FPE Corner Is bigger better?
M
Samuel S. Dannaway, PE, FSFPE President, S.S. Dannaway Associates, Inc., Honolulu
y first exposure to Pamphlet 13 came during my college years, with the 1974 edition of NFPA 13, or what old timers called the Red Book. It
was 171 pages in length. The pages were 5 inches by 7 ½ inches, and it would fit in your back pocket. The 2010 edition of NFPA 13 (in which the cover is finally, once more, that legendary red color) contains 421 8½-inch by 11-inch pages. This comparison is a little unfair, as NFPA 13 has absorbed requirements from other standards that have increased its contents, such as NFPA 231, 231C and others. Was this substantial page inflation necessary to achieve
the considerable improvements in life safety and property protection that have been achieved through sprinklers since then? I do not have the answer to that, but I will note that sprinklers have been doing a pretty good job for more than 100 years. While many fire protection engineers are promoting the
benefits of performance-based design methods, our sprin- kler standard is becoming a prescriptive nightmare. I understand that, with the advent of hydraulically designed systems in the ’70s, NFPA 13 started to lead fire protec- tion engineering out of the prescriptive wilderness to the city on the hill of performance-based design method. Granted, with performance-based fire protection engi-
neering design, there will always be a need for prescrip- tive standards. The prescriptive requirements for stair design are a good example. No need to reinvent the wheel there. The same goes for NFPA 13, which, except for its discharge design criteria and hydraulic design, is almost entirely a prescriptive standard. Most of 13’s prescribed requirements are important
and necessary. What concerns me is the continuous tin- kering with the standard in the hopes of prescribing solu- tions for the entire universe of situations. We all know that the major criticism of prescriptive codes and stan- dards is that they cannot cover all possible conditions. Yet, that is exactly what people spend a lot of time doing in their attempts to “improve” the standard. (Have you tried to apply the sprinkler obstruction rules lately? If not, please see the article in the October 2009 edition of Plumbing Engineer. You may still be confused, but do not worry; I wrote the piece and still have trouble with 13’s obstruction rules). Many of the proposals I see coming to the committee
that I serve on deal with trying to make a situation absolutely crystal clear so a particular authority having jurisdiction (insert the name of your favorite AHJ here) will not be able to misunderstand the requirement and force some onerous and unnecessary provision on the engineer, the contractor or the owner. I do not believe the standard is intended to be changed for this reason. We all have our AHJ stories to tell, and I am sure the AHJs have
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theirs. But there is one thing I am certain of; if an AHJ is prone to misunderstanding or misapplying provisions of NFPA 13, it is highly unlikely that solving one problem with more text in the standard will correct the situation. Like a whack-a-mole, once you have pounded one prob- lem down, another one will pop up. Rather than try to change the code or standard to deal
with these issues, our time would be better spent educat- ing the AHJ. Getting involved in the education of code enforcers has multiple positive effects. First, you get to know the person better and perhaps get a feel for their issues and concerns. It can help to develop trust between the AHJ and the engineer or contractor. When AHJs know that you are not going to feed them a load of bull, good things can happen. There are many ways to accom- plish this, such as inviting them to a meeting of the local
promoting the benefits of performance-based design methods, our sprinkler standard is becoming a prescriptive nightmare.
SFPE chapter, sharing articles with them or bringing in manufacturers to discuss new products and technology. If you want to go all out, you could organize a seminar and offer special rates for code enforcers. The goodwill created from providing these educational opportunities is priceless. But I digress. The point of this article is to question
whether or not the continuing expansion of 13, or any other code or standard, with each new edition is a good thing. Maybe the revision cycle should be lengthened from three years to four or five years to slow the rate of page inflation. Maybe code change proposals should be limited to items of an emergency nature or for the intro- duction of significant new technology. Another concern I have is that, in addition to page infla-
tion, each new edition seems to bring its share of sprinkler system price inflation. Increases in cost take the form of additional time to prepare shop drawings, additional time for engineers to review the submittals, additional cost for new required components. It may be wise to require that all code change proposals include an analysis of the impact of the cost of the proposal. Those of us who sit on technical committees or who write proposals (especially those that are paid to write proposals) need to do some reflection. Is bigger really better? Maybe, it’s naïve of me to think the standard can be
Continued on page 24 April 2011
While many fire protection engineers are
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