88a A2018 Gar Aaa FD Piresponses
88a A2018 Gar Aaa FD Piresponses
88a A2018 Gar Aaa FD Piresponses
Remove the "Exception" text to be consistent with direction provided in the MOS.
The current language in 88A has numerous section that contain text written with an "Exception" type
format. This is inconsistent with the direction provided by the Manual of Style. These sections should
be rewritten as modifiers to the core section rather than exception text.
Submitter Full
ANTHONY APFELBECK
Name:
ALTAMONTE SPRINGS BUILDING/FIRE SAFETY
Organization:
DIVISION
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jul 10 15:00:29 EDT 2015
Committee Statement
NFPA 72® , National Fire Alarm and Signaling Code, 2013 edition.
NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition.
NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015
edition.
Committee Statement
Resolution: Reject as documents are not referenced in the body of the standard. The committee
suggests that the submitter resubmit as a Public Comment to be placed in Annex B if so
desired.
NFPA 72® , National Fire Alarm and Signaling Code, 2013 edition.
NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition.
NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015
edition.
Committee Statement
NFPA 72® , National Fire Alarm and Signaling Code, 2013 edition.
NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition.
NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015
edition.
NFPA 2 - This is the Hydrogen Technologies Code and is referred to in Chapter 7 of NFPA 88A (by a
separately submitted PI). NFPA 2 addresses the parking of hydrogen fuel cell vehicles in parking
garages and confirms that no additional requirements beyond those needed for gasoline or diesel
fueled cars are needed. Adding this reference improves correlation.
NFPA 88A Public Input Report Page 7 of 37
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National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...
Committee Statement
Date updates
Committee Statement
Building Code.
The building code enforced by the jurisdiction or agency enforcing this standard.
Add a definition of building code and related Annex material similar to that used in the Life Safety
Code.
Committee Statement
Resolution: The committee did not include this term in the body of the standard and therefore this
definition can't be used per MOS.
5.2.1
Those parts of parking structures located within, immediately below, attached to, or less than 3
m (10 ft) from a building used for any other purpose shall be separated by walls, partitions,
floors, or floor–ceiling assemblies having fire resistance ratings of not less than 2 hours, unless
otherwise permitted by 5.2.2 or the building code .
NFPA 5000, as well as other nationally-recognized building codes, all have well established
requirements for the protection of multiple occupancies within a structure. These include both
separated occupancy approaches, with fire resistive barriers between the uses, as well as
nonseparated or mixed occupancy approaches, where the entire building is essentially designed to
the most restrictive requirements of the occupancies involved. NFPA 88A should not prohibit any of
these approaches to multiple occupancies.
Committee Statement
5.5.1
Each parking level shall have wall openings open to the atmosphere, for an area of not less
than 0.4 m2 for each linear meter (1.4 ft2 for each linear foot) of its exterior perimeter.
DELETE.
PROPOSED SUBSTITUTION: 5.5.1 For natural ventilation purposes, the exterior side of the
structure shall have uniformly distributed openings on two or more sides. The area of such
openings in exterior walls on a tier shall be not less than 20 percent of the total perimeter wall
area of each tier.
Glenwood Springs, Colorado has a newly constructed two-tier parking structure. The City specified
an open parking structure. The architect provided sufficient wall openings to meet NFPA No 88A, but
not sufficient openings to comply with the IBC. The structure now has $235,000 in a sprinkler system,
a dry standpipe, and a ventilation system.
The IBC and the IFC require approximately 50 percent larger area of wall openings than NFPA.
The IFC and the IBC Section 406.5.2 Openings and the NFPA No 88A must use identical language in
the definition of an open parking structure to avoid confusion.
Committee Statement
5.5.2
Such openings shall be distributed over 40 percent of the building perimeter or uniformly over
two opposing sides.
DELETE.
PROPOSED SUBSTITUTION: 5.5.2 The aggregate length (total of widths) of the openings
considered to be providing natural ventilation shall be not less then 40 percent of the perimeter
of the tier.
Exception: Openings are not required to be distributed over 40 percent of the building
perimeter where the required openings are uniformly distributed over two opposing sides of the
building.
Glenwood Springs, Colorado, has a newly constructed two-tier parking structure. The City specified
an open parking structure. The architect provided sufficient wall openings to meet NFPA No 88A, but
not sufficient openings to comply with the IBC. The structure now has $235,000 in a sprinkler system,
a dry standpipe, and a ventilation system.
The IBC and the IFC require approximately 40 percent greater aggregate length (total of widths) of
wall openings.
The IFC and the IBC Section 406.5.2 Openings and the NFPA No 88A must use identical language in
the definition of an open parking structure to avoid confusion.
Committee Statement
5.5.3
Interior wall lines and column lines walls shall be at least 20 percent open, with openings
distributed to provide ventilation.
The intent of the section is to provide openness for ventilation in walls, not wall lines or column lines.
Committee Statement
6.4.3
Automatic sprinkler systems shall be installed in enclosed parking structures located at or
above grade, or within or immediately below a building used for another occupancy.
Exception: Enclosed parking structures described above, having an approved, supervised,
automatic fire detection and alarm system installed throughout the parking area in accordance
with NFPA 72 and a mechanical ventilation system in accordance with 5 6 .3 . 2.
The current 5.3.2 references a section related for floor drains. It appears the intent is to reference
section 6.3 but that is unclear as that section does not provide justification for the elimination of the
fire sprinkler system. Regardless, the reference citation needs to be corrected.
Submitter Full
ANTHONY APFELBECK
Name:
ALTAMONTE SPRINGS BUILDING/FIRE SAFETY
Organization:
DIVISION
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jul 10 15:09:56 EDT 2015
Committee Statement
6.4.3
Automatic sprinkler systems shall be installed in enclosed parking structures located at or
above grade, or within or immediately below a building used for another occupancy.
Exception: Enclosed parking structures described above, having an approved, supervised,
automatic fire detection and alarm system installed throughout the parking area in
accordance with NFPA 72 and a mechanical ventilation system in accordance with 5.3.2 .
The exception does not appear to have any technical basis for the specified protection package in lieu
of the presence of fire sprinkler protection. An equivalency or technical justification for an equivalency
is not provided by the detection and mechanical reference.
Submitter Full
ANTHONY APFELBECK
Name:
ALTAMONTE SPRINGS BUILDING/FIRE SAFETY
Organization:
DIVISION
Street Address:
City:
State:
Zip:
Submittal Date: Fri Jul 10 15:16:02 EDT 2015
Committee Statement
6.4.3
Automatic sprinkler systems shall be installed in enclosed parking structures located at or
above grade, or within or immediately below a building used for another occupancy.
Exception: Enclosed parking structures described above, having an approved, supervised,
automatic fire detection and alarm system installed throughout the parking area in accordance
with NFPA 72 and a mechanical ventilation system in accordance with 5.3.2 . (Errata 6.3).
PROPOSED: DELETE the Exception .
An automatic fire detection and alarm system should not be a substitution for a sprinkler system,
especially under these circumstances.
Committee Statement
6.6.1
Where provided, fire detection and alarm systems shall conform to NFPA 72.
PROPOSED: Remove itallics from NFPA 72.
ERRATA
Committee Statement
6.6.2
An approved, supervised, automatic fire detection and alarm system shall be installed in
enclosed parking structures having a mechanical ventilation system, located at or above grade,
or within or immediately below a building used for another occupancy.
Exception: Enclosed parking structures described above in 6.6.2, having an approved
automatic sprinkler system installed throughout in accordance with NFPA 13.
PROPOSED SUBSTITUTION: 6.6.2 Exception: Enclosed parking structures described
above, having a sprinkler system installed in accordance with NFPA 13.
Simpler wording. All sprinkler systems shall conform to NFPA No 13, and are automatic.
Committee Statement
6.6.2
An approved, supervised, automatic fire detection and alarm system shall be installed in
enclosed parking structures having a mechanical ventilation system, located at or above grade,
or within or immediately below a building used for another occupancy .
Exception: Enclosed parking structures described above in 6.6.2, having an approved
automatic sprinkler system installed throughout in accordance with NFPA 13.
Committee Statement
Resolution: The committee concludes that it wants to retain the current language
6.6.4 Maintenance.
Fire alarm systems shall be regularly inspected, tested, and maintained in accordance with
NFPA 72.
PROPOSED: Remove italics from NFPA 72.
ERRATA
Committee Statement
Resolution: Reject. Editorial will make corrections per the NFPA MOS.
The NFPA Standards committee decided that the requirements for hydrogen storage, use, and fueling
in parking structures and all other buildings. are contained only in NFPA 2 and nowhere else. .
Therefore, the proposed text provides a reference to NFPA2 for the storage.
Committee Statement
Statement: The NFPA Standards committee decided that the requirements for hydrogen storage,
use, and fueling in parking structures and all other buildings. are contained only in NFPA
2 and nowhere else. . Therefore, the text provides a reference to NFPA2 for the storage.
7.1.4
The storage, use, handling, and dispensing of hydrogen fuels shall conform to NFPA 1 and
NFPA 2.
Because hydrogen is also a fuel this adds NFPA 2 which contains the requirements for dispensing of
hydrogen as a fuel. Also adds NFPA 1 to the list of requirements for this new section.
This is needed because adding fueling of any type to a parking garage (typically a storage occupancy)
can have an impact on the occupancy classification, required operational permits, and needed
protection measures that are best invoked, enforced, administered and inspected through a fire
prevention code. Adding NFPA 1 to the list of required documents invokes these requirements.
Committee Statement
NFPA 2 addressed the issue of parking FCEVs in parking garages in the 2016 edition and concluded
that no additional requirements are needed. This text clarifies that conclusion. The text from the 2016
editions of NFPA 2 is extracted. The new proposed Annex note explains the practice of using
brackets [ ] in the extracted text. This is the approach taken for extracts in NFPA 2 where not all of the
extract is applicable but the benefit of retaining the extract tag outweighs the option of dropping the
extract tag and revising the text to fit better with NFPA 88A scope.
Committee Statement
7.1.1
The storage, use, handling, and dispensing of flammable or combustible liquids shall conform to
NFPA 1, NFPA 30 and NFPA 30A.
Adds NFPA 1 to the list of requirements for NFPA 88A 7.1.1. Not sure Terra did legislative format
correctly.
This is needed because adding fueling of any type to a parking garage (typically a storage occupancy)
can have an impact on the occupancy classification, required operational permits, and needed
protection measures that are best invoked, enforced, administered and inspected through a fire
prevention code. Adding NFPA 1 to the list of required documents invokes these requirements.
Committee Statement
7.1.2
The storage, use, handling, and dispensing of liquefied petroleum gas shall conform to NFPA 1
and NFPA 58.
Adds NFPA 1 to the list of requirements for NFPA 88A 7.1.2. Not sure Terra did legislative format
correctly.
This is needed because adding fueling of any type to a parking garage (typically a storage occupancy)
can have an impact on the occupancy classification, required operational permits, and needed
protection measures that are best invoked, enforced, administered and inspected through a fire
prevention code. Adding NFPA 1 to the list of required documents invokes these requirements.
Committee Statement
7.1.3
The storage, use, handling, and dispensing of natural gas fuels shall conform to NFPA 1 and
NFPA 52.
Adds NFPA 1 to the list of requirements for NFPA 88A 7.1.3. Not sure Terra did legislative format
correctly.
This is needed because adding fueling of any type to a parking garage (typically a storage occupancy)
can have an impact on the occupancy classification, required operational permits, and needed
protection measures that are best invoked, enforced, administered and inspected through a fire
prevention code. Adding NFPA 1 to the list of required documents invokes these requirements.
Committee Statement
9.2.2.1
Access shall be provided in accordance with Table 40.2.5.2.1 of NFPA 101 except that the 560
mm (22 in.) minimum dimensional criteria shall be changed to 915 mm (36 in.) in all locations in
the table.
PROPOSED: Remove italics from 101.
ERRATA
Committee Statement
9.2.2.3
Travel distance to the exterior or to an enclosed stair shall not exceed 122 m (400 ft) comply
with NFPA 101 or NFPA 5000 .
The provisions would be consistent with other NFPA documents by referencing the provision in NFPA
101 or NFPA 5000 for travel distances.
Committee Statement
Resolution: Reject. Reject. NFPA 88A is a standalone. This is a different type of use than in the
Building Code.
Building Code.
Where no building code has been adopted, NFPA 5000, Building Construction and Safety
Code , should be used where the building code is referenced in this standard.
Add Annex material to reference NFPA 5000 if no other building code is adopted.
Committee Statement
A.4.1.5
Exit travel distance is measured in accordance with NFPA 101 and includes the distance
measured along the plane of the tread nosings in open stairs .
The current Annex note is not consistent with NFPA 101. Note that NFPA 101-2015, Paragraph
42.8.2.6.2 (2) states that the travel distance along an open stair in an open parking structure is not
limited.
Committee Statement
A.4.1.5
Exit travel distance is measured in accordance with NFPA 101 and includes the distance
measured along the plane of the tread nosings in open stairs. . To be deleted to be consistent
with NFPA 101:42.8.2.6.2(2).
The travel distance measurement in open parking structure will be in consistent with both NFPA 101:
42.8.2.6.2(2) and NFPA: 88A: A.4.1.5.
Committee Statement
A.4.1.5
Exit travel distance is measured in accordance with NFPA 101 and includes the unlimited
travel distance measured along the plane of the tread nosings in open stairs.
The Annex material is no longer accurate. Since 2009, NFPA 101 has allowed unlimited travel
distance on the open stairways within open parking structures.
Committee Statement
Public Input No. 12-NFPA Referenced current SDO names, addresses, standard
88A-2015 [Chapter 2] names, numbers, and editions.
Committee Statement