Interesting topic Francis, thanks. I found George Mann's especially interesting, and given the committee disapproved the proposed change, it was still approved as submitted. Me thinks I need to watch more of the testimony next time.
Public Comment 2:
George Mann, representing the Code Administrators Association of Kentucky, requests Disapproval.
I ask, how does the interpretations committee arrive at the conclusion that the building area is to be used to determine the fire area if the building has no exterior walls. The definition of fire area specifically states that a fire area has to be enclosed and bounded by exterior walls. This is where I believe the interpretation is flawed and in error. The interpretation makes statements of fact that do not exist. No where in the definition of fire area does it speak to using the building area or definition of building area to determine sprinkler requirements. The definition of building area and fire area are not interchangeable. If they were meant to be then Chapter 9 would base sprinkler systems on building area bounded by fire barriers or fire walls. No where in Section 903 does it read that a sprinkler system shall be provided when the building area exceeds a specified threshold. Again, we are supposed to determine fire area based on the area of the building enclosed and bounded by exterior walls, fire wall, fire barriers or fire-resistance-rated horizontal assemblies. Therefore, if we are looking at a building without exterior walls (column and roof only) we have no fire area and never have. This proposed change is attempting to merge 2 totally different definitions into one definition.
Second flaw with this proposed code change is in the application of the definition if approved. It reads that “areas not provided with surrounding walls shall be included in the fire area if such areas are included within the horizontal projection of the roof or floor above”. I read this as meaning that the area under the store front canopy, a roofed over area across the front of a retail establishment and the canopy over a loading / unloading dock would all have to be added to the area calculated within the exterior walls in order to determine sprinkler requirements. Even worse, I would include the area under the eave of the roof for it is a horizontal projection of the roof. Why would any of this be necessary?
Third flaw is implying that it is not clear from the definition of a fire area that building areas without surrounding walls are included in the fire area. The printed definition of fire area specifically reads “enclosed and bounded by fire walls, fire barriers, exterior walls”. I apologize but this would seem to be clear in the intent and application. What has confused the issue is the flawed interpretation that was produced last year.
Finally, the proponent proclaims that there is no increase to the cost of construction. Sprinkler system design, installation, maintenance and monitoring is not free. If this proposed change is approved, many community picnic shelters, theme park picnic shelters, open air flea markets which line every highway across the country, lumber storage shelters, open air concert venues with roofed over spectator seating (such as River Bend in Cincinnati) would be subject to sprinkler requirements that in the past would not been a
consideration. Under this proposed code change, there is no threshold that would grant an exemption from sprinklers for these types of roofed over structures; such as if the roof over the spectator seating were 40 feet above the floor level or if the flea market vendors &
tables were arranged such that the general public could not actually step under the roof only shelter.
