Download Eliminates smoke control for high-rise buildings. one of three

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.
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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
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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,
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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