NFPA Technical Committee on Animal Housing · 2015-12-14 · NFPA Technical Committee on Animal Housing . FIRST DRAFT MEETING AGENDA . Wednesday, October 9, 2013 . NFPA . 1 Batterymarch

NFPA Technical Committee on Animal Housing

FIRST DRAFT MEETING AGENDA

Wednesday, October 9, 2013 NFPA

1 Batterymarch Park Quincy, MA 02169

(and by web meeting/teleconference)

1. Call to Order. Call meeting to order by Chair Brad Cronin at 8:00 a.m. EDT on October 9, 2013 at NFPA Headquarters.

Web meeting/Teleconference information: To join the meeting by web: http://nfpa.adobeconnect.com/tracy/

To join the teleconference: 1-855-747-8824 Pass code: 533726

2. Introduction of Committee Members and Guests. For a current committee roster, see

page. 02.

3. Approval of Prior Meeting Minutes. Approve the April 5, 2011 meeting minutes see page 05.

4. New Process Review and Staff Liaison Report, see page 07.

5. NFPA 150 First Draft (formerly ROP) Preparation. For Public Input Review, see

page 12.

6. Other Business.

7. Future Meetings.

8. Adjournment.

Page 1 of 58

http://nfpa.adobeconnect.com/tracy/�

Address List No PhoneAnimal Housing Facilities ASF-AAA

Tracy L. Vecchiarelli09/05/2013

ASF-AAA

Bradford T. Cronin

ChairNewport Fire Department21 West Marlborough StreetNewport, RI 02840

E 11/02/2006ASF-AAA

Clay P. Aler

PrincipalKoffel Associates, Inc.8815 Centre Park Drive, Suite 200Columbia, MD 21045-2107Alternate: M. Steven Welsh

SE 11/2/2006

ASF-AAA

Michael J. Biel

PrincipalSprinkler Fitters Local Union 1836653 Channel RoadWaterford, WI 53185United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryAlternate: Rita L. Neiderheiser

L 1/10/2008ASF-AAA

John P. Boucher

PrincipalHarvard University1 Pine Hill DriveSouthborough, MA 01772

U 03/07/2013

ASF-AAA

Richard R. Brown

PrincipalBrown Sprinkler Corporation4705 Pinewood DriveLouisville, KY 40218National Fire Sprinkler Association

IM 7/14/2004ASF-AAA

Hal Cohen

PrincipalHCC and Associates, Inc.3 Mill Park CourtNewark, DE 19713

SE 7/23/2008

ASF-AAA

Chandra L. Davis

PrincipalHornbeak Fire Department406 Luther Davis RoadHornbeak, TN 38232

E 10/18/2011ASF-AAA

Richard L. Day

PrincipalMichigan State Fire Marshal's Office207 Jackson StreetAllegan, MI 49010

E 07/29/2013

ASF-AAA

Matthew Dominguez

PrincipalThe Humane Society of the United States700 Professional DriveBethesda, MD 20879

U 07/29/2013ASF-AAA

Michelle Dvorscak

PrincipalLake County Sheriff's Department2293 North Main StreetCrown Point, IN 46307

E 03/07/2013

ASF-AAA

Ajay Gulati

PrincipalSmithsonian Institution600 Maryland Avenue, Suite 7106Washington, DC 20013Alternate: Nandeep Bahra

U 4/14/2005ASF-AAA

Paul M. Haas

PrincipalAll Fire Solutions Inc.18862 105th RoadMcAlpin, FL 32062

SE 03/07/2013

ASF-AAA

Michael J. Keenan

PrincipalGallagher Grace Mayer Insurance10050 Regency Circle, Suite 300Omaha, NE 68114-3721

I 03/07/2013ASF-AAA

Loretta Krzastek

PrincipalFlorida State Fire Marshal’s Office1717 SE 14th StreetCape Coral, FL 33990

E 03/07/2013

1Page 2 of 58



ASF-AAA

Scott Learned

PrincipalDesign Learned Inc.116 Main StreetNorwich, CT 06360Alternate: Adam Farnham

SE 03/07/2013ASF-AAA

Laurie Loveman

PrincipalFire Safety in Barns17095 Abbey RoadChagrin Falls, OH 44023-1313Alternate: Rebecca M. Gimenez

SE 7/19/2002

ASF-AAA

Jeffery P. McBride

PrincipalEBL Engineers, LLCEBL Fire Engineering8005 Harford RoadBaltimore, MD 21234-5701

SE 7/14/2004ASF-AAA

Brian Morrison

PrincipalCenterville-Osterville-Marstons Mills Fire District1875 Falmouth RoadCenterville, MA 02632

E 03/07/2013

ASF-AAA

Paul W. Pressley

PrincipalUS Poultry and Egg Association1530 Cooledge RoadTucker, GA 30084

U 03/07/2013ASF-AAA

Brian L. Rieck

PrincipalAutomated Production Systems16 Linda LaneTaylorville, IL 62568National Pork Producers CouncilAlternate: Michael C. Formica

U 03/07/2013

ASF-AAA

Mark S. Rosenberger

PrincipalLos Alamos National LaboratoriesPO Box 1663, M791Los Alamos, NM 87545

U 3/15/2007ASF-AAA

Joe Scibetta

PrincipalBuildingReports1325 Satellite Boulevard, Suite 1607Suwanee, GA 30024

M 8/5/2009

ASF-AAA

Richard C. Staniland

PrincipalChubb Group of Insurance Companies610 West Ash Street, Suite 1101San Diego, CA 92101Alternate: Thomas A. Nappo

I 3/1/2011ASF-AAA

Nandeep Bahra

AlternateSmithsonian Institution600 Maryland Avenue, Suite 7106Washington, DC 20013Principal: Ajay Gulati

U 3/5/2012

ASF-AAA

Adam Farnham

AlternateExponent, Inc.15375 SE 30th Place, Suite 250Bellevue, WA 98007Principal: Scott Learned


Michael C. Formica

AlternateNational Pork Producers Council122 C Street NW, Suite 875Washington, DC 20001National Pork Producers CouncilPrincipal: Brian L. Rieck

U 03/07/2013

ASF-AAA

Rebecca M. Gimenez

AlternateTechnical Large Animal Emergency Rescue, Inc.1787 GA Highway 18 EastMacon, GA 31217Principal: Laurie Loveman


Thomas A. Nappo

AlternateChubb Group of Insurance Companies8000 Maryland, Suite 1500St. Louis, MO 63105Principal: Richard C. Staniland

I 1/14/2005

2Page 3 of 58



ASF-AAA

Rita L. Neiderheiser

AlternateRoad Sprinkler Fitters UA LU 669PO Box 40393Denver, CO 80204United Assn. of Journeymen & Apprentices of thePlumbing & Pipe Fitting IndustryPrincipal: Michael J. Biel

L 10/20/2010ASF-AAA

M. Steven Welsh

AlternateKoffel Associates, Inc.8815 Centre Park Drive, Suite 200Columbia, MD 21045-2107Principal: Clay P. Aler

SE 3/1/2011

ASF-AAA

Tracy L. Vecchiarelli

Staff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

01/04/2010

3Page 4 of 58

Page 1 of 2

ROC MEETING MINUTES NFPA Technical Committee on Animal Housing Facilities

April 5, 2011 Silver Spring, MD

1. Call to Order. The meeting of the Technical Committee on Animal Housing Facilities was called to order by Chair Brad Cronin at 8:00 AM. 2. Introduction of Committee Members and Guests. Self introductions of members and guests were completed. Those present included: TECHNICAL COMMITTEE MEMBERS PRESENT

NAME REPRESENTING

Cronin, Bradford, Chair Newport Fire Department

Aler, Clay, Principal Koffel Associates, Inc.

Cohen, Hal, Principal HCC and Associates, Inc.

Dorko, Christopher, Principal Berkley Life Sciences, LLC

Gulati, Ajay, Principal Smithsonian Institution

Houser, Karl, Principal EBL Engineers, LLC, EBL Fire Engineering

Lee, Lisa, Principal New York State Division of Homeland Security & Emergency Services

Scibetta, Joe, Principal Building Reports

Sullivan, Andrew, Principal The Protectowire Company, Inc.

Neiderheiser, Rita, Alternate to M. Biel United Assn. of Journeymen & Apprentices of the Plumbing & Pipe Fitting Industry

Boving, Peter, Non-voting Member National Cancer Institute-Frederick

Golinveaux, Tracy, Staff Liaison NFPA

TECHNICAL COMMITTEE MEMBERS NOT PRESENT

NAME REPRESENTING

Brown, Richard, Principal Brown Sprinkler Corporation Rep. National Fire Sprinkler Association

Corrigan, Mary, Principal Harvard University

Crowley, Michael, Principal The RJA Group

Filippi, Marion, Principal Ballard’s Farm, LLC

Page 5 of 58

Page 2 of 2

Heckman, Steven, Principal The Jackson Laboratory

Hohbein, Todd, Principal State of Utah Fire Marshal’s Office

Jaracz, James, Principal Hobart Fire Department

Loveman, Laurie, Principal Fire Safety in Barns

Manley, Bonnie, Principal American Iron and Steel Institute

Rosenberger, Mark, Principal Los Alamos National Security, LLC

Spinella, Lyn, Principal Brookside Equestrian Center

Staniland, Richard, Principal Chubb Group of Insurance Companies

Trzcinski, Philip, Principal No-Burn, Inc.

Turno, Donald, Principal Savannah River Nuclear Solutions, LLC

Harrod, Peter, Alternate to M. Crowley The RJA Group, Inc.

Nappo, Thomas, Alternate to R. Staniland Chubb Group of Insurance Companies 3. Announcements. NFPA Staff briefly reviewed the purpose of the meeting and NFPAs procedures. By the end of the meeting, an action would be completed for each of the public comments that were received. The committee would also have the opportunity to develop any committee comments to address any topics or issues related to the draft standard. Staff reviewed the timelines for processing the 2012 editions of 150:

Comment Closing Date was March 4, 2011

ROC will be published on August 26, 2011

4. Approval of Minutes. The minutes of the July 8, 2010 ROP meeting were approved. 5. NFPA 150 Proposals. The committee reviewed 10 public comments that had been received on NFPA 150. A motion passed to submit the meeting actions to a letter ballot. See the ROC letter ballot for committee actions. 6. Other Business. The committee discussed issuing a proposal to NFPA 901, Standard Classifications for Incident Reporting and Fire Protection Data to expand the data coding to include various types of animal housing facilities. The committee also discussed possible submissions for the Fire Protection Research Foundation code fund. Both items will be discussed in a future conference call. 7. Schedule Next Meeting. The next meeting date and location are to be determined at a later date. The next revision cycle is F2014. 8. Adjournment. The meeting was adjourned at 1:45 p.m. on April 5, 2011. Minutes Prepared by: Tracy Golinveaux, Staff Liaison

Page 6 of 58

9/9/2013

1

NFPA First Draft Meetings

Animal Housing

Welcome TC on

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October 9, 2013

Quincy, MA


At this and all NFPA committee meetings we are concerned with your safety. If the fire alarm sounds, please proceed to an exit.

9/9/2013


Members, please verify/update your contact information

Use of tape recorders or other means capable of

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reproducing verbatim transcriptions of this or any NFPA meeting is not permitted


Guests All guests are required to sign in and identify

their affiliations. Participation is limited to those individuals who

have previously requested of the chair time to

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have previously requested of the chair time to address the committee on a particular subject or individuals who wish to speak to Public Input they have submitted.

Guest chairs are located around the room as a courtesy.


Members categorized in ANY interest category who have been retained to represent the interests of ANOTHER interest category (with respect to a specific issue or issues that are to

9/9/2013

be addressed by a TC/CC) shall declare those interests to the committee and refrain from voting on any Public Input, Comment, or other matter relating to those issues.

NFPA First Draft MeetingsNew Process

General ProceduresFollow Robert’s Rules of Order.

Discussion requires a motion.

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Page 7 of 58

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2

Motions for Ending Debate Previous Question or “Call the Question” Not in order when another has the floor

Requires a second

Thi i i d b bl d DOES NOT


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This motion is not debatable and DOES NOT automatically stop debate

A 2/3 affirmative vote will immediately close debate and return to the original motion on the floor. Less then 2/3 will allow debate to continue.


Committee member actions:

Member addresses the chair.

Receives recognition from the chair.

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Introduces the motion.

Another member seconds the motion.

Committee chair actions:

States the motion.

Calls for discussion.


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Ensures all issues have been heard.

Takes the vote.

Announces the result of the vote.


Technical Committee on Animal Housing Enforcers, 6 Members: 26%

Insurance,2 Members: 9%

Installer/Maintainer, 1 Members: 4%

Labor 1 Member: 4%

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Labor, 1 Member: 4%

Manufacturers, 1 Members: 4%

Research & Testing,0 Member: 0%

Special Experts, 6 Members: 26%

Users, 6 Members: 26%


Timeline Public Input Stage (First Draft): First Draft Meeting: Oct 9, 2013 Posting of First Draft for Balloting Date: 1/31/2014 Posting of First Draft for Public Comment: 3/7/2014

Comment Stage (Second Draft): Public Comment Closing Date: 4/11/2014

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Public Comment Closing Date: 4/11/2014 Second Draft Meeting Period: May – Oct 2014 Posting of Second Draft for Balloting Date: 1/2015 Posting of Second Draft for NITMAM: 1/16/2015

Tech Session Preparation: NITMAM Closing Date: 3/6/2015 NFPA Annual Meeting: 6/22-25/2015

Standards Council Issuance: Issuance of Consent Documents: July 2015 with 2016 edition date Issuance of Documents with CAM: August 2015 with 2016 edition date

NFPA First Draft MeetingsNew Process – What’s New?

Changes in Terms:

New Term Old Term

Input Stage ROP Stage

Public Input Proposal

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First Draft Meeting ROP Meeting

Committee Input“Trial Balloon”

(or later, FR that fails ballot)

Committee Statement (CS) Committee Statement

First Revision (FR)Committee Proposal or Accepted

Public Proposal

First Draft Report ROP

First Draft ROP Draft

Page 8 of 58

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3

NFPA First Draft MeetingsNew Process – What’s New?

Changes in Terms:

New Term Old Term

Comment Stage ROC Stage

Public Comment Public Comment

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Second Draft Meeting ROC Meeting

Committee CommentComment that Failed Ballot

(Second Revision that failed ballot)

Second RevisionCommittee Comment or Accepted

Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Flowchart

See page 4 for flowchart overview

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NFPA First Draft MeetingsNew Process

NEW Committee Actions and Motions:

Resolve Public Input

Create a First Revision

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Create a Committee Input (Trial Balloon)

First DraftNew Process

• Resolve a Public Input (No Change to Text):

Committee does not want to incorporate the Public Input as a revision.

Committee develops a Committee Statement (CS)

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Committee develops a Committee Statement (CS) to respond (resolve) a Public Input.

Committee must clearly indicate reasons for not accepting the recommendation in CS.

Does not get balloted


• Create a First Revision (FR) Committee wants to make a change to a current

section.

Committee develops a Committee Statement (CS)

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Committee develops a Committee Statement (CS) substantiating the change.

If the revision is associated with one or more Public Input (s), the Committee develops a CS to respond to each PI.

Each FR gets balloted


• Create a Committee Input (Trial Balloon) Committee wants to receive Public Comment on a

topic but not ready to incorporate it into the draft

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topic, but not ready to incorporate it into the draft

Need to have a Committee Statement

Does not get balloted

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4


Committee Statements (Substantiation):

All Public Input must have a Committee Statement

Must include a valid technical reason

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Must include a valid technical reason

No vague references to “intent”

Explain how the submitter’s substantiation is inadequate


Committee Statements (Substantiation):

Should reference the First Revision if it addresses the intent of the Submitter’s Public Input

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Public Input


Formal voting Voting during meeting is used to establish

a sense of agreement (simple majority)

S d b l tt b ll t (2/3 t)

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Secured by letter ballot (2/3 agreement)

Only the results of the formal ballot determine the official position of the committee on the First Draft


Ballots are on the First Revisions (FR) ONLY Public Input and Committee Input not balloted Reference materials are available:

First Draft, PI, CI, CS, etc

Ballot form allows you to vote:

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Ballot form allows you to vote: Affirmative on all FR Affirmative on all FR with exceptions specifically noted

Ballot form provides a column for affirmative with comment Note: This box only needs to be checked if there is an

accompanying comment.

Reject or abstain requires a reason.


Initial ballotCirculation of negatives and commentsMembers may change votes during

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Members may change votes during circulation

First Revision that fails letter ballot becomes Committee Input (CI) – just like the trial balloon version of CI – so as to solicit Public Comment


Balloting

Ballots will be an online format

Alternates are strongly encouraged to return ballots

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return ballots

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5


No New Material after the Public Input Stage

What constitutes new material is to some extent a judgment call

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TC Struggles with an Issue

• TC needs data on a new technology or emerging

Code Fund Lends a Hand

• TC rep and/or staff liaison submits a Code Fund

Research Project Carried Out

• Funding for project is provided by the Code emerging

issue• Two opposing

views on an issue with no real data

• Data presented is not trusted by committee

Code Fund Request

• Requests are reviewed by a Panel and chosen based on need / feasibility

the Code Fund and/or industry sponsors

• Project is completed and data is available to TC

www.nfpa.org/codefund9/9/2013

Legal

Antitrust: the single most important provision-Federal law prohibits contracts, combinations, or conspiracies which unreasonably restrain trade or commerce. Section 1 of the Sherman Act

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Patent: Disclosures of essential patent claims should be made by the patent holder, but others may also notify NFPA if they believe that a proposed or existing NFPA standard includes an essential patent claim.

Legal

Activities Disapproved by the Courts Packing meetings

Hiding commercial interest throwing the committees out of balance

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committees out of balance

No final decision-making authority to unbalanced Task Groups; include all interested parties.

Hiding scientific or technical information from committees

Doc Info Pages

Document Information

• Document scope• Current/Previous

Edition information• Issued TIAs, FIs and

Errata

Next Edition

• Meetings and Ballots• ROP/ROC or First

Draft Report and Second Draft Report

• NITMAM and

Technical Committee

• Committee name, responsibility and scope

• Staff liaison• Committee list

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Errata• Archived revision

information• Standard Council

Decisions• Articles and Reports• Read only document

• NITMAM and Standard Council Decisions

• Submission of Public Input/Comment

• Private TC info• Ballot circulations,

informational ballots and other committee info

• Committee list• Private committee

contact information• Current committee

documents in PDF format

• Committees seeking members and committee online application


Thank you for participating!

Any questions?

9/9/2013

y q

Page 11 of 58

Public Input No. 41-NFPA 150-2013 [ Global Input ]

We strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150.

Additional Proposed Changes

File Name Description Approved

NFPA_150_public_input_form_7.8.2013_Animal_Ag_Industry.pdf Cover Sheet

email.pdf email

NFPA_150_Public_input_letter_07082013.pdf Letter

Statement of Problem and Substantiation for Public Input

Consideration potentially being given to expanding the fire sprinkler and smoke control requirements of NFPA 150 to include Category B animals should be rejected, per the attached letter from representatives of the animal agriculture industry.

Submitter Information Verification

Submitter Full Name: John Starkey

Organization: U.S. Poultry & Egg Assn.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Jul 12 07:48:40 EDT 2013

Copyright Assignment

I, John Starkey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Except tothe extent that I may lack authority to make an assignment of content identified above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyrightassignment.

By checking this box I affirm that I am John Starkey, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

Origin (from sources other than the submitter)

Letter was prepared by the 23 industry associations listed in the attached letter.

Page 1 of 42National Fire Protection Association Report

9/6/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...

Page 12 of 58

1

From: Paul Pressley [[email protected]]Sent: Monday, July 08, 2013 4:32 PMTo: proposals and commentsCc: Vecchiarelli, TracySubject: Public Input letter - NFPA 150 2015 Revision CycleAttachments: NFPA 150 public input form 7.8.2013 Animal Ag Industry.pdf; NFPA 150 Public input letter

07082013.pdf

Attached please find the public input form and an accompanying letter on behalf of 23 animal agriculture associations expressing our belief that language proposed during the 2012 revision cycle concerning fire sprinkler and smoke control systems for Category B animals would result in significant technical and operational disruptions and enormous costs, with little actual or observable benefit to the welfare, health, and safety of the animals. The producers of these animals raised for food believe that expanding the requirements for sprinkler and smoke control systems will not significantly reduce the risk of loss to the animals and stress that pre‐loss prevention efforts are much more effective than post‐loss control efforts in addressing animal welfare concerns. We strongly urge NFPA not to adopt future fire sprinkler amendments impacting Category B animals to the NFPA 150. We stand ready to work with the NFPA 150 Technical Committee on this and other issues. We thank you for the opportunity to provide this input.

Paul W. Pressley Executive Vice President – Industry Programs U.S. Poultry & Egg Association 1530 Cooledge Rd. Tucker, GA 30084 678.514.1972 (Direct) 770.403.0510 (Mobile)

This email message is intended only for the addressee(s) and contain information that may be confidential and/or copyrighted. If you are not the intended recipient, please notify the sender by reply email and immediately delete this email. Use, disclosure or reproduction of this email by anyone other than the intended recipient(s) is strictly prohibited. No representation is made that this email or any attachments are free of viruses. Virus scanning is recommended and is the responsibility of the recipient.

Page 13 of 58

July 8, 2013

Amy Cronin, Secretary

Standards Council

National Fire Protection Association

1 Batterymarch Park

Quincy, Massachusetts 02169

Re: NFPA 150 Standard on Fire and Life Safety in Animal Housing Facilities

2015 Revision Cycle Public Input

Secretary Cronin:

The undersigned organizations appreciate the opportunity to submit this letter of public

input concerning the 2015 revision cycle for the 150 Standard for Fire and Life Safety in Animal

Housing Facilities. Herein, we wish to briefly restate concerns we raised under appeal during the

2012 revision cycle concerning the proposal to require the installation of sprinkler and smoke

control systems in animal housing facilities for Category B animals.

Members of these organizations own and operate the overwhelming majority of animal

housing facilities in the United States that produce or contribute to the production of the

livestock and poultry in the United States. These farmers and ranchers are committed to the

practice of good animal husbandry and the welfare of the animals in their care. No one feels the

loss of their animals more acutely than them, and no one understands the devastating

implications of major fires on their operations. No one has more incentive than them to protect

the health and safety of their animals, and in the process, their businesses and livelihoods.

The farms and ranches owned by the members of these organizations include the

overwhelming majority of those that meet the definition of both NFPA Class 1 Facilities, such as

livestock, poultry and dairy barns, and the corresponding Category B animal housing facility as

defined by NFPA 150. The adoption of an amended NFPA standard expanding the requirement

for sprinkler and smoke controls systems for Category B animals including livestock and poultry

operations would result in significant technical and operational disruptions and enormous costs,

with little actual or observable benefit to the welfare, health, and safety of the animals.

These farmers and ranchers will be directly harmed if the NFPA 150 standard is amended

in future editions to require fire sprinkler and smoke control systems for Category B animals and

they publically oppose any efforts to do so.

They seek to retain the current treatment of such facilities in the NFPA 150 standard

which allows them to focus efforts on effective pre-loss prevention programs rather than

relatively ineffective and expensive post-loss control methods.

Our members believe that pre-loss activities such as good housekeeping practices,

effective equipment maintenance, and the control of ignition sources in livestock and poultry

housing have been effective in controlling the risk of fire.

Page 14 of 58

They also believe that the expense and associated risk of sprinkler systems far outweigh

the potential benefit. Many, if not most, farms will lack a water supply adequate to support a

well-designed sprinkler system, greatly increasing the cost to comply with the standard. The

addition of other water sources in livestock housing may inadvertently introduce uncontrolled

moisture into the houses, creating vectors of disease and infection (flies, bacteria, others) as well

as the simple, greater physiological challenges for wet animals. Maintenance and inspection of

sprinkler systems may also create biosecurity risks to these animals. Modern animal agriculture

operations have developed and strictly follow biosecurity protocols to minimize the risk that

diseases will be transmitted from flock to flock or herd to herd. The single largest such vector is

human beings and their vehicles. These protocols commonly dictate who can enter the animal

houses, how many days there must be between a visit to another flock or herd, whether they need

to shower or otherwise clean themselves before entry, and what they must wear. We also have

questions as to the possible biosecurity risks created by the non-potable sprinkler water itself in

the case of accidental release.

Finally, they question the ability of sprinklers and smoke control systems to actually

reduce the loss of livestock in a fire event. While sprinkler systems have always proven to be

extremely effective in controlling the spread of fire, the reality is that prior to sprinkler

activation, particularly with dry pipe systems, the size of the fire required to activate a single

sprinkler head and the amount of smoke generated before and as the sprinklers bring the fire

under control are extensive. The activation of the sprinkler heads would be further delayed due

to the rapid air movement throughout the housing due to the ventilation requirements in modern

production facilities. Before the fire is extinguished many animals will succumb to smoke or

smothering or possibly be exposed to toxic products of combustion which may render them unfit

for human consumption and therefore require that they be euthanized. Our farmers and ranchers

believe that only pre-loss prevention measures can be effective in reducing the loss of animal

lives in livestock and poultry housing.

For these reasons, we strongly urge NFPA not to adopt future fire sprinkler amendments

impacting Category B animals to the NFPA 150. We stand ready to work with the NFPA 150

Technical Committee on this and other issues and encourage you to adopt this course of action.

Sincerely,

John E. Starkey

President

U.S. Poultry and Egg Association

1530 Cooledge Road

Tucker, Georgia 30084

Page 15 of 58

On behalf of

National Pork Producers Council

122 C Street, N.W.

Suite 875

Washington, D.C. 20001

American Farm Bureau Federation

600 Maryland Ave, S.W.

Suite 1000W


United Egg Producers

1720 Windward Concourse

Suite 230

Alpharetta, GA 30005

National Chicken Council

1015 15th

Street, N.W.

Suite 930


National Turkey Federation

1225 New York Ave, N.W.

Suite 400


National Council of Farmer Cooperatives

50 F Street N.W.

Suite 900

Washington, DC 20001

National Cattlemen’s Beef Association

1301 Pennsylvania Ave, N.W.


National Milk Producers Federation

2101 Wilson Blvd,

Suite 400

Arlington, VA 22201

Dairy Farmers of America

10220 N. Ambassador Dr.

Kansas City, MO 64153

Dairylea Cooperative

P.O. Box 4844

Syracuse, NY 13221

Upstate Niagara Cooperative

25 Anderson Road

Cheektowaga, NY 14225

Select Milk Producers

320 West Hermosa Drive

Artesia, NM 88210

Agri-Mark Inc;

P.O. Box 5800

Lawrence, MA 01842

St. Albans Cooperative Creamery

140 Federal Street,

St. Albans, VT 05478

Northeast Dairy Farmers Cooperatives

6354 Alderman Drive

Alexandria, VA 22315

Dairy Producers of Utah

1315 K Street

Modesto, CA 95354

Dairy Producers of New Mexico

PO Box 6299

Roswell, NM 88202-6299

Idaho Dairymen’s Association

195 River Vista Place

Twin Falls, ID 83301

Texas Association of Dairymen Virginia Poultry Association

P.O. Box 13182 P. O. Box 2277

Austin, TX 78711 Harrisonburg, VA 22801

Page 16 of 58

Washington State Dairy Federation

P.O. Box 1768

575 E. Main Street 2

Elma Washington 98541

Milk Producers Council

13545 S. Euclid Avenue

Ontario, CA 91762

cc: Tracy Vecchiarelli, NFPA Staff

Page 17 of 58

Public Input No. 12-NFPA 150-2013 [ Section No. 1.3.3 ]

1.3.3This standard shall also apply to existing facilities where any one of the following conditions applies:

(1) A change of use or occupancy classification occurs where animals are introduced.

(2) A change is made in the subclassification or category of the animals housed.

(3) A renovation, modification, reconstruction, or addition is made That affects 50%or more of the total square footage of the facility, or increases the occupied square footage by at least 25% .

(4) A building or structure with an animal housing facility is relocated.

(5) A building with an animal housing facility is considered damaged, unsafe, or a fire hazard.

(6) A property line that affects compliance with any provision of this standard is created or relocated.


Any renovation, modification, or reconstruction or addition no matter how minor would prompt application of the new standard to existing structures. The standard as written may deter some building owners from making any modification or repairs in order to avoid application of the standard.


Submitter Full Name: Mike Keenan

Organization: Gallagher Grace Mayer Insurance

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Submittal Date: Tue Jul 02 16:18:37 EDT 2013



Page 18 of 58


I, Mike Keenan, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Mike Keenan, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Page 19 of 58


1.4.2In those cases where the authority having jurisdiction determines that the existing situation presents an unacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate .


This section provides to much authority to the AHJ without the benefit of due process to the property owner. The phrase "unacceptable degree of risk" is ambiguous as each party will have their own "acceptable degree of risk".




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I, Mike Keenan, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.




Page 20 of 58


2.3.2 ASTM Publications.

ASTM International, 100 Bar Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E 84, Standard Test Method of Surface Burning Characteristics of Building Material, 2010. 2013a

ASTM E 1591, Standard Guide for Obtaining Data for Deterministic Fire Models, 2007 2013 .


standards date update


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

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Submittal Date: Thu Dec 27 13:17:56 EST 2012


I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Ihereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Page 21 of 58


3.3.1 Addition.An increase in the building area, aggregate floor area, building height, ornumber of stories of a structure. [ASCE/SEI 7: 11.2 5000: 3.3.1 ]


It is unclear why the definition in NFPA 150 is being extracted from ASCE/SEI 7 when the definition for the term is located in NFPA 5000. The ASCE definition is nearly identical to the definition in NFPA 5000. We believe the definition should be extracted from NFPA.


Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, Washington

Affilliation: NFPA Building Code Development Committee (BCDC)

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Submittal Date: Mon Jul 08 12:52:43 EDT 2013


I, Jim Muir, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Jim Muir, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



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3.3.9 Fire Resistance Rating.The time, in minutes or hours, that materials or assemblies have withstood a fire exposure as established in accordance with the test procedures of NFPA 251, Standard Methods of Tests of Tests of Fire Resistance of Building Constuction and Materials . [ 220, 2012] tests, or methods based on tests, prescribed by this standard [NFPA 5000].


NFPA 251 has been withdrawn and NFPA 220 now extracts this definition from NFPA 5000. ASTM E119 replaces NFPA 251.




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Submittal Date: Wed Jul 03 16:21:46 EDT 2013






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4.2.2 Appropriateness of Safeguards.Every facility shall be provided with means of egress and other fire and life safety safeguards of the kinds, numbers, locations, and capacities appropriate to the individual facility, with due regard to the following:

(1) Character of the occupancy, including fire load

(2) Capabilities Characteristics and capabilities of both the human and animal occupants and their response to fire protection methods

(3) Number of animals and persons exposed

(4) Fire protection available

(5) Height and type of construction of the facility

(6) Other factors necessary to provide animal and human occupants with a reasonable degree of safety

(7) Other factors necessary to protect the facility and contents from unacceptable damage


File Name Descri

NFPA_150_4.2.2_13-34_that_carries_over_concepts_from_Rich_Davis_last_ROC_revision_scanned_signature.pdf

Cover Sheet


The University of Michigan is grateful that safety concepts of this nature are open for public comment through the NFPA/ANSI process and distributed through its vast network of safety experts and stakeholders. This issue is very important because::

a) many colleges and universities have research and teaching facilities with an abundance animals.b) we share the concern for the safety of human and non-human life. c) many colleges and universities are struggling with insufficient capital and operating budgets that may put this particular life safety concern on a lower rank than priorities affecting human life safety.d) there are may be factors that increase the cost and lower the benefit of sprinklers in facilities that house animals. Some facilities are not heated and subject to freezing. This could result in the increased cost of dry sprinkler systems. The animals will remain caged or otherwise restrained and might be harmed by sprinklers operating on them for long periods. Water might accumulate and cause drowning for smaller creatures or nursing young. Lastly, there may not be sufficient design data to assess the hazard, making design difficult for those who must determine a water application rate. It is noteworthy that there are no known prohibitions against installing sprinklers for all animal groups as an Owner option. Where this document may fail is if its provisions become mandatory without more understanding of how different animals may respond to fire protection regimes.




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Submitter Full Name: Michael Anthony

Organization: University of Michigan

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I, Michael Anthony, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Michael Anthony, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



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4.2.5 System Design and Installation.Any fire protection system, building service equipment, feature of protection, or safeguard provided for fire and life safety shall be designed, installed, and approved in accordance with applicable NFPA codes and standards. Consideration shall be given to the availability of water in agricultural housing and research facilities remote from municipal water supplies.


File Name Description Approved

NFPA_150_4.2.5_ESC_Proposal_on_Davis_concept_13-34_scanned_signature.pdf

Cover Sheet


This is a practical consideration and bright line language to address it will guide planning, design and O&M activities.


Submitter Full Name: Michael Anthony

Organization: University of Michigan

Affilliation: Evergreen State College

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I, Michael Anthony, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Michael Anthony, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Page 26 of 58

Public Input No. 14-NFPA 150-2013 [ Section No. 4.3.1.2 ]

4.3.1.2Where it is evident that a reasonable degree of safety is provided, any requirement shall be permitted to be modified if its application would be hazardous does not present new hazards under normal occupancy conditions in the judgment of the AHJ.


The original wording is confusing, I am not sure of the intent of the committee but this revision may be more appropriate to the original intention




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Public Input No. 15-NFPA 150-2013 [ Section No. 4.3.4.2.6 ]

4.3.4.2.6In accordance with the disaster/emergency management program, equipment designated as necessary for the evacuation orremoval of animals, such as halters and leads, shall be worn by or kept near each animal at all times. from the facility shall be made available. Intended personel and equipment shall be implemented to remove animals as quickly as possible to a safe location when it is safe to do so.


This standard may be useful for equestrian facilities but is not appropriate for other types of livestock such as swine, poultry and cattle.




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5.1.3 * Independent Review.The authority having jurisdiction shall be permitted to require an a mutually approved, independent third party to review the proposed design and provide an evaluation of the design to the authority having jurisdiction at the expense of the owner.


If the cost of the third party review is to be born by the owner then it should be one that is agreed upon with both the owner and the AHJ




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7.2.2* Additional Requirements.In addition to the requirements of 7.2.1, the allowable number of stories above grade where the animal housing facilities are permitted and the allowable area per story of animal housing facilities shall not exceed the limits set forth in Table 7.2.2. The values in Table 7.2.2 for sprinklered facilities shall apply to facilities protectedthroughout with an approved, electrically supervised automatic sprinkler system in accordance with Section 9.2.Table 7.2.2 Allowable Facility Height and Areas

Construction Type

I (442)

I (332)

II (222)

II (111)

II (000)

III (211)

III (200)

IVV

(111)V

(000)

Sprinklered or

NonsprinkleredS N S N S N S N S N S N S N S N S N S N

Class 1 Facilities

Category A Animals

Stories UL NP UL NP 12 NP 6 NP 4 NP 6 NP 4 NP 6 NP 4 NP 3 NP

Area

(1000 ft2)

UL NP UL NP UL NP 75 NP 46 NP 57 NP 38 NP 72 NP 36 NP 18 NP

Category B Animals

Stories UL UL UL UL 12 11 6 5 4 3 6 5 4 3 6 5 4 3 3 2

Area

(1000 ft2)

UL 90 UL 90 UL 90 75 37.5 46 23 57 28.5 38 19 72 36 36 18 18 9

Class 2 Facilities

Category A Animals


Area

(1000 ft2)


Category B Animals


Area (1000

ft2)UL 45 UL 45 UL 45 43 21.5 25 12.5 37 18.5 25 12.5 41 20.5 28 14 18 9

Class 3 Facilities

Category A Animals


Area

(1000 ft2)


Category BAnimals


Area

(1000 ft2)

UL 45 UL 45 UL 45 31 15.5 19 9.5 28 14 19 9.5 30 15 23 11.5 12 6

For SI units, 1 ft = 0.3048 m, 1 ft2 = 0.093 m2.



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S: Sprinklered. Allowable facility height in feet and allowable number of stories above grade in facilities protected with an automatic sprinkler system as specified in7.2.2.

N: Nonsprinklered. Allowable facility height in feet and allowable number of stories above grade in facilities not protected with an automatic sprinkler system as specified in 7.2.2.

UL: Unlimited.

NP: Not permitted.

Note: Within each subclassification, “Stories” refers to the allowable number of stories above grade where the animal housing facilities are permitted to be located; “Area” refers to the allowable area per story.


This table does not provide enough information for those not familiar with Construction Types. An explanation should be provided to help the user understand the Roman Numeral and numerical designation. As most livestock facilities are single story structures it may be helpful to start with a table showing single story structures and a second table for multiple story's.



Organization: Gallagher Grace Mayer Insuance

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7.3.1Stalls, cages, and enclosures housing one or more animals shall allow space for each animal to express all species-typical postures, social adjustment, behaviors, and movements. lie down fully on its side and easily stand back up. The animal should also have adequate room to lie down without having to lie on other animals or on raised feeders.


I believe the existing standard is beyond the scope of the committee. There are other entities and authorities from each industry or group that are better prepared to address this issue.




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7.3.2Animals shall be able to lie down with limbs extended in a normal manner without obstruction from enclosure sides or having to extend feet through feeder doors or bars.


My recommended changes to 7.3.1 would eliminate the need for this paragraph. Alternativly the second sentence of my changes to 7.3.1 could replace the current sentence.




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7.6.1Animal housing facilities shall be separated with a 2 1 -hour fireresistance-rated enclosure from hazardous areas, including, but not limited to, feed rooms, tack rooms, vehicle or equipment storage rooms, blacksmith shops, kitchens, mechanical equipment rooms, and electical rooms and emergancy generators or similar areas.


I beleive a 1 hour rated sepeartion is adequate for this standard. The addition of elecrical rooms and emergancy generators is more reflective of modern livestock facilities




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8.1.1 * Category A.Category A animals that can be safely egressed to a holding area, without human contact, shall have adequate means of egress provided.


Category A animals encompasses livestock such as swine, dairy, and beef cattle. It is not possible to have large numbers of livestock safely egress with or with out human intervention. In most cases livestock will not move to unfamiliar area willingly.




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8.1.2.1.1Two means Two means of egress for human and animal occupants, as a minimum, shall be provided in every facility, section, and area where size, occupancy, and arrangement endanger occupants attempting to use a single means of egress that is blocked by fire orsmoke.


I suggest ommting "area" as this implies that every area including small rooms or storage areas would require more than one exit




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8.1.2.4.1In animal housing facilities not sprinklered in accordance with Section 9.2 , exit travel distance shall not exceed 75 exceed 300 ft (23 m) from any point in the facility.


The 75 foot distance is impractical and far more restrictive than other standards for human occupancy. Most jurisdictions use the NFPA 40 for Special Purpose Industrial Occupancy for animal agriculture facilities. Under the NFPA 40.2.6 the standardis 300 ft.




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8.1.2.4.2In animal housing facilities sprinklered in accordance with Section 9.2 , exit travel distance shall not exceed 100 exceed 400 ft (30 m) from any point in the facility.


This standard is far more restrictive than other standards for human occupancy. Most jurisditctions use the NFPA 40 standards for Special Purpose Industrial Occupancy for aniamal agriculture structures that standard calls for 400ft to exit for sprinklered facilities




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9.4.2Extinguishers in accordance with 9.4.1 shall have a minimum 2-A:10-B:C rating and shall be not more than a 50 a 75 ft (15.2 m) travel distance from any point within the animal housing facility. in special purpose or general occupancy areas. Livestock areas not typicly occupied by humans shall have a minimum 2-A:10:B:C extinguisher located at each exit.


In animal agriculture structures such as hog farms and dairies many areas are not occupied by humans that can make use of the extinguishers. In modern livestock facilities such as these there are little no combustible materials, minimal electrical systems, and no fuel sources. Due to the large span of these facilities and the size of the animals there is no practical locations to mount the extinguishers.




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Public Input No. 28-NFPA 150-2013 [ Section No. 9.5 ]

9.5 Lightning Protection.Where lightning protection is required by this standard for the animal housing facility, lightning protection shall be in accordance with NFPA 780, Standard for the Installation of Lightning Protection Systems.


Most modern livestock raising facilities are steel buildings, and are bonded and grounded. Electrical systems installed in accordance with NFPA 70 are grounded systems. Lightning Arrestors are redundent in these structures and have no functional value.




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9.6.2.1Smoking shall be prohibited except in designated safe areas inanimal housing facilities .


As improperly discarded smoking materials are a major cause of structural fires, smoking should not be allowed in animal housing facilities or associated structures.




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9.6.3.2Detached noncombustible trash containers located no less than 20ft from any animal housing structure , for other than animal waste, shall be provided and a frequent removal program shall be established.


While it is important that waste containers be provided, they should also be located away from the structure to prevent the spread of fire to the building should one occur in the waste conatianer




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9.6.4.1Electrical systems and appliances shall be installed in accordance with the requirements of NFPA 70 , National Electrical Code . Animal Agriculture Facilities will be in accordance with Artical 547 for Agricultural Buildings


Agricultural Buildings are subject to the Artical 547 standards in many jurisdisctions and is approriate for this standard




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9.8 Special Requirements for Category A Animals.9.8.1 Sprinkler Systems.Animal housing facilities with Category A animals or horses shall besprinklered throughout in accordance with Section 9.2.9.8.2 Smoke Control Systems.Animal housing facilities with Category A animals or horses shall have a smoke control system unless modified as approved by the AHJ.9.8.2.1*

Smoke control systems shall be installed, inspected, tested, and maintained in accordance with NFPA 92, Standard for Smoke Control Systems, or nationally recognized standards, engineering guides, or recommended practices.

9.8.2.2The engineer of record shall clearly identify the intent of the system, the design method used, the appropriateness of the method used, and the required means of inspecting, testing, and maintaining the system.

9.8.2.3Acceptance testing shall be performed by a special inspector inaccordance with the following:

(1) Special inspections and tests shall be performed to verify the operation of the smoke control system in its final condition for acceptance by the AHJ.

(2) The design documents shall provide the procedures and methods to be used and items subject to special inspections and tests.

(3) The special inspector shall submit an inspection and test report to the AHJ and registered design professional in responsible charge.

9.8.2.4 Smoke Control System Operation.9.8.2.4.1

Smoke control systems shall be automatically activated by sprinkler waterflow, smoke detection, or other approved detection systems in accordance with NFPA 72. Smoke control systems shall remain operational throughout the emergency.

9.8.2.4.2Means for manual operation of smoke control systems shall be provided at an approved location.

9.8.3* Areas Requiring Human Attendance.With the approval of the AHJ, surgical, procedure, and treatment areas where the animals are anesthetized or otherwise require human attendance shall be designed, constructed, and maintained with a defend-in-place strategy to allow continued human attendance to minimize the unnecessary loss of animal life.9.8.4* Additional Safeguards.For animal housing facilities with Category A animals, the AHJ shall be permitted to require additional safeguards necessary to protect animal occupants that cannot be safely evacuated.




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The horse is not an expendable animal but highly prized during its lifetime for its usefulness and value to humans. Fire consumes the lives of horses more frequently than any other animal dying from fire, based on anecdotal evidence compiled over the last four years. During that time, and taking into account only the more widely publicized commercial stable fires, over 250 horses have died from fire in commercial stables, including 35 horses on June 20th, 2013 in Rossville, GA. This proposal extends sprinkler protection and smoke control beyond Category A animals to horses only and, given the scope of the document, this would apply primarily to newly constructed, commercial horse stables.

NFPA 150 was originally written in response to racetrack stable fires and was written specifically for the protection of horses and their handlers in those types of facilities. However, with the document expanding its scope to all animals, horses have been relegated to Category B, which encompasses a wide array of animals that do not receive the required sprinkler or smoke control protection afforded to Category A animals. However, horses require this type of protection as they are a highly valuable animal both commercially and therapeutically, and most often die from fire at a time when no humans are on hand to rescue them. Sprinkler and smoke control protection would give horses a fighting chance during the time it takes for handlers and fire service personnel to respond and come to their aid.


Submitter Full Name: Joe Scibetta

Organization: N/A

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Submittal Date: Mon Jun 24 15:01:39 EDT 2013


I, Joe Scibetta, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Joe Scibetta, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Page 45 of 58


9.8.1 Sprinkler Systems.Animal housing facilities with Category A animals shall be sprinklered throughout in accordance with Section 9.2 .


This blanket statement is not practical or feasible in most livestock production facilities. In most cases sprinkler systems would be totally ineffective due to numerous issues such as:lack of adequate water supplies in rural areasmost fires occur in overhead areas such as attic spaces rather than the livestock floor areas that are non combustiblethe area normally protected by sprinklers systems is primarily non combustible materials such as concrete and steel modern free stall dairy barns contain almost no combustible materials




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9.8.1 Sprinkler Systems.Animal housing facilities with Category A animals shall be sprinklered throughout in accordance with Section 9.2.


This standard is to broad as sprinkler systems in most livestock raising facilities are not feasible or of no practical benefit. In most rural areas there is not a large enough source of water. In a normal sprinkler systems the discharge is to the occupied space, the occupied space in most of these facilities is non combustible as the floor is concreste the ceiling and fixtures are metal and many of the walls are concrete and wood framing with metal liners.Most of the structure fires occur in the attic space not protected by sprinklers.Most modern free stall dairy barns are steel framed, with metal roof panels. concrete floors and metal headstalls. Many dairies use sand bedding and those that use composed materials are keep the bedding to damp to readily burn.




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9.8.2 Smoke Control Systems.Animal housing facilities with Category A animals shall have a smoke control system unless modified as approved by the AHJ.

9.8.2.1 *Smoke control systems shall be installed, inspected, tested, and maintained in accordance with NFPA 92, Standard for Smoke Control Systems , or nationally recognized standards, engineering guides, or recommended practices.

9.8.2.2The engineer of record shall clearly identify the intent of the system, the design method used, the appropriateness of the method used, and the required means of inspecting, testing, and maintaining the system.

9.8.2.3Acceptance testing shall be performed by a special inspector in accordance with the following:

(1) Special inspections and tests shall be performed to verify the operation of the smoke control system in its final condition for acceptance by the AHJ.

(2) The design documents shall provide the procedures and methods to be used and items subject to special inspections and tests.

(3) The special inspector shall submit an inspection and test report to the AHJ and registered design professional in responsible charge.

9.8.2.4 Smoke Control System Operation.9.8.2.4.1

Smoke control systems shall be automatically activated by sprinkler waterflow, smoke detection, or other approved detection systems in accordance with NFPA 72 . Smoke control systems shall remain operational throughout the emergency.

9.8.2.4.2Means for manual operation of smoke control systems shall be provided at an approved location.


Due to the size and scope of livestock raising facilities smoke control systems are not practical or feasible.




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9.8.4 * Additional Safeguards.For animal housing facilities with Category A animals, the AHJ shall be permitted to require additional safeguards necessary to protect animal occupants that cannot be safely evacuated.


This standard is ambiguish and allows for the AHJ to much leeway.




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10.2 Insulation.

Exposed insulation shall not be permitted Insulation in animal housing facilities shall comply with section 10.2.1 through 10.2.3.10.2.1 Exposed insulation shall comply with the interior finish requirements of section 10.1.10.2.2 Foam plastic insulation shall not be permitted to be used exposed unless: (a) it complies with the requirements of 10.2.2.1 as well as with the requirements of 10.2.2.2 or (b) it complies with the requirements of 10.2.2.3.10.2.2.1 Foam plastic insulation shall be covered by a thermal barrier complying with NFPA 27510.2.2.2 Foam plastic insulation shall comply with the requirements of10.1.1.1.10.2.2.3 Foam plastic insulation complies with the requirements of 10.1.1.3.10.2.3 Loose fill insulation shall not be permitted to be used exposed inanimal housing facilities.Also, add a reference to NFPA 275, Standard Method of Fire Tests for the Evaluation of Thermal Barriers Used over Foam Plastic Insulation, into Chapter 2 on referenced NFPA standards.


The section as written is unenforceable because everything used as interior finish could be construed to be insulation. There are two problems with exposed insulation and the proposed wording addresses both: (a) foam plastic insulation needs to be used behind a thermal barrier, which is a product that complies with NFPA 275 and will protects the insulation from fire exposure and (b) loose-fill insulation cannot be used exposed because it does not have adequate consistency for that purpose.

The new sections address the problem of using foam plastic insulation safely, from the point of view of fire safety. Either it complies with a room-corner test (i.e. NFPA 286, as in 10.1.1.3) or it is covered by a thermal barrier (per NFPA 275) and also complies with at least a Class B (75 flame spread index and 450 smoke developed index in ASTM E84). It has been shown that ASTM E84 is not suitable for testing exposed foam plastic insulation.




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Submittal Date: Thu Dec 27 13:22:51 EST 2012




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10.2 Insulation.Exposed insulation shall not be permitted in animal housing facilities. Insulation that has a radiant reflective barrier intact is acceptable


The existing standard should be reworded to better defined. Some insulating materials have barriers that contain and protect the insulating materials without additional barriers.




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Public Input No. 26-NFPA 150-2013 [ Section No. 11.3.1.1 [Excluding

any Sub-Sections] ]

A fire alarm system in accordance with Section 9 . 3 shall be required inaccordance with this subsection.


Manual alarm pull stations can be effective however detections systems are not feasible due to high levels of moisture, and dust that cause a high number of false alarms. It is appropriate to install smoke and heat detectors in areas such as electrical rooms, offices, utility areas, and generator rooms. In our experiance these are the areas that experiance the majority of incipeint stage fires.




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11.3.4 Lightning Protection.Lightning protection shall be required in accordance with Section 9.5 .


Most modern livestock raising facilities have metal roofs and walls making lightning arrestors redundent and ineffective. The electrical systems are grounded.




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11.3.7 Special Requirements for Category A Animals.Class 1 animal housing facilities with Category A animals or horses shall be in accordance with Section 9.8.


See Substantiation for PI No. 8

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 8-NFPA 150-2013 [Section No. 9.8]

This proposal is dependent on the acceptance of PI No.8



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