Document 65dLEEEZZOkaaGYb2pKxG9Eoo

%/m P(^1X4 "fa 3 technical services inc. August 14, 1991 failure analysis product development graphics technology software development Mr. A1 Reventas Shintech, Inc. #24 Greenway Plaza, Suite 811 Houston, TX 77046 REF: 88-076 - VINYL INSTITUTE CODES Dear Al, As a follow-up to my earlier letter relating to the twelve ICBO code change proposals having potential impact on Vinyl Institute member companies, only three code change proposals out of the twelve submittals we identified are on the challenge agenda. They are Items #192, #193, and #269. (See original text & challenge text attached). It is our opinion that the challenges to Items #192 and #193 will probably fail while Item #269 will probably pass. Code Change items #192 and #193 propose to eliminate a requirement for "suitable fire stops" in fire-rated walls and ceilings when "fire sprinklers and attachments" penetrate only a single member. ICBO staff criticizes the vagueness of the proposal and properly so. If the proponent responds to this analysis with an amendment specifying what hardware is allowed to penetrate, they could succeed. Reasoning is that a metal pipe or support hangers that would be no larger in area than the specified 100 square inches could be directly related to the acceptable steel electrical outlet boxes. If an amendment spells out such material, then it would be difficult to oppose especially when the sprinkler system is an added safeguard. CTL026973 PHONE 41S S48-34S! FAX S48 0290 2322 SIXTH STREET SUITE 107 BERKELEY CALIFORNIA 94710 USA Mr. AI Reventas August 14, 1991 Page Two Challenges to Code Change Item #292 attempt to correlate the proposed Uniform Mechanical Code Standard No. 10-3, Test Method For Fire and Smoke Characteristics of Electrical Cable and Plastic Sprinkler Pipe with UL Standard No. 910. Since the proponent and UL both submitted the same request, it places credibility on the proposal. The challenges describe the plastic pipe test samples and how they are placed on the tray. This change stands a good chance of passage. Sincerely yours, Joseph a. Zicherman President JBZ:smI 88076-10.Lsl Attachments cc: R. Gottesman - w/a CTL026974 hallways or comdors. There is also a technical problem w-nh Section 3802 (h). There are quick-response sprinklers and there are standard sprinklers. There is not. however, a quick-response standard sprinkler. A quick-response sprinkler is now defined as a fast-response version (standard) sprinkler. The code as cur rently written requires a sprinkler that is not manufactured. |84--Membership Action A A/R A/A FS D 192--Membership Action A A/R A/A FS D 192--As Submitted 4304 (f)-91-1--N.F.S.A.--[F.R.A.] Sec. 4304 (0. Revise the first sentence of the first paragraph as fol lows: Walls may have openings for fire sprinklers and attachments, and steel electrical outlet boxes not exceeding 16 square inches in area, pro vided the aggregate area of such openings is not more than 100 square inches for any 100 square feet of wall or partition area. Reason: Approval of this change would allow the penetration through a single membrane of a fire-resistant-rated wall assembly by fire spnnklers and their attachments. This would also eliminate the requirement for rated sealant around the actual sprinkler. There is no eudence that penetrations of a single membrane by a fire spnnkler has created any problem m a fire situation. A simi lar proposal has been submitted to allow this exemption for rated ceiling assem blies. Analysis! Section -304 lei. hem 1. now allows sprinkler piping to penetrate a membrane of a fire-resisnve wall when suitable fire stops are used. The pro posed change would allow omission of any fire stop when the opening is for "fire sprinklers and attachments." What is a suitable fire stop would depend on the depose of the wall and its construction. For example, if a wall is an occupancy ^paration in which openings are required to be protected, the fire slop should maintain the integrity of the wall. If the wall is not required to have opening pro tection. suitable protection could consist of the traditional escutcheon covering a minimum-sized opening. The wording "fire sprinklers and attachments" is \ague and may not accomplish the proponent's intent. Is "attachments" the pip ing for the sprinkler? Allow ing omission of all fire stopping does not seem appro priate. 192--Committee Action 4304 (f)-91-1--N.F.S.A. Disapproval Reason! Section 4304 (ft allows spnnkler piping to penetrate a membrane of a fire-resism e wall when suitable fire stops are used. The proposed change would allow omission of any fire stop when the opening is for "fire spnnklers and attachments." What is a suitable fire stop would depend on the purpose of the w all and its construction. For example, if a w all is an occupancy separation in which openings are required to be protected, the fire stop should maintain the integrity of the wall. If the wall is not required to hate opening protection, suit able protection could consist of the traditional escutcheon covering a mini mum-sized opening. The w ording "fire spnnklers and attachments" is vague and may not accomplish the proponent's intent. Are "attachments" the piping for the sprinkler? Allowing omission of all fire stopping does not seem appropnate. 193--As Submitted 4305 (b)-91-1--N.F.S.A.--{F.R.A.] Sec. 4305 (b). Revise Exception 1 as follows: Openings for noneembustible sprinkler pipe Sprinklers and attach ments and openings for steel electrical___ (Balance of exception to re main unchanged.) Reason: Approval of this change would allow the penetration through a single membrane of a fire-resistant-rated ceiling assembly by fire spnnklers and their attachments. Tnis would also eliminate the requirement for rated sealant around the actual sprinkler. There is no evidence that penetrations of a single membrane by a fre sprinkler have created any problem in a fire situation. A simi lar proposal has been submitted to allow this exemption for rated ceiling wall as semblies. Analysis: See analysis to code change 4304 (f)-9l-l. 193--Committee Action 4305 (b)-91-1--N.F.S.A. Reason: See reason for code change 4304 (f)-91 -1. Disapproval 193--Challenge National Fire Sprinkler Association requests Approval as Re vised. Revision: Sec. 4305 tb), page 699. Revise Exception 1 as follows: Openings for noncombustible sprinkler pipe, fire sprinklers and at tachments and openings for steel electrical outlet boxes .... (Balance to remain unchanged.) Reason: It was never the intent to permit the penetration of the spnnkler pip ing through the ceiling membrane as the proposal as submitted indicated. It is the intent that noncombustible spnnklers and their noncombustible attachments be allowed to peneirate the ceiling assembly. Currently the code allows up to 100 square inches per 100 square feet of sieel elecincal outlet boxes to penetrate a rated floor-ceiling assembly in a nonsprinklered building. Allowing noncombusuble fire spnnklers and iheir attachments to be included in this same 100 square inches in a fully sprinklered building appears to be at least as safe. 193--Membership Action A A/R A/A FS D 192--Challenge National Fire Sprinkler Association requests Approval. Reason: It is unclear why the committee denied this change. The proposal does not expand the allow able 16 square inches of unprotected penetrations cur rently allowed (for elecincal outlet boxes) in a nonspnnklered building. The change would only allow up to 16 square inches of unprotected openings, includ ing the sprinklers and attachments, in a sprinklered building. 194--As Submitted (See Committee Action) 194--Committee Action 4306-91-1--T.C.C. Approval Sec. 4306 (a). Revise as follows: Where required by this code for the fire protection of openings, fire resistive assemblies shall meet the requirements of this chapter sec tion. 60 CTL026975 Development Committee in preparing a broader-based code change to address * makeup air for wideT application. 268--Challenge No. 3 ^^Arizona Chapter requests Disapproval. ^BReason: The proposal is redundant and proposes an inappropriate w ay to pro^Pwe makeup air. Makeup air should be provided, but needs vary with each instal- lauon and cannot be addressed with a cookbook remedy for combustion air. 268--Challenge No. 4 Northwest chapters request Disapproval. Reason: It appears to apply to both domestic and commercial dryers when in serted in the U.M.C. where proposed. If makeup air is an issue, w hy is it limited to closets and confined spaces and not merely included as a reo.uirement for in stallation regardless of location within the building? The requirement is unclear in regards to opening requirements. Is it included in the opening provided for combusnon air, or is it in addition to that? 268--Membership Action A A/R A/A FS D 269--As Submitted M-A-10-3*91-1--B.F.G.--[Mech.] U.M.C. Standard No. 10-3. Revise as follows: 1. Revise heading as follows: IFORM MECHANICAL CODE STANDARD NO. 10-3 TEST METHOD FOR FIRE AND SMOKE CHARACTERISTICS OF ELECTRICAL CABLE AND PLASTIC SPRINKLER PIPE Based on Standard No. 910, 4532 1935 and Standard No. 1887. ~' of Underwriters Laboratories Inc. See Section '002, Uniform Mechanical Code 2. Sec. 10.301. Revise as follows: This is a test method for determining values of flame distance and smoke density for exposed electrical and plastic sprinkler pipe that are to be installed in concealed spaces above suspended ceilings used as air plenums without the cabies being enclosed in racew ays in those spaces. The purpose of this test method is to determine whether the flame- prop agation and smoke-generating characteristics of these cables without raceways and the plastic sprinkler pipe are in accordance with the provi sions of Exception 6 qlI to Uniform Mechanical Code Section 1002 (a). 3. Sec. 10.302. Revise as follows: This test method does not cover the construction or performance re quirements for cables or their eleeerieal and ether penenwancc require ments sprinkler pipe, nor does it covenhc electrical requirements of the cables. 4. Sec. 10.303. Revise paragraphs 4. 9,15 and 16 as follows: ... comparable to the following: Maximum effective temperature--1.200F. Bulk density--42-5 21.0 1.5 lbm/ft.3 Thermal conductivity--0.50-0.71 Btuinch per hoursquare foot* t 300-700cF. .. A draft-gauge manometer to indicate static pressure shall be con nected in the vent pipe upstream ef the damper and the pheioeleetrie eell opening inserted through the top at the midwidth of the tunnel, iust downstream of the air-intake shutter. .. . below the top surface of the gasketing tape and within 1.0 foot of the-vent end of the test chamber at the center of the-width ef the chamber 23 feet ' /- inch from the centerline of the burner pons and at the center of the width of the chamber. A No. 18 AWG thermocouple (nominal wire cross section of 1620 CM) embedded 0.125 inch below the floor surface of the test chamber shall be mounted in refractory or portland cement at distances of 13.5 and 3-45 23.0 feet from the fire end of the test chamber burner nons. 5. Sec. 10.304. Revise the heading as follows: Test Specimens--Cables 6. Sec. 10-305. Add a new Section 10.305 as follows and renumber remaining sections accordingly: Test Specimens--Pipe Sec. 10.305. One single 24.0-foot length of plastic sprinkler pipe shall be installed in the bonom of the tray. The specimen shall be lard in the center of the tray. The pipe specimen shall be placed on a mesh screen tn the tray. The mesh screen snail be galvanized ware cloth with 0.047-inch wire diameter and having 0.75-inch openings. The length of pipe is to be fastened to the screen with fasteners as described in the next paragraph. Bare copper tie wires not larger than No. 18 AWG (nominal wire cross section of 1620 CM) may be used to fasten the specimen to the mesh screen and rungs of the tray wherever a tie is necessary to keep a speci men in contact with the rung and to minimize movement during the test. A tie is not to be used in any manner that alters the ability ofthe specimen to transmit gases and/or vapor longitudinally through the core of the specimen. 6. Sec. 10.306 (new Section 10.307). Revise the second and fourth paragraphs as follows-. The furnace shall be preheated and cooled as described in Section 10.305$. The test equipment shall be adjusted and conditioned as described in Section 10.3056.with the open cable test specimens in place. 7. Sec. 10.307 (new Section 10.308). Revise Item 7 as follows: 7. For electrical cable ?the weight of nonmetallic components .... (Balance of item to remain unchanged.) 8. Sec. 10.308 (new Section 10.309). Revise as follow's: To be acceptable for installation exposed in concealed space above suspended ceilings used as air plenums, electrical cable and plastic sprinkler pine shall: (Balance of section to remain unchanged.) Reason: To update the standard 10 reflect wording in the current edition of UL 910 and incorporate provisions for testing plastic sprinkler pipe (per UL 1SS7; which uses the same test chamber, test procedure and acceptance cmena. Sec tion 1002 (a). Exception 7, was added to the Uniform Mechanical Code in Sep tember !9S9. This would eliminate an inconsistency between the Uniform Building Code and U.M.C. Standard No. 10-3. Analysis: None. 269--Committee Action M-A-10-3-91-1--B.F.G. Approval as Revised U.M.C. Standard No. 10-3. Rev ise as follows: 1. Revise heading as follows: UNIFORM MECHANICAL CODE STANDARD NO. 10-3 TEST METHOD FOR FIRE AND SMOKE CHARACTERISTICS OF ELECTRICAL CABLE AND PLASTIC SPRINKLER PIPE Based on Standard No. 910, 4332 1985 and Standard No. 1887,1989, of Underwriters Laboratories Inc. See Section 1002, Uniform Mechanical Code 2. Sec. 10.301. Revise as follows: This is a test method for determining values of flame distance and smoke density for exposed electrical cables and plastic sprinkler rioe that are to be installed in concealed spaces above suspended ceilings 156 CTL02697 6 used as air plenums without the cables being enclosed in raceways in ihose spaces. The purpose of this test method is to determine whether the flame-propagation and smoke-generating characteristics of these cables without raceways and the plastic sprinkler pipe are in accordance with the provisions of Exception 6 or 7 to Uniform Mechanical Code Section 1002 (a). 3. Sec. 10.302. Revise as follows: This test method does not cover the construction or performance re quirements for cables or their-eieetrcal end other performance requifemerHS sprinkler oice. nor does it cover the electrical requirements of the cables. 4. Sec. 10.303. Revise paragraphs 4, 9,15 and 16 as follows: ... comparable to the following: Maximum effective temperature--1.200F. Bulk density--1-St5 21.0 w 1.5 Ibm/ft.3 Thermal conductivity--0.50-0.71 3tutnch per hoursquare foot* CF. at 300CF. to 700F. ... .A draft-gauge manometerto indicate static pressure shall be con nected in th-e-vent-pipe upstream of the dampef^nd the photoelectric cell opening inserted through the top at the rnidwidth.of the. mnnsLJua downstream of the air-intake shutter. . . . below- the top surface of the gasketing tape and within 1.0 foot-ef the vent end-af the test chamber at the center of the w idth of the chamber 23 feet -inch from the centerline of the burner pons and at the center of the width ot the chamber. A No. 18 AW'G thermocouple (nominal wire cross section of 1620 CM) embedded 0.125 inch below the floor surface of the test chamber shall be mounted in refractory or portland cement at distances of 13.5 and 23 0 feet from the fire end of the tc-.it chamber burner pons. 5. Sec. 10.304. Reuse the heading as follows: Test Specimens--Cables 6. Sec. 10.305. Add a new Section 10.305 as follows and renumber remaining sections accordingly: Test Specimens--Pipe Sec. 10.305. Plastic sprinkler pipe shall be installed to fill the bottom of the tray. The pipe specimens shall be placed on a mesh screen in the tray. The mesh screen shall be galvanized w ire cloth with 0.047-inch wire diame ter and ha\ mg 0.75-inch openings. The length of pipe is to be fastened to the screen with fasteners as described in the next paragraph. Bare copper tie wires not larger than No. 18 AWG (nominal wire cross section of 1620 CM) may be used to fasten the specimen to the mesh screen and rungs of the tray wherever a tie is necessary to keep a speci men in contact with the rung and to minimize movement during the test. A tie is not to be used in any manner that alters the ability of the specimen to transmit gases or sapor longitudinally through the core of the speci men. 7. Sec. 10.306 (new Section 10.307). Revise the second and fourth paragraphs as follows: The furnace shall be preheated and cooled as described in Section I0.305fi. The test equipment shall be adjusted and conditioned as described in Section 10.3056.with the open cable test specimens in place. 8. Sec. 10.307 (new Section 10.308). Revise Item 7 as follows: 7. For electrical cable Tthe weight of nonmetallic components (Balance of item to remain unchanged.) 9. Sec. 10J08 (new Section 10.309). Revise as follows: To be acceptable for installation exposed in concealed space above suspended ceilings used as air plenums, electrical cable and plastic sprinkler pipe shall: (Balance of section to remain unchanged ) samnReeewasaovn:asEfloerctfririceatlecsatibnlge. aAndtepnldaestniccyp"i.poecrsehao.eulsd ph,?. ? ^ should be resisted. ***.iai for product 269--Challenge No. 1 B. F. Goodrich Company requests Approval as Revised witli fur ther revision. Revision: Sec. 10.305 of the proposal. Revise as follows: Test Specimens--Pipe Sec. 10.305. One single 2-UO-fQQl lsnsih-0f plastic sprinkler pipe shall be installed fa fill in the bottom of the tray. The-SPgcimen shall be laid in the center of the trav. The pipe specimens-shall be placed on a mesh screen in the trav. (Balance to remain unchanged.) Reason: Changes made by the committee are not appropriate for the follow ing reasons: 1. This introduces test conditions that are inconsistent with those of ihe CL 1SS7 standard referenced in the heading. Therefore. CL-listed plenum cables would be acceptable, but CL-listed fire sprinkler pipe would not be acceptable. 2. The CL investigation ihat lead to their report and the CL 1S87 standard in cluded tunnel tests on pipe water filled and empiv. In addition, a full-scale ple num test was run in which wood cnb fires were built directly under the 3-inch pipe. 3. In :he CL 1SS7 tests with 3-inch pipe. 45 pounds of plastic pipe were ex posed in an 13-inch-wide tunnel with gas jets below and all the smoke was col lected and measured. Alien compared with an actual fire sprinkler system in a light-hazard occupancy. :he runnel contained more than 25 times as much com bustible material per square foot of ceiling area than an actual plenum would have. 269--Challenge No. 2 Underwriters Laboratories Inc. requests Approval as Revised with further revision. Revision: Sec. 10.305 of the proposal. Revise as follows: Sec. 10.305. One single 24.0-foot length of plastic sprinkler pipe shall be installed ta-fill ia the bottom of the tray. The specimen shall be laid in the center of the trav. The pipe specimens-shail be placed on a mesh screen in the tray. (Balance to remain unchanged.) Reason: The use of a single length of plastic pipe as the sample for the UL 1SS7 lest technically is substantiated based on results of a UL Fact-Finding Pro gram (EX36-18, S6NK2409). This program consisted of full-scale simulated airhandling plenum fire tests and tests ustng the UL 1887 procedure. The installation of spnnkJer piping in the full-scale test was representative of current field practice, which is one main line and several branch lines, as re quired. T> pically, sprinkler piping is not installed in groups with minimum dis tance between branch lines specified in NFPA 13. A positive relationship was obtained between the results of the full-scale tests and the UL 1887 test with a single length sample. Accordingly, it is appropriate to maintain the single length sample as described in UL 1887 when investigating plastic sprinkler pipe for flame and smoke characteristics. 269--Membership Action A A/R A/A FS D CTL026977 157