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Proposed Modification to the Florida Building Code Modification #: Name: Address: E-mail: Phone: Fax: Code: Section #: Code: Section #: Section 553.73, Fla Stat Gene Boecker 1804 Borman Circle Drive, Saint Louis, MO 63146 [email protected] 314-991-2633 314-991-4614 Building 403.15 Mechanical 513.1 Text of Modification [additions underlined; deletions stricken]: Building 403.15 Smoke control shall be provided in accordance with Section 909. Mechanical 513.1 Scope and purpose. This section applies to mechanical and passive smoke control systems that are required by the Florida Building Code, Building, and shall apply to high rise buildings as defined in the Florida Building Code, Building. The purpose of this section is to establish minimum requirements for the design, installation and acceptance testing of smoke control systems that are intended to provide a tenable environment for the evacuation or relocation of occupants. These provisions are not intended for the preservation of contents, the timely restoration of operations, or for assistance in fire suppression or overhaul activities. Smoke control systems regulated by this section serve a different purpose than the smoke- and heat-venting provisions found in Section 910 of the Florida Building Code, Building . Fiscal Impact Statement [Provide documentation of the costs and benefits of the proposed modifications to the code for each of the following entities. Cost data should be accompanied by a list of assumptions and supporting documentation. Explain expected benefits.]: A. Impact to local entity relative to enforcement of code: Fiscally, the impact would be a reduction of the need for reviews for smoke control. For some departments the costs for outside contracted plan reviewers with expertise in the discipline of smoke control would be less. Overall, a cost savings. B. Impact to building and property owners relative to cost of compliance with code: The cost to Owners would be significantly less since the need to install additional or larger mechanical systems would be reduced or eliminated. The costs have a continuing savings in that the maintenance and service for these systems could also be reduced or eliminated over the life of the building. Cost saving is both in the initial construction and also in life-cycle expenses. Official Form 9B-3.047-2004 478189671 C. Impact to industry relative to cost of compliance with code: There is no known cost impact to industry. Rationale [Provide an explanation of why you would like this Proposed Modification to the Florida Building Code.]: This is one of three alternative proposals submitted. It represents the first choice (highest recommendation). In considering the three, please act on this first, then the second choice, then the third. The simplest item is that the text in the mechanical code is unnecessary. If the building code requires smoke control, then the issue is already addressed in the lead-in sentence. If the building code does not require smoke control in high-rise buildings, the mechanical code is in conflict. The text is superfluous and should be deleted regardless of the action on the action for text in the building code. The effectiveness of smoke control in high-rise buildings to either save lives or to reduce cost has not been proven. All the data seems to indicate that life safety is not significantly raised with a smoke control system in modern high-rise buildings. Many years ago after the MGM Grand Hotel fire codes across the country added extensive provisions in order to improve life safety including fire sprinkler protection, fire alarms, penetration fire-stopping, air circulation shut-down, interior finish rating reductions, and smoke control. Many of these have compounding effects and some do not. Subsequently, smoke control was removed in the 1980’s from one of the model codes based on research performed on reported fires. This proved to be such a reasonable position that the ICC adopted the attitude when it considered the model codes in the formation of the combined building code. The current requirement in the Florida code is based on out dated understandings of high-rise fires and does not take into consideration the improvements made over the past 20 – 30 years in building design. The cost of design and installation as well as the cost to maintain such systems does not prove itself in the area of life safety or property protection. Millions of square feet of high-rise buildings that are sprinklered have been constructed without smoke control and there are no adverse life safety or property protection issues showing up in the fire records. Please explain how the proposed modification meets the following requirements: 1. Has a reasonable and substantial connection with the health, safety, and welfare of the general public: In the most recent High Rise Fires report published in August 2005 by the NFPA comparisons are made between fires in high-rise buildings and other types of buildings. The report does not include statements as to whether or not the buildings had smoke control systems. It is important to remember that most high-rise buildings in the country do not have smoke control systems. Consequently, the comparison is largely between buildings without smoke control. On pages 31 and 32 of that report comparisons are made for apartments; hotels and motels; hospitals and other health care facilities; and, offices. In all cases the instances of Official Form 9B-3.047-2004 478189671 no smoke damage was either the same or greater for high-rise buildings compared to other types. More interesting is that fact that in every case the instances where smoke damage was limited to the room of origin were greater in high-rise buildings. Smoke spread is less in high-rise than in other types of buildings even without smoke control. Page 30 contains a comparison for flame damage in high-rise buildings compared to all other types and shows that flame damage was less for high-rises in all cases. The report also indicates that nearly two-thirds of the fires occurred in high-rise buildings that were not sprinklered. These older facilities would not be expected to have smoke control if they did not have sprinklers. Of related interest is that fact that fires originate in areas other than stairways in all occupancies except apartments. This was the only condition where fires in the means of egress posed an issue to safety. However, since all high-rise stairways are required to be constructed as smoke-proof towers the issue of smoke control for the stairways is moot. Fully sprinklered high-rise buildings are among the safest types of buildings that we can have. As the data indicates, buildings constructed in other parts of the country without smoke control did not skew the data to show higher risks. 2. Strengthens or improves the code, and provides equivalent or better products, methods, or systems of construction: The omission of the smoke control requirement for high-rise buildings improves the code in its standing nation-wide by joining the ranks of those who participate in the national discussion of these issues. The insurance rates of the citizens of the state are directly related to the amount of changes that are made to the base document. The revision improves that code by recognizing the national understanding of high-rise buildings. At the latest ICC code hearings (in 2005), a proposal was submitted that would require smoke control for high-rise buildings. Many people – both code officials and code users – spoke against the proposal. The issue was originally recommended for disapproval by the ICC Fire Code Committee. A portion of the reason was that “[t]here is no documented fire record in sprinklered buildings to support the proposal. Section 909 assumes that the sprinklers will work. Smoke control to maintain tenability in high-rise buildings with only 8 – 10 foot ceilings would be extremely expensive, difficult to design and of questionable values since the smoke buildup would outpace the ability of the smoke control system.” At the final hearing where the membership votes, the matter was overwhelmingly voted to be disapproved. Less than 10 percent of those voting showed an interest in smoke control in high-rise buildings. Because the proposal is for the elimination of a provision the concept of “equivalent product, method or system” cannot be made. There is no equivalence for the omission of a thing – only the statistical data presented that shows that high-rise buildings without smoke control are equivalent in safety to those with such systems (as noted in the NFPA fire report and testified at the ICC code change hearings). 3. Does not discriminate against materials, products, methods, or systems of construction of demonstrated capabilities: The ability to eliminate smoke control does not discriminate against any products, Official Form 9B-3.047-2004 478189671 methods or systems of construction. 4. Does not degrade the effectiveness of the code: The effectiveness of the code would be enhanced by the proposal in that the effectiveness of the code can be based on whether sound technical reasons are used as the basis for amendments to the base document (the ICC Building Code). The elimination of this amendment strengthens the code and its effectiveness. Florida should follow the ICC lead in this matter or should demonstrate through the fire record for buildings within the state that sprinklered high-rise buildings have a documented detrimental fire record where there is no smoke control. To require smoke control without documented justification weakens the code and lessens its effectiveness. Section for DCA Only Committee Action: Committee Reason: Commission Action: Commission Reason: Official Form 9B-3.047-2004 478189671