2021 Submitter Substantiations Committee Statements

Motion Substantiation
Certified Amending Motion No. 10-5

Motion to Reject Second Revision No. 18
June 2021
Bottom Line:
 A vote in favor of the recommended text will remove proposed annex material that simply
does not correlate with the section referenced. To allow A.7.2.2 (5) to stay would be to
allow non-correlating language to remain.
 A.7.2.2 (5) was actually voted down by the NFPA-10 Committee, but somehow
erroneously added at the end of the process.
 The NFPA-10 Committee agreed with a proposed TIA to amend A.7.2.2 in order to avoid
this process. The TIA met the 75% threshold on the Technical Merit but narrowly missed
with the Emergency Nature.
 Section 7.2.2 (5) deals with the Inspection Procedures for non-pressurized portable fire
extinguishers. The proposed A.7.2.2 (5) attempts to install annex material inferring an
unnecessary physical processes for pressurized fire extinguishers. It’s non-applicable
language that intentionally or unintentionally brings into question the recognized, listed and
proven electronic monitoring for the readiness of fire extinguishers.
 To oppose Cam 10-5 would wrongly allow language into the Standard that clearly does
not correlate, going against the majority voting by the Committee.
 Simply put, a vote in favor of 10-5 is best for life safety and the code process.
Recommended Text if Motion Passes:

7.2.2 Inspection Procedures. Periodic inspection of fire extinguishers shall include a check of at
least the following items:
(1) Location in designated place
(2) Visibility of the extinguisher or means of indicating the extinguisher location
(3) Access to the extinguisher
(4) Pressure gauge reading or indicator in the operable range or position
(5) * Fullness determined by weighing or hefting for self-expelling-type extinguishers, cartridge
operated extinguishers, and pump tanks
A.7.2.2 (5) To perform a monthly visual inspection, a stored-pressure extinguisher is removed

from its mounting location, and its fullness is determined. An empty extinguisher with a pressure
gauge reading that indicates it is pressurized should be replaced with an extinguisher complying
with 7.1.3.
(6) Condition of tires, wheels, carriage, hose, and nozzle for wheeled extinguishers
(7) Indicator for non-rechargeable extinguishers using push-to-test pressure indicators
Recommended
June 8, 2021 Submitter Substantiations and Committee Statements Page 1

Non-Correlating Text if Motion Fails:
7.2.2 Inspection Procedures. Periodic inspection of fire extinguishers shall include a check of at
least the following items:
(1) Location in designated place
(2) Visibility of the extinguisher or means of indicating the extinguisher location
(3) Access to the extinguisher
(4) Pressure gauge reading or indicator in the operable range or position
(5) * Fullness determined by weighing or hefting for self-expelling-type extinguishers, cartridge
operated extinguishers, and pump tanks
A.7.2.2 (5) To perform a monthly visual inspection, a stored-pressure extinguisher is removed

from its mounting location, and its fullness is determined. An empty extinguisher with a pressure
gauge reading that indicates it is pressurized should be replaced with an extinguisher complying
with 7.1.3.
(6) Condition of tires, wheels, carriage, hose, and nozzle for wheeled extinguishers
(7) Indicator for non-rechargeable extinguishers using push-to-test pressure indicator
Respectfully submitted,
Danielle Felch.
Johnson Controls

Report of the Technical Committee on Portable
Fire Extinguishers
June 2021
The Report of the Technical Committee on Portable Fire Extinguishers presented as found
in the First Draft Report and Second Draft Report for the Annual 2021 revision cycle of NFPA 10,
Standard on Portable Fire Extinguishers. The revisions were submitted to letter ballot of the
responsible Committee(s) in accordance with the Regulations Governing the Development of
NFPA Standards. The reports and ballot results can be found on the next edition tab of the
Document Information page for NFPA 10 at www.nfpa.org/10next .
Certified Amending Motion 10-5 addresses an Annex item that was addressed in a TIA
submitted and rejected by the technical committee for several reasons including the following:
1. While the annex item was recognized as having a few editorial issues, many members
observed that this was an annex item and not a part of the body of the standard and
therefore would be better addressed editorially in the next edition.
2. There was information contained in the annex item that addressed the need to make
sure an empty extinguisher, however the pressurization state was observed, is
replaced with an appropriate extinguisher. This information would not be presented
if the annex item is deleted as indicated by the amending motion.
To be clear, the TIA not only recommended deletion of the last two sentences, it also contained a
recommendation to add a new sentence that reads as follows:
“A self‐expelling, cartridge-operated, or pump tank extinguisher’s fullness can be

determined by removing the extinguisher from its mounting location.”

The vote on the TIA by the committee was that the Standards Council not issue the TIA.
Subsequent to the committee vote, the decision of the Standards Council was not to issue the
TIA.
Since this motion contains a recommendation to delete the same two sentences as the TIA,
it is important that the NFPA membership understand the background information provided above.
No further deliberation was conducted by the technical committee. Based on the ballot results for
the TIA, the position of the committee is to oppose this motion.
Inclusion of a new A.7.7.2(5) is the subject of SR-18. The ballot results for this item
indicate there were 27 Eligible Voters, 15 Affirmative, 2 Affirmative with Comments, 5 Negative
with Comments, and 5 Not Returned.
Based on these ballot results, the position of the committee is to oppose this motion.
Nathaniel J. Addleman
on behalf of the Technical Committee on Portable Fire Extinguishers

June 2021
The language at the center of this filing was added to Annex 5.1 which now concludes
that when Class A (ordinary) fuels are also present with Class B (liquid & gas) fuels then high-
flow extinguishers are the 'most appropriate' type. If such a statement was even true then it
constitutes a requirement of NFPA 10 and should be located in the body of the Standard. If the
Committee truly believes that high-flow extinguishers are indeed the most appropriate
extinguisher selection for Class A&B fuels then this is a true code requirement. The fact of the
matter is that the selection of a high-flow extinguisher based solely on the presence of Class
A&B fuels is completely contrary to the body of study and product development which led to the
first high-flow extinguisher language in NFPA 10's 2007 edition. That 2007 language, which
remains unchanged to this day, is only triggered when any of three very specific Class B fire
hazards are identified; obstacle, gravity, or pressurized. It is through the long established
principles of extinguisher selection spelled out in Annex C of NFPA 10 that users would have to
consider whether any three of those specific Class B fire hazards are predicted to be present.
(See Annex C, Section C.2, C.2.6.3, C.2.6.4, & C.2.6.5). In the absence of any of those
triggering scenarios there is no need or requirement for high-flow extinguishers and in fact there
is a substantial risk under fire conditions if a high-flow extinguisher is provided for Class A fire
extinguishment.
When high-flow multi-purpose (ABC) extinguishers are compared to their standard
discharge counterparts a striking difference is noted in the Class A protection ratings as assigned

in the UL evaluation process. Since there is no such extinguisher as a 5# high-flow the 10# and
20# are used for this comparison:
High-flow 10# typical rating 1-A:20-B:C compared to a standard rate 10# which carries a
4-A:60(or 80)-B:C rating. In the 20# variety a high-flow model only carries a 4A rating which
the 20# standard flow models typically provide a 10A rating.
There is an appreciable and in fact detrimental difference in Class A extinguishment
capability between same sized high-flow and standard rate extinguishers. Through the UL
evaluation for ratings it is well established that high-flow models cannot achieve comparable
Class A ratings based on the inability to handle re-flash during the mandatory holding time
period of the UL tests, +15 minutes, after extinguishment to still have reserve agent to reapply if
re-flash occurs.
Protection of Class B special hazards as discussed above goes back earlier than the 1978
edition of NFPA 10 and was only revised in 2007 for the high-flow performance criteria of a
minimum 1 pound per second versus manufacturer recommendation language. This was to
establish uniformity and level the product listing and evaluation process. At no time in recent
history or back 45+ years has NFPA 10 ever considered high-flow dry chemical as the 'most
appropriate' extinguisher selection based solely on the presence of Class A&B fuels. The Annex
C language defining a uniform hazard evaluation and extinguisher selection criteria remains
valid and is irreparably harmed by this recent of 'most appropriate' to the extinguisher selection
section Annex. This Annex language appears to conclude for any NFPA 10 user that there is no
need for the Annex C subjective analysis for extinguisher selection and instead the Committee
has concluded that high-flow dry chemical is 'most appropriate' for any and all Class A&B fuel

scenarios. There is no such thing as a universally 'most appropriate' extinguisher without first
having completed the subjective analysis process well described in Annex C. Thank you.
David T. Phelan.
Township of North Bergen

Report of the Technical Committee on Portable
Fire Extinguishers
June 2021
The Report of the Technical Committee on Portable Fire Extinguishers presented as found
in the First Draft Report and Second Draft Report for the Annual 2021 cycle of NFPA 10, Standard
on Portable Fire Extinguishers. The revisions were submitted to letter ballot of the responsible
Committee(s) in accordance with the Regulations Governing the Development of NFPA Standards.
The reports and ballot results can be found on the next edition tab of the Document Information
page for NFPA 10 at www.nfpa.org/10next .
Certified Amending Motion No. 10-12 addresses an Annex item that provides additional
information regarding extinguisher selection. It discusses a specific situation regarding the
involvement of flammable liquids in a fire that involves ordinary combustibles. The discussion
describes the potential difference of such a fire. The last sentence provides guidance that may
result in the selection of a fire extinguisher that may be more suitable for such a fire. To delete
the last sentence, as proposed by 10-12, leaves only the description of the potentially more
challenging fire with no suggestion of how the situation may be addressed.
The ballot results for this item in the Second Revision were 27 eligible voters with 18
affirmative, 2 affirmative with comments, 2 negative with comments, and 5 ballots not returned.
The comments did not cause members to change their votes to negative. Based on just two
negative votes, the position of the committee is to oppose this motion.
Nathaniel J. Addleman
on behalf of the Technical Committee on Portable Fire Extinguishers

Certified Amending Motion No. 13-4 (same motion as 13-18 and 13-26 grouped by
Motions Committee)
June 2021
The first revision No. 1112-NFPA 13-2019 (Section 9.3.6.1) to eliminate the pit sprinklers has
passed the AUT-SSI Ballot with 26 Affirmative Votes Vs. 4 Negative Votes. The Committee
statement was detailed and comprehensive: I greatly support this AUT-SSI Committee Statement
with the following cited bottom line: "It will be the right thing to do for the next edition to delete
the pit sprinkler requirement from NFPA 13 and to increase safety." This issue was discussed
during the last code cycle - It was requested by the SIG-AUT TC to provide examples for
elevators associated injuries and fatalities which was provided to the TC. (1) It was presented by
the NEII's representative (Mr. Lawrence Taylor) during the 2018 Tech-Session that in the last
150 years of elevators data gathering, there is not even one documented hydraulic elevator pit
fire that caused the sidewall pit sprinkler to activate. (2). It is evident that the elevator hoistways
and pits are dangerous working locations for elevator and non-elevator workers. There are many
injuries and fatalities of elevator personnel and non-elevator personnel performing work in
elevator pits. (Examples were provided to the TC and are available from OSHA and other
sources indicating Crushing, Falling, Shock and miscellaneous accidents) (3). Removing the pit
sprinkler requirement for hydraulic elevators from NFPA 13 will increase safety by not requiring
elevator and non-elevator workers to service the sprinklers and their associated fire alarm
initiating devices located in those pits. (4). The majority of NFPA members supported this
proposal at the 2018 Tech-Session in Las Vegas (See results for CAM 13-6) (5) Three National
Organizations: NEII, BOMA and AFAA had supported the removal of the pit sprinklers
requirement from NFPA-13 at the 2018 Tech-Session, Also, the CAFAA is also in support of

this proposal to increase safety for Fire Alarm personnel (6) The majority of the SIG-AUT
committee members (14-12) were in favor of CAM 13-6 after the 2018 Tech-Session, however,
CAM 13-6 had failed because it did not achieve the NFPA required 2/3 majority. It will be the
right thing to do for the 2022 edition to delete the pit sprinklers requirement from NFPA 13 and
increase safety.
Additional Reasons to Reject SR No. 1105: (1) The First Revision No. 1112 was passed with the
AUT-SSI ballot results of 26 in favor and only 4 negative votes and with a detailed committee
statement and substantiation. It is not clear why the Second Revision 1105 changed the
committee decision made in FR No.1112 without any detailed and specific substantiation as was
provided for FR 1112. Therefore, I ask that the AUT-SSI Committee revert back to their decision
on FR 1112 and reject the unsubstantiated SR 1105. (2). The only reason made by the committee
for SR 1105 in their Committee Statement was that sprinklers are required in the hoistway
(including the pit) until "Fire Data presented otherwise”. I would like to cite Mr. Lawrence
Taylor's (AUT-SSI Member) Negative response to the SR-1105 argument that “Fire Data was
not presented to present otherwise”. This is Mr. Lawrence Taylor's statement on SR 1105 Ballot:
"Taylor, Lawrence M. I am not in favor of sprinklers anywhere in the elevator machine
rooms/space, control rooms/spaces or hoistways. The lack of evidence of their usefulness and
effectiveness is the evidence. Otherwise those who are in favor of this would have information
available to show the effectiveness and usefulness, and such evidence has not been presented"
(3). I would like to also cite AUT-SSI Committee Member, Mr. Michael Meehan's statement to
reject SR No. 1105. I strongly agree with his statement. "Meehan, Michael F. The committee
should have stayed with the voted on position from the First revision and allowed the sprinklers
to be omitted. I disagree with the committee substation that evidence was not provided,

numerous, substantial and specific evidence was provided including this point from the National
Elevator Industry. It was presented by the NEII's representative (Mr. Lawrence Taylor) during
the 2018 Tech-Session that in the last 150 years of elevators data gathering, there is not even one
documented hydraulic elevator pit fire that caused the sidewall pit sprinkler to activate”. (4). The
State of California has recently amended the 2019 California Building Code in Chapter 35 -
Referenced Standards, to delete the pit sprinklers sections from NFPA 13. Effective 7/1/2021,
per the published CBC 2019 Supplement, pit sprinklers shall not be required for all elevators
(electric and hydraulic) throughout the state of CA. This decision was made by the California
State Building Standards Commission based on the CA state Fire Marshal (CSFM) Task Force
work on elevator safety issues. Other US states and jurisdictions have also eliminated the NFPA
13 requirement for pit sprinklers in their local codes (Mr. Lawrence Taylor can reference and
specify over 200 Counties in Texas and in Minnesota who have eliminated pit and hoistway
sprinklers from their codes with no negative impact). This shows that many people and
jurisdictions throughout the US understand that the right way to increase safety is to eliminate
the pit sprinklers. This is based on the AUT-SSI FR 1112 committee statement, the majority of
NFPA membership per Cam 13-6, and major states and jurisdictions throughout the country.
From all the above reasons, I urge the committee to reject SR 1105 and stay with FR 1112
decision to increase safety.
Sagiv Weiss-Ishai,
San Francisco Fire Department

Certified Amending Motion No. 13-18 (same motion as 13-4 and 13-26 grouped
by Motions Committee)
June 2021
The first revision No. 1112 NFPA 13-2019 (Section 9.3.6.1) to eliminate the pit sprinklers has
passed the AUT-SSI Ballot with 26 Affirmative Votes Vs. 4 Negative Votes. The Committee
statement was detailed and comprehensive: I greatly support this AUT-SSI Committee Statement
with the following cited bottom line: "It will be the right thing to do for the next edition to delete
the pit sprinkler requirement from NFPA 13 and to increase safety." This issue was discussed
during the last code cycle - It was requested by the SIG-AUT TC to provide examples for elevators
associated injuries and fatalities which was provided to the TC.
(1) As NEII's representative during the 2018 Tech-Session, I submitted that in the last 150 years
of elevator data gathering, I could not find one documented hydraulic elevator pit fire that caused
the sidewall pit sprinkler to activate.
(2). It is evident that the elevator hoistways and pits are dangerous working locations for elevator
and non-elevator workers. There are many injuries and fatalities of elevator personnel and non-
elevator personnel performing work in elevator pits. (Examples were provided to the TC and are
available from OSHA and other sources indicating Crushing, Falling, Shock and miscellaneous
accidents)
(3). Removing the pit sprinkler requirement for hydraulic elevators from NFPA 13 will increase
safety by not requiring elevator and non-elevator workers to service the sprinklers and their
associated fire alarm initiating devices located in those pits.
(4). The majority of NFPA members supported this proposal at the 2018 Tech-Session in Las
Vegas (See results for CAM 13-6)

(5) Three National Organizations: NEII, BOMA and AFAA had supported the removal of the pit
sprinklers requirement from NFPA-13 at the 2018 Tech-Session, Also, the CAFAA is also in
support of this proposal to increase safety for Fire Alarm personnel
(6) The majority of the SIG-AUT committee members (14-12) were in favor of CAM 13-6 after
the 2018 Tech-Session, however, CAM 13-6 had failed because it did not achieve the NFPA
required 2/3 majority. It will be the right thing to do for the 2022 edition to delete the pit sprinklers
requirement from NFPA 13 and increase safety.
(7). The State of California has recently amended the 2019 California Building Code in Chapter
35 - Referenced Standards, to delete the pit sprinklers sections from NFPA 13. Effective 7/1/2021,
per the published CBC 2019 Supplement, pit sprinklers shall not be required for all elevators
(electric and hydraulic) throughout the state of CA. This decision was made by the California State
Building Standards Commission based on the CA state Fire Marshal (CSFM) Task Force work on
elevator safety issues.
(8). Other US states and jurisdictions have also eliminated the NFPA 13 requirement for pit
sprinklers in their local codes. (More than 200 Counties in Texas have eliminated hoistway
sprinklers from their codes with no negative impact). This shows that many people and
jurisdictions throughout the US understand that the right way to increase safety is to eliminate the
pit sprinklers. This is based on the AUT-SSI FR 1112 committee statement, the majority of NFPA
membership per Cam 13-6, and major states and jurisdictions throughout the country. From all the
above reasons, I urge the committee to stay with FR 1112 decision to increase safety.
Lawrence M. Taylor,
Schindler Elevator Corporation

Certified Amending Motion No. 13-26 (same motion as 13-4 and 13-18 grouped by
Motions Committee)
June 2021
The first revision No. 1112-NFPA 13-2019 (Section 9.3.6.1) to eliminate the pit
sprinklers passed the AUT-SSI Ballot with 26 Affirmative Votes Vs. 4 Negative Votes. The
Committee statement was detailed and comprehensive. I greatly support this AUT-SSI
Committee Statement with the following bottom line: "It will be the right thing to do for the next
edition to delete the pit sprinkler requirement from NFPA 13 and to increase safety." This issue
was discussed during the last cycle. It was requested by the SIG-AUT TC to provide examples
for elevator-associated injuries and fatalities, which was provided to the TC.
It was presented by Mr. Lawrence Taylor during the 2018 Tech-Session that in the last
150 years of elevator data gathering, there is not even one documented hydraulic elevator pit fire
that caused the sidewall pit sprinkler to activate. There are many injuries and fatalities of elevator
personnel and non-elevator personnel performing work in elevator pits. (Examples were
provided to the TC). Removing the pit sprinkler requirement for hydraulic elevators from NFPA
13 will increase safety by not requiring elevator and non-elevator workers to service the
sprinklers and their associated fire alarm initiating devices located in those pits. The vast
majority of NFPA members supported this proposal with overwhelming majority. Three National
Organizations NEII, BOMA and AFAA support the removal of the pit sprinklers requirement
from NFPA-13. The Majority of the SIG-AUT committee members (14-12 vote) were in favor of
this proposal (CAM 13-6) during the last Ballot after the Tech-Session, however, CAM 13-6
failed because it did not achieve the required 2/3 majority. This proposal passed the majority of
both the NFPA membership with CAM 13-6 and also the majority of the AUT-SSI after CAM

13-6 was passed. In addition, the First Revision No. 1112 was passed with AUT-SSI ballot
results of 26 in favor and only 4 negative votes and with a detailed committee statement and
substantiation. Therefore it is not clear why the Second Revision changed the committee decision
made in FR No.1112 without any detailed and specific substantiation. I ask that the AUT-SSI
Committee revert back to their decision on FR 1112 and reject the unsubstantiated SR 1105. The
only reason made by the committee for SR 1105 in their Committee Statement was that
sprinklers are required in the hoistway (including the pit) until "Fire Data presented otherwise". I
would like to cite Mr. Lawrence Taylor's (AUT-SSI Member) Negative response to the argument
that Fire Data was not presented to present otherwise. THE LACK OF Fire Data (during the last
150 years of documented elevator fires) in elevator pits which are intended to cause the
activation of a pit sprinkler IS THE EVIDENCE that no such fires exist. Rather, the reverse logic
should be used. If someone would like to prove that pit sprinklers are effective to extinguish
potential hydraulic pit fires - they should provide evidence for such events. Also, during the
public comment phase, elevator hoistways injuries and fatalities data was presented to the
committee to show that both elevator and non-elevator personnel are subjected to a relatively
high risk when they perform work in the hoistway and pits. If the pit sprinklers are omitted, less
persons (especially untrained non-elevator personnel such as sprinkler and fire-alarm personnel)
would be required to perform sprinkler and Fire Alarm associated work (maintenance, repair,
testing, inspection, etc.) in these spaces and this will increase safety. This is Mr. Lawrence
Taylor's statement on SR 1105 Ballot:
"I am not in favor of sprinklers anywhere in the elevator machine rooms/space, control
rooms/spaces or hoistways. The lack of evidence of their usefulness and effectiveness is the
evidence. Otherwise those who are in favor of this would have information available to show the
effectiveness and usefulness, and such evidence has not been presented". I would like to cite

Committee Member, Mr. Michael Meehan's statement to reject SR No. 1105. I strongly agree
with this statement: "The committee should have stayed with the voted-on position from the First
revision and allowed the sprinklers to be omitted. I disagree with the committee substantiation
that evidence was not provided, numerous, substantial and specific evidence was provided
including this point from the National Elevator Industry – It was presented by the NEII's
representative (Mr. Lawrence Taylor) during the 2018 Tech Session that in the last 150 years of
elevators data gathering, there is not even one documented hydraulic elevator pit fire that caused
the sidewall pit sprinkler to activate”.
The State of California has recently amended the 2019 California Building Code in
Chapter 35 - referenced standards to delete the pit sprinklers sections from NFPA 13. Effective
7/1/2021 pit sprinklers shall not be required for all elevators (electric and hydraulic). This
decision was made by the California State Building Standards Commission based on the CA
state Fire Marshal Task Force work on elevator safety. Other US states and jurisdictions have
also eliminated the NFPA 13 requirement for pit sprinklers in their local codes (Mr. Lawrence
Taylor can reference and specify over 200 Counties in Texas and in Minnesota who have
eliminated pit and hoistway sprinklers from their codes). This shows that many people
understand that the way to increase safety is to eliminate the pit sprinklers based on the AUT-SSI
FR 1112 committee statement, the majority of NFPA membership per CAM 13-6, and major
states and jurisdictions throughout the country.
From all the above reasons, I urge the committee to reject SR 1105 and stay with the FR
1112 decision to increase safety.
David McColl, P. Eng.,

Otis Elevator Company

Report of the Technical Committee on Sprinkler
System Installation Criteria
Certified Amending Motion No. 13-4/13-18/13-26
June 2021
The Report of the Technical Committee on Sprinkler System Installation Criteria is
presented as found in the First Draft Report and Second Draft Report for the Annual 2021 revisions
cycle of NFPA 13, Standard for the Installation of Sprinkler Systems. The revisions were
submitted to letter ballot of the responsible Committee(s) in accordance with the Regulations
Governing the Development of NFPA Standards. The reports and ballot results can be found on
the next edition tab of the Document Information page for NFPA 13 at www.nfpa.org/13next.
This CAM proposes to eliminate the requirement for sprinklers in the pits of hydraulic
elevators using combustible hydraulic fluids. This Issue has had significant debate within the
committee and at the NFPA Annual meeting over the last two code development cycles. During
this current code development cycle, the committee requested data supporting the removal of
sprinklers from elevator pits for elevators using combustible hydraulic fluids. The committee did
not receive data that they felt they could act on.
The vote to keep the requirement for sprinklers in pits of elevators using combustible
hydraulic fluids was 23 affirmative and 9 negative votes.
Raymond A. Grill
on behalf of the Technical Committee on Sprinkler System Installation Criteria

Certified Amending Motion No. 13-17 (same resulting text as 13-44 grouped by the
Motions Committee)
Motion to Accept an Identifiable Part of Public Comment No. 47
June 2021
The substantiation/rationale for this proposal was explained in detail in PC # 47; However, the
AUT-SSI committee did not address this rationale in their committee resolution statement. (1)
Subsection # 2 of 9.3.6.1 is proposed to be deleted since it is unnecessary to be included in
NFPA 13. There is no need for NFPA 13 to require smoke detectors or other fire detection in
elevator spaces even if these spaces are un-sprinklered since the requirements for smoke
detectors or other fire detection initiating devices in sprinklered and un-sprinklered elevator
hoistways are already listed in ASME A17.1 (National Elevator Code). (2) This subsection # 2
creates major conflicts and inconsistencies between NFPA 13 and the ASME A17.1 Elevator
code. The biggest problem and inconsistency is regarding passenger elevators (hydraulic and
electric) with associated machine rooms: Per NFPA 13 Section 9.3.6.6, sprinklers are not
required for these elevators at the top of the hoistway and per the ASME A17.1 Code, Fire
Alarm Initiating Devices (FAIDs) which could be smoke detectors or other fire detectors are also
NOT required at the top of these hoistways. The problem is that based on this Subsection # 2,
many designers and AHJs are interpreting the intent of NFPA 13 to require smoke detectors at
the top of all un-sprinklered passenger elevator hoistways (hydraulic and electric) despite the fact
that these FAIDs are not required by the elevator code.
NOTE (for reference only): From the above reason of inconsistency, the state of CA has deleted
subsection # 2 from NFPA 13 in the 2019 California Building Code Supplement in Chapter 35 as
a CA amendment to NFPA 13. This deletion of Subsection # 2 will become effective in CA on
7/1/2021when the CBC-2019 Supplement will take effect. This work was done in CA by an

Elevator-Fire codes Task Force led by the CA State Fire Marshal (CSFM) with NEII
representatives, AHJs and other stake holders. (3) The AUT-SSI committee resolution for this
item in PI 258 was: "Elimination of NFPA 72 requirements lowers the level of safety too far."
However, there is not any elimination of NFPA 72 requirements in this proposal. The Phase I
Recall Smoke Detectors (FAIDs) are still required by the A17.1 Code Section 2.27.3.2 and they
are still required to be installed in accordance with NFPA 72. Per the A17.1 Code, a FAID is
required to be installed at the top of every Machine Room Less (MRL) elevator at the machinery
space containing the motor controller or driving machine even if it is un-sprinklered (See item b
to A17.1 section 2.27.3.2 and the specific NOTE associated with item b at the bottom of this
section) This (2.27.3.2) is the code section from ASME A17.1 which requires Phase I Recall
smoke detectors in elevator spaces:
2.27.3.2 Phase I Emergency Recall Operation by Fire Alarm Initiating Devices 2.27.3.2.1 In
jurisdictions not enforcing the NBCC, smoke detectors or other automatic fire detectors in
environments not suitable for smoke detectors (fire alarm initiating devices) used to initiate
Phase I Emergency Recall Operation shall be installed in conformance with the requirements of
NFPA 72, and shall be located (a) at each elevator lobby served by the elevator (b) in the
associated elevator machine room, machinery space containing a motor controller or driving
machine, control space, or control room (c) in the elevator hoistway, when sprinklers are
located in those hoistways NOTE [2.27.3.2.1(b)]: A machinery space containing a motor
controller or driving machine located in the elevator hoistway, or a control space located in the
elevator hoistway requires a fire alarm initiating device regardless of the presence of sprinklers.
(4) It should not be the purview of NFPA 13 to mandate or require smoke detectors or other
FAIDs in elevator associated spaces. It is only the purview of the A17.1 Code to require FAIDs

in elevators associated spaces since all FAIDs in elevator associated spaces are also required to
generate Elevator Phase I Emergency Recall Operation which is outside the scope of NFPA 13.
(5) The intent of the current NFPA 13 Section 9.3.6.6 which has the same code language as in
many previous NFPA 13 editions was to not require sprinklers at the tops of passenger elevators
hoistways (meeting the A17.1 non-combustibility requirements). This NFPA 13 section never
required the addition of top-of-hoistway smoke detection in lieu of this non-required sprinkler.
And this is where the conflict exist: the current section 9.3.6.3 item # 2 seems like it requires a
smoke detector to be installed at the top of passenger elevator hoistways when sprinklers are not
required to be installed at those hoistways per 9.3.6.6. The smoke detectors are still required to
be provided at the tops of all Machine-Room-Less (MRL) Passenger Elevators per the A17.1
Code and installed per NFPA 72. But there are still many passenger elevators with machine
rooms (standard overhead traction elevator and hydraulic elevators) which currently do not
require associated smoke detection at their top of hoistways and this is the main issue that this
proposal is trying to resolve. (6) NFPA 72 Section 21.3.7 requires all FAIDs installed inside
elevator hoistways to be accessible from outside the hoistway. Based on this Subsection (2) to
Section 9.3.6.1, if FAIDs are required to be installed at the tops of all un-sprinklered elevator
hoistways, this drastically and unnecessarily increases the cost and burden to building owners by
forcing them to provide the required access means to the FAID from outside the hoistway and
also the associated maintenance, testing, repair and inspection of the FAIDs.
This unnecessary cost and burden will be eliminated if this Subsection # 2 is deleted.
Sagiv Weiss-Ishai

Certified Amending Motion No. 13-44 (same resulting text as 13-17 grouped by
the Motions Committee)
Motion to Accept an Identifiable Part of Public Comment No. 317
June 2021
The substantiation/rationale for this proposal was explained in detail in PC # 317; However, the
AUT-SSI committee did not address and ignored this rationale in their committee resolution
statement. Subsection # 2 of 9.3.6.1 is proposed to be deleted since it is unnecessary to be
included in NFPA 13. There is no need for NFPA 13 to require smoke detectors or other fire
detection in elevator spaces even if these spaces are unsprinklerd since the requirements for
smoke detectors or other fire detection devices in sprinklered and unsprinklered elevator
hoistways are already listed in ASME A17.1 (National Elevator Code).
This subsection # 2 creates major conflicts and inconsistencies between NFPA 13 and the ASME
A17.1 Elevator code. The biggest problem and inconsistency is regarding passenger elevators
(hydraulic and electric) with associated machine rooms. Per NFPA 13 Section 9.3.6.6, sprinklers
are not required for these elevators at the top of the hoistway and per the ASME A17.1 Code,
Fire Alarm Initiating Devices (FAIDs) which could be smoke detectors or other fire detectors are
also NOT required at the top of these hoistways. The problem is that based on this subsection #
2, many designers and AHJs are interpreting the intent of NFPA 13 to require smoke detectors at
the top of all unsprinklered passenger elevator hoistways (hydraulic and electric) despite the fact
that these FAIDs are not required by the elevator code.
REFERENCE NOTE: Due to this inconsistency, the state of California has deleted subsection #
2 from NFPA 13 in the Next California Building Code edition in Chapter 35 (referenced
standards as a CA amendment to NFPA 13) . This deletion of subsection # 2 will become
effective in CA effective 7/1/2021.

The AUT-SSI committee resolution for this item in PI 258 was: "Elimination of NFPA 72
requirements lowers the level of safety too far." However, there is not any elimination of NFPA
72 requirements in this proposal. The Phase I Recall Smoke Detectors (FAIDs) are still required
by the A17.1 Code Section 2.27.3.2 and they are still required to be installed in accordance with
NFPA 72. Per the A17.1 Code, a FAID is required to be installed at the top of every Machine
Roomless (MRL) elevator at the machinery space containing the motor controller or driving
machine even if it is unsprinklered (See item (b) to this section and the specific NOTE associated
with item (b) at the bottom of this section).
It should not be the purview of NFPA 13 to mandate or require smoke detectors or other FAIDs
in elevator-associated spaces. It is only the purview of the A17.1 Code to require FAIDs in
elevator- associated spaces since all FAIDs in elevator associated spaces are also required to
generate Elevator Phase I Emergency Recall Operation which is outside the scope of NFPA 13.
The intent of the current NFPA 13 Section 9.3.6.6 which has the same code language as in many
previous NFPA 13 editions was to not require sprinklers at the tops of passenger elevators
hoistways (meeting the A17.1 non-combustibility requirements). This NFPA 13 section never
required the addition of top-of-hoistway smoke detection in lieu of this non-required sprinkler.
The current section 9.3.6.3 item # 2 seems like it requires a smoke detector to be installed at the
top of passenger elevator hoistways when sprinklers are not required to be installed at those
hoistways per 9.3.6.6.
The smoke detectors are still required to be provided at the tops of all Machine-Room-Less
(MRL) Passenger Elevators per the A17.1 Code and installed per NFPA 72. But there are still
many passenger elevators with machine rooms (standard overhead traction elevator and

hydraulic elevators) that currently do not require associated smoke detection at their top of
hoistways and this is the main issue that this proposal is trying to resolve.
NFPA 72 Section 21.3.7 requires all FAIDs installed inside elevator hoistways to be accessible
from outside the hoistway. Based on this Subsection (2) to Section 9.3.6.1, if FAIDs are required
to be installed at the tops of all unsprinklered elevator hoistways, this drastically and
unnecessarily increases the cost and burden to building owners by the required access to the
FAID from outside the hoistway and the associated maintenance, testing, repair and inspection of
the FAIDs and the required access means. This unnecessary cost and burden will be eliminated if
this Subsection 2 is deleted.
David McColl, P. Eng.,

Otis Elevator Company

Certified Amending Motion No. 13-17/13-44
June 2021
presented as found in the First Draft Report and Second Draft Report for the Annual 2021 revision
This CAM proposes to remove any reference to the installation of smoke detectors or fire
alarm initiating devices as part of the allowance to not require sprinklers in elevator machine
rooms, machinery spaces, control rooms, control spaces or hoistways as part of the allowance to
eliminate the requirement for sprinklers.
The committee deliberated on a number of public inputs and public comments during the
development of the first and second revision and by a vote of 30 affirmative to 1 negative,
decided to maintain the requirement in NFPA 13 as part of the allowance.
Raymond A. Grill

Certified Amending Motion No. 13-23 (same resulting text as 13-37 and 13-42
grouped by the Motions Committee)
Motion to Accept Public Comment No. 256
June 2021
NFPA 13-2022 First Revision No. 1195 (FR-1195) attempts to add requirements for water
supply adjustments that were previously reversed by NFPA membership at the 2018 Technical
Meeting. Certified Amending Motion 13-23 moves to accept Public Comment No. 256, reverse
the changes made by FR-1195, and return the water supply language back to the language currently
published in the 2019 edition of NFPA 13.
Responsible Parties
Although the proposed language for the 2022 edition of NFPA 13 was slightly softened
from the proposed 2019 language, the requirements are still not acceptable for installing
contractors. The burden of the water supply adjustment needs to be placed solely on the
owner/engineer of record and that needs to be clearly stated in the standard and not just inferred
through reference. The location of requirements has meaning when enforcing the standard and
these requirements would be more appropriately located as annex language to the requirements for
the owner’s certificate in section 4.2.
The requirements of proposed sections 5.2.2.2.1 and 5.2.2.2.2 require knowledge of the water
supply and an engineering judgement. Without retaining a professional engineer, both requests
would require an installing contractor to practice engineering without a license. It is unreasonable
to require an installing contractor or any entity other than the water purveyor to have sufficient
knowledge of the water supply to make a reasonable adjustment. As stated in the purpose of NFPA
13:

1.2.1 The purpose of this standard shall be to provide a reasonable degree of protection
for life and property from fire through standardization of design, installation, and testing
requirements for sprinkler systems, including private fire service mains, based on sound
engineering principles, test data, and field experience.
While the installation standard is based on sound engineering principles, engineering judgements
should not extend outside of the owner’s requirements in Chapter 4 or into the prescriptive
requirements of the standard. NFPA 13 is an installation standard and not a design guide, and
decisions to modify water supplies need to be left to the owner/engineer.
Enforceability
Who makes the final determination on whether the water supply adjustment based on
knowledge of the water supply and engineering judgement is sufficient? Is it the owner? Is it the
engineer? Does the fire marshal approve the adjustment? Does the water purveyor have a final
say? Is the same adjustment going to be used by all parties involved in bidding a project? The
current proposed process is inconsistent, not repeatable, and will vary from jurisdiction to
jurisdiction. The proposed language leaves too many unanswered questions that will prove to be
roadblocks in the future and cause delays in the progression of a project. Water supplies should be
handled at a local level and left up to the local jurisdictions to mandate consistent policies for
adjustments.
Double Jeopardy
Historically, NFPA 13 has not required a safety factor to be applied to the hydraulic design of
sprinkler systems. Safety is inherently built into the installation of a sprinkler system through
several design factors:

1. Estimated C Values – Lower C Values are utilized to account for interior deterioration and
corrosion of pipe over time.
2. Spacing and overspray of sprinklers – Sprinklers cover rectangular areas, but have conical
discharge patterns.
3. Design areas – Data and testing show that the number of sprinklers that activate and control
a real fire event are less than the number of sprinklers that are calculated during the design
of the system.
4. K-factors of sprinklers – The discharge coefficient of a sprinkler varies within a given
range; however, the designer is required to utilize the nominal value.
Because this adjustment specifically states that it is to be taken before comparison to the
sprinkler demand, safety factors imposed by local jurisdictions would be compounded with a
diminished water supply. This would unnecessarily penalize the contractor, increase costs for the
owner, and provide no greater level of protection.
Conclusion
The proposed requirements in FR-1195 are unenforceable and only add confusion – not
clarity – to the standard. The current language contained in the body and annex of the 2019 edition
are sufficient and clear. Until there are technical data and documented failures or close calls to
support the adjustment, the language should remain unchanged. Please vote in favor of CAM 13-
23.
John August Denhardt, P.E., ET, CWBSP, FSFPE

American Fire Sprinkler Association

June 2021
Certified Amending Motion 13-37 has been submitted on behalf of the National Fire
Sprinkler Association Engineering and Standards Committee and seeks to accept Public Comment
No. 172 which will delete the language added by First Revision No. 1195 and return the language
on this issue to the that of the 2019 edition (and earlier editions) of NFPA 13. The existing language
in Sections 5.2.2, A.5.2.2, and A.5.2.2.2 is adequate and gives sufficient guidance regarding
performing and evaluating hydrant flow tests. The proposed change regarding water supply
evaluations does not provide clarification and will likely cause additional confusion regarding this
issue.
The following issues were considered in submitting this motion:
• As shown by the enviable record of fire sprinkler systems, the current language found in
5.2.2.2 and its associated annex language has been proven to be adequate and needs to
remain as currently written. As shown by NFPA’s own data, fire sprinkler systems are
extremely effective, and the rare failures are primarily caused by closed control valves and
not by insufficient water supplies.
• The current language found in 5.2.2.2 states the flow and pressure of the water supply must
be determined by an approved method. This means that the Authority Having Jurisdiction
(AHJ) needs to be consulted and approve the method used to determine the volume and
pressure of the public water supply. The annex to this section gives sufficient guidance for
the AHJ to use to evaluate the adequacy of the water supply depending on multiple factors,

and to approve the method used to determine volumes and pressures available including
any adjustments that might be needed where appropriate.
• The time-tested process mandated by NFPA 13 in determining the proper design criteria
has been proven to be adequate. While a specific safety factor is not mandated by NFPA
13, the process has been shown to be more than sufficient. NFPA 13 has safety built into
the process. The hydraulic calculation process and the listing process for sprinklers is
inherently conservative. Some of the factors that build in safety include required discharge
densities, size and shape of the hydraulically most remote area, Hazen-Williams C values,
and more. It needs to be noted the data indicates most fires are controlled with far fewer
sprinklers than are typically included in the remote area and when fewer sprinklers are
activated, they discharge at a higher pressure.
• The proposed language in Sections 5.2.2.2.1, 5.2.2.2.2.2, 5.2.2.22.1 and all associated
annex text is inappropriate to be included in the general section of NFPA 13 (Chapter 5).
Specific knowledge of the water supply is the responsibility of the water purveyor and
engineering judgment is the responsibility of a professional engineer. It is not reasonable
to give this responsibility to all users of NFPA 13. If these new requirements are to be
added to NFPA 13, they would be more appropriate to be included in the Owner’s
Certificate (Section 4.2) which requires the owner and their responsible design professional
to provide the water supply information including any needed evaluation. However, the
fact that this information will be added to Chapter 5, will force all users including the
installing contractor to take on the responsibilities of the engineer and of the owner.
• The information required to comply with these new requirements is difficult and, in some
cases, impossible to obtain and would require contacting multiple sources. Some of the

information may be obtained from the water purveyor, however, this is not a given. Some
of the larger water utilities may have the information on maximum daily use and peak hour
demand, but there are many small utilities that may not have this information available.
Future planned development that may impact the existing water supply would be very
difficult to obtain.
In conclusion, the current language in the 2019 edition of NFPA 13 provides, as the scope in
Section 1.1.1 requires, the “minimum requirements for the design…” The new requirements
proposed for the body of the standard are not needed and will lead to confusion and misapplication
of this “required” evaluation. No data was submitted showing that the current language is a
problem or is leading to ineffective systems. The new requirements are unreasonable, not needed,
and difficult if not impossible to comply with and must be deleted from the next edition of NFPA
13.
Roland Asp
National Fire Sprinkler Association

June 2021
My motion to accept a public comment is intended to delete new text that was added to
NFPA 13 during the first revision dealing with water supplies and how to obtain the necessary
water supply data in flow (GPM) and pressure (PSI) to perform hydraulic calculations for a
sprinkler system. The basis for my motion is that the language in the 2019 edition of NFPA 13 is
perfectly adequate, and the new requirements go above and beyond a reasonable means to obtain
water supply information. There are several key reasons why it’s essential for the NFPA
membership to vote to delete the new unreasonable criteria that requires an evaluation and the use
of engineering judgement to determine if an adjustment is needed to the raw water supply test data:
1. The existing requirement in section 5.2.2.2 is adequate because it requires the method used to
provide water supply data to be approved. That means the AHJ must be consulted and approve
the method used. The AHJ has specific knowledge of the water supplies in their jurisdiction
and can require any adjustment that they believe is needed. The annex to 5.2.2 and 5.2.2.2
provides directions on how to conduct a water flow test using hydrants as well as adequate
guidance on what factors should be taken into consideration when discussing any needed
adjustments with the AHJ.
2. The added requirements in sections 5.2.2.1 through 5.2.2.2.2.3 and all related annex text puts
an undue burden on sprinkler contractors trying to do the right thing when trying to establish
water supply data. NFPA 13 is the Standard for the Installation of Sprinkler Systems and is

geared toward the installing sprinkler contractor. These new sections require an evaluation,
requires that engineering judgement be used, and requires the use of data for the evaluation
that isn’t available to the installing contractor, such as daily and seasonal fluctuations. The
AHJ has knowledge of this data and access to it, whereas the sprinkler contractor does not.
3. The added requirements in sections 5.2.2.1 through 5.2.2.2.2.3 and all related annex text
applies to a design professional or engineer of record and should not be a general requirement
for the users of NFPA 13. The SFPE Position Statement 2020-1 makes it very clear that water
supply adjustments are the responsibility of the engineer, and I quote:
“The Engineer is responsible for the preparations of engineering documents that establish
the objectives and design criteria of the system(s). …the documents should include, at a
minimum, the following information when applicable:
• Water-based suppression systems: …. d) determine and confirm the available water
supply including any necessary adjustments; …
Had these new requirements only been applied to section 4.2 Owner’s Certificate item (3) no
one would object to them because the owner’s agent would have the responsibility to comply.
However, by putting these new requirements in chapter 5, they apply to anyone using the
document, whether qualified to perform engineering or not.
4. There isn’t any history of fire losses that can be directly tied to using a water flow test that
wasn’t adjusted as these new requirements describe. These new requirements aren’t being
introduced to solve any know problem, but instead will create many new problems for
installing contractors. There are already multiple safeguards built into the design criteria for
sprinkler systems in NFPA 13 including the design density, the remote area size and shape, the
pipe friction loss factors, and many others. For those worried about the adequacy of the water

supply there are many safeguards built into the standard to ensure the water supply data used
in the hydraulic calculations is adequate to meet the system demand. This information is
included on various signs required by the standard and is verified periodically with main drain
tests and water supply tests required by NFPA 25. In addition, most high-risk buildings
including warehouses, high rise buildings, manufacturing facilities, large assembly
occupancies, and hazardous facilities have fire pumps and/or standpipe systems. The water
supply for these buildings are full flow tested annually (fire pumps) and every five years
(standpipes) in accordance with NFPA 25. These tests verify the adequacy of the water supply
very time they’re performed.
5. It will be virtually impossible for anyone to gather all the information included in these new
requirements. Where does someone go to gather information on maximum daily use, peak hour
demand, anticipated degradation due to planned development, elevation of the water supply,
daily fluctuations, and seasonal fluctuations? In addition, how much time will it take to analyze
and apply this information to an adjustment if sources can be found? In the new annex text, it
states “The design professional needs to work in conjunction with the authority having
jurisdiction to determine the appropriate adjustment.” Therefore, the user is right back to where
they were in the 2019 edition.
These new requirements are onerous, unreasonable, and in many cases impossible to comply with
and therefore need to be deleted from the 2022 edition of NFPA 13.
Terry L Victor.
Johnson Controls

Report of the Correlating Committee on
Automatic Sprinkler Systems
Certified Amending Motion No. 13-23/13-37/13-42
June 2021
The Report of the Correlating Committee on Automatic Sprinkler Systems is presented as
found in the First Draft Report and Second Draft Report for the Annual 2021 revision cycle of
NFPA 13, Standard for the Installation of Sprinkler Systems. The revisions were submitted to
letter ballot of the responsible Technical Committees and Correlating Committee in accordance
with the Regulations Governing the Development of NFPA Standards. The reports and ballot
results can be found on the next edition tab of the Document Information page for NFPA 13 at
www.nfpa.org/13next.
Per NFPA 13, a waterworks system is an acceptable water supply for a sprinkler system.
The available volume and pressure are permitted to be determined from waterflow test data. It Is
generally recognized that waterflow test data is accurate only at the time the test was conducted.
The Technical Committee for Sprinkler System Discharge Criteria feels that that daily or seasonal
fluctuations along with other factors should be considered when evaluating the data from a
waterflow test. It is the intent of the evaluation to determine the potential for lower pressures
and/or flows than shown by the test data. Without the evaluation, it is possible that the water supply
may be Inadequate for control or suppression of a fire.
The concern for accurate waterflow test data has been considered by the technical
committee for several revision cycles. The problem was addressed last cycle with second draft
revision 386. However, the revision was deleted by action taken at the Technical Session for the
2019 edition of the Standard. With the creation of FR-1195, the Technical Committee feels it

addressed the comments and concerns expressed during the referenced Technical Session. Further,
the technical committee rejected PC-256, which Is the basis for this CAM.
Russell Leavitt
on behalf of the Technical Committee on Sprinkler System Discharge

June 2021
Certified Amending Motion No. 13-34 has been submitted on behalf of the National Fire
Sprinkler Association Engineering and Standards Committee and seeks to reject Second Revision
No. 1162. Second Revision No. 1162 added K-28 and K-33.6 ESFR sprinklers to Table 23.3.1 and
would mandate that these sprinklers be used with 12 sprinklers in the design area although they
have been approved and tested with a 9 or 10 sprinkler design area. This will lead to confusion and
this change needs to be rejected.
Newer types of ESFR sprinklers have been approved by Factory Mutual with a design area
consisting of 9 or 10 sprinklers. Fire test reports were submitted to the discharge committee,
however, Second Revision No. 1162 would specifically mandate the traditional 12 sprinkler
design. This Second Revision should be rejected based upon the following:
• Fire tests have shown that these ESFR sprinklers perform adequately with a 9 or 10
sprinkler design area. Mandating 2 or 3 additional sprinklers will substantially increase the
needed demand. This will limit options for designers and installers and would substantially
increase the costs to the owners.
• This Second Revision would limit options for Authorities Having Jurisdiction (AHJs) from
accepting these approved designs and cause confusion. Although AHJs do have the ability
to approve the use of these sprinklers based upon approved 9 or 10 sprinkler design area,
the fact that NFPA 13 would specifically mandate a twelve sprinkler design area for the
same product would certainly cause confusion and conflicting requirements.

• It is not good for the fire protection industry to have conflicting requirements for the same
product. This will simply cause confusion and differing requirements project to project.
As the technical committee responsible for Chapter 23 is not ready to include these
sprinklers in the standard with the 9 and/or 10 sprinkler designs, instead of modifying the approved
design it would be better to remove mention of K-28 and K-33.6 sprinklers from Table 23.3.1.
Second Revision No 34 should be rejected, and the committee can address this issue next cycle.
Roland Asp
National Fire Sprinkler Association

Report of the Correlating Committee on
Automatic Sprinkler Systems
June 2021
The Report of the Correlating Committee on Automatic Sprinkler Systems is presented as
NFPA 13, Standard for the Installation of Sprinkler Systems. The revisions were submitted to
www.nfpa.org/13next .
This CAM specifically addresses the rejection of PC 200 which sought to add criteria for
a K28 ESFR sprinkler permitting its use with ceiling heights up to 55 ft. The associated design
criterion permits, under certain conditions, a design area of 10 or 9 flowing sprinklers. While the
committee supports the inclusion of new sprinkler technology in the standard, it Is concerned about
dropping the number of sprinklers in the design area below the currently mandated minimum of
12. The 12-sprinkler design area was originally determined to create a safety margin for conditions
encountered in the field that were not considered in the original tests. Subsequent testing for
conditions such as HVLS fans and other obstructions were found to open as many as 8 sprinklers.
These tests are deemed acceptable because a 50 percent safety margin was maintained with the
12-sprinkler design area. The committee does not believe sufficient testing has been conducted to
demonstrate that a 9 or 10 sprinkler design is acceptable. The committee feels that design areas
incorporating fewer sprinklers could be permitted but the testing specifications found in chapter
24 should be utilized. Finally, the committee recognizes that it is unusual to repeat the 12-sprinkler

design requirement in the notes for the table but feels that the standard must be clear that when
using larger K-factor sprinklers (such as the K28), the 12-sprinkler design requirement still applies.
Russell Leavitt
on behalf of the Technical Committee on Sprinkler System Discharge Criteria

June 2021
NFPA Membership,
The goal of this CAM is to create more consistency within the NFPA Standards. When this was
submitted as a PI, the committee statement resolution stated, "Does not adequately address
qualifications." The PI was submitted again as a PC and included a definition of qualified, as the
chair of the correlating committee suggested. The committee statement resolution on the PC
"Current language clarifies that design and installation requires knowledge and experience. It is
the state and local jurisdiction’s responsibility to determine qualifications." yet the NFPA glossary
of terms doesn't define knowledge, knowledgeable, experienced or experience, however it does
define qualified. The PC on "qualified" A competent and capable person that has met the
requirements and training for a given field acceptable to the authority having jurisdiction, which
is consistent with the NFPA glossary of terms.
Using the term qualified to install and design sprinkler systems and private fire service
mains that are specialized fire protection systems that require components to be approved, listed
and certified. For consistency, I encourage you to accept this certified amending motion, thank
you.
Kenneth R Schneider.
United Association International Training Fund

June 2021
This CAM proposes to replace "knowledgeable and experienced" with "qualified." The
committee considered this change as a public Input and as a public comment during this code
development cycle. The committee's position is that the design and Installation of sprinkler
systems need to be performed by Individuals that have knowledge of the systems they are
designing and that they should have experience designing systems. The committee's position is
that it is the state or local jurisdiction's responsibility to establish qualifications.
Raymond A. Grill

June 2021
NFPA Membership,
I would expect that your expectations of someone who sits on NFPA committees to be
qualified. I consider their acceptance on these committees as Qualified Professionals.
When it comes to System Designer, I believe the public belief is these individuals are qualified
professionals.
• Plans and specifications shall be developed in accordance with this Code by persons who
are experienced in the design, application, installation, and testing of the systems.
• State or local licensure regulations shall be followed to determine qualified personnel.
Personnel shall provide documentation of their qualification by one or more of the following:
• Registration, licensing, or certification by a state or local authority
• Certification by an organization acceptable to the authority having jurisdiction
• Manufacturer's certification for the specific type and brand of system provided
• The system designer shall be identified on the system design documents.
System design trainees shall be under the supervision of a qualified system designer.
The system designer shall provide evidence of their qualifications and/or certifications when
required by the authority having jurisdiction.
When it comes to System Installer, I believe the public belief is these individuals are
qualified professionals.
• Installation personnel shall be qualified in the installation, inspection, and testing of the
systems.

• State or local licensure regulations shall be followed to determine qualified personnel.
Personnel shall provide documentation of their qualification by one or more of the following:
• Registration, licensing, or certification by a state or local authority
• Certification by an organization acceptable to the authority having jurisdiction
• Manufacturer's certification for the specific type and brand of system provided
System installation trainees shall be under the supervision of a qualified system installer.
The system installer shall provide evidence of their qualifications and/or certifications when
requested by the authority having jurisdiction. This language is consistent with other NFPA
Standards.
Manufacturers are held to a high standard of having their products approved, listed and
certified, I believe the personnel tasked with designing, installing, testing and maintaining these
life safety systems should be held to a higher standard as well. The addition of this new section
provides a platform to raise the standard of qualification to a required minimum. Please note, this
is not a certification, it is a qualification stating, “A competent and capable person that has met the
requirements and training for a given field, acceptable to the authority having jurisdiction.” I would
think we would want these individuals to be trained for designing, installing, testing and
maintaining life safety systems in the buildings we work, play and live in. I encourage you to vote
in favor of this motion and I thank you for your time and consideration.
Kenneth R Schneider,

June 2021
The Report of the Technical Committee on Technical Committee on Sprinkler System
Installation Criteria is presented as found in the First Draft Report and Second Draft Report for
the Annual 2021 revision cycle of NFPA 13, Standard for the Installation of Sprinkler Systems.
The revisions were submitted to letter ballot of the responsible Committee(s) in accordance with
the Regulations Governing the Development of NFPA Standards. The reports and ballot results
can be found on the next edition tab of the Document Information page for NFPA 13 at
This CAM proposes to incorporate specific qualifications in NFPA 13 for designers and
installers. This was considered as a public input and as a public comment during this code
development cycle. The committee's position is that it is the state or local jurisdiction's
responsibility to establish qualifications.
Raymond A. Grill

June 2021
NFPA Membership,
Qualified is used multiple times in NFPA 13 without a definition. The definition submitted is
“Qualified, a competent and capable person that has met the requirements and training for a given
field acceptable to the authority having jurisdiction.” This is consistent as defined in NFPA 3, 4,
15, 25, 72 and 96. The reason the definition was submitted as a Public Comment was to define it
for making a proposed change to “qualified” from “experienced and knowledgeable” 1.2.2. Please
note that experience, experienced, knowledge, or knowledgeable are not defined in any NFPA
standard. Adding the definition in NFPA 13 will be consistent with other NFPA standards. I thank
you for your time and consideration, I encourage you to vote in favor on this motion.
Kenneth R Schneider.

June 2021
This CAM proposes to add a definition for "qualified" into NFPA 13. This was
considered as a public input and as a public comment during this code development cycle. The
committee's position is that it is the state or local jurisdiction's responsibility to establish
qualifications and therefore adding a definition to NPA 13 would be inappropriate.
Raymond A. Grill

June 2021
The IFC Requires the FA system to be monitored by an Approved supervising station. The only
way for an AHJ to legally approve anything related to a fire alarm system is if it is submitted on
shop drawings to be reviewed and approved by the AHJ. If the specific supervising station is not
identified on the shop drawings, it cannot be reviewed and approved by the AHJ prior to the
acceptance test. But this review process may take long time during the acceptance test to verify
the type of the proposed supervising station service such as remote, proprietary or central
service, and even if the specific proposed supervising station is approved during the FA system
acceptance test, it will still be required to be legally documented as an "approved supervising
station" by the AHJ.. This may trigger additional and unnecessary submittal to be legally
approved and recorded. The Committee resolution indicates: "The supervising station can be
readily changed, and while a supervising station service may be required and provided, the
selection of the specific supervising station can be deferred until system commissioning" This
resolution does not specify how the AHJ can review and approve the specific supervising station
prior to system acceptance test or commissioning as required by the code. Therefore, if the
specific supervising station is included on the shop drawings per this proposal, it can be reviewed
and approved by the AHJ as a part of the shop drawings approval. If for some reason a change
from the indicated supervising station on the shop drawing will be desired - this will be done on
shop drawing revision or as-built permit, etc. Based on my experience as an AHJ, once a specific
listed supervising station is identified on the shop drawings and gets reviewed and approved as a

part of the shop drawing submittal, it is very rarely requested to be changed in the field, during
system commissioning, etc.
Sagiv Weiss-Ishai,

Report of the Technical Committee on
Fundamentals of Fire Alarm and Signaling
Systems
June 2021
The Report of the Technical Committee on Fundamentals of Fire Alarm and Signaling
Systems is presented as found in the First Draft Report and Second Draft Report for the Annual
2021 revision cycle of NFPA 72, National Fire Alarm and Signaling Code. The revisions were
the next edition tab of the Document Information page for NFPA 72 at www.nfpa.org/72next .
Although the supervising station information Fire Inspector Weiss-Ishai is asking to be
included on shop drawings is useful, the Committee does not agree that the name of the supervising
station is necessary to be on the shop drawings. It may not even known at the time the shop
drawings are being developed. The supervising station can be readily changed, and while a
supervising station service may be required and provided, the selection of the specific supervising
station can be deferred until system commissioning. This information can be provided on the
Record of Completion and the as-built drawings. The Technical Committee recommends the
motion to reject CAM 72-4.
Manuelita E. David
on behalf of the Technical Committee on Fundamentals of Fire Alarm and Signaling Systems

June 2021
The committee resolution indicates: "The existing text clearly defines the upper and
lower limits of the textual display." The Existing Text indicates: "...that the distance to the
highest switch, lamp, or textual display" and "...."and the lowest switch, lamp, or textual display"
It is not clear how upper and lower limits of the textual display are clearly defined? For
example: If the textual display includes a 15" high screen, computer monitor or other large type
touch-screen/display, etc. - How is this distance between the textual display and the finished
floor is measured? From the top of the screen? from the bottom of the screen? from the center of
the screen ? The current code text is not clear and specific on this and may cause inconsistencies
of enforcement between different AHJs - This is what this PC is trying to correct.
Sagiv Weiss-Ishai,

Fundamentals of Fire Alarm and Signaling
Systems
June 2021
The Report of the Technical Committee on Fundamentals of Fire Alarm and Signaling
2021 revision cycle of NFPA 72, National Fire Alarm and Signaling Code. The revisions were
The Committee does not agree that the proposed changes to the text. The addition of
"lowest line of" to the textual display Is not necessary. The existing text clearly defines the upper
and lower limits of the control unit displays, visible indicators, or controls which Includes the
textual display. The Technical Committee recommends the motion to reject CAM 72-5.
Manuelita E. David
on behalf of the Technical Committee on Fundamentals of Fire Alarm and Signaling Systems

June 2021
While I understand and accept the committee resolution statement that: "ANSI/ASA S3.41 is the
industry acceptable code reference that is to apply to evacuation and relocation signals." I am
asking the committee to consider the following: It is a relatively new change to NFPA 72 (started
in the 2013 edition) to require Temporal-3 tone for relocation messages and the reference to
ANSI/ASA S3.41 was not even yet published in NFPA 72. Therefore, there are still many US
Fire jurisdictions and many existing relocation buildings that do not employ Temp-3 alert tone
for relocation messages. (For example the City and County of San Francisco, CA with hundreds
of relocation high-rise buildings does not implement Temp-3 tone for relocation messages as it
was not required per previous editions of NFPA 72 prior to the 2013 edition). By making the
Temp-3 tone a mandatory requirement in NFPA 72 for relocation messages, the Code creates
enforcement issues for AHJs and potential inconsistencies between existing and new buildings in
the same jurisdiction. Therefore, the intent of this CAM is not to change the committee's decision
for relocation messages which may apply to all new relocation buildings. Rather, the intent is to
add a permissive language in the code that would allow AHJs to use a steady tone for relocation
messages as they were previously utilizing for many existing buildings prior to the 2013 edition
without the need to write local ordinances/codes superseding the NFPA 72 mandatory language
for Temp-3. Also, I still think that there may be inconsistency within NFPA 72 regarding the
"Evacuation" Vs. "Relocation" procedures which this proposed permissive language in PC 59
could be used to resolve these conflicts. You can see my rationale to PC # 59 for the specific

inconsistencies within NFPA 72 and also the indication to CAM 72-1 which passed the NFPA
membership vote in favor of this proposal in the 2018 Tech-Session in Las Vegas.
NFPA 72 clearly indicates: "A.3.3.100 Evacuation. Evacuation does not include the relocation of
occupants within a building."
Per the NFPA 72 Annex, some AHJs treat RELOCATION within the building differently than
"EVACUATION" to the outside of the building. In my opinion, the TC should consider allowing
to use permissive language within the code to help different AHJs to enforce this requirement
without deviating from the mandatory Code language.
This CAM is trying to ensure that AHJs will have the flexibility within the code to either enforce
the T-3 signal for both evacuation and relocation procedures OR they could enforce a 1-3 Second
alert tone for Relocation per Section 24.4.8.3, which treats Relocation Messages as "NON-
Evacuation" messages: "24.4.8.3 Where the system is used to transmit relocation instructions or
other fire emergency non-evacuation messages, a 1-second to 3-second alert tone followed by a
message (or messages where multi-channel capability is used) shall be provided.".
Also, as a reference: This proposal has passed the 2018 Tech-Session CAM 72-1 with a large
majority (262-176 Pass) to accept Public comments 386 and 387. Based on the Tech-Session
debate (see available script on the NFPA 72 online page) it was clear that "Evacuation Signal"
means to alert occupants to "Leave the building", While "Relocation signal" means to alert
occupants to move from one area to another area within the building.
The definition for "Relocation" in section 3.3.242 clearly states this intent: "3.3.242 Relocation.
The directed movement of occupants from one area to another area within the same building"
The definition for "Evacuation" is: "3.3.100* Evacuation. The withdrawal of occupants from a
building. (SIG-PRO)"

It is specifically explained in the Annex as: "A.3.3.100 Evacuation. Evacuation does not include
the relocation of occupants within a building." Also, the definition of an Evacuation Signal is:
"3.3.263.4 Evacuation Signal. A distinctive alarm signal intended to be recognized by the
occupants as requiring evacuation of the building. (SIG-PRO)"
Based on the above NFPA 72 Section, it could be interpreted by different AHJs that an
Evacuation signal may be different than a Relocation signal
Lastly, the SIG-NAS Committee has made a similar permissive language decision on section
18.4.4.2 "Where approved by the AHJ based on emergency plans..." and this is the same intent
for this CAM: To give some more room for AHJs to be consistent with the code without having
to write local amendments.
Sagiv Weiss-Ishai,

Notification Appliances for Fire Alarm and
Signaling Systems
June 2021
The Report of the Technical Committee on Notification Appliances for Fire Alarm and
Signaling Systems is presented as found in the First Draft Report and Second Draft Report for the
Annual 2021 revision cycle of NFPA 72, National Fire Alarm and Signaling Code. The revisions
were submitted to letter ballot of the responsible Committee(s) in accordance with the Regulations
Mr. Weiss-Ishai (Sagiv Weiss-Ishai with the San Francisco Fire Department) is asking to
accept his public comment (PC-59) for section 18.4.2 (18.4.2.1). This section was modified with
a public input in the first revision to add in the ANSI standard that was deleted last cycle to better
clarify the required notification signal. The public input also deleted the figure of the temporal
three general evacuation signal to better correlate with Chapter 24, Emergency Communications
Systems. Mr. Weiss-Ishai public comment substantiation ask for a couple of different actions.
He first asks NFPA staff to investigate and make sure rules and procedures were followed
regarding FR 5013. The technical committee in their statement for this issue to be resolved and
responded by NFPA staff. This report is not addressing that issue.
Mr. Weiss-Ishai second point is to clarify the difference between evacuation and relocation
and allow some flexibility for different fire jurisdictions to enforce this requirement differently if
they believe that different alert tones should be provided for evacuation and relocation.

The technical committee, after review Mr. Weiss-Ishai public comment did not feel
additional clarification was needed after the changes that were made during the first revision.
ANSI/ASA S3.41, Audible Emergency Evacuation (E2) and Evacuation Signals with Relocation
Instructions (ESRI) specifies the characteristics of acoustic signals to be used for audible
emergency evacuation (E2) and audible evacuation signals with relocation instructions (ESRI). It
applies to the audible signal (not the components or equipment). The use of these signals either
as the only audible means of signaling or as a part of a voice message is subject to the requirements
of governing laws, codes or other standards. This standard specifies parameters of the audible
emergency signal, i.e., the temporal pattern, the required sound pressure level at all places within
the intended signal reception area, and the spectral content for certain applications, in order for the
audible emergency signal to be recognizable. This Standard applies to:
• The audible signal that is used alone as a general evacuation signal (E2 application) for a
building or area, or
• The audible evacuation signal component of a pre-recorded or system-generated voice
message that is played in a building or area to signal general evacuation (E2 application),
or
• The audible signal component of a pre-recorded or system-generated voice message that is
played in a building or area to signal instructions to evacuate one area and relocate to
another area of a building (ESRI application).
ANSI/ASA S3.41 clearly applies to both general evacuation as well as relocation of
occupants for emergency notification. It is an international standard and the technical committee
did not feel a need to change or add confusion with a different signal.

It should be noted that Mr. Weiss-Ishai references the 2019 CAM (72-1) as to what the
"majority of NFPA" members want. The technical committee based their vote and statement on
both the public input as well as the public comment submitted for the 2022 edition. Likewise, Mr.
Weiss-Ishai substantiation did not include any analytical data showing that there is or has been
confusion among fire jurisdiction or any actual cases where someone has not been able to
understand what to do when a fire alarm sounds.
Any fire jurisdiction can amend their adopted codes and standard to fit into their emergency
response plans. Section 18.4.2.1 does not prohibit that in anyway.
Lastly, the occupant’s response from the signal is all based on their training for that
occupancy. Most if not all occupants of a building do not know that a T-3 signal means to evacuate
(or relocate), they react to the signal as a fire alarm. Based on the occupancy’s emergency plan,
they will either evacuate or relocated. The signal needs to be consistent with a response based on
education/training. Adding a different signal for relocation only will only add additional
confusion.
David Lowrey,
on behalf of the Technical Committee on Notification Appliances for Fire Alarm and
Signaling Systems

June 2021
The committee resolution indicates: "Adding “approved” would require all messages to be
approved including live messages which is unenforceable." However, this code section
requires messages to be developed for each identified scenario in the emergency response
plan. This requires planning and preparation of specific messages based on specific
potential scenarios and therefore this section does not address live spontaneous messages. If
specific messages are to be developed for specific scenarios they must be reviewed and approved
by the AHJ on the emergency plan regardless if they are automatically broadcasted (pre-
recorded) or manually broadcasted via the use of the microphone - In that case the script of the
approved message should be available for the person who is authorized to broadcast the message.
This will prevent confusion on which message or verbiage should be used during a specific
emergency.
It is acknowledged that during different type emergencies, responding emergency personnel may
use the microphone to broadcast live and spontaneous messages without a script based on the
specific event; However, these spontaneous live messages could not be developed as required by
this section for identified scenarios and they are outside the scope of this proposal for specific
developed messages.
Sagiv Weiss-Ishai,

Emergency Communication Systems
June 2021
The Report of the Technical Committee on Emergency Communication Systems is
cycle of NFPA 72, National Fire Alarm and Signaling Code®. The revisions were submitted to
As noted in Public Comment 71, the Technical Committee considered the concerns raised
by the Submitter during the First Draft Phase (Public Input 303). A requirement that pre-recorded
messages be approved already exists In paragraph 24.3.7.2.2. The Intent of the submitted of the
PI and PC Is that all messages be pre-approved by the AHJ, Including live messages. It Is not
practical to expect that the system designer and Installer can pre-determine all possible emergency
conditions and situations and submit a list of all possible live messages to be approved by the AHJ.
As such, the Technical Committee voted to reject Public Comment 71.
A prudent designer/Installer may submit some templates and typical live messages for
approval. However, to require that all possible live messages be pre-approved Is unenforceable.
Should an emergency condition arise for which the previously approved messages do not properly
address, should one use a message that was pre-approved even If It Is not appropriate or should
one violate the Code and broadcast a message that was not previously approved but provides the
occupants of the building with the proper Information?

Whereas the Committee Action on Public Comment 71 was to Reject the Public Comment,
the Committee Action was not submitted to a formal ballot.
William E. Koffel, P.E., FSFPE, SASHE

on behalf of the Technical Committee on Emergency Communication Systems

Motion to Accept Public Comment No.72
June 2021
The committee resolution indicates: "Some systems could be used for other emergencies
other than just fire evacuation. Other emergencies such as CO could be handled by a fire panel."
While I agree with the committee that some systems could be used for other than FIRE
emergencies these systems will not be defined as: "FIRE EVACS” or Fire Emergency Voice
Alarm Communication System, as this section specifies.
FIRE EVACS should only generate automatic FIRE related messages upon activation of
fire alarm initiating device(s). If the intent is to add onto the FIRE EVACS other non-fire
automatic pre-recorded messages such as CO, etc. this will make this system to be a
Combination Fire + CO ECS and not a FIRE EVACS since CO Emergency is not a Fire
Emergency.
Sagiv Weiss-Ishai,

June 2021
cycle for NFPA 72, National Fire Alarm and Signaling Code®. The revisions were submitted to
As noted in Public Comment 72, the proposed change was considered during the First Draft
Phase (PI 321). The concept that a fire alarm system may be used for purposes other than fire
emergencies Is addressed throughout NFPA 72. For example, Paragraph 23.2.1 refers to fire alarm
systems being used to Indicate "the existence of heat, fire smoke, carbon monoxide, or other
emergencies Impacting the protected premises." It Is possible to use an In-building fire emergency
voice/alarm communication system for purposes other than fire emergencies or carbon monoxide
emergencies. Such systems need to be considered mass notification systems.
Removal of the phrase "alarm or other" In Paragraph 24.4.1 would result In no criteria In
the document for those systems that are used to address emergencies, other than fire emergencies.

Motion Accept Public Comment No. 73
June 2021
The committee resolution indicates: The Technical Committee retains "trained and authorized" to
ensure that “other” building personal must be "trained and authorized." Emergency personnel
would fall under the definition of authorized personnel. All other personnel should be trained.”
There are two new definitions in NFPA 72 for Authorized (3.3.24) and for Emergency personnel
(3.3.101) and there is no definition for "trained and authorized" - trained by whom?, etc. Also, if
“Emergency Personnel” fall under the definition of “Authorized Personnel” – why there are two
separate definitions in Chapter 3?
Based on the two different definitions in Chapter 3 - Emergency Personnel does not fall under
the definition of authorized personnel.
Therefore, this CAM is proposing to make Section 24.4.5.2 be consistent with the new two
definitions in Chapter 3.
Sagiv Weiss-Ishai,
San Francisco Fire Deparment

June 2021
The Committee recognizes as defined In Chapter 3, "emergency personnel" are different
from "authorized personnel." However, the Committee also felt that "emergency personnel" are a
subset of "authorized personnel" and therefore, the use of "authorized personnel" Is Inclusive of
"emergency personnel."
In addition, a key concept Is lost If the CAM Is approved. The text In Paragraph 24.4.5.2
requires that "authorized personnel" be trained In the use of the controls. If the CAM Is approved,
an owner can authorize personnel to have access to the controls but would not be required to
properly train those personnel In the use of the controls.

Motion to Accept Public Comment No.74
June 2021
The committee resolution indicates: "Addition of 24.4.5.7(4) does not consider other
visual message considerations such as message signs and other means of communicating with
the deaf and hard of hearing" This is an incorrect statement since the proposed addition (4)
indicates "shall also activate the visual notification at the same area(s)..." - Visual notification
could be any type of visual based notification and is not limited to any specific type of visual
notification. The intent of this proposal is to provide equal access to notification for deaf and
hard of hearing occupants. If there was no automatic "previously initiated signal" in the building
and the first signal was a live message transmitted via the microphone to the speakers in the
notification zone, there will be no visual indication to deaf and hard of hearing occupants that
there is a potential emergency in the building. Therefore, it is the intent of this proposal to have
any type of visual notification (as approved on the emergency plan) at the same time that voice
messages are transmitted, regardless if they are live or pre-recorded/automatic messages. This
will ensure that deaf and hard of hearing occupants will be visually notified and alerted to seek
additional information regarding the potential emergency situation. The intent of this CAM is
also consistent with the intent of Section 10.11.2: "The intent of this requirement is to ensure that
persons who are deaf or hard of hearing are alerted to seek additional information regarding an
emergency situation. Persons who are deaf or hard of hearing are not always alerted by the
loudspeakers that provide evacuation tones or voice instructions. It is intended that the
loudspeakers and visual notification appliances located in the same area be activated together

whenever tones, recorded voice instructions, or live voice instructions are being provided. (SIG-
ECS)"
If live voice messages are transmitted via the microphone without any associated visual
indication - this will be inconsistent with the intent of the code and this is what this CAM is
trying to correct.
Sagiv Weiss-Ishai,
San Francisco Fire Deparment

June 2021
Paragraph 10.11 of NFPA 72 already addresses alarm signals and required that all visual
notification appliances, textual visual notification appliances, and loudspeaker notification
appliances located in the same area be activated and deactivated as a group. The language
proposed In Public Comment 72 is redundant to the requirements currently In Paragraph 10.11 and
is not as inclusive as the language In Paragraph 10.11 since it only refers to visual notification
appliances. If CAM 10-11 Is approved, Is It the Intent of Paragraph 24.4.5.7 to override the
requirements of Paragraph 10.11, since Chapter 24 Is a more specific requirement?
It is recognized that the submitted uses the phrase "visual notification" which would
normally include textual visual notification appliances. However, the language difference between
existing Paragraph 10.11 and the proposed language In Public Comment 74 could result in some
confusion and misinterpretations.



June 2021
The committee resolution indicates: "Emergency personnel would fall under the
definition of authorized personnel" This is incorrect statement per the two new definitions in
NFPA 72 Chapter 3. Emergency personnel do not fall under the definition of authorized
personnel. The emergency personnel could be responding firefighters or other first responders
and they are not required to be authorized by the property owner to perform emergency
operation. Therefore, the intent of this proposal is to make Section 24.5.2.1 be consistent with the
two new definitions in NFPA 72 Chapter 3, and to specifically indicate that Emergency
personnel in addition to authorized personnel could also control messages initiation over the
MNS.
Sagiv Weiss-Ishai,

June 2021
This issue is similar in nature to CAM 72-10. Although this particular action deals with
mass notification systems, the action on the two CAM's should probably be the same.
The Committee recognizes as defined in Chapter 3, "emergency personnel" are different
from "authorized personnel." However, the Committee also felt that "emergency personnel" are a
subset of "authorized personnel" and therefore, the use of "authorized personnel" is inclusive of
"emergency personnel."


June 2021
The committee resolution indicates: "The Technical Committee does not agree that a
momentary activation of the microphone button should actuate visual notification because it will
cause confusion for the deaf and hard of hearing." However, the intent of the code is to provide
equal access for notification for deaf and hard of hearing occupants.
The question is what is a safer condition? To have hearing impaired occupants be visually
notified and alert them to seek additional information? OR, not notifying them at all since this
notification "will cause confusions"?
The answer is indicated in the intent of the code in Section 10.11.2: The intent of this
requirement is to ensure that persons who are deaf or hard of hearing are alerted to seek
additional information regarding an emergency situation. Persons who are deaf or hard of
hearing are not always alerted by the loudspeakers that provide evacuation tones or voice
instructions. It is intended that the loudspeakers and visual notification appliances located in the
same area be activated together whenever tones, recorded voice instructions, or live voice
instructions are being provided. (SIG-ECS)” Therefore, the intent of this CAM is to make
Section 24.5.16.1 be consistent with the intent of the Code as provided for Section 10.11.2.
Sagiv Weiss-Ishai,

June 2021
The proposed text in Public Comment 77 is an Annex note and as such it provides
supplemental Information. However, the proposed language would state that if the microphone
key button Is pushed, even if momentarily without a message being transmitted, the associated
visual notification should be provided. The Technical Committee is concerned that such a
clarification, even as an Annex note, could result in confusion for the occupants who rely on visual
notification means and would not hear that there is no audible message being transmitted.

June 2021
The committee resolution was: "Research done at NIST, and in “Process and React”
studies have shown that the three times repeating of the message is valuable."
While it is acknowledged that a three time repetition of the sequence is valuable, the
intent of this CAM was to make the code safer by not allowing this repetition to be automatically
and potentially cut-off completely (the alert tone+ the message) after three cycles only.
This potential automatic cut-off condition (after three times repeating only) may put in
danger building occupants who have started the evacuation procedure and during this process the
sequence is automatically cut-off as currently permitted by this section. This permissive
automatic cut-off may potentially cause building occupants to stop their emergency evacuation
procedure and this is the unsafe condition that this CAM is trying to prevent.
This proposal was discussed and debated during the last 2018 NFPA Tech-Session in Las
Vegas as CAM 72-5 and the majority of NFPA voting members were in support of this proposal
for the safety concern associated with a potential automatic cut-off of an emergence signal
(potentially after three repetitions only).
Also, the SIG-NAS Committee has done a similar correction in Section 18.4.2.2 to not allow the
automatic cut-off option of an emergency signal
Therefore, this CAM, if passed, will make the Code to be more consistent between voice
and non-voice notification systems and will increase safety by eliminating the automatic cut-off
option.

Sagiv Weiss-Ishai,

June 2021
www.nfpa.org/72next .
The Committee recognizes the vote by the NFPA membership taken during the last revision
cycle In response to CAM 72-5. Two new Annex notes have been added to address the situation
(A.24.4.8.3.1 and A.24.4.8.3.2). Specifically, to the automatic cut-off of emergency signals, the
first sentence of A.24.4.8.3.2 specifically states that "Only first responders or other trained
authorized emergency personnel should be able to Intentionally and manually silence or reset the
automatic prerecorded message sequence. The content of A.24.4.8.3.1 refers to research that
indicates that pausing before repeating emergency messages can be more effective than repeating
messages consecutively. With the new Annex notes, the Committee does not support deleting the
phrase “at least three times".


Report of the Technical Committee on Protected
Premises Fire Alarm and Signaling Systems
Certified Amending Motion No. 72-24/72-25 (approved as a Group Amending
Motion by the Motions Committee)
June 2021
The Report of the Technical Committee on Protected Premises Fire Alarm and Signaling
2021 revision cycle for NFPA 72, National Fire Alarm and Signaling Code®. The revisions were
submitted to letter ballot of the responsible Technical Committees and Correlating Committee in
accordance with the Regulations Governing the Development of NFPA Standards. The reports
and ballot results can be found on the next edition tab of the Document Information page for NFPA
72 at www.nfpa.org/72next .
I would like to first point out that the SIG-PRO Technical Committee had a Task Group
on Section 21.5 (Fire Service Access Elevators - FSAE) during the last code cycle, and the TG
agreed to monitor the temperature in the elevator lobbies. The concern was that potential high
temperatures in FSAE lobbies and other FSAE associated spaces could occur even without direct
smoke, such as due to radiant heat, etc. If the fire is outside the lobby and the elevator lobby doors
are closed, the firefighters need to know the temperature in the affected lobbies and FSAE spaces
before they make the decision to take the elevator to a specific lobby or location. However, Mr.
Grill's contention is that monitoring of temperature in the FSAE and elevator equipment areas is
unnecessary whichh is why Public Input 255 and 256 were submitted by Mr. Grill. Mr. Crill's
contention Is that these areas are required to be provided with smoke detection and that in the event
of smoke detection in those areas, the fire fighters warning indicator in the car activates. If the
lobbies, shaft or elevator equipment is threatened by smoke, the fire service should not be using
the elevators and if here isn't smoke, the areas will not be threatened by fire, concluding that this

requirement is being misinterpreted to require a totally separate temperature sensing system for
compliance.
As part of the NFPA process, Mr. Grill submitted Public Comments 166 and 167 with the
Intent to eliminate Sections 21.5 and A21.5 indicating that the TC's rationale that there can be
radiant heat that could threaten fire fighters without there being smoke in an elevator lobby of a
high rise building, is hard to comprehend. This requirement for continuous temperature sensing on
a control panel is creating design and enforcement challenges.
However, after much discussion the Technical Committee does not agree position of Mr.
Grill and the desire to eliminate Sections 21.5 and A21.5, eliminating the temperature monitoring
requirements. The position of the Techincal Committee is that Sections 21.5 and A21.5 shall
remain as written for the following reasons:
1. This section has existed in NFPA 72 for four code editions: 2010, 2013, 2016 and 2019 and
there is no strong substantiation why it needs to be deleted after it was in the code since 2010.
2. There are currently hundreds existing and new high-rise buildings over 120 feet having
FSAEs per Section 3007 of the IBC that are already in compliance with this section since the
2009 edition of IBC was published.
3. The current published IBC-2018 still has Section 3007.7 which requires the continuous
monitoring of FSAE lobbies in accordance with NFPA 72 which is clearly not just lobby
smoke detectors as used for standard elevators.
4. Since section 21.5 was included in NFPA 72 since the 2010 edition and it was
acknowledged by fire jurisdictions that a continuous monitoring for FSAEs was required,
many performance-based designs were developed to comply with this requirement, such as
via analog heat detection systems, temperature sensors monitored by analog monitoring
modules, etc.

5. It should be acknowledged that when Section 21.5 was first entered into the 2010 edition
of NFPA 72, NFPA had intended to develop a Standard FSAE Annunciator to monitor FSAEs
per NEMA SB-30 2005 standard which was indicated in Annex F of the 2010 edition of NFPA
72. However, Annex F was removed from NFPA 72 and a standard FSAE annunciator per
NEMA SB-30 was never developed. The specific fire service requirement and intent in IBC
Section 3007 to be able to continuously monitor the smoke and heat conditions in the FSAE
lobbies is an important life-safety requirement that can greatly increase the safety of the
responding firefighters before they make the decision to take the FSAE to a specific lobby.
6. During the last decade, Standard Operation Procedures (SOPs) for fire service jurisdictions
with FSAE buildings have already been developed with specific high-rise firefighting
procedures on how to use FSAEs to fight fires in high floors.
7. There was a great deal of work and research done by the SIG-PRO Task Group on this
issue (many meetings and hours of work by many people) and a relatively simple solution
was developed in the 2019 edition of NFPA 72 to provide specific enhanced safety conditions
to firefighters using FSAEs.
From all the above reasons, deleting Sections 21.5 and its associated annex (A21.5) per CAM 72-
24 and 72-25 and the PC's will only leave the lobby smoke detectors in FSAE lobbies as for any
other standard elevator without specific enhancement for FSAEs. This will decrease safety for
firefighters and will conflict with the IBC intent and the fire service needs. Therefore, the
Technical Committee recommends disapproval of CAM 72-24 and 72-25.
Jack Poole, PE FSFPE

on behalf of the Technical Committee on Protected Premises Fire Alarm and Signaling
Systems

June 2021
The removal of the modifier, “where permitted by the AHJ” addresses the current
imbalance of facilities as defined in Section 26.5.3. Facility types should be considered equivalent
to each other. This proposed change accomplishes this. A listed central station, or supervising
station is required to meet the following standards: UL 827, and UL 1981. 827 identifies the
physical requirements of the facility, and 1981 identifies the hardware and software associated
with fire alarm signals. Once an organization meets the listing requirements, a contractual
relationship exists between a NRTL, and the listed supervising station, to build, maintain, and
operate in compliance with UL 827, Central Station Services, and UL 1981. Mandatory annual site
visits are designed to ensure facilities adhere to the contractual requirements of the listing. The
initial requirements and the ongoing audits provide a level of security that exceeds the minimum
requirements in the Facilities Section, located in 26.5.3. Listed central supervising station meet the
requirements of listed as defined in Section 3.2.5 of the 2016 NFPA 72 edition. Exceeding the
minimum requirements of the Facilities Section of 26.5.3, and also meeting the listed definitions
should provide to the AHJ the necessary requirements for the monitoring of remote supervising
station service. All listed central supervising stations meet the same UL 827 and 1981
requirements. There are over 400 listed supervising stations operating in the United States today.
I'm a Committee member of the HouseHold Fire Chapter NFPA 72 for 18 the last 18 years.
Household Fire Chapter filed the facilities requirements in Section 26.5.3 of 20 NFPA 72, 2016.
In 2019, the Household fire Committee accepted public input, thereby removing the clause where
permitted by the AHJ, and now allows listed central supervising stations to monitor household fire

alarm systems. There is no process in place for approving UL Listed facilities, currently the
approval method is approved or not approved without any technical guidance. Where permitted by
the AHJ remains undefined related to allowing a listed central supervising station to receive
signals. Section 26.1.1 states: "Where any system regulated by this code sends signals to a
supervising station, the entire system shall become a supervising station alarm system. Section
26.1.2 states the requirements of Chapters 7,10,12,14 and 23 shall apply. Section 26.5.3 states
“where permitted by the AHJ” does this mean for every system installed or is the AHJ approving
a single instance of an installation? If the approval is for a single installation of a supervising
station alarm system there remains a possibility that the AHJ can permit and mandate signals travel
almost anywhere. The subscriber is defined as the recipient of a contractual supervising station
signal service however the subscriber can only use a supervising station approved by the AHJ or
if there is no approved facility then the subscriber shall use a government facility as defined in the
facilities section. Not sure many Americans would want this oversight, this should be a choice to
use a service similar to where we shop, what doctors we see, what hospital we can go to, what type
of vehicle we can purchase, where and how we live. Local jurisdictions have the ability to modify
local ordinance for fire alarm services. Let local jurisdictions make their own choices. In 2009 the
NFPA 72 edition did not require AHJ approval for a listed central supervising station to receive
signals. In 2013 “where permitted by the AHJ” was added to the code. Why the change, listed
service requirements did not change and the supervising stations continued to provide essential
signaling services? There were no NFPA studies suggesting listed supervising stations were failing
to meet listed requirements? Currently UL Listed facilities can supervise Central Station Fire
Alarm Systems, Household Fire systems without AHJ Approval. Non supervised stations can
supervise household fire systems. A Remote Station fire alarm system which is transmitting alarm

events to the same facility supervising both Central Station Systems and Household Fire systems
requires AHJ Approval.
Richard Simpson,
Vector Security, Inc.

Supervising Station Fire Alarm and Signaling
Systems
June 2021
The Report of the Correlating Committee on Technical Committee on Supervising Station
Fire Alarm and Signaling Systems is presented as found in the First Draft Report and Second Draft
Report for the Annual 2021 revision cycle for NFPA 72, National fire Alarm and Signaling Code®.
The revisions were submitted to letter ballot of the responsible Technical Committees and
Correlating Committee in accordance with the Regulations Governing the Development of NFPA
Standards. The reports and ballot results can be found on the next edition tab of the Document
Information page for NFPA 72 at www.nfpa.org/72next.
The Technical Committee does not agree to accept Public Comment No 277. Section 26.5
(and previous like sections in prior editions of the code) has long established requirements for
governmental monitoring in Section 26.5.3.1.1, and 26.5.3.1.2, except where an alternate location
is permitted by the AHJ (26.5.3.1.3). Listed central stations provide a valuable service and the
language of the 2019 edition, as well as previous editions, of NFPA 72 would allow their use in
the Remote Supervising Station monitoring process where approved by the AHJ. Listed central
stations are also an element of Central Station Service where no other type of supervision station
is permitted. National model codes specifically permit monitoring by an approved supervising
station in accordance with NFPA 72. Depending on several factors, some AHJ’s may be able to
specifically name their approved supervising station of choice and others cannot. Local conditions
and condition in various countries where NFPA 72 is applied the AHJ approval can be important
to assuring reliable monitoring service is achieved.

Daniel O’Connor
on behalf of the Technical Committee on Supervising Station Fire Alarm and Signaling
Systems.

June 2021
The purpose of the visual periodic inspection process is to assure that actions done by
unqualified individuals, pre and post occupancy, do not negatively affect the safety of unsuspecting
building occupants. Periodic Inspections commonly find fire and smoke dampers with control
wiring or other post occupancy alterations being run through existing dampers. As shown in the
attached pictures, a remote damper inspection will not identify these post occupancy issues as they
develop through the life of the building. Additionally, per 7.7.2 (NFPA 105) and 19.6.2 (NFPA
80) all exposed moving parts of the damper shall be dry lubricated as required by the manufacturer.
A periodic inspection ensures that a technician will physically inspect the damper to determine if
contaminates such as dirt, moisture, rust, and other airborne particles that could affect moving
parts causing an inconsistent result. The maintenance, which is more than “duct cleaning”, is
intended to maintain the proper operation of a damper and catch potential issues before they
become a life safety event.
As it is shown in 19.3.3 (NFPA 80) 7.4.1.3 (NFPA 105) Inspections: “Following
completion of the test, a visual inspection shall be made of the assembly to ensure no obstructions
have been introduced.” As per the code, this may not be possible with remote inspections which,
if continued to be permitted by 19.5.2.3.3 (NFPA 80) will increase in their installation and
application. Further compounding occupant and first responder risk. In addition, 8.6.2 (NFPA 92)
requires that “the equipment shall be maintain in accordance with manufactures recommendations”
Please see the attached as example of manufactures recommendations.

Even with remote inspection capability an unqualified Installer (especially from another
craft), can cause dampers from giving a complete condition report of the damper, and damper
environment. Because it is possible for the indication device to report a positive closure when in
actuality, there is a damaged blade, damaged seal, an entire blade missing from the damper or even
blocked by one communication cable, we have a responsibility to maintain the integrity of the
system through visual inspections.
Through knowledge and experience, we know that none of these scenarios are out of the
range of possibility in combination fire/smoke dampers. Through remote inspections, there is a
risk of missing damaged seals and components, or the potential for toxic gas and smoke to
penetrate the damper and pose a threat to the lives of occupants and first responders. Keep in mind
that some devices rely upon shaft movement to make the switch for indication and not blade
movement, further compounding the risk – a linkage may be jammed, disconnected or damaged,
causing the device to report positive closure when the damper did not close. Nothing will mitigate
the risk to first responders, occupants and property better than a complete and routine visual
inspection. Devices fail, environments change, components require maintenance, and further – the
reporting process is proof that all parties are performing their due diligence to keep everyone safe.
Dion Abril
Western States Council SMART

Report of the Technical Committee on Fire Doors
and Windows
June 2021
The Report of the Correlating Committee on Fire Doors and Windows is presented as
NFPA 80, Standard for Fire Doors and Other Opening Protectives. The revisions were submitted
to letter ballot of the responsible Technical Committees and Correlating Committee in accordance
First, I would like to thank Mr. Abril for his participation and interest in this process. The
technical committee rejected the public comment (PC) 47 on 19.5.2.3.3 on both an NFPA process
reason and a technical reason. The PC requested the deletion of the remote inspection process for
dampers in NFPA 80. However, neither public comment, nor Mr. Abril, nor any of the more than
twenty guests in attendance offered any documented technical substation supporting the deletion
of the remote inspection process. The lengthy discussion related to this PC at the second draft
meeting included input from attending guests.
Committee input (CI) 29 was related to the PC and specific to the possibility of needing a
new requirement for a visual inspection interval for remotely inspected dampers. The committee
input sought to discover and review failure data for remotely inspected and tested dampers to
determine the need for additional periodic visual inspection intervals. The task group formed to
address CI-29 did not identify or obtain any documented failure data of remotely inspected

dampers and recommended not changing the current provisions and requirements for the remote
inspection process. The committee passed a motion to accept the task group’s recommendation.
Regarding the NFPA process reason for rejecting PC-47, the committee deemed the public
comment as substantial new material that had not been subjected to the NFPA public review
process and, therefore, rejected the public comment pursuant to §4.4.4.2 of the Regulations
Governing the Development of NFPA Standards.
The committee further motioned to reject the public comment instead of holding the public
comment, based on the technical reason that the provisions for remote inspections of dampers are
important and have been taking place in the field for some time. Therefore, the committee
concluded that the remote inspection process should be retained in the standard.
The committee was not provided sufficient data of the failure of remotely tested dampers
to justify removing the provisions permitting the remote inspection and testing of dampers from
the standard. The committee statement points out that the pandemic has further increased the need
for and reliance on remote inspections; the current provisions provide the necessary guidelines for
a remote inspections program.
Keith E. Pardoe
on behalf of the Technical Committee on Fire Doors and Windows

June 2021
Currently, NFPA 291 provides guidance as to capacity marking of public fire hydrants in section
5.2.1. However, there is no guidance provided for the capacity marking of private fire hydrants
other than marking it at “owner discretion.” There is no technical justification to provide guidance
in the document for the capacity marking of public fire hydrants but not do the same for private
fire hydrants. Both public and private hydrants serve a similar purpose and fire departments utilize
the information from the capacity marking of fire hydrants to make operational decisions during
suppression operations.
The TC appeared to acknowledge the lack of a technical justification to deny the original PI-6 by
only stating in the rejection of the PI that “Private hydrant marking is at the owner’s discretion.”
Subsequently, at the Public Comment stage, the TC reversed itself and clearly acknowledged that
the “…submitter’s justification makes perfect sense…”
Although the TC acknowledged at the Public Comment phase that the “...submitter’s justification
makes perfect sense…”, the TC again rejected the request to reconsider PI-6. The TC then changed
the reasoning of the rejection to “…the submitter’s proposed charging statement would create
mandatory requirements.” This is very confusing as the charging statement in this PI/PC is
IDENTICAL to the existing language in NFPA 291 section 5.2.1 specifying the marking approach
for public fire hydrants. The proponent of this PI/PC specifically utilized the existing language in
section 5.2.1 to model the proposed language in the PI/PC addressing the marking of private fire
hydrants. If the language in PI-6/PC-31 is faulty, then the existing language in NFPA 291 that the
TC has already approved is also faulty.

In its rejection of PC-31, the TC also added that a local jurisdiction “…is free to adopt local rules
to compel owners to follow specific rules to comply with the submitter’s substantiation and
concerns.” If this statement is valid justification for a rejection, then every code, standard or
recommended practice that is adopted by NFPA can be justified as invalid by this logic. The point
of promulgating codes, standards and recommended practices is to establish model provisions that
reflect best practices based on the technical evidence and the need. Just because a local jurisdiction
can adopt a local provision is not a valid reason to reject a PI/PC when the issue is not just a local
issue but has a broad impact across all jurisdictions that utilize NFPA documents. Failing to find
a valid technical reason to reject the content of the PI/PC, it appears the TC was struggling for a
reason to continue rejecting this PI/PC without providing any arguments of technical substance.
The TC has stated that the “…submitter’s justification makes perfect sense…” which, in addition
to the other reasons for the TC’s rejection, is without any technical standing. Therefore, I
respectfully request the membership approve this CAM to insert this needed guidance in the
recommended practice.
Anthony C. Apfelbeck,
Altamonte Springs Building and Fire Safety Department

Report of the Technical Committee on Private
Water Supply Piping Systems
June 2021
The Report of the Technical Committee on Private Water Supply Piping Systems, is
cycle of NFPA 291, Recommended Practice for Fire Flow Testing and Marking of Hydrants. The
revisions were submitted to letter ballot of the responsible Technical Committees and Correlating
Committee in accordance with the Regulations Governing the Development of NFPA Standards.
page for NFPA 291 at www.nfpa.org/291next .
First, on behalf of the 291 committee, I would like to thank Mr. Apfelbeck for his thought
filled input and related substantiation in the submittal of P.I. 31. As noted in the committee
statement in response to P.I. 31, NFPA 291 is a recommended practice and the submitter’s
proposed charging statement would create mandatory requirements, which would not be
appropriate for this document or any recommended practice. Any mandatory language would not
be compliant with NFPA’s Manual of Style.
The TC comment in resolving the submitters proposed change stated that private hydrants
and enclosures are within the owner’s purview. While the members found the submitter’s
justification to make good sense, the technical committee believes it is within the purview of the
local AHJ to adopt local rules to compel owners to follow specific requirements.
During discussion of the original public input, it was noted that many local fire departments
allow local youth groups, including scouts and team sports groups, to paint public and private

hydrants to look like dogs, cats, or other decorative art forms. As noted above, the TC found the
original input to have merit but inappropriate for a recommended practice document.
The voting was unanimous during the meeting with no member speaking in support of the
proposed change during the first or second draft meetings.
Robert G. (Bob) Caputo

on behalf of the Technical Committee on Private Water Supply Piping Systems

June 2021
The CAM 318-2 recommends allowing the use of materials complying with the
requirements of FM 4910 or UL 2360 in semiconductor facilities without the “subterfuge” of
“where process concerns or process chemicals require alternatives”.
For many years now it has been common practice to allow both noncombustible materials
as well as materials complying with the requirements of FM 4910 (FM Global calorimeter) or UL
2360 (cone calorimeter) to be used in semiconductor facilities. In fact, the materials that comply
with the FM 4910 or UL 2360 requirements have been shown to provide minimal contribution to
fire and to have virtually no effect on increased fire hazard. Note that in many applications
throughout the NFPA codes and standards it is common for requirements to apply to
“noncombustible or limited combustible” materials. The fire performance of materials complying
with the FM 4910 or UL 2360 requirements is very similar (if not identical) to that of limited
combustible materials.
The committee’s reason for rejecting (resolving) the public input was: “The existing
language in this section covers a variety of process conditions and chemicals that would need an
alternate material of construction. The default is to use noncombustible materials and only use FM
4910/UL 2360 materials when process chemicals dictate an alternate to noncombustible materials
of construction.” The committee’s reason for rejecting the public comment was: “The default is to
use noncombustible materials, and only use FM 4910/UL 2360 materials when process chemicals
dictate an alternate to noncombustible materials of construction.” In neither case did the committee

discuss whether there is any evidence that the permission to use materials complying with the
requirements of FM 4910 or UL 2360 would lower fire safety.
The fact is, there is no evidence that using such materials would decrease fire safety. It
would provide greater flexibility to semiconductor facilities in choice of materials. In practice,
many of the materials in use are not noncombustible but provide adequate fire safety (as evidenced
by the lack of fire losses in these facilities.
Notice that, in NFPA 318, “Materials that are reported as passing ASTM E136, Standard
Test Method for Assessing Combustibility of Materials Using a Vertical Tube Furnace at 750°C,
shall be considered noncombustible materials.” This means that materials need to comply with the
pass/fail requirements of ASTM E136 to be deemed noncombustible. A material can meet the
criteria of ASTM E136, and both be ignited, experience some flaming and undergo some mass
loss. The criteria of ASTM E136 in its latest edition (2019a) are shown below.
“15.1 Report the material as passing the test if at least three of the four test specimens tested meet
the individual test specimen criteria detailed in 15.2 or 15.3. The three test specimens do not need
to meet the same individual test specimen criteria.
15.2 If the weight loss of the test specimen is 50 % or less, the material passes the test when the
criteria in 15.2.1 and in 15.2.2 are met:
15.2.1 The recorded temperatures of the surface and interior thermocouples do not at anytime
during the test rise more than 30°C (54°F) above the stabilized furnace temperature measured at
T2 prior to the test.
15.2.2 There is no flaming from the test specimen after the first 30 s.
15.3 If the weight loss of the specimen exceeds 50 %, the material passes the test when the criteria
in 15.3.1 and in 15.3.2 are met:

15.3.1 The recorded temperatures of the surface and interior thermocouples do not at anytime
during the test rise above the stabilized furnace temperature measured at T2 prior to the test.
15.3.2 No flaming from the test specimen is observed at any time during the test.
15.4 Report the option that was used.”
The annex of NFPA 318 notes that materials meeting the requirements of FM 4910 or of
UL 2360 “are likely not to propagate a fire beyond the ignition zone” and “are likely to perform
well in a larger-scale flammability test known as the parallel panel test”.
In conclusion, accepting the CAM would recognize reality, would not decrease fire safety,
and would allow greater flexibility to users and designers of semiconductor facilities.
Marcelo M. Hirschler
GBH International

Semiconductor and Related Facilities
June 2021
The Report of the Technical Committee on Semiconductor and Related Facilities is
presented as found in the First Draft Report and Second Draft Report for the Fall 2020 revision
cycle of NFPA 318, Standard for the Protection of Semiconductor Fabrication Facilities. The
revisions were submitted to letter ballot of the responsible Technical Committees and Correlating
page for NFPA 318 at www.nfpa.org/318next.
COMMITTEE POSITION STATEMENT:
First, I want to say thank you to Dr. Hirschler for raising this issue for review. The
following is an explanation of the technical committee actions along with additional technical
details. At the first draft stage, the technical committee received a Public Input to 8.2.1.2. to
eliminate the text “only where process concerns or process chemicals require alternatives”. The
substantiation stated - A number of semiconductor facilities use the materials that are listed to FM
4910 or UL 2360. Therefore, the phrase stating that they should only be used in what amounts to
extreme circumstances should by now be obsolete and needs to be eliminated. Materials listed to
FM 4910 or UL 2360 provide adequate fire performance characteristics and have been shown to
be appropriate for the application. The committee resolved the Public Input. The same proposed
change was submitted as a Public Comment, and the committee once again rejected the change,
and reiterated their position taken during the First Draft stage.

The Committee’s resolution/rejection was based on the following expanded points:
1. We agree that FM4910/UL2360 materials are used extensively, effectively, and offer
favorable fire performance characteristics (fire propagation is not expected beyond the
ignition zone and smoke generation is limited). However, FM4910/UL2360 materials are
not truly noncombustible.
2. Section 8.2.1 under Materials of Construction indicates that materials of construction shall
be noncombustible, with two exceptions offered.
3. Section 8.2.1.2 is one of the exceptions to the default use of noncombustible materials.
Typically, tools (i.e., process equipment) are constructed of stainless steel, as long as the
process chemicals are compatible with metallic surfaces. The exception 8.2.1.2 offers an
alternative material type when process chemicals (e.g., acids) dictate an alternate to
noncombustible materials (stainless steel).
4. The elimination of the text “only where process concerns or process chemicals require
alternatives” from Section 8.2.1.2 would create a situation where tools handling flammable
or combustible process chemicals could be constructed out of FM4910/UL2360 materials,
which is not the intent of the standard. A fire involving flammable or combustible process
chemicals could generate enough heat to deform the FM4910/UL2360 constructed tools
and impact their favorable fire characteristics due to external fire loading. This could lead
to tool and facility damage. Flammable and combustible process chemicals should be
handled in tools constructed of truly noncombustible materials, like stainless steel.
5. The committee does not believe the phrase “only where process concerns or process
chemicals require alternatives” creates a situation that they only be used in extreme
circumstances. In fact, the committee strongly encourages the use of FM4910/UL2360

listed materials in cases where there are concerns with process chemical compatibility.
These materials offer significant risk reduction, but should not be used for tools handling
flammable or combustible chemicals. The current wording has not limited the use of these
materials as noted by their extensive use throughout semiconductor and related facilities.
Rick Guevara
on behalf of the Technical Committee on Semiconductor and Related Facilities

June 2021
The CAM 501-2 recommends pointing out to users of NFPA 501 that several standard
practices have been issued to accompany ASTM E84, which modify the way in which tests are to
be conducted for a variety of materials. These standard practices have been issued, over the last 20
years or so, to require more appropriate testing for a variety of materials and products.
The following is a list of such standard practices issued by the committee responsible for ASTM
E84 and associated with methods to ensure safe fire testing with the Steiner tunnel test:
“E2231: Standard Practice for Specimen Preparation and Mounting of Pipe and Duct Insulation
Materials to Assess Surface Burning Characteristics
E2404: Standard Practice for Specimen Preparation and Mounting of Textile, Paper or Polymeric
(Including Vinyl) and Wood Wall or Ceiling Coverings, Facings and Veneers, to Assess Surface
Burning Characteristics
E2573: Standard Practice for Specimen Preparation and Mounting of Site-Fabricated Stretch
Systems to Assess Surface Burning Characteristics
E2579: Standard Practice for Specimen Preparation and Mounting of Wood Products to Assess
Surface Burning Characteristics
E2599: Standard Practice for Specimen Preparation and Mounting of Reflective Insulation,
Radiant Barrier and Vinyl Stretch Ceiling Materials for Building Applications to Assess Surface
E2688: Standard Practice for Specimen Preparation and Mounting of Tapes to Assess Surface

E2690: Standard Practice for Specimen Preparation and Mounting of Caulks and Sealants to
Assess Surface Burning Characteristics
E2988: Standard Practice for Specimen Preparation and Mounting of Flexible Fibrous Glass
Insulation for Metal Buildings to Assess Surface Burning Characteristics
E3202: Standard Practice for Specimen Preparation and Mounting of Plastic Composites for Use
as Deck Boards, Stair Treads, Guards or Handrails to Assess Surface Burning Characteristics
E3287: Standard Practice for Specimen Preparation of Fenestration Profiles Intended to Support
Non-Combustible In-Fill Materials”
The reason for highlighting the use of the standard practices issued is that tests conducted
many years go with ASTM E84 did not use the revised procedures identified in those standard
practices. Therefore, tests that were conducted without using the specimen preparation and
mounting procedures required by the standard practices have potentially generated misleading
results.
One example is the testing of wall coverings and ceiling coverings. ASTM E2404 requires that
they be tested using the adhesive to be used in actual practice and using the substrate backing that
the wall covering or ceiling covering will be used with. In the past, such coverings have often been
tested using specially flame retarded adhesives and noncombustible substrates when they are, in
practice, being used with combustible substrates and normal adhesives. The result is an unsafe
classification of the product.
In conclusion, accepting the CAM would increase fire safety by preventing the continued
acceptance of test results that are potentially misleading by using testing procedures that have been
rendered obsolete by the committee issuing these standards.
Marcelo M. Hirschler
GBH International

Manufactured Housing
June 2021
The Report of the Technical Committee on Manufactured Housing is presented as found in
the First Draft Report and Second Draft Report for the Fall 2020 revision cycle of NFPA 501,
Standard on Manufactured Housing. The revisions were submitted to letter ballot of the
responsible Technical Committees and Correlating Committee in accordance with the Regulations
First, I want to thank Mr. Hirschler for participating in the NFPA standards development
process.
Regarding Public Comment No. 3, the Manufactured Housing technical committee
determined, upon discussion and careful review, that there were three main areas for concern,
ultimately leading to the Public Comment being rejected during the Second Draft meetings.
First, the proposed language provides reference to ASTM E84 and UL 723. These
documents are already referenced within 5.3.1.1, which mandates the use of the appropriate testing
methods. Therefore, adding additional reference to these documents within the same requirement
was determined to be redundant.
Second, the proposed language was determined to be unenforceable. The phrase "when
appropriate" provides no criteria for applicable uses when the standard practices referenced In the
Public Comment should be utilized.
Third, the proposed language lists two mandatory requirements within the same section,
which does not comply with the NFPA Manual of Style.

The motion to reject the Public Comment passed during the Second Draft meeting.
The committee looks forward to the next cycle of NFPA 501 and potentially working with
Mr. Hirschler to continue further discussion on this topic.
Stanley C. Harbuck, Chair

on behalf of the Technical Committee on Manufactured Housing

June 2021
FLAME EFFECTS vs. FIREWORKS
The difference between “Flame Effects” and “Fireworks” is critical to understanding the issue of
this NITMAM. It is why a Technical Committee (TC) on Special Effects was created in 1994 and
assigned NFPA 1126, Standard for the Use of Pyrotechnics before a Proximate Audience as well
as NFPA 160, Standard for the Use of Flame Effects Before an Audience after the TC on
Pyrotechnics developed NFPA 1126, which was approved in 1992.
At that time, the use of theatrical pyrotechnics at concerts, plays and various other productions,
often inside public assemblies was an issue. Open flames, with limited exceptions, were
prohibited inside public assembles and the use of theatrical pyrotechnic was growing.
NFPA 1126 was developed by the TC on Pyrotechnic to provide standards for the indoor use of
theatrical pyrotechnics as well as at distances closer than those in NFPA 1123 for traditional
outdoor fireworks displays.
The use of flame effects using solids, liquids, or gases as fuels in combination with atmospheric
oxygen for combustion inside public assembles and before audiences at any distance was also an
issue; however at that time the NFPA determined that the TC on Pyrotechnics did not have the
requisite expertise or balanced representation to address flame effects.
Thus, the need for a new TC to address flame effects used before an audience. And given that
flame effects are often used with theatrical pyrotechnics in the same productions, the re-
assignment of NFPA 1126 to this new TC.
FLAMMABLE LIQUID FIREBALLS vs. FIREWORKS
A flammable liquid fireball is a dramatic special effect most often associated with movie and TV
productions. They are also used at live action stunt shows, air shows, battlefield reenactments,
and outdoor fireworks displays. Flammable liquid fireballs can only be created in the field where
they are used – they cannot be produced at a manufacturing facility, stored or shipped.
Flammable liquid fireballs consist of a propellent, usually blackpowder or det cord, that propels
the flammable liquid into the air so there is a sufficient fuel air mixture for combustion. The fuel
air mixture is also ignited by the propellant. A flammable liquid fireball can be created with or
without a mortar and relies solely on atmospheric oxygen for combustion.
Fireworks are devices that contain solid fuels and solid oxidizers that do not rely on atmospheric
oxygen for combustion. Fireworks are most frequently produced at a manufacturing facility,
stored and then shipped to where they will be used.

The only similarity between fireworks and flammable liquid fireballs is the use of blackpowder as
a propellant; however blackpowder is also used as a propellant in model rocket motors, modern
muzzleloaded rifles or shotguns for sport and hunting, antique and replica firearms for sport,
special effects for creating blasts of debris, or moving objects rapidly, and specialty charges for
quarrying soft rock, such as shale, etc.
TECHNICAL COMMITTEE ON SPECIAL EFFECTS vs. PYROTECHNICS
The Committee scopes for the two TCs were carefully revised by the Standards Council between
the TC on Explosives, the TC on Pyrotechnics and the TC on Special Effects. The Standards
Council decision of April 1997 ensured the scopes differentiated between explosives used in
commercial purposes, fireworks used for entertainment before spectators as well as model and
high power rockets used as a hobby, and theatrical pyrotechnics and flame effects used for
entertainment before an audience.
Each of these TCs address explosives or fireworks/pyrotechnics that are defined, classified and
regulated based on Federal laws and industry standards for their manufacture, transportation,
storage and use. The NFPA Codes and Standards each TC develops are based in large part on
these Federal definitions, classifications and regulations as well as industry standards in their
respective documents (e.g. American Pyrotechnics Association APA 87-1 Standard for the
Construction & Approval for Transportation of Fireworks, Novelties and Theatrical
Pyrotechnics, 2001).
NFPA 160 vs. NFPA 1123
NFPA 1123 has always addressed the use of fireworks in public displays. It has never addressed
any flame effects until this single proposal was introduced. The document does not contain any
definitions for any flame effects, nor does it reference any of the NFPA documents related to
flammable or gas fuels.
This proposal only addresses the distances from one type of flame effect to the spectators.
NFPA 1123 has no standards for the preparation of the undefined flammable liquid fireballs, the
equipment required for their use, the methods for ignition (manual or remote), the distances to the
fireworks in the display, overhead objects (Trees, wires, lights, etc.), buildings, membrane
structures or the personnel in the discharge site.
The requirements for personal protective equipment (PPE) for a fireworks display are not
appropriate for personnel in close proximity to flammable liquid fireball.
The standards for mortars for aerial fireworks are not always appropriate for flammable liquid
fireballs (e.g. paper, HDPE or fiberglass mortars or mortars in wooden racks).
NFPA 1123 is mute regarding the use of flammable liquid fireballs near combustible materials or
stored hazardous materials. The fire prevention and fire protection measures for flammable liquid
fireballs are not addressed and there is nothing regarding procedures for any misfires.

NFPA 160 has always addressed the use of flame effects that utilize solid, flammable or gas fuels
and rely on atmospheric oxygen for combustion. The document contains definitions for flame
effects, including an example of flammable liquid fireballs (A.3.3.13.2 Hybrid Flame Effect – 3rd
example). It also references NFPA flammable and gas fuels documents.
NFPA 160 includes a method for establishing the distances from all types of flame effects to the
spectators. It also has standards for the preparation of all flame effects, the equipment required for
use and the methods for ignition.
TC BALANCE
Both the NFPA Regulations Governing the Development of NFPA Standards and the American
National Standards Institute (ANSI) Essential Requirements require balanced interests within the
membership of those organizations that develop standards. For the NFPA, this means the TCs
must have balanced interests in order to be considered consensus standards.
The TC on Pyrotechnics has about a handful of Principals/Alternates with experience with flame
effects. There are no representatives from the manufacturers of flame effects equipment or the
solid, flammable or gas fuels used to create flame effects.
A significant number of the of Principals/Alternates on the TC on Special Effects have experience

with flame effects. There are also representatives on the TC from the manufacturers of flame
effects equipment or the solid, flammable or gas fuels used to create flame effects.
SUMMARY
1. “Flammable liquid fireball effects” are a Flame Effect as defined by NFPA 160 and arenot
Fireworks as defined by NFPA 1123 or NFPA 1124.
2. Flame effects are within the scope of the TC on Special Effects and NFPA 160 and notthe
TC on Pyrotechnics and NFPA 1123
3. The TC on Pyrotechnics does not have the balanced representation required by NFPA
Regulations and the ANSI Essential Requirements to address Flame Effects, only the TC
on Special Effects has such balanced representation.
ACTION REQUESTED
Public Comment No. 8 to NFPA 1123 should be accepted and the proposed new NFPA 5.1.3.7*
Flammable Liquid Fireball Effects rejected in its entirety.
Charles P Weeth,
Weeth & Associates, LLC

Report of the Technical Committee on Pyrotechnics
June 2021
The Report of the Technical Committee on Pyrotechnics is presented as found in the First
Draft Report and Second Draft Report for the Annual 2021 revision cycle of NFPA 1123,
Pyrotechnics. The revisions were submitted to letter ballot of the responsible Technical
Committees and Correlating Committee in accordance with the Regulations Governing the
Development of NFPA Standards. The reports and ballot results can be found on the next edition
tab of the Document Information page for NFPA 1123 at www.nfpa.org/1123next.
It must be first noted that Mr. Charles Weeth, who authored the CAM, is a valuable member
of both the Pyrotechnics and Special Effects committees. His value is in the fact that he sometimes
brings totally unique perspectives in the committees’ respective effects to ensure the documents
are as valuable and technically up to date for the ultimate users of those documents. Having said
that, Mr. Weeth provided a fervent argument for deleting the language that arose from the
committee adopting First Revision No. 14-NFPA 1123-2019.
In leading up to the First Revision publication, the Pyrotechnic (PYR-AAA) and Special
Effects (SPE-AAA) committees separately considered the proposed PI and after much debate,
including Mr. Weeth’s perspective, the committees mutually agreed the PI was appropriate for
inclusion in the NFPA 1123 Pyrotechnics document and NOT in the NFPA 160 Flame Effects
document.
Through Mr. Weeth’s CAM he refers to the scope of the respective committees and
documents. The committees also studied and discussed the scope of the respective committees and
documents. There were two factors used for determining which is the more appropriate document,
NFPA 1123 or NFPA 160, to insert language on fireball effects. The first is the Pyrotechnics

Committee Scope wherein it also mentions having “primary responsibility” for “pyrotechnic
special effects”. The second resides within the Special Effects Committee scope itself. The Special
Effects Committee has “primary responsibility” for special effects “before a proximate audience”
This leads to the question, what is “proximate”?
Since neither NFPA 1123 or NFPA 160 defines “proximate”, the committees relied upon
common definition and usage. (Some guidance/reliance can also be obtained in NFPA 1126, which
is within the scope of the Special Effects Committee. In it, “Proximate Audience” is defined as
“closer to pyrotechnic devices than permitted by NFPA 1123.” NFPA 1126 was not seriously
considered for including language on fireball effects.) Proximate can allude to distance or lack
thereof. Since the effect uses black powder in concert with a flammable or combustible liquid –
AND – most importantly, just like fireworks, the PI and resulting First Draft provide distance
requirements. (The distance requirement is based principally on the liquid capacity of the device
over the amount of black powder.) Therefore, both committees felt the language should reside in
NFPA 1123.
Under that light, and with 33 eligible voters, there were 24 affirmative votes cast (8 ballots
were not returned) and Mr. Weeth’s singular negative vote with comment. The issue was not put
before the Special Effects for a vote since it was, again, mutually agreed to by the committees the
language can reside in NFPA 1123.
Glenn Dean
on behalf of the Technical Committee on Pyrotechnics

June 2021
The revision to NFPA 1225 section 18.4, made in the second draft, contains erroneous
requirements and references.
1. Section 820 of NFPA is the wrong article for requirements for rooftop mounted
antennas and surge protection. The correct requirements are in NFPA 70 Article 810.
Article 810.6 is the correct article to be referenced. Article 820 applies to the in-building
distribution, as stated in Article 810.4.
2. UL-497C is the wrong standard for donor antenna lead-in protection. The correct
standard is UL-497E per NFPA 70 Article 810.6
3. Article 18.4 First Draft Is Better Than Article 18.4 Second Draft. The first draft is a
more accurate statement of requirements until this Article is revised to reference the
correct Articles in NFPA 70 and the correct UL standards.
Richard Abbott
InBuildingRadio Inc.

Report of the Technical Committee on Public
Emergency Service Communication
June 2021
The Report of the Correlating Committee on Technical Committee on Public Emergency
Service Communication is presented as found in the First Draft Report and Second Draft Report
for the Custom ERRS Group 1 revision cycle of NFPA 1225, Standard for Emergency Services
Communications. The revisions were submitted to letter ballot of the responsible Technical
The reports and ballot results can be found on the next edition tab of the Document
First, I want to say thank you to Mr. Abbott for continued engagement in the development
of the NFPA 1225 Standard. The Committee revised the text to specify the correct NFPA standard
that provides lightning protection for In-Building Emergency Responder Communications
Enhancement Systems. This change was needed because the scope of NFPA 780 covers lightning
protection of the structure and not the equipment inside the structure. Specifically, 1.1.2 of NFPA
780 states the document shall address lightning protection of the structure but not the equipment
or installation requirements for electric generating, transmission, and distribution systems except
as given in Chapter 9 and Chapter 12. Chapter 9 details requirements for Wind Turbines and
Chapter 12 details requirements for Solar Arrays. The challenge is that many buildings are not
required to have NFPA 780 compliant lightning protection systems. The cost to protect an entire
building in accordance with NFPA 780 can be many times the cost of an In-Building Emergency
Responder Communications Enhancement System itself. The goal is the survivability of the
system by providing surge protection for its components. The Committee identified NFPA 70 as

the more appropriate reference document. The voting of 43 eligible voters resulted in 38
affirmative, 2 negative and 3 no response.
Charles Berdan
on behalf of the Technical Committee on Public Emergency Service Communication

June 2021
NFPA 1225 18.3.4 Communications Antenna Density would impose a new requirement for
distributed antenna density, not present in the current NFPA 1221 requirements. It is recommended
that this new requirement be rejected for the following reasons:
1. Design requirements should not be imposed in place of performance requirements. Antenna
density is a design requirement. The relevant performance requirement is near-far effect
immunity. The imposition of a design requirement imposes an arbitrary solution to a performance
deficiency, a problem that may or may not exist depending upon the venue. Imposing an antenna
density requirement is a design solution that may be much more expensive than other design
approaches. When design specifications are used in lieu of performance requirements, they
invariably relieve contractors of associated performance requirements if the code clearly provides
a design solution for the performance requirement. The performance requirement should look
similar to the following;
18.3.4 Near-Far Effect
In-building emergency responder systems shall be engineered to minimize the near-far effect. The
system shall provide the required coverage regardless of the number, type and location of
simultaneous radio system users specified by the AHJ.
2. The Near-Far Effect Is Not Always A Risk. There is nothing mysterious about the near-far effect.
The near-far effect is the result of a reduction in signal booster gain that causes the uplink signal
level at the public safety repeater to be reduced to a level that is not adequate for reliable
communications. The susceptibility of a design to the near far effect is significantly affected by
the proximity of a venue to the donor public safety repeater, and the RF attenuation environment

(“RF heaviness”) of the venue, and the type of signal booster used, Type A or Type B. A venue
that is close the donor public safety repeater and/or has a light RF attenuation environment, is
unlikely to have a near-far risk. Venues that use Class A signal boosters are almost immune from
the near-far effect. As portable radios migrate to being similar to cellular handsets, radio
manufacturers may incorporate uplink power control for public safety, as is done in the cellular
world, also eliminating the near-far effect.
3. Other Design Alternatives Should Be Considered. The near-far effect is caused by an inadequate
uplink signal, it is not caused specifically by antenna density. The uplink link budget depends
upon a number of factors, including the aforementioned donor site proximity and RF heaviness.
But there are other solutions to an inadequate uplink. The most obvious being the use of Class A
signal boosters that have per channel AGC instead of entire uplink band AGC. The use of a higher
power signal booster will minimize the amount of AGC that is incurred due to near signals. The
use of a higher gain donor antenna and or the use of lower loss donor and service cables can
increase the uplink signal strength. Imposing an antenna density requirement is probably the least
effective, most expensive, and most intrusive approach to addressing the near-far effect, and by
itself does not always eliminate the risk.
4. Antenna Placement Is More Important Than Antenna Density. Usually, if there is a near-far effect
issue, the cause is not the density of antennas used, but the locations of the antennas that are used.
That is why we have tools such as iBwave for designing distributed antenna systems. The RF
density of venues is generally not uniform. In a typical apartment building for example, the RF
density of the garage areas is quite different than any areas set aside for mechanical equipment,
and also much different than the floors and areas dedicated to apartments. The areas around
elevators and stairwells is quite different than the areas around offices or apartment rooms. The
number of antennas needed in each of these areas is quite different. On the upper floors of venues,

frequently the macro coverage is adequate except for a few interior areas. In such cases, antennas
are only needed in the poor macro coverage areas, especially since the macro coverage is not
subject to any near-far effects.
5. Coverage Balance Is More Important Than Antenna Density. The near-far affect is caused by
an inability of the signal booster to accommodate the uplink signal dynamic range. The uplink
signal dynamic range can be significantly reduced by ensuring that the venue coverage is
“balanced”, that there are no areas where there are extremely weak signal levels and very strong
signal levels. The location of antennas at discontinuities in RF heaviness is also very important
for achieving coverage balance, which can be optimized through the use of tools like iBwave.
6. Requiring An Antenna Density Is A Bad Precedent. Distributed antenna systems have to have
enough antennas to provide adequate coverage, but that is not a density requirement. An antenna
“density” requirement would lead to an antennas per square foot or antenna spacing requirement.
It potentially would require many more antennas than are necessary for coverage, at significant
additional expense without added value. The coverage design should be left to the distributed
antenna system designers and should not be dictated by code or interpreters of the code.
7. A Bad Requirement Is Worse Than No Requirement. One might argue that there is no harm to
including an antenna density requirement in the code. This is not correct. Including this
requirement in the code would perpetuate the myth that near-far effect is always a problem, and
that an antenna density requirement is the best approach to resolving the problem should one exist.
It would empower plan reviewers to incorporate arbitrary antenna density requirements when they
generally do not have sufficient data to assess a problem or the qualifications to resolving the
problem.
Richard Abbott
InBuildingRadio Inc.

June 2021
The Committee recognizes the important challenge of the near-far effect as brought for
by Mr. Abbott. The Committee evaluated the public comment submitted on this section and
identified the near-far effect is diminish in addressing antenna density in a building. The
Committee identified this specific approach in reducing the negative effects of having a portable
radio overpowering a weaker signal portable radio further away from an antenna, by addressing
antenna density which has proven to be the best approach in most cases. The public comment as
presented to the Committee appeared to be restating the challenge of near-far, where-as the
Committee identified a best practices approach for correcting issue.
The voting of 43 eligible voters resulted in 40 affirmative and 3 no response.

Charles Berdan

Motion to Reject an Identifiable Part of Second Revision No. 16
June 2021
The proposed change to 18.12.3.3 creates a conflict with NFPA 72 and NFPA 1221 requirements
that define pathway survivability requirements. The minimum criteria for Pathway Survivability
Level 1 in NFPA 72 requires metal conduit in addition to fully sprinklered building per NFPA 13,
as referenced in NFPA 72 Section 12.4 definitions of Pathway Survivability levels. NFPA 1221
requires minimum Level 2 Pathway Survivability for the backbone cables. This change does not
even reach that minimum of Level 1. There is no technical justification whatsoever provided for
this departure from established minimums.
Sprinkler systems are not designed to provided fire resistance ratings to building components. For
additional context, the International Building Code section 703.2 states the following:
703.2 Fire resistance. The fire-resistance rating of building elements, components or
assemblies shall be determined in accordance with Section 703.2.1 or 703.2.2 without the use
of automatic sprinklers or any other fire suppression system being incorporated, or in
accordance with Section 703.2.3
In the case of the IBC for example, the prescribed approach is to use Alternative Means & Methods
(e.g. equivalency requirements) which requires a full, case-by-case analysis. Consequently,
whether the building is sprinklered or not has no bearing on the fire-resistance of a cable backbone
system.
Equivalency clauses already exist in NFPA 101 and NFPA 1 in Section 1.4.3, and NFPA 5000, all
permit the use of alternative systems, methods, or devices to meet the intent of the prescribed code
provisions where approved as being equivalent. Through the rigor of a performance-based design,
it can be demonstrated whether a building design is satisfactory and complies with the implicit or

explicit intent of the applicable code requirement. Clause 1.4.3, and A.1.4.3, of NFPA 101 requires
that an equivalent method of protection provide an equal or greater level of safety. It is not a waiver
or deletion of a Code requirement. There are portions of a sprinkled building that cables can pass
through that are not accessible to an activated sprinkler. It is very foreseeable that a cable running
through such a space could be damaged from heat, flames, or higher temperature such that the
ERCES system will no longer operate.
On the issue of the NFPRF report referenced, UL 2196 is titled Fire Test for Circuit Integrity of
Fire-Resistive Power, Instrumentation, Control and Data Cables. In addition to testing to this
Standard, UL has supplemented these Listings with UL Subject 1724, "Outline of Investigation for
Fire Tests for Electrical Circuit Protective Systems." This category covers electrical circuit
integrity systems, and includes components, connections, bends and materials intended for
installation as protection for specific electrical wiring systems, with respect to the disruption of
electrical circuit integrity upon exterior fire exposure. Electrical circuit integrity system
performance criteria are based on functionality of the cable during the fire and after the hose
stream. These systems are intended to be installed in accordance with all provisions of the NEC
and as amended by the details of each individual system (such as type of supports) and the
accompanying instructions. Even cable splices need to be tested as part of the systems, otherwise
the hourly fire-resistive rating assigned applies to continuous lengths of cable passing completely
through a fire zone and terminating a minimum of 12 in. beyond the fire-rated wall or floor
bounding the fire zone.
Tony Crimi, P. Eng. MASc.

A.C. Consulting Solutions Inc.
On behalf of International Firestop Council

June 2021
The Committee appreciates the perspective of the submitter Mr. Crimi in his goal to protect
backbone cables and backbone cable components. The Committee revised component
requirements in its entirety to address many practical difficulties faced by building owners, in-
building emergency responder communications enhancement system design and installation
professionals, and authority having jurisdictions in the acceptance and potentially having to use
these systems. The Committee recognized the need to potentially requiring physical protection of
cabling and components in Section 18.12.3.2:
18.12.3.2
Mechanical protection of work and raceways for coaxial cables shall comply with
Article 820 of NFPA 70.
The Committee deferred to NFPA 70 to provide guidance on the installation and protection
of the cabling as required. The proposed text, as presented by the Committee in the second draft
of NFPA 1225 does not prohibited the use metal raceways, and encourages the physical protection

of cabling and components where required. The proposed revision to Section 18.12.3 to require
cabling and components in metal raceways is now addressed Section 18.12.3.2. Section 18.12.3.3
now addresses the fire resistance rating of the cable and components. By accepting the proposed
motion, this would create an upset condition on the requirement of fire resistance of back bone
cabling and components where the Committee identified different requirements for fire resistance
for buildings having a fire sprinkler system and for those buildings that do not have fire sprinkler
systems.
The committee also provided the following substation in its second revision for Section
18.12.3.3:
• Backbone cables are not protected from attack by fire when installed in metal
conduit. Metal conduit only provides physical protection of the cable.
• Installing backbone cables in conduit adds unnecessary cost to the installation of
the system without improving the performance or solving a known problem that is
occurring in the field.
The voting of 43 eligible voters resulted in 39 affirmative, 1 negative and 3 no response.
Charles Berdan

Certified Amending Motion No. 2001-5 (same motion as 2001-9 grouped by
Motions Committee)
June 2021
This SR should be rejected until sufficient data are provided to the committee for
consideration.
Allowing a halocarbon agent for use in occupied spaces with a toxicological profile as
currently understood for HB-55 would be unprecedented in the NFPA 2001 standard. No other
halocarbon agent’s toxicological profile currently in the standard, and deemed appropriate for use
in normally occupied spaces, has an adverse acute toxicological endpoint below its cardiac
sensitization no observed adverse effect level (NOAEL).
Discussion:
There remains a data gap regarding the toxicological profile for the HCFO-1233zd(E)
component of the blend HB-55 which is proposed to be incorporated into the standard. A published
study described the presence of central nervous system (CNS) effects during acute inhalation
exposures as low as 96,000 ppm in rats reporting “Among the survivors, tremors were observed
during exposure,” [Ann Tveit, George M. Rusch, Hans Muijser, Mabel J. W. van den Hoven and
Gary M. Hoffman (2014), The acute, genetic, developmental and inhalation toxicology of trans-1-
chloro,3,3,3-trifluoropropene (HCFO-1233zd(E)), Drug and Chemical Toxicology, 37:1, 83-92].
Tremors are a clinical sign of toxicity which indicates neurotoxicity (the test material having a
direct effect on the central nervous system), similar to other changes in motor activity and
coordination. The report also describes similar CNS effects during the initial cardiac sensitization
study with this material conducted in the dog where exposures to 35,000 ppm resulted in tremors

so severe that obtaining an EKG was not possible. The conclusions for that study contained in the
Occupational Alliance for Risk Science (OARS) Workplace Environmental Exposure Level
(WEEL) Committee documentation for HCFO-1233zd(E) stated “the threshold for general toxicity
(not cardiac sensitization) was 35,000 ppm and the NOEC was 25,000 ppm.”
Subsequent cardiac sensitization studies were apparently conducted that allowed for the
establishment of a cardiac sensitization NOAEL (No Observed Adverse Effect Level) of 8.7% for
the blend as proposed to be included in Table 4.3.2.3. It is acknowledged that a cardiac
sensitization study is not the best model to assess neurotoxicity. However, CNS effects have been
observed in two species involving acute inhalation exposures and should not be dismissed.
These observations warrant that the data gap involving potential neurotoxicity be further
investigated in an appropriate model, such as additional acute inhalation studies in the rat. These
studies should be completed at the minimum design concentrations for the HCFO component to
provide a complete data set for proper risk assessment on the proposed blend before acceptance
into the NFPA 2001 standard for use in normally occupied spaces. The results published by Tveit
et al., indicate that neurotoxicity is observed at 9.6 volume % (96,000 ppm) for the HCFO
component which was the lowest concentration dosed in the acute inhalation rat study. The OARS
WEEL documentation reports no clinical observations for CNS effects at 25,000 ppm (2.5 volume
%) in the dog cardiac sensitization study. Therefore, based upon the publicly available data, the
NOAEL for this toxicological endpoint appears to be 2.5 volume % (25,000 ppm) for the HCFO
component of the proposed blend. The minimum design concentrations for the proposed blend
required for protecting Class A, B or C hazards are well above this NOAEL for the HCFO
component in the blend (see table below).

HB-55 Concentration Fractional HCFO
based upon manufacturer Component
supplied data Concentration
Volume % ppm Volume % ppm
Neurotoxicity NOAEL unknown unknown 2.5% 25,000
(CNS effects)
Minimum Design
Concentration: Class A 5.5% 55,000 3.9% 39,000
Hazards
Minimum Design
Concentration: Class B 7.2% 72,000 5.1% 51,000
Hazards
Minimum Design
Concentration: Class C 5.9% 59,000 4.2% 42,000
Hazards
The fire protection industry has typically relied upon the cardiac sensitization study for
establishing the NOAEL for an agent since cardiac sensitization was frequently determined to be
the toxicological endpoint with the lowest acute effect level for agents addressed in the standard
to date. However, the presence of additional toxicological endpoints in other acute exposure
studies cannot be disregarded, especially since a CNS effect could potentially impact a person’s
egress from an occupied space which is protected by that agent. Note that this committee
recognized the potential for toxicological endpoints other than cardiac sensitization with the
revision to the quality requirements in the new Chapter 5 (see SR-24).
Therefore, additional data are necessary before this agent can be accepted into the standard
to fill the existing data gap and adequately assess potential hazards to personnel created by
discharge of the proposed blend into occupied spaces.
John Owens,
3M Company

Certified Amending Motion No. 2001-9 (same motion as 2001-5 grouped by Motions
Committee)
June 2021
The safety in use and efficacy of HB-55 have not been demonstrated, and its inclusion in
NFPA 2001 is premature, pending the addressing of these issues.
Safety in Use Issue 1:
Formation of Explosive Compounds Upon Exposure to Flames and/or Heat. Blend 55 is a
50:50 weight mixture of HCFO-1233zdE and FK-5-1-12. The use of such a mixture is
unprecedented in that the HCFO-1233zdE component is known to form explosive compounds
(trifluoropropyne, chloroacetylene) upon exposure to flame and/or heat (A.M. Lovelace, Aliphatic
Fluorine Compounds, Reinhold, 1958, Chapter III; Haszeldine, R.N., Nature (1950), 165, 152-3;
US7964759, Method for Producing 3,3,3-Trifluoropropyne, Central Glass, 6/21/2011;
US9272968, Process to Suppress the Formation of 3,3,3-Trifluoropropyne in Fluorocarbon
Manufacture, Honeywell, 3/1/2016; Wu, R., et. al., “Experimental and theoretical studies on the
thermal decomposition of trans-1-chloro-3,3,3-trifluoropropene and 2-chloro-3,3,3-
trifluoropropene and their fire-extinguishing performance”, New J. Chem 2020, 44 (30), 12932).
This formation of explosive decomposition products from chemicals with structures similar
to that of HCFO- 1233zdE is well known and expected (M.L. Robin, Hazards Associated with
Halogenated Olefins in Fire Suppression Applications, December 2020). The implications of this
formation of explosive compounds from HCFO-1233zdE, or mixtures containing HCFO-
1233zdE, upon exposure to flames in real world total flooding scenarios has not been investigated.

Safety in Use Issue 2:
Formation of High Levels of Acids During Flame Suppression/Extinction. US Army testing (S.
McCormick, et. al., Low Global Warming Potential Fire Suppressants, Oct 18, 2018) indicates the
formation of dangerously high levels of hydrofluoric acid (HF) and carbonyl fluoride (COF 2 ) in
total flooding applications with HB-55 compared to other halogenated clean agents such as HFC-
227ea. In these total flooding tests conducted by the US Army, HB-55 formed 1800 ppm HF and
560 ppm COF 2 , whereas in the identical test HFC- 227ea produced HF and COF 2 in levels below
the detection limit. HF and COF 2 levels produced from HFC-227ea in typical total flooding
scenarios have been well studied and found to be below levels harmful to humans or electronic
equipment (see NFPA 2001, 2018 edition, Section A.5.7.1.1). There has been no similar
decomposition product testing conducted on HCFO-1233zdE or on its blend with FK-5-1-12 (i.e.,
on HB-55).
Efficacy Issue. The efficacy of HB-55 in fire suppression - especially in the protection of Class
A and Class C hazards - which comprise approximately 95% of clean agent applications - has not
been established. Class A fire tests reported for HB-55 (E.W. Forssell and B. Stilwell, Forssell,
et. al., ISO Standard Agent Extinguishment Tests with Honeywell Halocarbon Blend 55
Final Report, Jensen Hughes, August 22, 2019) were not performed in compliance with the
requirements of ISO 14520-1 or NFPA 2001, 2018 edition Section A.5.4.2.2.
The HB-55 Class A tests employed a radically different design for the polymeric sheet
support rack used in the establishment of the Class A (and Class C) minimum extinguishing
concentration (MEC) compared to the support rack specified in NFPA 2001 and ISO 14520-1. As
is well known throughout the fire suppression testing community, even small changes in the test

configuration used in fire tests can lead to large changes in the fire challenge presented and hence
to large changes in the MEC.
Neither Underwriters Laboratories nor Jensen-Hughes (who conducted the tests) have
provided any evidence whatsoever to indicate that the modified test configuration provides
equivalent results to the ISO/NFPA test configuration.
The ISO/NFPA test configuration has been employed for the establishment of the Class A
and Class C MECs for every single clean agent currently listed in the NFPA and ISO standards,
and there is no logical or technical reason to alter the test configuration. Until it can be
demonstrated in comparison testing that the two experimental configurations provide equivalent
results, it is dangerous to establish a MEC for Class A (and Class C) hazards based on the reported
HB-55 tests, as the MECs could actually be higher if established using the widely accepted, peer-
reviewed ISO/NFPA configuration. The ISO/NFPA configuration was employed for the
establishment of the Class A (and Class C) MEC for all of the agents currently listed in NFPA
2001, and it is curious as to why the test configuration was altered, as hundreds of tests have been
performed on NFPA 2001 clean agents employing the ISO/NFPA support rack.
Mark L. Robin, PhD

The Chemours Company

Report of the Technical Committee on Gaseous
Fire Extinguishing Systems
Certified Amending Motion No. 2001-5/2001-9
June 2021
The Report of the Technical Committee on Gaseous Fire Extinguishing Systems is
cycle of NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems. The revisions were
submitted to letter ballot of the Technical Committee in accordance with the Regulations
the next edition tab of the Document Information page for NFPA 2001 at nfpa.org/2001next.
Following is a chronology of events leading to the creation of Second Revision No. 24
(SR-24) and the adoption of clean agent HB-55 into the draft of NFPA 2001-2022.
Public Input was solicited by NFPA for the revision cycle of NFPA 2001. The closing date was
January 3, 2019. A clean agent manufacturer submitted Public Inputs requesting a new clean agent
with an agent designation, Halocarbon Blend 55 (HB-55), be added to the Standard. Words,
formula, and other values for the clean agent characteristics were proposed by specific paragraph.
A total of twelve Public Inputs (#’s 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, and 60) were submitted
pertaining to the inclusion of HB-55 into the standard.
The technical committee met April 24-26, 2019, in Memphis, Tennessee to consider all Public
Inputs and create a First Draft Report.
NFPA 2001-2018 paragraph 1.5 Safety and subsequent paragraph 1.5.1.1 states: “Any
agent that is to be recognized by this standard or proposed for inclusion in this standard shall first
be evaluated in a manner equivalent to the process used by the U.S. Environmental Protection
Agency (EPA) Significant New Alternatives Policy (SNAP) Program for total flooding agents.”

Summarizing portions of the US EPA SNAP webpage, the SNAP program is designed to:
• Identify and evaluate substitutes in end-uses that historically used ozone-depleting
substances
• Look at overall risk to human health and environment of both existing and new substitutes
• Publish lists of acceptable substitutes
EPA’s evaluation of each substitute in an end-use is based on the following types of information
and analyses:
• Atmospheric effects
• Exposure assessments
• Toxicity data
The submitter of the Public Input made a presentation to the Technical Committee and
explained they had made submittal to the EPA for SNAP approval but had not yet received
approval. A motion was made, seconded, discussed, and passed to reject all Public Inputs related
to HB-55 on the basis that the new clean agent did not have EPA SNAP approval per the
requirement of 1.5.1.1. It was explained to the technical committee by the NFPA Staff Liaison
that the topic would remain open and that the technical committee could review subsequent
information, if available, at the second draft meeting.
During the Public Comment period, the manufacturer submitted Public Comment No. 21
(PC-21), which provided an updated heptane cup burner concentration for the HB-55 clean agent.
The Second Draft meetings were held via Microsoft Teams over several sessions that took place
between September 9 and October 8, 2020.
For the discussion of PC-21, the US EPA’s technical committee member was present at
the meeting and confirmed that the HB-55 agent had been submitted, reviewed, and was

progressing toward approval but final SNAP approval would only be official when it is published
in the Federal Register. At the conclusion of the second draft meeting, EPA SNAP approval was
not final. A motion to create SR-24 was made, seconded, and passed. This global revision
incorporated all the information and data needed to support the use of HB-55 as a clean agent and
allowed the technical committee to vote separately on HB-55, without impacting other parts of the
standard.
The TC was made aware that the second draft ballot would be issued near the end of 2020.
If the EPA granted SNAP approval to HB-55 before the ballot due date, the committee members
would be notified and could consider this additional information before casting their vote on SR-
24.
Prior to the final ballot, HB-55 was granted SNAP approval under the trade name Solstice™
Quench 55 and was published in the Federal Register on December 11, 2020. The technical
committee was provided this information prior to final balloting.
The ballot closed on January 15, 2021. Of the 34 members eligible to vote, 24 voted
affirmative and 4 voted negative.
Brent Ehmke
on behalf of the Technical Committee on Gaseous Fire Extinguishing Systems

2021 Submitter Substantiations Committee Statements

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Motion Substantiation

Certified Amending Motion No. 10-5

Recommended Text if Motion Passes:

A.7.2.2 (5) To perform a monthly visual inspection, a stored-pressure extinguisher is removed

June 8, 2021 Submitter Substantiations and Committee Statements Page 1

A.7.2.2 (5) To perform a monthly visual inspection, a stored-pressure extinguisher is removed

June 8, 2021 Submitter Substantiations and Committee Statements Page 2

responsible Committee(s) in accordance with the Regulations Governing the Development of

Document Information page for NFPA 10 at www.nfpa.org/10next .

therefore would be better addressed editorially in the next edition.

sure an empty extinguisher, however the pressurization state was observed, is

replaced with an appropriate extinguisher. This information would not be presented

if the annex item is deleted as indicated by the amending motion.

recommendation to add a new sentence that reads as follows:

“A self‐expelling, cartridge-operated, or pump tank extinguisher’s fullness can be

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the TIA, the position of the committee is to oppose this motion.

with Comments, and 5 Not Returned.

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When high-flow multi-purpose (ABC) extinguishers are compared to their standard

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20# are used for this comparison:

the 20# standard flow models typically provide a 10A rating.

There is an appreciable and in fact detrimental difference in Class A extinguishment

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page for NFPA 10 at www.nfpa.org/10next .

information regarding extinguisher selection. It discusses a specific situation regarding the

challenging fire with no suggestion of how the situation may be addressed.

negative votes, the position of the committee is to oppose this motion.

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"Taylor, Lawrence M. I am not in favor of sprinklers anywhere in the elevator machine

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decision to increase safety.

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associated injuries and fatalities which was provided to the TC.

the sidewall pit sprinkler to activate.

associated fire alarm initiating devices located in those pits.

Vegas (See results for CAM 13-6)

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support of this proposal to increase safety for Fire Alarm personnel

requirement from NFPA 13 and increase safety.

elevator safety issues.

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Taylor's statement on SR 1105 Ballot:

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the sidewall pit sprinkler to activate”.

states and jurisdictions throughout the country.

1112 decision to increase safety.

David McColl, P. Eng.,

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The Report of the Technical Committee on Sprinkler System Installation Criteria is

hydraulic fluids was 23 affirmative and 9 negative votes.

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Subsection # 2 of 9.3.6.1 is proposed to be deleted since it is unnecessary to be included in

that these FAIDs are not required by the elevator code.

a CA amendment to NFPA 13. This deletion of Subsection # 2 will become effective in CA on

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smoke detectors in elevator spaces:

located in those hoistways NOTE [2.27.3.2.1(b)]: A machinery space containing a motor

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