M E M O R A N D U M
DATE:
February 20, 2015
TO:
Principal and Alternate Members of the Technical Committee on Electronic
Computer System (ELT-AAA)
FROM:
Jon Hart, Fire Protection Engineer/NFPA Staff Liaison
SUBJECT:
AGENDA PACKAGE– NFPA 75 Second Draft Meeting (F2015)
________________________________________________________________________
Enclosed is the agenda for the NFPA 75 Second Draft meeting of the Technical Committee on
Electronic Computer Systems, which will be held on Monday, March 23, 2015 and Tuesday,
March 24, 2015, at the Holiday Inn – Houston Northwest Willowbrook, in Houston, TX.
Please review the attached comments in advance, and if you have alternate suggestions, please
come prepared with proposed language and respective substantiation.
If you have any questions prior to the meeting, please do not hesitate to contact me at:
Office: (617) 984-7470
Email:
[email protected]
For administrative questions, please contact Elena Carroll at (617) 984-7952.
I look forward to working with everyone.
(ELT-AAA)
NFPA 75 Second Draft Meeting (Fall 2015)
Monday, March 23, 2015 through Tuesday, March 24, 2015
Holiday Inn – Houston Northwest Willowbrook
18818 Tomball Parkway, Houston, TX 77070
AGENDA
Monday, March 23, 2015 – Tuesday, March 24, 2015
Call to Order of NFPA 75 First Draft Meeting
Chairman Comments
Introductions and Attendance
Approval of Previous Meeting Minutes
Staff Liaison Presentation
Preparation of the Second Draft
Address the 3 Larger Topical Issues from Comments (See Handout)
Review Public Comments
Create Second Revisions
New Business
Adjournment
Wednesday, March 25, 2015 – HP Facility Tour
Please submit requests for additional agenda items to the chair and staff liaison at least
seven days prior to the meeting.
(ELT-AAA)
NFPA 75 Second Draft Meeting (Fall 2015)
Monday, March 23, 2015 through Tuesday, March 24, 2015
Holiday Inn – Houston Northwest Willowbrook
18818 Tomball Parkway, Houston, TX 77070
Key Dates for the Fall 2015 Revision Cycle
Public Input Closing Date
January 3, 2014
Final Date for First Draft Meeting
June 13, 2014
Final First Draft Posted
September 5, 2014
Public Comment Closing Date
November 14, 2014
Final Date for Second Draft Meeting
May 1, 2015
Posting of Second Draft and Ballot
June 12, 2015
Final Second Draft Posted
July 17, 2015
NITMAM Closing Date
August 21, 2015
Issuance of Document with No NITMAM November 10, 2015
NFPA Annual Meeting (Las Vegas)
June 2014
(ELT-AAA)
NFPA 75 Second Draft Meeting (Fall 2015)
Monday, March 23, 2015 through Tuesday, March 24, 2015
Holiday Inn – Houston Northwest Willowbrook
18818 Tomball Parkway, Houston, TX 77070
Note from the Staff Liaison
Dear Technical Committee Members:
We are very pleased that you will be participating in the processing of the 2016 Edition of NFPA
75, Standard for the Fire Protection of Information Technology Equipment. Development of this
document would not be possible without the participation of volunteers like you.
Meeting Preparation
Committee members should review the published Public Comments prior to the meeting and to be
prepared to act on each item.
Handout materials should be submitted to the chair and staff liaison at least seven days prior to the
meeting.
Only one posting of the Public Comments will be made; it will be arranged in section/order and
will be pre-numbered. This will be posted to the NFPA 75 Document Information page
(
www.nfpa.org/75
) under the “Next Edition” tab. If you have trouble accessing the website please
contact Elena Carroll at
[email protected]
.
Mandatory Materials:
Last edition of the standard
Meeting agenda
Public Comments
Committee Officers' Guide (Chairs)
Roberts’ Rules of Order (Chairs; An abbreviated version may be found in the
Committee Officer’s Guide)
Optional Materials:
NFPA Annual Directory
NFPA Manual of Style
(ELT-AAA)
NFPA 75 Second Draft Meeting (Fall 2015)
Monday, March 23, 2015 through Tuesday, March 24, 2015
Holiday Inn – Houston Northwest Willowbrook
18818 Tomball Parkway, Houston, TX 77070
Regulations and Guiding Documents
All committee members are expected to behave in accordance with the Guide for the Conduct of
Participants in the NFPA Codes and Standards Development Process.
All actions during and following the committee meetings will be governed in accordance with the
NFPA Regulations Governing the Development of NFPA Standards. Failure to comply with these
regulations could result in challenges to the standards-making process. A successful challenge on
procedural grounds could prevent or delay publication of the document.
The style of the document must comply with the Manual of Style for NFPA Technical Committee
Documents.
(ELT-AAA)
NFPA 75 Second Draft Meeting (Fall 2015)
Monday, March 23, 2015 through Tuesday, March 24, 2015
Holiday Inn – Houston Northwest Willowbrook
18818 Tomball Parkway, Houston, TX 77070
General Procedures for Meetings
Use of tape recorders or other means capable of producing verbatim transcriptions of any
NFPA Committee Meeting is not permitted.
Attendance at all NFPA Committee Meetings is open. All guests must sign in and identify
their affiliation.
Participation in NFPA Committee Meetings is generally limited to committee members
and NFPA staff. Participation by guests is limited to individuals, who have received prior
approval from the chair to address the committee on a particular item, or who wish to speak
regarding public proposals or comments that they submitted.
The chairman reserves the right to limit the amount of time available for any presentation.
No interviews will be allowed in the meeting room at any time, including breaks.
All attendees are reminded that formal votes of committee members will be secured by
letter ballot. Voting at this meeting is used to establish a sense of agreement, but only the
results of the formal letter ballot will determine the official action of the committee.
Note to Special Experts: Particular attention is called to Section 3.3(e) of the NFPA Guide
for the Conduct of Participants in the NFPA Codes and Standards Development Process in
the NFPA Directory. This section requires committee members to declare any interest they
may represent, other than their official designation as shown on the committee roster. This
typically occurs when a special expert is retained by and represents another interest
category on a particular subject. If such a situation exists on a specific issue or issues, the
committee member shall declare those interests to the committee and refrain from voting
on any action relating to those issues.
ELT-AAA
Ralph E. Transue
Chair
JENSEN HUGHES
82 North West Road
Lombard8, IL 60148-2118
Alternate: James R. Lugar
SE 8/5/2009
ELT-AAA
Scott R. Lang
Secretary
Honeywell International
System Sensor Division
3825 Ohio Avenue
St. Charles, IL 60174
Automatic Fire Alarm Association, Inc.
Alternate: Max McLeod
M 10/20/2010
ELT-AAA
Mark J. Aaby
Principal
Koffel Associates, Inc.
8815 Centre Park Drive, Suite 200
Columbia, MD 21045-2107
Alternate: William E. Koffel
SE 08/09/2012
ELT-AAA
Wayne J. Aho
Principal
Xtralis, Inc.
175 Bodwell Street
Avon, MA 02322-1122
M 10/27/2009
ELT-AAA
Alastair R. Brown
Principal
Rushbrook Consultants, Ltd.
216 West George Street
Glasgow, G2 2PQ Scotland
SE 7/12/2001
ELT-AAA
Thomas M. Burke
Principal
UL LLC
455 East Trimble Road
San Jose, CA 95131-1230
Alternate: Kerry M. Bell
RT 1/1/1991
ELT-AAA
Thomas G. Deegan
Principal
The Viking Group, Inc.
3033 Orchard Vista SE, Suite 308
Grand Rapids, MI 49546
National Fire Sprinkler Association
Alternate: James Archer
M 7/12/2001
ELT-AAA
Jeffry T. Dudley
Principal
National Aeronautics & Space Administration
503 Glenbrook Circle
Rockledge, FL 32955
U 10/20/2010
ELT-AAA
Ronald A. Durgin
Principal
Mohave County Development Services
3250 East Kino Avenue
PO Box 7000
Kingman, AZ 86402-7000
E 07/29/2013
ELT-AAA
Edward S. Goldhammer
Principal
Qualcomm
5775 Morehouse Drive
San Diego, CA 92121-1714
U 03/03/2014
ELT-AAA
Lee A. Kaiser
Principal
Orr Protection Systems, Inc.
11601 Interchange Drive
Louisville, KY 40229
IM 8/9/2011
ELT-AAA
Stanley Kaufman
Principal
CableSafe, Inc./OFS
PO Box 500082
Atlanta, GA 31150-0082
Society of the Plastics Industry, Inc.
ELT-AAA
Chad Mariska
Principal
APS Fire
400 North Walnut Street
Broken Arrow, OK 74012-2353
National Association of Fire Equipment Distributors
Alternate: William D. Johnson
IM 08/11/2014
ELT-AAA
Stephen McCluer
Principal
APC by Schneider Electric
3903 Walden Way
Dallas, TX 75287-4918
Alternate: Vince Hawxhurst
U 10/23/2003
ELT-AAA
Tina R. Nelissen
Principal
Amerex Corporation
PO Box 17908
Anaheim, CA 92817
Fire Equipment Manufacturers' Association
Alternate: Derek P. Wester
M 08/09/2012
ELT-AAA
Michael Paras
Principal
Environmental Systems Design, Inc.
175 West Jackson Blvd., Suite 1400
Chicago, IL 60604
Alternate: Jocelyn Sarrantonio
SE 08/09/2012
ELT-AAA
Keith J. Polasko
Principal
US National Security Agency
9800 Savage Road, ATTN: M445/SAB1
Fort Meade, MD 20755-6000
E 1/1/1993
ELT-AAA
Jack Poole
Principal
Poole Fire Protection, Inc.
19910 West 161st Street
Olathe, KS 66062-2700
SE 03/05/2012
ELT-AAA
Bryan K. Powell
Principal
XL Global Asset Protection Services
10112 Lindsay Meadow Drive
Mechanicsville, VA 23116
Alternate: Steven M. Guthrie
I 10/20/2010
ELT-AAA
Brian P. Rawson
Principal
International Business Machines (IBM)
61 Wellingwood Drive
East Amherst, NY 14051-1744
U 7/24/1997
ELT-AAA
Rodger Reiswig
Principal
Tyco/SimplexGrinnell
3640 Haddington Court
Apopka, FL 32712-5690
M 08/11/2014
ELT-AAA
Mark L. Robin
Principal
DuPont Fluoroproducts
107 Saint Andrews Court
Middletown, DE 19709
Fire Suppression Systems Association
Alternate: Robert J. Ballard
U 03/05/2012
ELT-AAA
Patrick S. Saba
Principal
Hewlett Packard Company
1707 Ritchie Highway
Annapolis, MD 21409
U 10/18/2011
ELT-AAA
Joseph A. Spataro
Principal
Liberty Mutual Commercial Markets
135 Dalton Drive
Buffalo, NY 14223
I 10/1/1993
ELT-AAA
Mark Suski
Principal
Aon Fire Protection Engineering Corporation
4 Overlook Point
Lincolnshire, IL 60069-4302
I 10/27/2009
ELT-AAA
Randy Willard
Principal
US Central Intelligence Agency
3960 Point of Rocks Road
Jefferson, MD 21755
Alternate: Stacie K. Tunnessen
ELT-AAA
Thomas J. Wysocki
Principal
Guardian Services, Inc.
111 Luther Lane
Frankfort, IL 60423
SE 1/1/1988
ELT-AAA
David Zolotar
Principal
Oracle America, Inc.
Product Safety Engineering
500 Eldorado Boulevard
Mail Stop UBRM05-223
Broomfield, CO 80021
Information Technology Industry Council
M 4/4/1997
ELT-AAA
Robert Kasiski
Voting Alternate
FM Global
1151 Boston Providence Turnpike
PO Box 9102
Norwood, MA 02062-9102
Voting Alt to FM Rep.
I 8/9/2011
ELT-AAA
Robert V. Scholes
Voting Alternate
Fireman's Fund Insurance Company
16200 Pacific Highway, Unit 26
Lake Oswego, OR 97034
Voting Alt. to FFIC rep.
I 9/30/2004
ELT-AAA
James Archer
Alternate
National Fire Sprinkler Association, Inc.
42 Blueberry Lane
Stormville, NY 12582
National Fire Sprinkler Association
Principal: Thomas G. Deegan
M 03/05/2012
ELT-AAA
Robert J. Ballard
Alternate
Victaulic Company of America
PO Box 31
Easton, PA 18044-0031
Fire Suppression Systems Association
Principal: Mark L. Robin
M 03/05/2012
ELT-AAA
Kerry M. Bell
Alternate
UL LLC
333 Pfingsten Road
Northbrook, IL 60062-2096
Principal: Thomas M. Burke
RT 4/1/1993
ELT-AAA
Steven M. Guthrie
Alternate
XL Global Asset Protection Services
1328 Airport Road
Coatesville, PA 19320
Principal: Bryan K. Powell
I 10/29/2012
ELT-AAA
Vince Hawxhurst
Alternate
APC Corporation
85 Rangeway Road
North Billerica, MA 01862
Principal: Stephen McCluer
U 10/29/2012
ELT-AAA
William D. Johnson
Alternate
Mid State Fire Equipment Inc.
297 Washington Blvd. NE
Lake Placid, FL 33852-8801
National Association of Fire Equipment Distributors
Principal: Chad Mariska
IM 08/11/2014
ELT-AAA
William E. Koffel
Alternate
Koffel Associates, Inc.
8815 Centre Park Drive, Suite 200
Columbia, MD 21045-2107
Principal: Mark J. Aaby
SE 08/09/2012
ELT-AAA
James R. Lugar
Alternate
JENSEN HUGHES
14502 Greenview Drive, Suite 500
Laurel, MD 20708
Principal: Ralph E. Transue
ELT-AAA
Max McLeod
Alternate
Siemens Industry, Inc.
285-A Cahaba Valley Parkway North
Pelham, AL 35124
Automatic Fire Alarm Association, Inc.
Principal: Scott R. Lang
M 10/20/2010
ELT-AAA
Jocelyn Sarrantonio
Alternate
Environmental Systems Design, Inc.
175 West Jackson Blvd., Suite 1400
Chicago, IL 60604-2766
Principal: Michael Paras
SE 10/28/2014
ELT-AAA
Stacie K. Tunnessen
Alternate
US Central Intelligence Agency
NHB 5X62
Washington, DC 20505
Principal: Randy Willard
U 08/09/2012
ELT-AAA
Derek P. Wester
Alternate
Amerex Corporation
7595 Gadsden Highway
PO Box 81
Trussville, AL 35173-0081
Fire Equipment Manufacturers' Association
Principal: Tina R. Nelissen
M 10/29/2012
ELT-AAA
Edward D. Leedy
Member Emeritus
2033 Butterfly Lane, CC304
Naperville, IL 60563
SE 1/1/1978
ELT-AAA
Donald E. Reilly
Member Emeritus
36 Delafield Avenue
Staten Island, NY 10301
I 1/1/1984
ELT-AAA
Jonathan Hart
Staff Liaison
National Fire Protection Association
1 Batterymarch Park
Quincy, MA 02169-7471
Technical Committee
Distribution
Ronald A. Durgin
Mohave County Development
Services
E
Principal
Keith J. Polasko
US National Security Agency
E
Principal
2
Voting Number Percent
7%
Bryan K. Powell
XL Global Asset Protection Services
XLGAPS
I
Principal
Joseph A. Spataro
Liberty Mutual Commercial Markets
I
Principal
Mark Suski
Aon Fire Protection Engineering
Corporation
AON
I
Principal
Robert Kasiski
FM Global
FM
I
Voting Alternate
Robert V. Scholes
Fireman's Fund Insurance Company
I
Voting Alternate
5
Voting Number Percent
17%
Lee A. Kaiser
Orr Protection Systems, Inc.
IM
Principal
Chad Mariska
APS Fire
NAFED
IM
Principal
2
Voting Number Percent
7%
Scott R. Lang
Honeywell International
AFAA
M
Secretary
Wayne J. Aho
Xtralis, Inc.
M
Principal
Thomas G. Deegan
The Viking Group, Inc.
NFSA
M
Principal
Stanley Kaufman
CableSafe, Inc./OFS
SPI
M
Principal
Tina R. Nelissen
Amerex Corporation
FEMA
M
Principal
Rodger Reiswig
Tyco/SimplexGrinnell
TYCO
M
Principal
David Zolotar
Oracle America, Inc.
ITIC
M
Principal
7
Voting Number Percent
23%
Thomas M. Burke
UL LLC
UL
RT
Principal
1
Voting Number Percent
3%
Ralph E. Transue
JENSEN HUGHES
SE
Chair
Mark J. Aaby
Koffel Associates, Inc.
SE
Principal
Alastair R. Brown
Rushbrook Consultants, Ltd.
SE
Principal
Michael Paras
Environmental Systems Design, Inc.
SE
Principal
Jack Poole
Poole Fire Protection, Inc.
SE
Principal
Thomas J. Wysocki
Guardian Services, Inc.
SE
Principal
6
Voting Number Percent
20%
Jeffry T. Dudley
National Aeronautics & Space
Administration
U
Principal
Edward S. Goldhammer
Qualcomm
U
Principal
Stephen McCluer
APC by Schneider Electric
U
Principal
Brian P. Rawson
International Business Machines
(IBM)
U
Principal
Mark L. Robin
DuPont Fluoroproducts
FSSA
U
Principal
Patrick S. Saba
Hewlett Packard Company
U
Principal
Randy Willard
US Central Intelligence Agency
U
Principal
7
Voting Number Percent
23%
30
Tuesday Thursday April 22-24, 2014
Holiday Inn Inner Harbor Baltimore; Baltimore, MD
1. Call to Order
The meeting of the Technical Committee on Electronic Computer Systems at the
Holiday Inn Inner Harbor Baltimore in Baltimore was called to order by Chair, Ralph
Transue at 1:30 PM on Tuesday, April 22, 2014.
2. Introduction of Committee Members and Guests
Self introductions of members and guests were completed. Those present are indicated
below:
Name
Representing
Transue, Ralph Chair
The RJA Group, Inc.
Spataro, Joe Secretary
Liberty Mutual Insurance
Aaby, Mark Principal
Koffel Associates, Inc.
Aho, Wayne Principal
Xtralis, Inc.
Archer, James Alternate to T. Deegan
National Fire Sprinkler Association
Ballard, Robert Alternate to M. Robin
Fire Suppression Systems Association
Crowder, Vincent Principal
Deegan, Thomas Principal
National Fire Sprinkler Association
Durgin, Ronald Principal
Mohave County Development Services
Goldhammer, Edward Principal
Qualcomm
Kaiser, Lee Principal
Orr Protection System s, Inc.
Kasiski, Robert Voting Alternate
FM Global
Kaufman, Stanley Principal
Society of the Plastics Industry, Inc.
Lang, Scott Principal
Automatic Fire Alarm Association, Inc.
McCluer, Stephen Principal
APC by Schneider Electric
McLeod, Max Alternate to S. Lang
Automatic Fire Alarm Association, Inc.
Nelissen, Tina Principal
Polasko, Keith Principal
US National Security Agency
Poole, Jack Principal
Poole Fire Protection, Inc.
Powell, Bryan Principal
XL Global Asset Protection Services
Rawson, Brian Principal
International Business Machines (IBM)
Robin, Mark Principal
Fire Suppression Systems Association
Saba, Patrick Principal
Hewlett Packard Company
Schwartz, William Alternate to J. Spataro Liberty Mutual Insurance
Suski, Mark Principal
Aon Corporation
Tunnessen, Stacie Alternate to R. Willard US Central Intelligence Agency
Willard, Randy Principal
US Central Intelligence Agency
Zolotar, David Principal
Information Technology Industry Council
Hart, Jonathan NFPA Staff Liaison
National Fire Protection Association
Quirk, David Guest
DLB Associates
Schlasser, Brian Guest
EBL Engineers
3. Announcements
procedures,
rules, and regulations. Key dates for the 2015 Fall Revision Cycle were discussed.
Amanda Kimball with the NFPA Research Foundation discussed their role with the NFPA &
NFPA Technical Committees, research functions, losses, studies, etc.
Status on work by the Joint Task Group consisting of NFPA 75 & NFPA 76 technical
committee members and non-committee / general industry representatives for high air
velocity air and aisle containment was provided during the Joint NFPA 75 & 76 TC Meeting
from 8:00 AM 12:00 PM on Tuesday, April 22, 2014. Also, a presentation of preliminary
findings from Hughes Associates on the Fire Protection Research Foundation project:
Validation of Modeling Tools for Detection in High Air Flow Environments was provided.
4. Approval of Minutes
The minutes of the April 14-15, 2011 ROC Meeting held at the Doubletree Hotel in Dallas,
TX were approved without changes.
5. Chairman Comments
Ralph Transue discussed
TC
Members dated April 18, 2014.
Ralph Transue led open, extensive discussions to determine if our Standard is responsive to
modern data centers of today (i.e. has it kept with modern data centers, etc.), Equivalences,
Risk Analysis and the Performance-Based Approach. TC also discussed the status of the
high air velocity air and aisle containment research, preliminary conclusions,
recommendations and Public Input; which resulted inclusion of a mention of aisle
containment in 8.2.1 with Annex material and a new Annex E.
Ralph Transue distributed a 3-page handout titled Summary of Prescriptive Requirements of
NFPA 75 2013 Edition and open discussion followed.
6. Task Group Reports
Joint Task Group consisting of NFPA 75 & NFPA 76 technical committee members and
non-committee / general industry representatives for high air velocity air and aisle containment
will continue with new Chair, Patrick Saba. Timothy Carman Principal representing Tyco
Fire Suppression & Building Products has been added to this joint task group.
New electrical task group has been formed with Chair, Ralph Transue, Tom Burke (UL
LLC), Stan Kaufman, Stephen McCluer, Brian Rawson and Joe Spataro to address two (2)
objectives in the short term. First, examine and revise the text of 10.3 and 10.4 to use
consistent circuit and wire descriptions that harmonizes with the NEC without changing the
content of 10.3 and 10.4. Second, prepare suggestions to the committee for simplification of
the electrical requirements of Chapter 10 in a
technical committee has indicated it wants in NFPA 75 by prior and current actions. Longer
term, the electrical task group may prepare Input to CMP-12 from NFPA 75 as may become
appropriate.
New task group has been formed with Chair, Patrick Saba, Lee Kaiser, Mark Aaby, Keith
Polasko, Brian Rawson, Timothy Carman (Tyco Fire Suppression & Building Products),
Mark Suski and Robert Kasiski to address the technical committee adding a statement that
the scope of NFPA 75 include modular Information Technology Equipment (ITE) containers
or PODS, since the NEC has a new article covering modular ITE containers or PODS.
7. Action on Public Inputs
The committee resolved the 71 public inputs that were received by providing a committee
statement of creating a corresponding first revision (FR). Several other FRs were developed
and one additional committee input was generated. Refer to F2015 First Draft and First Draft
Report for specific actions taken on each.
8. Old Business
There was no old business.
9. New Business
Discussed next TC meeting which is tentatively planned for early March 2015 in Houston,
TX or another location in the Southern portion of the US. One day will be a joint meeting of
NFPA 75 & 76 Technical Committees which will potentially include a tour of a Hewlett
Packard Company data center and a presentation from FM Research on the full-scale testing
that did on aisle containment fire detection.
10. Adjournment
Public Comment No. 3-NFPA 75-2014 [ Section No. 2.3.1 ]
2.3.1 ASTM Publications.
ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2007 2014 . ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750°C, 1999 2012 . ASTM E814, Standard Method of Fire Tests of Through-Penetration Fire Stops, 1997 2013a .
ASTM E1537, Standard Test Method for Fire Testing of Upholstered Furniture, 2007 2013 .
ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-Shaped Airflow Stabilizer, at 750°C, 2012.
Statement of Problem and Substantiation for Public Comment
date updates
Related Item
Public Input No. 5-NFPA 75-2013 [Section No. 2.3.1]
Submitter Information Verification
Submitter Full Name:Marcelo Hirschler
Organization: GBH International
Street Address: City:
State: Zip:
Public Comment No. 40-NFPA 75-2014 [ Section No. 3.3.16.2 ]
3.3.16.2 Limited-Combustible Material.
A material not meeting the definition for noncombustible material and that, in the form in which it is used, exhibits a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg) where tested in accordance with NFPA 259; and either has a structural base of a noncombustible material with a surfacing not exceeding a thickness of 1⁄8 in. (3.2 mm) where the surfacing exhibits a flame spread index not greater than 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials , or ANSI/UL 723, Standard for
Test for Surface Burning Characteristics of Building Materials, or is composed of materials that, in the form and thickness used, exhibit neither a
flame spread index greater than 25 nor evidence of continued progressive combustion when tested in accordance with ASTM E84 or ANSI/UL 723 and of such composition that all surfaces that would be exposed by cutting through the material on any plane would exhibit neither a flame spread index greater than 25 nor evidence of continued progressive combustion when tested in accordance with ASTM E84 or ANSI/UL 723. (see 6.1.2)
Statement of Problem and Substantiation for Public Comment
I understand the committee's reluctance but the NFPA Manual of Style does not allow references to standards or codes in definitions because definitions are not enforceable. That s why other codes and standards, like NFPA 101 and NFPA 5000 moved the definitions. Adding a new subsection to the section on building construction is a simple way to resolve this problem. This addresses the definition of limited combustible material because it was added by the technical committee. See also explanation in public comment and public input 9.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 36-NFPA 75-2014 [New Section after 6.1] Public Comment No. 42-NFPA 75-2014 [Section No. 3.3.16.3]
Related Item
Public Input No. 7-NFPA 75-2013 [Section No. 3.3.16] Public Input No. 9-NFPA 75-2013 [New Section after 6.1]
Submitter Information Verification
Submitter Full Name:Marcelo Hirschler Organization: GBH International
Street Address: City:
Zip:
Public Comment No. 42-NFPA 75-2014 [ Section No. 3.3.16.3 ]
3.3.16.3 Noncombustible Material.
A material that, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat, or a material that is reported as passing ASTM E136, Standard Test Method for Behavior of
Materials in a Vertical Tube Furnace at 750°C, or a material that is reported as complying with the pass/fail criteria of ASTM E136 when tested in accordance with the test method and procedure in ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a
Cone-Shaped Airflow Stabilizer, at 750°C. (see 6.1.1)
Statement of Problem and Substantiation for Public Comment
See explanation in associated public comments 36 and 40 and public input 9.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 36-NFPA 75-2014 [New Section after 6.1] Public Comment No. 40-NFPA 75-2014 [Section No. 3.3.16.2]
Related Item
Public Input No. 9-NFPA 75-2013 [New Section after 6.1]
Submitter Information Verification
Submitter Full Name:Marcelo Hirschler Organization: GBH International Street Address:
City: State: Zip:
Public Comment No. 19-NFPA 75-2014 [ Section No. 4.1 ]
4.1
4.1.2
Fire Risk Analysis Factors.
The fire protection for information technology equipment, information technology rooms, and information technology equipment areas shall be determined based on an evaluation of fire risks and hazards associated with the site and services provided and the business continuity planning and disaster restoration capabilities of the information technology equipment service provider specific to the site.
4.1.1
The fire protection shall be established with consideration given to the following factors:
(1) Exposure threat to facility occupants, the general public, emergency responders, and exposed property from a fire occurring at the facility, adjacent to, or within the information technology areas
(2) The importance of the continuity of the data being stored or processed by the information technology equipment
(3) Methods and equipment employed, as part of a risk management or business continuity strategy, that allow data to remain viable during and after an event or to be replaced or restored
(4) The potential for a given protection strategy to result in a service or data disruption or inhibit the ability of the data provider to restore operation and access to the data in a timely manner post-event
4.1.1* A fire risk analysis shall be permitted to be used to determine
the construction, fire protection ,
and fire detection , and utility
requirements for information technology equipment, information technology rooms, and information technology
equipment areas
where specifically permitted by Chapters
5 and 8.
4.1.
3*
2 The fire risk analysis conducted in 4.1. 2
1 shall be documented
and acceptable to the authority having jurisdiction .
4.1.
4
The fire risk analysis shall include an evaluation of the risk management considerations as outlined in Section 4.2.
3* The following factors shall be considered to determine the level of acceptable fire risk (see also Annex C) :
(1) Life safety aspects of the function (e.g., process controls, air traffic controls)
(2) Fire threat of the installation to occupants or exposed property
(3) Economic loss from loss of function or loss of records (4) Economic loss from value of equipment
(5) Regulatory impact (6) Reputation impact
(7) Redundant off-site processing systems
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. This problem is resolved by the Comment which is to delete the entirety of First Revision 1 and replace it with the text in the current edition of NFPA 75.
Related Item
First Revision No. 1-NFPA 75-2014 [Section No. 4.1]
Submitter Information Verification
Submitter Full Name:Mark Robin
Affilliation: Fire Suppression Systems Association
Street Address: City:
State: Zip:
Public Comment No. 9-NFPA 75-2014 [ Section No. 4.1 [Excluding any Sub-Sections] ]
The fire protection for information technology equipment, information technology rooms, and information technology equipment areas shall be determined permitted to be determined based on an evaluation of fire risks and hazards associated with the site and services provided and the business continuity planning and disaster restoration capabilities of the information technology equipment service provider specific to the site. Fire protection based on risk assessment shall be at least equivalent to the fire protection specified in Chapter 9.
Statement of Problem and Substantiation for Public Comment
As proposed in the first draft, this paragraph would require fire protection to be based on risk assessment for the specific site. Users of the standard should have the option of using the prescriptive measures of the standard as set forth in Chapter 9 to determine the fire protection requirements for a site. Further fire protection based on risk assessment should be at least equivalent to the minimum protection required by Chapter 9.
Related Item
First Revision No. 1-NFPA 75-2014 [Section No. 4.1]
Submitter Information Verification
Submitter Full Name:Thomas Wysocki
Organization: Guardian Services, Inc. Street Address:
City: State: Zip:
Public Comment No. 20-NFPA 75-2014 [ Section No. 4.2 ]
4.2 Risk Considerations. 4.2.1*
The following elements shall be considered to determine the level of acceptable fire risk documented as part of the risk analysis (see also
Annex C):
(1) Life safety aspects of the function (e.g., process controls, air traffic controls) (2) Fire threat of the installation to occupants or exposed property
(3) Continuity of service, operation, and data access (4) Size and value of the information technology areas (5) Economic loss from loss of function or loss of records (6) Economic loss from value of equipment
(7) Regulatory impact (8) Reputation impact
(9) Construction and compartmentation of the information technology equipment areas
(10) Fire protection and detection features provided for the information technology equipment areas (11) Response time to an alarm
(12) Local fire-fighting capabilities
(13) Redundant infrastructure, including off-site processing systems
(14) Life safety of occupants of information technology equipment areas and adjacent spaces, emergency responders, and general public 4.2.2
The fire risk analysis shall cover the entire information technology equipment area, including all adjacent exposures. 4.2.3
The fire protection approach shall be developed in conjunction with the considerations in 4.2.1 resulting in the use of one or both of the following strategies for areas within the information technology equipment area:
(1) Prescriptive-based approaches in accordance with this standard (2) Performance-based approaches in accordance with Chapter 6
4.2.4
An approved performance-based approach, in accordance with Chapter 5, shall be permitted to be applied selectively to specifically identified areas, hazards, or equipment or to specific fire protection requirements for an entire information technology equipment area.
Statement of Problem and Substantiation for Public Comment
Proposed Section 4.2.2 provides the opportunity to replace fire protection in the equipment area and adjacent exposures based upon the risk analysis. There are no guidelines or qualifications for the individuals performing the evaluation of fire risks and hazards. 4.2.4 allows for selective fire protection. These problems are addressed by the comment which is to delete the section inits entirety.
Related Item
First Revision No. 2-NFPA 75-2014 [New Section after 4.1.3]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts
Affilliation: Fire Suppression Systems Association (FSSA) Street Address:
City: State: Zip:
Public Comment No. 21-NFPA 75-2014 [ Section No. 5.2 ]
5.2 Goals and Objectives.
The performance-based design shall meet the following goals and objectives:
(1) The performance-based approach is to allow the alternative means to be utilized for the elements of the information technology equipment (ITE), ITE rooms, and ITE areas as permitted in Chapters 6, 9, and 11.
(2) The risk analysis, design criteria, design brief, system performance, and testing criteria are developed in accordance with this section. (3) The fire protection system(s) disseminates information to the target audience in an accurate and timely manner.
(4) The design and performance criteria are specific to the nature and anticipated risks of each location.
(5) The fire protection system(s) is capable of withstanding various scenarios and survives even if some damage has already occurred. (6) Message initiation can be affected by all responding entities responsible for the safety and security of occupants.
(7) The performance based design shall not be less than the minimum requirements for both the A&D and suppression system
requirements in the prescriptive requirement section of the existing NFPA 75.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. This problem is resolved by the Comment.
Related Item
First Revision No. 5-NFPA 75-2014 [New Section after 4.2.2.2]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 45-NFPA 75-2014 [ Section No. 5.3 ]
5.3 Qualifications.
The performance-based design and risk analysis shall be prepared by a licensed design professional experienced in fire protection and approved by the authority having jurisdiction. The licensed design professional shall be experienced in the preparation of fire risk assessments.
Statement of Problem and Substantiation for Public Comment
The qualitative and quantitative methods used in fire risk assessments require considerable technical judgement normaally developed through exsperience.
Related Item
Public Input No. 95-NFPA 75-2013 [Global Input]
Submitter Information Verification
Submitter Full Name:Thomas Deegan
Organization: The Viking Group, Inc. Affilliation: NFSA
Street Address: City:
State: Zip:
Public Comment No. 46-NFPA 75-2014 [ Section No. 5.4 ]
5.4 Independent Review.
The authority having jurisdiction shall be permitted to require an approved, independent third party to review the proposed design brief and documented fire risk assessment and to provide an evaluation of the design to the authority having jurisdiction.
Statement of Problem and Substantiation for Public Comment
This would clarify that the required fire risk assessment can be required by the AHJ to have a third party review.
Related Item
Public Input No. 95-NFPA 75-2013 [Global Input]
Submitter Information Verification
Submitter Full Name:Thomas Deegan Organization: The Viking Group, Inc. Affilliation: NFSA
Street Address: City:
State: Zip:
Public Comment No. 36-NFPA 75-2014 [ New Section after 6.1 ]
6.1* Combustibility of materials.
6.1.1 A material that complies with any of the following shall be considered a noncombustible material:
(1)*A material that, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat
(2) A material that is reported as passing ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at
750 Degrees C
(3) A material that is reported as complying with the pass/fail criteria of ASTM E 136 when tested in accordance with the test method and procedure in ASTM E 2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shaped Airflow Stabilizer, at
750 Degrees C
6.1.2* Limited-Combustible Material. A material shall be considered a limited-combustible material where all the conditions of 6.1.2.1
and 6.1.2.2, and the conditions of either 6.1.2.3 or 6.1.2.4, are met.
6.1.2. 1 The material shall not comply with the requirements for noncombustible material in accordance with 6.1.1.
6.1.2.2 The material, in the form in which it is used, shall exhibit a potential heat value not exceeding 3500 Btu/lb (8141 kJ/kg) where
tested in accordance with NFPA 259, Standard Test Method for Potential Heat of Building Materials.
6.1.2.3 The material shall have the structural base of a noncombustible material with a surfacing not exceeding a thickness of 1⁄8 in.
(3.2 mm) where the surfacing exhibits a flame spread index not greater than 50 when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning
Characteristics of Building Materials.
6.1.2.4* The material shall be composed of materials that, in the form and thickness used, neither exhibit a flame spread index
greater than 25 nor evidence of continued progressive combustion when tested in accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, and shall be of such composition that all surfaces that would be exposed by cutting through the material on any plane would neither exhibit a flame spread index greater than 25 nor exhibit evidence of continued progressive combustion when tested in accordance with ASTM E84 or ANSI/UL 723.
6.1.2.5 Where the term limited-combustible is used in this standard, it shall also include the term noncombustible. Also add:
A.6.1 The provisions of 6.1 do not require inherently noncombustible materials to be tested in order to be classified as noncombustible
materials.
A.6.1.1(1) Examples of such materials include steel, concrete, masonry, and glass.
age, moisture, or other atmospheric condition are considered combustible.
Also add ASTM E136 (2012) and ASTM E2652 (2012) to section 2 on referenced ASTM standards and NFPA 259 to the section on referenced NFPA standards.
Also, renumber existing sections 6.1.1 as 6.1.2.
Statement of Problem and Substantiation for Public Comment
I understand the committee's reluctance but the NFPA Manual of Style does not allow references to standards or codes in definitions because definitions are not enforceable. That s why other codes and standards, like NFPA 101 and NFPA 5000 moved the definitions. Adding a new subsection to the section on building construction is a simple way to resolve this problem.
This public comment addresses both non-combustible and limited combustible materials, since the technical committee added limited combustible during the first draft.
Related Public Comments for This Document
Related Comment Relationship
Public Comment No. 40-NFPA 75-2014 [Section No. 3.3.16.2] Public Comment No. 42-NFPA 75-2014 [Section No. 3.3.16.3]
Related Item
Public Input No. 9-NFPA 75-2013 [New Section after 6.1]
Submitter Information Verification
Submitter Full Name:Marcelo Hirschler
Organization: GBH International
Street Address: City:
State: Zip:
Public Comment No. 22-NFPA 75-2014 [ Section No. 6.1.1.1 ]
6.1.1.1
The building construction requirements in 6.1.1 shall be permitted to be modified where a performance-based risk analysis, as outlined in Chapters 4 and 6, demonstrates that alternate building construction types can be used.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. The comment addresses this problem.
Related Item
First Revision No. 6-NFPA 75-2014 [Section No. 5.1.1]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 31-NFPA 75-2014 [ Section No. 6.1.1.1 ]
6.1.1.1
The building construction requirements in 6.1.1 shall be permitted to be modified where a performance-based risk analysis, as outlined in Chapters 4 and 6 5, demonstrates that alternate building construction types can be used.
Statement of Problem and Substantiation for Public Comment
Editorial comment to correct the reference to performance-based risk analysis described in Chapters 4 and 5 (not chapter 6).
Related Item
First Revision No. 6-NFPA 75-2014 [Section No. 5.1.1]
Submitter Information Verification
Submitter Full Name:Stephen McCluer Organization: Schneider Electric Street Address:
City: State: Zip:
Public Comment No. 23-NFPA 75-2014 [ Section No. 6.1.3.6 ]
6.1.3.6
Under the following conditions, the fire separation requirements of 6.1.3 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and 5:
(1) The anticipated fire exposures are documented.
(2) Alternate forms of fire separation are provided based on the anticipated fire exposures.
Statement of Problem and Substantiation for Public Comment
This section does not reference Federal, State and local building codes prior to making changes based upon the performance based risk analysis evaluation. Deleting the section in its entirety resolves the problem.
Related Item
First Revision No. 7-NFPA 75-2014 [New Section after 5.1.3.5]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 24-NFPA 75-2014 [ Section No. 6.2.2 ]
6.2.2
A risk analysis as outlined in Chapter 4 shall be used to identify the need for protective features identified in 6.1.2.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. This is resolved by deleting the section in its entirety.
Related Item
First Revision No. 8-NFPA 75-2014 [New Section after 5.2.1]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 25-NFPA 75-2014 [ Section No. 6.3.3 ]
6.3.3
Where an alternate solution, such as containment with leak detection, is provided, the drainage requirements in 6.3.2 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and 5.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. This is resolved by deleting the sectin in ts entirety.
Related Item
First Revision No. 9-NFPA 75-2014 [New Section after 5.3.2]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 43-NFPA 75-2014 [ Section No. 7.1.2 ]
7.1.2
Small work areas shall be permitted within the ITE room provided all the following conditions are met: (1) Areas are not occupied on a full-time basis.
(2) Case furniture, including desks, is constructed of noncombustible material (e.g., metal). The construction can include a high-pressure laminate veneer on the desktop.
(3) Space dividers and system furniture panels and chairs with upholstered assemblies exhibit a maximum rate of heat release not exceeding 80 kW and a maximum total heat release not exceeding 25 MJ within the first 10 minutes of test when tested in accordance with one of the following:
(4) ASTM E1537, Standard Test Method for Fire Testing of Upholstered Furniture
(5) California Technical Bulletin 133, Flammability Test Procedure for Seating Furniture for Use in Public Occupancies
(6) Paper records, manuals, drawings, and all other combustible materials are stored in fully enclosed noncombustible cabinets or cases. (7) The quantity of records, manuals, drawings, and all other combustible materials kept in the room are limited to the absolute minimum
required for essential and efficient operation.
(8) Trash receptacles, where provided, are shall be listed, noncombustible, and provided with tight-fitting or self-closing lids and constructed of materials that are either noncombustible or meet a peak heat release rate not exceeding 300 kW/m2 when tested in accordance with ASTM E1354 at an incident heat flux of 50 kW/m2 in the horizontal orientation .
Also, add ASTM E1354, Standard Test Method for Heat and Visible Smoke Release Rates for Materials and products Using an Oxygen Consumption Calorimeter (2013) into section 2 on referenced ASTM standards,
.
Statement of Problem and Substantiation for Public Comment
The approach taken by the technical committee solves one problem (eliminating the unenforceable concept of "self-extinguishing") and, very reasonably, introduces the concept that trash containers should be listed and have self-closing lids. Unfortunately the language proposed does not offer what the committee wants because it requires the trash receptacles to be noncombustible, which is an excessive requirement, and thus introduces another concern. NFPA 1 (Fire Code) and IFC both have incorporated the requirements that trash receptacles that meet the ASTM E1354 (cone calorimeter) heat release requirements proposed are shown to be acceptably safe and they are increasingly present in multiple environments and are manufactured by multiple companies. These trash receptacles are on the market, are not proprietary (and I don't work for or with any company manufacturing them) and will provide adequate fire safety.
Public Input No. 8-NFPA 75-2013 [Section No. 6.1.2]
Submitter Information Verification
Submitter Full Name:Marcelo Hirschler Organization: GBH International Street Address:
City: State: Zip:
Public Comment No. 28-NFPA 75-2014 [ Section No. 8.1.4 ]
8.1.4*
Enclosures of floor-standing equipment having external surfaces of combustible materials of such size that can contribute to the spread of an external fire shall have a flame spread index of 50 or less in accordance with ASTM E84, Standard Test Method for Surface Burning
Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials. 8.1.4.1
Equipment conforming to the requirements of UL 60950, Safety of Information Technology Equipment , or ANSI/UL 62368-1, Audio/Video,
Information and Communication Technology Equipment — Part 1: Safety Requirements, shall be considered as meeting the requirements of
8.1.4. 8.1.4.2
Equipment conforming to the requirements of ANSI/UL 60950, Safety of Information Technology Equipment; ANSI/UL 60950-1, Information
Technology Equipment — Safety — Part 1: General Requirements; or ANSI/UL 62368-1, Audio/Video, Information and Communication Technology Equipment — Part 1: Safety Requirements, shall be considered as meeting the requirements of 8.1.4.
Statement of Problem and Substantiation for Public Comment
DELETE all of 8.1.4.1 as it is redundant to 8.1.4.2, except that 8.1.4.2 references an additional document (ANSI/UL 60950-1). 8.1.4.2 becomes 8.1.4.1.
Related Item
First Revision No. 14-NFPA 75-2014 [Section No. 7.1]
Submitter Information Verification
Submitter Full Name:Stephen McCluer
Organization: Schneider Electric
Street Address: City:
State: Zip:
Public Comment No. 8-NFPA 75-2014 [ New Section after 8.2 ]
8.2.1 Acoustical Materials.
All sound-deadening material used inside information technology equipment shall be of such material, or so arranged, that it does not increase the potential of fire damage to the unit or the potential of fire propagation from the unit.
Statement of Problem and Substantiation for Public Comment
Still finding acoustical material out in the field. This provision will help reduce potential fire damage.
Related Item
First Revision No. 15-NFPA 75-2014 [Section No. 7.2]
Submitter Information Verification
Submitter Full Name:Jim Muir
Organization: Clark County, Washington, Building Safety Division
Affilliation: NFPA's Building Code Development Committee (BCDC)
Street Address: City:
State: Zip:
Public Comment No. 26-NFPA 75-2014 [ Sections 9.1.1.1, 9.1.1.2 ]
Sections 9.1.1.1, 9.1.1.2 9.1.1.1
Information technology equipment rooms and information technology equipment areas located in a nonsprinklered building shall be provided with one or more automatic fire protection systems as permitted by Chapter 9.
9.1.1.2
The requirement of 9.1.1.1 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and 5.
Statement of Problem and Substantiation for Public Comment
In proposed 9.1.1.1, fire "protection" system could be interpreted as meaning an automatic detection system as listed in Chapter 8.2(9.2) and it could be interpreted that the detection system meets the requirement. This is resolved by striking "protection" and replacing it with "suppression. For Section 9.1.1.2,fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75 and 9.1.1.2 could allow for a performance based risk analysis to eliminate the need for a fire suppression system. This is resolved by the deletion of 9.1.1.2 in its entirety.
Related Item
First Revision No. 11-NFPA 75-2014 [Section No. 8.1.1.1]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 30-NFPA 75-2014 [ Section No. 9.1.1.3 ]
9.1.1.3* An automatic
fire protection system as permitted by Chapter 9shall
sprinkler system or a gaseous fire extinguishing system shall be provided for the protection of the area below a raised floor in an information technology equipment room or information technology equipment area where oneor more of the following exist
(1) there is a critical need to protect datain the process, reduce equipment damage, and facilitate return to service. (1) the area below the raised
floor
(1) flor contains combustible material other than the following:
(1)
Cables listed for plenum use
Listed plenum communications raceways
Listed equipment power cords up to 4.6 m (15 ft) each Cables installed in metallic raceways
Installations in compliance with NFPA 70 , Section 300.22(C) Listed cooling hoses
Statement of Problem and Substantiation for Public Comment
Automatic fire suppression under raised floors is a long standing requirement of the standard. The requirement is related to life safety and so long as combustible or limited combustible material is present under a raised floor automatic fire suppression shall be required. Tis is resolved by deletion of the proposed text and reverting to current edition wording.
Related Item
First Revision No. 13-NFPA 75-2014 [Section No. 8.1.1.2]
Submitter Information Verification
Organization: DuPont Fluoroproducts Affilliation: FSSA Street Address: City: State: Zip:
Public Comment No. 5-NFPA 75-2014 [ Section No. 9.1.1.3 ]
9.1.1.3*
An automatic fire protection system as permitted by Chapter 9shall be provided for the protection of the area below a raised floor in an information technology equipment room or information technology equipment area where the area below the raised floor contains combustible material other than the following:
(1) Cables listed for plenum use
(2) Listed plenum communications raceways
(3) Listed equipment power cords up to 4.6 m (15 ft) each (4) Cables installed in metallic raceways
(5) Installations in compliance with NFPA 70 , Section 300.22(C) (6) Listed cooling hoses
materials.
Statement of Problem and Substantiation for Public Comment
The presence of combustible cables, raceways, other materials should trigger the requirement for automatic suppression under the raised floor This requirement addresses the difficulty in accessing the space under the raised floor to allow manual fire fighting and the ancillary danger to emergency responders. Open floor tiles under fire conditions with possibly limited visibility present a fall danger to responders. The difficulty in locating a fire under a raised. floor can lead to delays in suppression with unacceptable equipment damage and unacceptable build up of toxic products of combustion.
Related Item
Public Input No. 107-NFPA 75-2013 [Section No. 8.1.1.2]
Submitter Information Verification
Submitter Full Name:Thomas Wysocki Organization: Guardian Services, Inc. Street Address:
City: State: Zip:
Public Comment No. 29-NFPA 75-2014 [ Section No. 9.1.1.4 ]
9.1.1.4
The requirement of 9.1.1.2 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and
5.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. 9.1.1.4 could allow for a performance based risk analysis to eliminate the need for a fire suppression system. Deletion of 9.1.1.4 in its entirety resolves this problem.
Related Item
First Revision No. 12-NFPA 75-2014 [New Section after 8.1.1.2]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts
Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 32-NFPA 75-2014 [ Section No. 9.1.5 ]
9.1.5
The requirement of 9.1.4 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and 5.
Statement of Problem and Substantiation for Public Comment
Fire protection should be as required by NFPA 75 with exceptions based on a fire risk assessment where such exception are specifically permitted by NFPA 75. This is resolved by deleting the current text.
Related Item
First Revision No. 17-NFPA 75-2014 [New Section after 8.1.4]
Submitter Information Verification
Submitter Full Name:Mark Robin
Organization: DuPont Fluoroproducts Affilliation: FSSA
Street Address: City:
State: Zip:
Public Comment No. 47-NFPA 75-2014 [ Section No. 9.1.5 ]
9.1.5
The requirement of 9.1.4 shall be permitted to be evaluated as part of the performance-based risk analysis as outlined in Chapters 4 and 5.
Additional Proposed Changes
File Name Description Approved
The_requirement_of_9.docx
Statement of Problem and Substantiation for Public Comment
Tests done by manufacturers of AISS demonstrated that fire in these units produce large amounts of toxic, corrosive products of combustion - such fires can become deep seated. Access to AISS for manual fire fighting is difficult and the difficulty is exacerbated by the dark, dense smoke which is produced by burning media. Testing demonstrated the ability of properly designed automatic suppression systems to extinguish such fires. Unless the reasons for which the existing requirement for automatic suppression systems in AISS with an aggregate storage capacity of more than 0.76 m3 (27 ft3) are clearly stated in the Standard, this requirement for automatic suppression in larger AISS should not be subject to waiver based on fire risk assessment. No specific reasons which would reasonably permit waiver of the requirement have been put forth.
Related Item
First Revision No. 17-NFPA 75-2014 [New Section after 8.1.4]
Submitter Information Verification
Submitter Full Name:Thomas Wysocki
Organization: Guardian Services, Inc.
Street Address: City:
State: Zip:
