The following paragraph appears in NFPA codes and standards published prior to 2015. It is located in the introductory text for the document, between the end of the Table of Contents and the beginning of Chapter 1.
"Changes, other than editorial, are indicated by a vertical rule beside the paragraph, table or figurein which the change occurred. These rules are included as an aid to the user in identifying changes from the previous edition. Where one or more complete paragraphs have been deleted, the deletion is indicated by a bullet (•) between the paragraphs that remain."
Now as jurisdictions are adopting 2015 and 2016 editions of NFPA codes and standards many are finding that the above paragraph has been removed. Along with that all those tell-tale vertical bars and bullets, those great harbingers of change; are gone. No longer will we be able to quickly get familiar with the revisions to a new edition of a standard simply by checking to see if there are any editorial bars.
Those editorial beacons used to be the first place I went to develop material on columns looking at changes to the new editions. My recent columns on changes to 13, 13D and 13R in the 2016 editions (See Plumbing Engineer issues of August, September and October) took many more hours to develop because those bars and bullets were absent.
Designers, contractors and AHJ’s will now need to find other ways to inform themselves of the important changes that have been made to the NFPA documents important to their work. Also, it is easy to imagine that conflicts will occur when one party or another is not familiar with a change.
Here is a hypothetical example from the jurisdiction of Frostbite Falls, now enforcing the 2016 edition of NFPA 13. The sprinkler contractor, R & B enterprises, has completed the preparation of sprinkler submittal for a 200,000 square foot warehouse. Recently,they were awarded the project, being the successful bidder. The project is design-build. The warehouse requires sprinkler protection in accordance with the most current edition of NFPA 13. The RFP indicates the warehouse will have double-row rack storage of Class IV commodities with a maximum storage height of 25 feet. Being sharp sprinkler people (at least The R of R&B is sharp) and understanding the owner would appreciate a sprinkler system that did not need to have in-rack sprinklers, R & B decided to go with an ESFR design from NFPA 13 (2016), “Table 220.127.116.11 Single- or Double-Row Racks of Class I Through Class IV Commodities Stored Over 25 ft (7.6 m) in Height with Aisles 4 ft (1.2 m) or More in Width.”
R & B was aware of paragraph 18.104.22.168, the existing prohibition against the use of this table when solid shelves were involved. They were also aware of new paragraph: 22.214.171.124.1 Where solid shelves are used, in-rack sprinklers shall be installed in every level below the highest solid shelf. What they failed to noticed was the subtle change to the title of that table. In the 2013 edition of NFPA 13 the table title is,
“Table 126.96.36.199 ESFR Sprinkler Protection of Rack Storage Without Solid Shelves of Class I Through Class IV Commodities Stored Up to and Including 25 ft (7.6 m) in Height.”
In the 2016 edition the phrase, “without solid shelves,” was removed.
You may think, “This is not significant; this is only editorial and besides paragraphs 188.8.131.52 and 184.108.40.206.1 caution us about solid shelves.”
Well, the problem lies in the revised definition of solid shelving. The criteria in the table does not just apply to racks without solid shelves, it may also apply to racks with open shelves that can be defined as solid shelves based on another subtle change to the definition of solid shelving. From the 2016 edition of NFPA 13 that definition is: 220.127.116.11* solid shelving. Shelving that is fixed in place, slatted, wire mesh or other type of shelves located within racks. The area of a solid shelf is defined by perimeter aisle or flue space on all four sides or by the placement of loads that blocks openings that would otherwise serve as the required flue spaces. Solid shelves having an area equal to or less than 20 square feet are defined as open racks. Shelves of wire mesh, slats or other materials more than 50 percent open and where the flue spaces are maintained, are defined as open racks.
What is different from the 2013 edition is the addition of the phrase, “or by the placement of loads that block openings that would otherwise serve as the required flue spaces.”
This now means that depending on where it is located in the rack, a stored commodity can determine whether that rack is open or has solid shelves. Not something that is easily enforceable, and may result in conservative judgments.
Mr. Peabody, the very Akamai plan reviewer in the Frostbite Falls Building Department, is also a very smart dog. He knows the changes to NFPA 13 quite well, having spent many hours educating himself on the 2016 edition. He is also very conservative when it comes to applying codes and standards and realizes that the new definition of solid shelves opens up any type of shelving to be classified as such. How is the warehouse owner/operator going to control the placement of stock with racks not defined as solid shelf storage? His decision is to rule that the racks are considered solid shelves.
Too bad for R&B, who bid the job based on compliance with the 2016 NFPA 13, but was unaware NFPA 13’s subtle shift towards a greater reliance of in-rack sprinklers. Had there been vertical bars perhaps R&B would still be solvent. Well, maybe they can make it up on the next job.
I’ve heard but not been able to confirm, that that the reason the codes and standards of NFPA don’thave the bars and bullets is because the software used to publish the documents doesn’t have that capability. If that is the case, it is my hope that NFPA takes steps to fix the software so it can give us users of those documents back that very convenient and helpful code application and enforcement feature.
I wonder what Steve Jobs would say if his staff told him that the first iPad had to have a USB connection.
Thank you all for spending some of your valuable time reading FPE Corner. Please have a wonderful and fire-safe Holiday Season.
Samuel S. Dannaway, P.E., is a registered fire protection engineer and mechanical engineer with bachelor’s and master’s degrees from the University of Maryland Department of Fire Protection Engineering. He is past president and a Fellow of the Society of Fire Protection Engineers. He is president of S. S. Dannaway Associates Inc., a 15-person fire protection engineering firm with offices in Honolulu and Guam. He can be reached via email at SDannaway@ssdafire.com.