Voting Guide for the 2024 NFPA Technical Meeting

In preparation for the 2024 NFPA Technical Meeting in Orlando, AFSA’s Technical Advisory Council has reviewed the posted Certified Amending Motions (CAM) for the relevant standards on the A2024 and F2023 revision cycles and is providing this voting guide to aid our members attending the Technical Meeting.

NFPA 13, Standard for the Installation of Sprinkler Systems

This CAM moves to reject SCR-3. If the CAM passes, section 1.2.2 will utilize the term “qualified personnel” in lieu of “knowledgeable and trained personnel.”

Using the terms “qualified” or “knowledgeable and trained” may seem like semantics, but it is important to choose our words carefully when dealing with enforceable documents. Where a term is used in an NFPA document and not specifically defined in Chapter 3, the definition comes from its ordinarily accepted meaning within the context in which it is used. Outside of NFPA 13, the term “qualified” is defined as “fitted (as by training or experience) for a given purpose.” This definition is inclusive of the language already chosen by the technical committee and requires no further action.

This CAM moves to reject SR-1015. If the CAM passes, the definition of “Qualified Personnel” will be re-inserted into chapter 3.

As currently presented in the second draft report of the 2025 edition of NFPA 13, the term “qualified personnel” is not used in the document. The proposed language of the CAM defines “qualified personnel” as a “competent and capable individual having met the requirements and training for a given field acceptable to the AHJ.” A seemingly benign definition has great implications when the language is dissected. Qualified, by itself, is synonymous with “training and experience,” but the inclusion of “acceptable to the AHJ” at the end of the definition greatly changes how that definition is applied. Typically, qualifications are determined by individual jurisdictions through legislative actions requiring some kind of licensure, certification, or training by the company or individual to perform work in that jurisdiction. These laws create enforceable criteria known by those doing work in the jurisdiction and can be applied equally. With the inclusion of “acceptable to the AHJ” at the end of the definition, this now provides an avenue for any AHJ to circumvent the legislative process and inconsistently arbiter the required training and experience needed to install and design sprinkler systems.

This CAM moves to reject SR-1079. If the CAM passes, the requirement to provide an approved storage floor plan with the working plans and hydraulic calculations will be removed from Chapter 28.

The approved storage floor plan includes information about the building that the party developing the shop drawings and working plans would not easily have at their disposal. While the language is extracted from NFPA 1 Fire Code, the inclusion of this provision in Chapter 28 for sprinkler system plans and calculations only confuses the issue of who’s responsibility it is to provide this document. The requirements of the Fire Code are enforceable through the building owner. The specific items needed for the approved storage floor plan are already identified in Chapter 4 under the Owner’s Certificate requirements and needs to be handled by the owner or their designated representative upon completion of the sprinkler system, not during the review of working plans and hydraulic calculations. This requirement should remain in the fire code and not be included in the requirements for plans and calculations.

This CAM moves to accept part of CC-1055. If the CAM passes, section 29.1.2 will be modified to state the approval of the sprinkler system can be “performed” remotely in accordance with NFPA 915, instead of “witnessed” remotely in accordance with NFPA 915.

Section 29.1.2 deals with the APPROVAL of the sprinkler system. Approval is given by the AHJ. The role of the AHJ in the acceptance testing process is to WITNESS tests not to PERFORM them. This section has nothing to do with remote inspections and distance monitoring, and the action taken by the correlating committee to use the term “witnessed” was the correct action to take.

This CAM moves to reject SCR-17. If the CAM passes, suggested design criteria for car stackers will be re-inserted in the annex of Chapter 10 Installation of Standard Spray Sprinklers.

The current outlook on the protection schemes appropriate for parking structures and car stackers is uncertain. There is an ongoing project with the Fire Protection Research Foundation that is looking to determine the proper design criteria for parking structures. That project is still in its early phases and has yet to provide any technically substantiated recommendation for appropriate protection schemes. The other concern with the inclusion of this language is that it is a discharge criteria recommendation hidden in an installation requirement chapter. While the stricken annex text suggests installing sidewall sprinklers below each car stacker, what would the required density be? What about the end head pressure or the maximum area of coverage? All of these questions need to be answered before it is provided as a recommendation in NFPA 13. The classification of an occupancy or hazard needs to stay within the realm of engineering judgment and not provided as an unsubstantiated recommendation by the installation standard.

This CAM moves to reject SR-1122. If the CAM passes, the definition of “Automated Inspection and Testing” will be re-inserted into Chapter 3.

The definition was removed by the correlating committee stating that the term was not used within the body of NFPA 13. This statement was incorrect, and the term is actually used in section 29.2.7. Since the term is used in the document, it should be re-inserted by approving this CAM.

This CAM moves to accept PC-214. If the CAM passes, the qualifications for a flexible coupling used for seismic protection will be added to Chapter 18.

The definition of “flexible coupling” — currently under the scope of the installation committee and not the hanging and bracing committee — includes the minimum flexibility criteria to be used in seismic applications. This CAM simply takes those requirements and includes them in Chapter 18 for better visibility.

This CAM moves to accept PC-213. If the CAM passes, the definition of “flexible coupling” would be simplified to apply to any listed coupling whether it is used in a seismic application or not.

While couplings with lesser degrees of flexibility should be permitted to be used in areas where seismic protection is not required, the change in the definition is not necessary at this stage in the revision cycle process. The only other use of the term “flexible coupling” outside of the Chapter 18 requirements for seismic protection are for the flexible connection permitted to attach an air supply to a dry or preaction sprinkler system. The current definition is appropriate until NFPA 13 better addressed flexible couplings used in non-seismic designs.

NFPA 20, Standard for Installation of Stationary Pumps for Fire Protection

This CAM moves to accept PC-29. If the CAM passes, the horsepower rating on fire pump motors would only need to be sized based off of the 200 percent capacity of the pump.

The required power to operate a fire pump is not a novel concept to the Technical Committee on Fire Pumps and has been debated for two cycles in a row. In the 2022 revision cycle PIs-91, 92, 93, 94, and 95 were submitted to limit the motor capacity to be rated up to 175 percent of pump’s capacity. These were resolved with the statement that standard requires non-overloading across the entire pump curve. Based on that action, the committee wants a pump to be able to perform past the available water supply and cavitate the suction supply lines and destroy the fire pump. This is not reasonable.

When the topic was brought up again this cycle, the initial proposal looked to revise the requirement to assign the horsepower rating based on 175 percent capacity of the pump. This achieved a majority during the first draft meeting, but ultimately failed letter ballot (21 affirmative/ 12 negative) and resulted in CI-66 in the first draft report. A public comment was submitted addressing all of the negative votes.

The response to the technical committee’s negative votes made four technical points while taking into consideration their concern about safety factor by proposing the horsepower rating to be based on 200 percent capacity of the pump instead of 175 percent:

• It is not reasonable to expect a fire pump to maintain performance if an underground main ruptures. In fact, it could be argued that it would not be beneficial for the fire pump to continue to run during this catastrophic event due to the risk of additional water damage and damage to the foundation and structure of a building depending on the proximity of the break. In any event, the pump running during this event is not providing fire protection.
• Issues were raised with correlating with other sections. Corresponding PCs have been submitted to address the correlation issue.
• This revision would have no effect on the pump performance during a “normal fire event.” Sprinkler systems are calculated with at least a 50% safety margin for storage applications and demands that surpass what has been hydraulically calculated would exceed the design criteria from multiple full-scale fire tests that are used to determine the discharge criteria
• One negative comment indicated that the “maximum pump load” was the 150% capacity duty point. This would clarify that interpretation and provide a prescriptive data point to derive the horsepower rating.

Despite the technical rebuttal, the public comment was rejected but held citing there was not sufficient data to act, and no technical reason was provided for the rejection. Based on this action, the committee was able to punt action on this issue without refuting any technical argument made in the public comment. The action of “reject but hold,” given the history of this issue, should not have been in order. Why can the mechanical components of a fire pump cavitate, be destroyed, and are considered disposable, but the electric components must be indestructible. This is not reasonable.

On the manufacturing side, the current requirement rewards an inefficient design. To obtain a lower horsepower rating, the pump impellers will be manufactured to sharply cut off after 150% capacity is reached. For existing fire pumps installed under prior edition of NFPA 20 that need replacement, many require an upsizing of the electrical service and wiring to meet the horsepower rating based on the maximum capacity of the pump — even when the fire pump is being replaced in kind! These are not good practices or reasonable requirements.

The current requirement grossly over-sizes the power requirements for fire pumps. Pumps are only permitted to utilize up to 150 percent capacity for fire protection design and past that point the liquid supply could be insufficient. Flows beyond 200 percent capacity of the pump are indicative of an abnormal or catastrophic event that are not within the purview of NFPA 20 to mitigate. The purpose of NFPA 20 is to provide a reasonable degree of protection and mandating that a fire pump motor and controller must be indestructible is not reasonable.

NFPA 150, Fire and Life Safety in Animal Housing Facilities Code

This CAM moves to reject SR-12. If the CAM passes, the standard will be silent on the sprinkler requirements for Class A facilities with an animal size threshold of a Medium Concentrated Animal Feeding Operation.

The action taken by the technical committee provides a practical approach to protect life and property for these facilities. Sprinklers would provide the appropriate level of protection and the language presented in the second draft report permits other options of with an equivalent level of safety where acceptable to the AHJ.

Other CAMs

NFPA 13, NFPA 20, and NFPA 150 are not the only standard being debated at the NFPA Technical Meeting, but they are the only standards directly relevant to our membership. AFSA encourages NFPA members in attendance to listen to the debate on the other CAMs to cast an informed vote.

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ABOUT THE AUTHOR:

Kevin Hall, M.Eng., P.E., ET, CWBSP, PMSFPE, is the senior manager of engineering and technical services for the American Fire Sprinkler Association (AFSA). He is a member of several National Fire Protection Association (NFPA) technical committees responsible for developing the model codes and standards, including, NFPA 1 Fire Code, NFPA 13/13R/13D Installation of Sprinkler Systems, NFPA 20 Installation of Stationary Fire Pumps for Fire Protection, NFPA 25 Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, and NFPA 200 Hanging, Bracing, and Anchorage of Water-Based Fire Protection Systems. He also represents AFSA on numerous UL technical committees responsible for revising and maintaining the product standards used in the sprinkler industry. He is a registered professional engineer in Delaware and Maryland, NICET III certified in water-based system layout, a certified water-based system professional through NFPA, and a professional member of the Society of Fire Protection Engineers (SFPE). He earned his Bachelor of Science and Master of Engineering degrees from the University of Maryland College Park in fire protection engineering. In 2021, he was recognized as one of SFPE’s “5 Under 35” award recipients. Prior to his association and committee work, he worked for Reliance Fire Protection in Baltimore, Maryland as a project manager overseeing projects of various sizes and complexity.

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