California Fire Chiefs’ Association
Fire Prevention Officers, Northern Section
Comments to SFM Amendments to the 2000 UFC

Typical – Many references whether editorial or substantive are specific to non-building standards. The charge of the California Building Standards Commission is to amend only the Building Standards contained within the Uniform Fire Code. References to testing associated with acceptance and performance of newly installed equipment should be viewed as a building standard. However, maintenance type testing should always be viewed as non-building standard.

If the intent is to give better direction to FPO’s (end-users) in the field, it is suggested that those portions of non-building standards necessary for FPO’s to do their job be adopted under Title 19 whereas Title 19 adopts the Fire Code directly.

SFM/CFC-04: §1001, See "Typical". Oppose

SFM/CFC-06: §1001.5.2, Testing frequencies are a non-building standard. Oppose

SFM/CFC-09: §1002.1, Fire extinguisher placement is a non-building standard with non-building standard direction. Oppose

SFM/CFC- : §1003.2.9, Sort of a non-statement, may be NFPA 13R, five stories or more shall be NFPA 13. This doesn’t need to be re-stated; the scope of NFPA 13R already limits it to four stories. Who isn’t reading this… that it is a public problem in need of resolution. Oppose

SFM/CFC- : §1003.2.9.2, For consistency with all residential occupancies whereas, H&S requires that RCF’s, RCFE’s, and CLHF’s be residential in nature; shouldn’t the UFC also require that Residential or quick-response standard sprinklers shall be used in the dwelling units and guest room portions of the building (sleeping rooms)? This would be the perfect time to address this. Also notice that Exception #2 provides exception for R-2.3.1.Occupancies for the use of NFPA 13R yet 1003.2.9.2 doesn’t address R-2.3.1 Occupancies. Support with amendment

SFM/CFC- : §1003.2.9.3, This section should be merged into §1003.2.9.2. The merge would allow for the reference of Residential or quick-response standard sprinklers and the exception in §1003.2.9.2 would not relate. Support with amendment

SFM/CFC-13: §1005.2.7, The requirements for a Class K extinguisher is a stretch as a building Standard. Does this mean a jurisdiction has to issue a building permit if a facility choose to switch to a Class K by choice with existing pre-U.L. 300 systems? Oppose

SFM/CFC-15: §1006.2.1.3, Where the thought of "Heat Detectors not being a life safety device" is carried to the extreme, in some cases it serves a purpose. Think of all the occupancies where Heat Detectors are required, Group I Division 3 occupancies as an exception and in Group R, Division 1 and 2.1 occupancies. The heat detectors maintain a "rate of rise" concept that sprinklers do not. Additionally, larger Group R, Division 1 and 2.1 occupancies are generally providing addressable systems which provide for specific locations in the general areas of recreational rooms, laundry rooms, furnace rooms, and similar areas that would be lost if notification reliance was limited to sprinklers. Oppose

SFM/CFC-16: §1006.2.1.4, Might be better fitted to utilize this section under §1006.2.12 Special uses and conditions. All other occupancies, the direction for smoke detector placement is prescriptive. Oppose

SFM/CFC-26: §1006.2.9.1.1, Jurusdicitons have not been having trouble with this item as written. The consolidation of R-1 and R-2.1 requirements was to fix the lack of direction and clarity regarding automatic fire alarm systems in R-2.1. R-2.1 requirements under the ’94 Code w/State Amendments never gave direction as to the location of smoke detectors specific to an automatic system. If there is confusion does exist, separate the two but retain and repeat the prescriptive language that provides direction as to the placement of initiating devices specific to automatic fire alarm systems. Oppose/Support with amendment

SFM/CFC-35: §1006.2.9.2.1, First of all the section does not describe the locations for automatic detection that current code provides for. A complete automatic smoke detection system would require automatic system detectors adjacent to single-station detectors. Somewhat overkill, past practices of smoke detectors in common areas and corridors have not resulted in failures. What specific problems have been presented in recent years to increase the level of protection. The specific purpose and rationale is contradictory to the purpose and rationale utilized in ’97 for current amendment. The rational of the fire service was to require systems in the CBC and give direction for installation in the CFC. Additionally, the current requirements are still consistent with Health and Safety Code 13131.5(b)(2). The requirement does not require that the system be a complete detection system. Oppose

SFM/CFC-54: §7801, Firework regulations are not a building standard. Not even direction to refer to Title 19. Oppose

SFM/CFC-55: §7801.3, See above. Oppose