparent than ever. The documentation associated with existing smoke control systems that were designed and installed in buildings during the 70’s, 80’s and 90’s has left a lot to be desired. In many instances, reverse-engineering these systems becomes necessary as their entire design is often limited to 2 or 3 notes on a fire alarm drawing. Had these NFPA documents existed 20-30 years ago, many of the recurring issues that we encounter when recommissioning existing smoke control systems would not exist.

Though many people have heard of NFPA 3 and 4 but since their inception 5 years ago, very few engineers, owners and/or contractors have been involved with projects where they have been implemented. This underscores the importance of having a well-qualified fire commissioning agent. In the Annex of NFPA 3, Section A.4.2.1.1, it states that the fire commissioning agent should have a minimum of five years of experience in facility construction, inspection, acceptance testing or commissioning as it relates to fire protection and life safety. Finding someone with said experience and starting the commissioning process during design are probably the two most critical aspects to successfully commissioning of life safety systems. While there is certainly a cost associated with commissioning life safety systems, our experience has shown that early involvement with commissioning can pay for itself by avoiding costly last-minute change orders that in some instances can delay occupancy.

A question that is commonly asked on projects is how to classify the occupancy of occupied roof decks. Does the roof deck contribute to the building area? Does the height and area table (IBC Table 503) apply to the outdoor area? Under the 2015 IBC and prior editions, no guidance is given with respect to this issue. Some jurisdictions classify them as occupancies in the building and others do not, which can have a significant impact on the design of the building relating to construction type, fire protection systems, etc. To clear up the confusion, new language is being added in the 2018 IBC that will specifically address occupied roof decks as follows (new text is underlined):

302.1 General. Structures or portions of structures shall be classified with respect to occupancy in one or more of the groups listed in this section. A room or space that is intended to be occupied at different times for different purposes shall comply with all of the requirements that are applicable to each of the purposes for which the room or space will be occupied. Structures with multiple occupancies or uses shall comply with Section 508. Where a structure is proposed for a purpose that is not specifically provided for in this code, such structure shall be classified in the group that the occupancy most nearly resembles, according to the fire safety and relative hazard involved. Yards, patios, courts, occupied roofs and similar outdoor areas accessible to and usable by the building occupants shall be classified in the group that the occupancy most nearly resembles, according to the fire safety and relative hazard involved.

503.1.4 Occupied roofs. A roof level or portion thereof shall be permitted to be used as an occupied roof provided the occupancy of the roof is an occupancy that is permitted by Table 504.4 for the story immediately below the roof. The area of the occupied roofs shall not be included in the building area as regulated by Section 506.

Exceptions:

  1. The occupancy located on an occupied roof shall not be limited to the occupancies allowed on the story immediately below the roof where the building is equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2 and occupant notification in accordance with Section 907.5 is provided in the area of the occupied roof.
  2. Assembly occupancies shall be permitted on roofs of open parking garages of Type I or Type II construction, in accordance with the exception to Section 903.2.1.6.

Elements or structures enclosing the occupied roof areas shall not extend more than 48 inches above the surface of the occupied roof.

Exception: Penthouses constructed in accordance with Section 1510.2 and towers, domes, spires, and cupolas constructed in accordance with Section 1510.5

With this new change, the occupied roof will be classified as an occupancy in the building, and may or may not be limited in height based on the fire protection features provided. One important caveat associated with this code change is the height limitation on elements or structures enclosing the roof deck. The code proposal states that this was added due the concern that having walls or screens surrounding a roof deck could lead to firefighting challenges. Given that many of the new roof decks we have seen in the Northeast are well above the height a ladder truck can reach, we anticipate this limitation to be a common topic of conversation with the local fire departments.

Want to learn more about this code change and how it may impact/help your projects? Contact us at info@crcfire.com for more information.

The International Building Code (IBC) first adopted a requirement for the special inspection of firestopping and fire resistance joint assemblies in certain buildings with the 2012 Edition. Since its adoption, we have performed third party fire stop and fire resistant joint inspections on over 1 Million square feet of space in accordance with ASTM E 2393 and ASTM E 2174. Below are some of the frequently asked questions we hear when serving in this capacity.

Want to know more about where its required? See our previous post here.

Where is firestopping required?

  • Through Penetrations: Breaches in both sides of a floor, floor-ceiling or wall assembly to accommodate an item passing through the breaches.
  • Membrane Penetrations: Breaches in one side of a floor ceiling, roof-ceiling or wall assembly to accommodate an item installed into or passing through the breach.
  • Joints and Perimeter Barriers: Openings in or between adjacent assemblies that is created due to building tolerances, or is designed to allow independent movement of the building in any plane caused by thermal, seismic, wind or any other loading (i.e. head of wall assemblies, curtain wall/slab edge joints).

What test standards govern approved firestop systems?

The table below outlines the required test standard particular to each firestopping application:

Each of these test standards outline fire test methods effective in determining the performance of firestop systems subject to fire exposure governed by a standard time-temperature test and hose stream test. The time-temperature curve utilized mirrors that utilized for determining the hourly rating for walls and floors (ASTM E119).

Can’t I use this red caulk on all my penetrations?

The code calls for the use of listed firestopping assemblies. It’s easy to get these confused with listed firestop products. A firestopping product is just one of the components in a listed firestopping assembly. The wall or floor assembly being penetration, penetrating item itself, annular space around the penetration, the manner in which the penetrating item is configured through the opening, etc.. are all part of the listed firestop assembly. For an arrangement to be considered a listed firestop assembly, it is required to be installed in the same manner in which it was tested. This information is readily available from the firestopping product manufacturer’s or from approved testing laboratories such as Underwriters Laboratories (UL).

What is the difference between a “F Rating” and “T Rating”?

  • F-Rating, or Flame Rating, is the period of time in hours the tested assembly remains in place without allowing the passage of fire during exposure or water during the hose stream test following exposure. T-Rating, or Temperature Rating, indicates the time in hours it took for the temperature on the unexposed side of the assembly to reach 325°F above ambient.
  • In order to obtain a T Rating, an F Rating must be obtained prior. Exposed penetrations through floors and fire resistance rated joints require a T Rating whereas membrane and through wall penetrations are only required to obtain an F rating.

Do membrane penetrations by electrical boxes need to be firestopped?

Membrane penetrations by electrical boxes may not require a firestopping assembly if they (1) have been tested for use in a fire resistance rated assembly and are installed per their listing or (2) they meet all of the following conditions (IBC 2012 714.3.1):

  • The electrical box area does not exceed 16 square inches;
  • The aggregate area of openings through membrane does not exceed 100 square inches in any 100 square feet of wall area;
  • The annular space between the wall membrane and the box does not exceed 1/8”; and
  • If located on opposite sides of the wall, electrical boxes are separated by 24 inches in different stud cavities.

If these conditions are not satisfied, additional insulation, fireblocking, or listed firestop assemblies arranged per Section 714.3.1 need to be added to achieve compliance with the code.

In need of help on firestopping inspections or details? Please do not hesitate to give us a call.

Rubberized asphalt melters are useful for roofing material application during construction, however open flame associated with such operations on roofs are specifically prohibited by 527 CMR in high rise buildings. Rubberized asphalt melters have an exposed burner flame and operate at temperatures up to 500 degrees Fahrenheit. These burners are fired by flammable gas/liquids, which further complicate the process as the storage of said materials inside a building is generally prohibited.

As a result, one must consider seeking permission from the authorities having jurisdiction. We suggest applying 527 CMR Section 1.4, which permits the use of equivalencies, alternatives, or modifications. Self-contained rubberized asphalt melters are not currently included in NFPA 1, however the practicality of this option has been recognized recently in several jurisdictions such as Florida.

Rubberized asphalt melters have a fully enclosed burner flame and typically operate at temperatures between 350 degrees Fahrenheit to 380 degrees Fahrenheit. The melters typically range in size from 100 gallons to 230 gallons and only utilize either diesel or gasoline for fuel. These melters are equipped with temperature controls and only run on a properly operating control system. The membrane material used in these melters has a lower melting point than traditional asphalt based products and is less flammable and combustible.

These rubberized melters have been approved within the City of Boston in the past with the appropriate required permits. These permits include a General Permit to permit fuel storage on the roof, as well as a Hot Work Permit to provide an avenue to secure a uniformed fire watch.

If you have any questions about how you can achieve alternative means of compliance for roof melters, please contact us!

Emergency wash systems are required by 248 CMR, Massachusetts Uniform Plumbing Code in every school, college, university, or building laboratory where corrosive or flammable liquids are handled, chemicals are stored or used, or open flame devices are used (248 CMR 10.13 (l)(1)). The systems are required to include drench/deluge showers, hand held body/face washers and deck mounted drench hoses. The permanently mounted showers are required to be located as close to the main door of the laboratory as possible, but must not be located more than 50 feet from an experimental area. The systems are required to be installed in a manner that prevents stagnation of water in the piping that supplies permanently mounted showers and face/eye wash stations.

Enacted on June 29, 2016, the Board of State Examiners of Plumbers and Gas Fitters issued an interpretation for the installation requirements of emergency eyewash and emergency showers to better align the requirements with ANSI Z-358.1. The Board voted to make the following changes:

  • The Board now allows emergency shower products to be accepted with a minimum flow of 20 gpm for 15 minutes. Previously, 248 CMR 10.13(1)(l)(4) required a 30 gpm continuous spray.
  • The Board now allows a water temperature range of 60 – 90 degrees Fahrenheit based on documented data showing an increase in bacteria growth in water above 70 degrees. Previously, the water was required to be tempered to between 70 – 90 degrees Fahrenheit.

On July 28, 2017, the Centers for Medicare & Medicaid Services issued a memorandum on required annual inspection of swinging fire door in healthcare occupancies (Click Here for the full memo). The memo extends the deadline for compliance with the annual fire door inspections for swinging fire doors from July 5, 2017 to January 1, 2018.

The extension is being granted due to conflicting information that was issued regarding the code path and subsequent nature of the door inspections that were required to be performed. The memo clarified that Section 7.2.1.15.1 of NFPA 101 2012 Edition would not apply to healthcare occupancies. This does not mean that these occupancies are not subject to the annual testing requirements of NFPA 80 but rather that they are not subject to the additional requirements layered on top of the NFPA 80 requirements contained in Section 7.2.1.15.1. In addition to swinging fire doors, 7.2.1.15.1 also applied to doors with panic hardware, electronically controlled egress locks, and doors with special locking arrangements such as delayed egress locks and access control locking system. Nonrated doors that contain such devices are not required by NFPA 101 or NFPA 80 to be inspected annually.

Hospitals are still subject to the annual inspection of swinging fire doors from NFPA 80 via Section 8.3.3 of NFPA 101 2012 Edition.

Previously Joint Commission and CMS had issued notices that 7.2.1.15.1 was applicable to Healthcare Occupancies. Due to the confusion created by this clarification, CMS has extended the deadline for compliance.

If you need assistance creating an inventory of fire doors or performing NFPA 80 testing please do not hesitate to contact us. Unlike many fire door inspectors, our work as code consultants and fire protection engineers gives us the expertise to examine your life safety drawings and understand the necessity for walls and doors to be rated by NFPA 101 and the applicable building codes.

Lt. Chris Towski of Cambridge Fire Department has been instrumental in educating the design/build/enforcement industry on the newly enforced NFPA 241, Standard for Safeguarding Construction. Most recently, Lt. Towski was published in Fire House Magazine, which circulates to fire services on a national level. In this article, his vantage point as authority having jurisdiction (AHJ) offers a fresh perspective to a subject matter that cannot be ignored on our construction sites. The article can be found here: http://www.firehouse.com/article/12349715/fire-prevention-safety-for-buildings-under-construction-firefighter-training-education

One of the most significant changes in the upcoming 9th Edition adoption relates to fire service access elevator requirements.

8th Edition 780 CMR

The current Massachusetts State Building Code (8th Edition; also known as 780 CMR) is an amended version of the 2009 IBC. The 8th Edition 780 CMR requires a fire service access elevator (FSAE) in buildings more than 70 feet in height above grade plane. In order to serve as the FSAE, an elevator must satisfy the following conditions (780 CMR 3007):

  • The FSAE must serve every floor of the building;
  • The FSAE must be open to a lobby that is:
    • 150 ft2 minimum with an 8-foot minimum dimension on every floor except the street floor.
    • Enclosed by 1-hour smoke barriers with 3/4 –hour doors.
    • Provided with direct access to an exit enclosure.
  • A Class I standpipe hose connection must be provided in the exit enclosure having direct access from the FSAE lobby;
  • FSAE must be continuously monitored at the fire command center; and
  • Normal and standby power must be provided in accordance with 780 CMR Chapters 27 & 30

9th Edition 780 CMR

The 9th Edition 780 CMR is an amended version of the 2015 IBC. The 9th Edition 780 CMR, significantly changes the requirements related to FSAEs. Specifically, in buildings with an occupied floor more than 120 feet above the lowest level of fire department vehicle access, no fewer than two fire service access elevators, or all elevators, whichever is less, is required to be provided. The impact of this code change is twofold in that buildings less than 120 feet in height above the lowest level of fire department vehicle access no longer require a FSAE; however, buildings exceeding this threshold now need two FSAEs instead of one. It is important that this code change be considered early in design based on the considerable impact on building core configuration.

In addition to the above code change, the 9th Edition 780 CMR also introduces the following notable changes:

  • Under the 8th Edition 780 CMR it was required that a Class I standpipe hose connection be provided in the exit enclosure having direct access from the FSAE lobby. This requirement has been updated such that the exit enclosure containing the standpipe must have access to the floor without passing through the fire service access elevator lobby. A change was made to this requirement in order to prevent the passage of smoke from the floor to the FSAE lobby and hoistway when firefighters run hoses from the standpipe to the floor (2015 IBC 3007.9.1).
  • Access to not less than one of the required exits from the floor must be provided without travel through enclosed elevator lobbies (2015 IBC 1016.2).
  • A pictorial symbol designating which elevators are fire service access elevators must be installed on both sides of the hoistway door (2015 IBC 3007.6.5).

There are several new changes affecting health care design and construction associated with the upcoming 9th Edition adoption. The 9th Edition of 780 CMR is an amended version of the 2015 International Building Code (IBC). These changes include smoke damper omissions, occupancy classifications, smoke compartment and suite sizes, and third party firestopping inspections.

Smoke Dampers

Likely the most impactful change in the upcoming 9th Edition is the new exception in Section 717.5.5 that allows the omission of smoke dampers at HVAC duct penetrations in smoke barrier walls in Group I-2 occupancies. To qualify for the exception, the HVAC system must be “fully ducted” per Section 603 of the International Mechanical Code and the area is required to be protected with quick response sprinklers in accordance with Section 903.3.2 of the IBC. These conditions should be easily satisfied in new construction. Note that this new exception aligns with the requirements of NFPA 101 which have allowed smoke dampers to be omitted at smoke barrier walls since 1991. Read more about this change in our previous blog post here.

Occupancy Classifications

The use and occupancy classifications of buildings and structures are located in IBC Chapter 3. Hospitals, nursing homes, and behavioral health institutions have historically been classified as Group I-2, Institutional Occupancies. Under the 9th Edition, Group I-2 occupancies will now be separated into 2 different occupancy conditions. Condition 1 includes facilities that provide nursing and medical care but not emergency care, surgery, obstetrics, or in-patient stabilization units such as nursing homes and foster care facilities. Condition 2 includes facilities that provide emergency care, surgery, obstetrics, or in-patient stabilization units such as hospitals. The code requirements for the two conditions vary as indicated in IBC Section 407. This is an organizational change in the Code, however should not affect the code requirements in the built environment.

Smoke Compartment Size

Under the 8th Edition, the maximum smoke compartment size is limited to 22,500 square feet. This size is increased to 40,000 square feet in hospitals under Section 407.5 of the 9th Edition. Although this is a substantial change, it should be noted that most hospitals receive funding from the Centers for Medicare and Medicaid Services (CMS) and therefore are also required to comply with the 2012 Edition of NFPA 101, Life Safety Code. NFPA 101 Section 18.3.7.1 requires smoke compartments in new construction to not exceed 22,500 square feet and therefore this more stringent requirement still applies. Note that at the 2017 NFPA Conference & Expo earlier this month, the proposed code change to increase the smoke compartment size to 40,000 square feet in the 2018 Edition of NFPA 101 passed, however it still needs to be adopted by CMS in order to designers to utilize this less restrictive requirement.

Suite Size

The 9th Edition Section 407.4.4 allows considerable size increases for patient care sleeping and non-sleeping suites. These include permitting sleeping suites to be increased from 5,000 square feet to 7,500 square feet (10,000 square feet if full smoke detection in suite), and non-sleeping suites to be increased from 10,000 square feet to 12,500 square feet (15,000 square feet if full smoke detection in suite). However, like smoke compartment sizes, NFPA 101 is more restrictive in their suite size limitations. NFPA 101 Section 18.2.5.7.2 permits both sleeping and non-sleeping suites to be a maximum size of 10,000 square feet, which is more restrictive than the IBC for non-sleeping suites. This is another example of why hiring a life safety consultant like Code Red Consultants, that is familiar with both IBC and NFPA 101 provisions, is so critical to the success of your health care project.

Third Party Firestop Inspections

There is a new requirement in the 9th Edition which requires a special inspector for firestop systems in fire-resistance rated assemblies that are tested and listed where required by Chapter 7 of the Code. Section 1705.17 of the 2015 IBC requires the third party inspections for high-rise buildings as well as those buildings assigned to Risk Categories III and IV which includes all Group I-2 occupancies. Read more about this significant change in our Special Inspection article contained within this newsletter or on our blog.

There is a new special inspection requirement in the 9th Edition that owners, developers, contractors, and Authorities Having Jurisdiction (AHJ) will want to be prepared for when the new code comes into effect. Section 1705.17 of the 2015 Edition of the International Building Code (IBC), which is the basis of the 9th Edition, requires a special inspector for through-penetrations, membrane penetration firestops, fire-resistance joint systems, and perimeter fire barrier systems that are tested and listed where required by Ch. 7 of the Code.

Where does the requirement apply?

The new requirement will apply to high-rise buildings and to buildings assigned a risk category of III or IV per Section 1604.5 of the IBC. This table includes occupancies such as large assembly with occupant loads in excess of 300, educational occupancies with occupant loads over 250 occupants, most hospitals, jails/prisons, buildings with Group H, High Hazard Occupancies, and facilities housing emergency responders, among others. The requirement applies to any joint (i.e. head of wall intersection with floor construction), through penetration or membrane penetration of fire resistance rated walls, floors, and ceilings as specified on the project construction documents.

How do I know if I am installing the right firestopping prior to inspection?

Firestopping systems are approved assemblies and not products. The assemblies consist of the wall /floor construction itself, the penetrating item(s) or joint details, and the firestopping components utilized. The assemblies utilized are required to meet certain fire test standards and be listed by an approved testing agency. The tests illustrate that the specific assembly listed has passed the required fire test standard for a specified amount of time (i.e. 1-hour). The inspector’s role is to compare the installations viewed in the field with the details of the approved assemblies. All firestopping assemblies utilized should be included in an approved submittal for both the installer’s and inspector’s use.

How must the Inspections be Performed?

The code states that the inspections are to be performed in accordance with two ASTM Standards; ASTM E2174 governs penetration firestop systems and ASTM E2393 applies to joint systems. Some highlights on how the inspections are to be performed include:

  • Inspector is to witness the installation of 10% of each type of firestop system or perform destructive testing of 2% of each type of firestop system per floor or for each area of a floor when a floor is larger than 10,000 ft2.
  • Complete submittals showing all listed firestop assemblies are required to be provided to the inspector before they perform their inspections. This includes any engineering judgements that may be needed for assemblies which don’t meet all the details of a listed assembly.

Who can serve as the special Inspector?

The IBC states that the inspections are to be performed by an approved agency, which is defined as “An established and recognized agency that is regularly engaged in conducting tests or furnishing inspection services, where such agency has been approved by the building official.” The ASTM standards provide additional guidance on the qualifications of an inspector and state that an inspector should have a minimum of 2-years experience in construction field inspections and have education, credentials, and experience that is acceptable to the authorizing authority. The document goes on to address conflicts of interest and stipulates that the inspector should be independent from and not in competition with the manufacturer, contractor, installer, and supplier of the firestopping products.

The engineers at Code Red Consultants are all degreed fire protection engineers and have been engaged in performing fire stop inspections and evaluating firestop assemblies for over a decade. If we can be of assistance in evaluating if this requirement applies to your project or serving as the special inspector please do not hesitate to contact us.