Public Input No. 42-NFPA 101-2018 [ Global Input ]

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1. Add new 9.3.5 to read as follows:

9.3.5 Integrated System Testing. Smoke control systems that are integrated with other fire protection or life safety systems shall be tested in accordance with 9.11.4.2. 2. Revise 9.11.4 to read as follows:

9.11.4* Integrated Fire Protection and Life Safety System Tests. 9.11.4.1 Basic Testing. Where required by Chapters 11 through 43, installations involving and where two or more integrated fire protection or life safety systems are integrated, the integrated system shall be tested to verify the proper operation and function of such systems in accordance with 9.11.4.1.1 and 9.11.4.1.2N 4. 9.11.4.1.1 When a fire protection or life safety system is tested, the response of integrated fire protection and life safety systems shall be verified. 9.11.4.1.2 After repair or replacement of equipment, required retesting of integrated systems shall be limited to verifying the response of fire protection or life safety functions initiated by repaired or replaced equipment. 9.11.4.2* NFPA 4 Testing. Where required by 9.3.5 or Chapters 11 through 43, the following integrated fire protection and life safety systems shall be tested in accordance with 9.11.4.1 and 9.11.4.2.1 through 9.11.4.2.2: 1. Integrated fire protection and life safety systems in high-rise buildings 2. Integrated fire protection and life safety systems that include a smoke control system 9.11.4.2.1 For new buildings, integrated testing in accordance with NFPA 4 shall be conducted prior to the issuance of a certificate of occupancy. 9.11.4.2.2 For existing buildings, integrated testing in accordance with NFPA 4 shall be conducted at intervals not exceeding 10 years unless otherwise specified by an integrated system test plan prepared in accordance with NFPA 4.

3. Delete A.9.11.4 and add new A.9.11.4.2 to read as follows:

A.9.11.4 NFPA 4 requires that integrated fire protection and life safety systems be periodically retested as specified in the integrated system test plan. In addition, for existing systems, an integrated system test plan must be developed within 5 years of adoption of NFPA 4.

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A.9.11.4.2 It is intended that the requirements in 9.11.4.1.2 be applied to retesting of any integrated systems following repair or replacement of equipment in lieu of applying retesting provisions in NFPA 4.

Additional Proposed Changes

File Name Description Approved Issued_TIA_101-18-5_Final_-_TIA_101_18_5.pdf NFPA 101 TIA No. 101-18-5 (Log No. 1322)

Statement of Problem and Substantiation for Public Input

NOTE: This public input originates from Tentative Interim Amendment No. 101-18-2 (Log. 1320) issued by the Standards Council on November 18, 2017 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the Document.

Substantiation. Often, in order for fire and life safety objectives to be met, interdependence on two or more fire protection and life safety systems is required. When that occurs, there is a fundamental expectation for integrated features to remain functional. Common sense has always dictated a need to verify the response of integrated features when individual systems are tested, but standards historically lacked guidance for such testing.

To fill that gap, NFPA 4 Standard for Integrated Fire Protection and Life Safety Systems Testing was developed and published in 2015 as an outgrowth of recommended practices that were previously established by NFPA 3. As a new standard that was derived from a recommended practice, the requirements of NFPA 4 have not yet been widely adopted and remain somewhat untested.

Nevertheless, in the just-completed cycle for the 2018 editions of NFPA 101 and NFPA 5000, NFPA 4 was proposed for adoption by reference in nearly all occupancy chapters with inconsistent results that can be attributed to at least two factors:

1. The content of NFPA 4 was not consistently and adequately explained to all of the NFPA 101 and NFPA 5000 technical committees that were asked to review these proposals and comments. 2. The “one size fits all” approach to integrated testing currently used by NFPA 4 is well suited for complex systems, but it is unnecessarily burdensome for testing of simple integrations, such as a sprinkler waterflow switch connecting to a fire alarm system for alarm initiation and monitoring. For example, NFPA 4 always requires an integrated test team and development of an integrated test plan that is carried out by an integrated test team, unless waived by the AHJ. It is understandable that some technical committees viewed mandatory references to NFPA 4 as excessive and rejected proposals that would have mandated compliance.

As the 2018 editions of NFPA 101 and NFPA 5000 currently stand, some occupancy chapters broadly reference NFPA 4 for all integrated systems. Others contain no reference to NFPA 4 at all, and still others reference NFPA 4 but modify how it is to be applied. These inconsistencies will lead to confusion among code users and code enforcers and could result in unsafe conditions. For example, omission of requirements for integrated testing in some 2018 edition chapters will essentially convey that it is unnecessary to test ANY integrated functions in new or existing occupancies regulated by chapters that do not contain such a requirement. This undermines the traditional common-sense minimum of making sure that even simple integrations must be tested to verify cause- effect functionality.

To deal with this issue, multiple NITMAMs to delete all references to integrated testing requirements and NFPA 4 were submitted and certified for consideration at the annual conference in Boston. However, rather than advancing these motions, the proponents agreed to support an alternate path of using TIAs to repair issues with the code text instead of deleting it.

The TIAs are the result of a collaborative effort that included fire alarm and fire sprinkler industry participation, among others. The approach can be summarized as follows:

1. Because of the complex interaction of systems needed to accomplish smoke control, new and existing buildings with smoke control systems will be required to comply with NFPA 4. This is entirely handled in Chapter 9. 2. Because of the complex interaction of systems needed to accomplish safety objectives in high-rise buildings, new and existing high-rise buildings will be required to comply with NFPA 4. Note that new high-rise buildings are handled by Chapter 11. However, existing high-rise buildings had to be individually addressed in existing occupancy chapters since there is no central location in the codes where regulations are established for existing high-rise buildings. 3. All other buildings and occupancies WILL NOT be required to follow NFPA 4. However, such other buildings Page 2 of 27

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and occupancies WILL be required to comply with a simple, prescriptive requirement ensuring that cause-effect relationships of integrated systems are verified when testing is conducted.

It is important to note that the approach suggested by this TIA correlates with code provisions that were adopted in the 2018 edition of the International Fire Code. Therefore, acceptance of this TIA will ensure that provisions in the 2018 editions of NFPA and ICC codes will be consistent with respect to integrated test requirements.

Emergency Nature. The standard contains an error or an omission that was overlooked during the regular revision process. The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation.

Although it is only necessary to satisfy one of the six possible TIA emergency nature criteria, this TIA satisfies two.

1. The standard contains an error or an omission that was overlooked during the regular revision process. Because some occupancy chapters in the 2018 (Chapters 15, 17, 29, 31, 32, 33, 38 and 39) omitted references to Chapter 9 for integrated testing and others did not, NFPA 101 and 5000 will essentially be conveying that it is unnecessary to test ANY integrated functions in new or existing occupancies regulated by the chapters that do not contain such a requirement. This undermines the traditional common-sense minimum of ensuring that simple integrations must be tested to verify cause-effect functionality. Although each technical committee is certainly authorized to oversee requirements for occupancies under its authority, it was probably unrecognized or overlooked that omitting a reference to Chapter 9 in some chapters, when such references appear in other chapters, conveys a message that testing of integrated features can be entirely ignored in some cases. Rather, it is believed that committees that chose to reject inclusion of a Chapter 9 reference for integrated testing did so for the purpose of rejecting NFPA 4, not basic common-sense tests to verify functionality of connected systems. 2. The proposed TIA intends to offer to the public a benefit that would lessen a recognized (known) hazard or ameliorate a continuing dangerous condition or situation. It is essential to safety for fire protection and life safety systems, including integrated features, to function as designed. Should system interactions fail, dangerous conditions can certainly result. As indicated in Item 1 above, the inclusion of integrated test requirements for some occupancies but not others conveys that integrated testing is NEVER required in occupancies that don’t include a reference to Chapter 9. However, some technical committees reportedly rejected referencing Chapter 9 for integrated testing because of the connection to NFPA 4, not because they opposed the concept of verifying basic functionality of integrated features. The proposed TIA resolves this issue by establishing a minimum requirement for ensuring basic functionality of integrated features and only referencing NFPA 4 for complex systems associated with high-rise buildings and buildings with smoke-control systems.

Submitter Information Verification

Submitter Full Name: TC ON SAF-BSF Organization: NFPA TC on Building Service and Fire Protection Equipment Street Address: City: State: Zip: Submittal Date: Mon Mar 05 14:25:37 EST 2018 Committee: SAF-BSF

Committee Statement

Resolution: The TC reaffirmed the existing language in Chapter 9 related to Integrated testing (from TIA 101-18-2). The TC discussed the applicability of the smoke control requirements.

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(SC 17-12-13 / TIA Log #1322)

Regulations Governing the Development of NFPA Standards Life Safety Code

1. Add new 9.3.5 to read as follows:

2. Revise 9.11.4 to read as follows:

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3. Delete A.9.11.4 and add new A.9.11.4.2 to read as follows:

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Public Input No. 142-NFPA 101-2018 [ New Section after 9.1.3.1 ]

9.1.3.1 Essential electrical systems in health care occupancies shall be maintained, tested, and inspected in accordance with NFPA 99.

Statement of Problem and Substantiation for Public Input

The NFPA 99 covers the type, class and level of systems and outlines the increased requirements for healthcare systems. This change is part of a group of changes that are being submitted to direct users to go to NFPA 99 for Essential Electrical System requirements. NFPA 110 only covers emergency and standby power systems, health care occupancies must use more robust essential electrical systems. NFPA 99 is the governing document for health care occupancies and references NFPA 110 when appropriate.

Submitter Information Verification

Submitter Full Name: Steven Spaanbroek Organization: MSL Healthcare Partners Affiliation: ASHE Street Address: City: State: Zip: Submittal Date: Wed Jun 06 15:49:54 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: Requirements for essential electrical equipment are already covered in 18/19.5.1.4 and 18/19.5.1.3. Chapter 9 typically does not include occupancy specific requirements. (Note: See FR-6864 on 18.5.1.4 and FR-6865 on 19.5.1.3 by the TC on Health Care Occupancies.)

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Public Input No. 341-NFPA 101-2018 [ Section No. 9.1.3.1 ]

9.1.3.1 Emergency generators and standby power systems shall be installed, inspected, tested, and maintained in accordance with NFPA 110.

Statement of Problem and Substantiation for Public Input

Emergency and standby power systems require inspections to assist reliability and operational success. Inspections are an integral component of NFPA 110 section 8.4. Recommend inclusion of the "inspection" activity to improve consistency with other ITM activities common to critical building service utilities.

Submitter Information Verification

Submitter Full Name: David Soens Organization: Wisconsin Department Of Health Street Address: City: State: Zip: Submittal Date: Tue Jun 26 09:35:43 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6538-NFPA 101-2018 Statement: Emergency and standby power systems require inspections to assist reliability and operational success. Inspections are an integral component of NFPA 110 section 8.4. Inclusion of the "inspection" activity will improve consistency with other sections in this code and with ITM activities common to critical building service utilities.

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Public Input No. 344-NFPA 101-2018 [ Section No. 9.1.4 ]

9.1.4 Stored Electrical Energy Systems. Stored electrical energy systems shall be installed, inspected, tested, and maintained in accordance with NFPA 111.

Statement of Problem and Substantiation for Public Input

Stored electrical energy emergency and standby power systems require inspections to assist reliability and operational success. Inspections are an integral component of NFPA 111 section 8.4. Recommend inclusion of the "inspection" activity to improve consistency with other ITM activities common to critical building service utilities.

Submitter Information Verification

Submitter Full Name: David Soens Organization: Wisconsin Department Of Health Street Address: City: State: Zip: Submittal Date: Tue Jun 26 09:52:12 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6539-NFPA 101-2018 Statement: Emergency and standby power systems require inspections to assist reliability and operational success. Inspections are an integral component of NFPA 111 section 8.4. Recommend inclusion of the "inspection" activity to improve consistency with other sections in this code and with ITM activities common to critical building service utilities.

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Public Input No. 305-NFPA 101-2018 [ New Section after 9.6 ]

TITLE OF NEW CONTENT 9.6* Two-Way Radio Communication Enhancement Systems. 9.6.1 In all new and existing buildings, minimum radio signal strength for fire department communications shall be maintained at a level determined by the AHJ. 9.6.2 Where required by the AHJ, two-way radio communication enhancement systems shall comply with NFPA 1221. 9.6.3 Listing and Labeling. 9.6.3.1 Two-way radio communication enhancement systems used to comply with Section 11.10 shall be listed and labeled in accordance with ANSI/UL 2524, In-Building 2-Way Emergency Radio Communication Enhancement Systems. 9.6.4 Where a two-way radio communication enhancement system is required and such system, components, or equipment has a negative impact on the normal operations of the facility at which it is installed, the AHJ shall have the authority to approve a manually activated responder system. A.9.6 Two-way radio communication enhancement systems provide for greater flexibility and safety for emergency responders during in-building operations.

Statement of Problem and Substantiation for Public Input

This Public Input seeks to: 1. Ensure reliable emergency responder communications in new buildings when the authority having jurisdiction determines the building fails to meet the radio thresholds specified in NFPA 1221. 2. Correlate the requirements for two-way radio communication enhancement systems with section 11.10 of NFPA 1 and section 510 of the International Fire Code.

Two-way radio communication enhancement systems are designed to protect life and property by assuring effective public safety radio communications among emergency response personnel during fire and all other emergencies.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 308-NFPA 101-2018 [New Section after 2.3.9]

Submitter Information Verification

Submitter Full Name: Alan Perdue Organization: Safer Buildings Coalition Affiliation: Safer Buildings Coalition Street Address: City: State: Zip: Submittal Date: Mon Jun 25 08:17:17 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6540-NFPA 101-2018

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Statement: This revision seeks to:

1. Ensure reliable emergency responder communications in new buildings when the authority having jurisdiction determines the building fails to meet the radio thresholds specified in NFPA 1221.

2. Correlate the requirements for two-way radio communication enhancement systems with section 11.10 of NFPA 1 and section 510 of the International Fire Code.

This revision is supported by 1.1.8 and 1.1.8 of the Code. Life safety in buildings includes more than safety from fire. Although fire safety has been the long-standing focus of NFPA 101, its widely known title, Life Safety Code, and its technical requirements respond to a wider range of concerns, including, for example, crowd safety. Code requirements that contribute to the safe movement of people during fire emergencies might also assist in responding to many other hazards that require decisions about where people can be safely located.

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Public Input No. 6-NFPA 101-2018 [ New Section after 9.6.1.3 ]

9.6.1.3.1 An approved existing installation shall be permitted to be continued in use and shall comply with Section 9.6.1.4.

Statement of Problem and Substantiation for Public Input

This section is existing language currently in 9.6.1.3 and is proposed as a sub-section to provide greater clarity and accuracy with regard to the Code's intent for existing fire alarm systems. (See substantiation for PI 5).

This new sub-section takes that same language and links it to the next section to ensure that the reader understands that a testing and maintenance program applies to both new and existing systems.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 5-NFPA 101-2018 [Section No. 9.6.1.3] Public Input No. 5-NFPA 101-2018 [Section No. 9.6.1.3]

Submitter Information Verification

Submitter Full Name: Joe Scibetta Organization: BuildingReports Street Address: City: State: Zip: Submittal Date: Mon Jan 22 11:20:35 EST 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6541-NFPA 101-2018 Statement: This revisions provides clarity for existing installations and editorially corrects an exception in section 9.1.6.3.

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Public Input No. 5-NFPA 101-2018 [ Section No. 9.6.1.3 ]

9.6.1.3 Fire alarm systems required by this Code shall be installed, tested, and maintained in accordance with the applicable requirements of NFPA 70 and NFPA 72 unless it is an approved existing installation, which shall be permitted to be continued in use .

Statement of Problem and Substantiation for Public Input

The conditional phrase at the end of this section implies that inspection, testing and maintenance requirements only apply to new systems and that existing systems shall simply be permitted to be continued in use without adhering to the requirements for testing and maintenance per NFPA 72. A related PI will move this language to its own section making it clearer that existing systems must also be tested and maintained if permitted to continue being utilized.

While Section 9.6.1.4 addresses the requirement for a maintenance and testing program, "the fire alarm system" mentioned in that section applies to new system installations required by the current edition of NFPA 101 per 9.6.1.3, not existing systems.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 6-NFPA 101-2018 [New Section after 9.6.1.3] Public Input No. 6-NFPA 101-2018 [New Section after 9.6.1.3]

Submitter Information Verification

Submitter Full Name: Joe Scibetta Organization: BuildingReports Street Address: City: State: Zip: Submittal Date: Mon Jan 22 11:08:11 EST 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6541-NFPA 101-2018 Statement: This revisions provides clarity for existing installations and editorially corrects an exception in section 9.1.6.3.

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Public Input No. 199-NFPA 101-2018 [ Section No. 9.6.2.10 ]

9.6.2.10 Smoke Alarms. 9.6.2.10.1 Where required by another section of this Code, single-station and multiple-station smoke alarms shall be in accordance with NFPA 72 unless otherwise provided in 9.6.2.10.3, 9.6.2.10.4, 9.6.2.10. 6 5, or 9.6.2.10.7 or 9 .6.2.10.8. 9.6.2.10.2 Where automatic smoke detection is required by Chapters 11 through 43, smoke alarms shall not be used as a substitute. 9.6.2.10.3* Where required by Chapters 11 through 43, the audible alarm notificaiton signal provided in sleeping rooms that is activated by smoke alarms shall be a 520 Hz low-fregquency signal complying NFPA 72. 9.6.2.10.4* The interconnection of smoke alarms shall apply only to new construction as provided in 9.6.2.10.9. 9.6.2.10. 4 * 5 Unless otherwise provided in 9.6.2.10.6, smoke alarms and smoke detectors shall not be installed within an area of exclusion determined by a 10 ft (3.0 m) radial distance along a horizontal flow path from a stationary or fixed cooking appliance, unless listed for installation in close proximity to cooking appliances. Smoke alarms and smoke detectors installed between 10 ft (3.0 m) and 20 ft (6.1 m) along a horizontal flow path from a stationary or fixed cooking appliance shall be equipped with an alarm-silencing means or use photoelectric detection. [72:29.8.3.4(4)] 9.6.2.10. 5 6 Smoke alarms or smoke detectors that use photoelectric detection shall be permitted for installation at a radial distance greater than 6 ft (1.8 m) from any stationary or fixed cooking appliance when the following conditions are met: (1) The kitchen or cooking area and adjacent spaces have no clear interior partitions or headers. (2) The 10 ft (3.0 m) area of exclusion would prohibit the placement of a smoke alarm or smoke detector required by other sections of NFPA 72. [72:29.8.3.4(4)] 9.6.2.10. 6 * 7 Smoke alarms and smoke detectors shall not be installed within a 36 in. (910 mm) horizontal path from a door to a bathroom containing a shower or tub unless listed for installation in close proximity to such locations. [72:29.8.3.4(6)] 9.6.2.10. 7 8 System smoke detectors in accordance with NFPA 72 and arranged to function in the same manner as single-station or multiple-station smoke alarms shall be permitted in lieu of smoke alarms. 9.6.2.10.8 9 Smoke alarms, other than battery-operated smoke alarms as permitted by other sections of this Code, shall be powered in accordance with the requirements of NFPA 72. 9.6.2.10.9 10 * In new construction, where two or more smoke alarms are required within a dwelling unit, suite of rooms, or similar area, they shall be arranged so that operation of any smoke alarm shall cause the alarm in all smoke alarms within the dwelling unit, suite of rooms, or similar area to sound, unless otherwise permitted by one of the following: (1) The requirement of 9.6.2.10.9 shall not apply where permitted by another section of this Code. (2) The requirement of 9.6.2.10.9 shall not apply to configurations that provide equivalent distribution of the alarm signal.

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9.6.2.10. 10 11 The alarms described in 9.6.2.10.9 shall sound only within an individual dwelling unit, suite of rooms, or similar area and shall not actuate the building fire alarm system, unless otherwise permitted by the authority having jurisdiction. 9.6.2.10.11 12 Smoke alarms shall be permitted to be connected to the building fire alarm system for the purpose of annunciation in accordance with NFPA 72.

Statement of Problem and Substantiation for Public Input

This Public Input seeks to accomplish the following: 1. Correlate the carbon monoxide (CO) detection requirements for Board and Care facilities with those in Chapter 28 and Chapter 30 of the Code. 2. Require CO detectors to be installed in locations that are remote and normally unoccupied from occupied areas. Requiring only CO detectors to be installed in locations that are remote from occupied areas will: 1. Enhance public life safety by notifying a responsible party of a malfunctioning fuel–burning appliance installed in a normally unoccupied location 2. Clarify the locations where CO alarms can be installed in accordance with their ANSI/UL2034 listings, which is only in ordinary indoor locations of dwelling units.

This Public Input seeks to enhance the waking effectiveness of high risk segments of the population by providing a requirement for the 520 Hz low frequency audible fire alarm signal in sleeping rooms for occupancies where required Chapters 11 through 43. The reason this Public Input is necessary is because NFPA 72 stipulates both the 520 Hz and 3 KHz signal in the sleeping rooms of hotels, dormitories and apartment building bedrooms when smoke alarms are installed in the sleeping room. Specifically, Chapter 18 of NFPA 72 requires audible notification appliances (horns, speakers or smoke detectors with an integral sounder bases) to produce the 520 Hz low frequency signal in all sleeping rooms of buildings with a protected premises fire alarm system. Whereas Chapter 29 of NFPA 72 only requires smoke alarms to produce the 520 Hz low frequency signal for people with hearing loss or provided voluntarily for those with hearing loss.

The different requirements within NFPA 72 present a life safety issue because peer-reviewed research has concluded the wakening effectiveness of the 520 Hz low frequency is superior to 3 KHz audible alarm signal awakening high risk segments of the population. Peer-reviewed research has concluded the 520 Hz low frequency is six times more effective than the standard 3 KHz signal at waking high risk segments of the population (people over 65, people who are hard of hearing, school age children and people who are alcohol impaired). The standard 3 KHz audible alarm signal has been used in most fire alarm horns and smoke alarms for the past 30 years. The low frequency signal needs to be provided in areas intended for sleeping to protect people over 65, people who are hard of hearing, school age children and people who are alcohol impaired.

The Public Input does not require the low frequency technology in buildings without a fire alarm system because there are no smoke alarms currently available with an integral sounder capable of producing the low frequency signal. However, it does not prohibit their installation if the product becomes available in the future. The reason the Public Input does require the low frequency signal in sleeping areas within hotels and dormitories with a fire alarm system is because there are numerous manufacturers of system connected smoke detectors with an integral sounder that produces the 520 Hz low frequency signal.

Submitter Information Verification

Submitter Full Name: Vince Baclawski Organization: Nema Street Address: City: State: Zip: Submittal Date: Fri Jun 15 09:42:23 EDT 2018 Committee: SAF-BSF

Committee Statement

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Resolution: FR-6582-NFPA 101-2018 Statement: This revision seeks to enhance the waking effectiveness of high risk segments of the population by providing a requirement for the 520 Hz low frequency audible fire alarm signal in sleeping rooms for occupancies where required Chapters 11 through 43. The reason this change is necessary is because NFPA 72 stipulates both the 520 Hz and 3 KHz signal in the sleeping rooms of hotels, dormitories and apartment building bedrooms when smoke alarms are installed in the sleeping room. Specifically, Chapter 18 of NFPA 72 requires audible notification appliances (horns, speakers or smoke detectors with an integral sounder bases) to produce the 520 Hz low frequency signal in all sleeping rooms of buildings with a protected premises fire alarm system. Whereas Chapter 29 of NFPA 72 only requires smoke alarms to produce the 520 Hz low frequency signal for people with hearing loss or provided voluntarily for those with hearing loss. The different requirements within NFPA 72 present a life safety issue because peer-reviewed research has concluded the wakening effectiveness of the 520 Hz low frequency is superior to 3 KHz audible alarm signal awakening high risk segments of the population. Peer-reviewed research has concluded the 520 Hz low frequency is six times more effective than the standard 3 KHz signal at waking high risk segments of the population (people over 65, people who are hard of hearing, school age children and people who are alcohol impaired). The standard 3 KHz audible alarm signal has been used in most fire alarm horns and smoke alarms for the past 30 years. The low frequency signal needs to be provided in areas intended for sleeping to protect people over 65, people who are hard of hearing, school age children and people who are alcohol impaired. The revision does not require the low frequency technology in buildings without a fire alarm system because there are no smoke alarms currently available with an integral sounder capable of producing the low frequency signal. However, it does not prohibit their installation if the product becomes available in the future. The reason the revision does require the low frequency signal in sleeping areas within hotels and dormitories with a fire alarm system is because there are numerous manufacturers of system connected smoke detectors with an integral sounder that produces the 520 Hz low frequency signal.

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Public Input No. 200-NFPA 101-2018 [ Section No. 9.6.3 ]

9.6.3 Occupant Notification. 9.6.3.1 Occupant notification shall be provided to alert occupants of a fire or other emergency where required by other sections of this Code. 9.6.3.2 Occupant notification shall be in accordance with 9.6.3.3 through 9.6.3.10.2, unless otherwise provided in 9.6.3.2.1 through 9.6.3.2.4. 9.6.3.2.1* Elevator lobby, hoistway, and associated machine room smoke detectors used solely for elevator recall, and heat detectors used solely for elevator power shutdown, shall not be required to activate the building evacuation alarm if the power supply and installation wiring to such detectors are monitored by the building fire alarm system, and if the activation of such detectors initiates a supervisory signal at a constantly attended location. 9.6.3.2.2* Smoke detectors used solely for closing dampers or heating, ventilating, and air-conditioning system shutdown shall not be required to activate the building evacuation alarm, provided that the power supply and installation wiring to the detectors are monitored by the building fire alarm system, and the activation of the detectors initiates a supervisory signal at a constantly attended location. 9.6.3.2.3* Smoke detectors located at doors for the exclusive operation of automatic door release shall not be required to activate the building evacuation alarm, provided that the power supply and installation wiring to the detectors are monitored by the building fire alarm system, and the activation of the detectors initiates a supervisory signal at a constantly attended location. 9.6.3.2.4 Detectors in accordance with 22.3.4.3.1(2) and 23.3.4.3.1(2) shall not be required to activate the building evacuation alarm. 9.6.3.3 Where required by Chapters 11 through 43, the audible alarm notification signal provided in sleeping rooms that is activated by the fire alarm system or smoke alarms shall be a 520 Hz low-frequency signal complying with NFPA 72. 9.6.3.4 Where permitted by Chapters 11 through 43, a presignal system shall be permitted where the initial fire alarm signal is automatically transmitted without delay to a municipal fire department, to a fire brigade (if provided), and to an on-site staff person trained to respond to a fire emergency. 9.6.3. 4 5 Where permitted by Chapters 11 through 43, a positive alarm sequence shall be permitted, provided that it is in accordance with NFPA 72. 9.6.3.5 6 Unless otherwise provided in 9.6.3.5.1 through 9.6.3.5.8, notification signals for occupants to evacuate shall be by audible and visible signals in accordance with NFPA 72 and ICC/ANSI A117.1, Accessible and Usable Buildings and Facilities, or other means of notification acceptable to the authority having jurisdiction. 9.6.3.5.1 Areas not subject to occupancy by persons who are hearing impaired shall not be required to comply with the provisions for visible signals.

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9.6.3.5.2 Visible-only signals shall be provided where specifically permitted in health care occupancies in accordance with Chapters 18 and 19. 9.6.3.5.3 Existing alarm systems shall not be required to comply with the provision for visible signals. 9.6.3.5.4 Visible signals shall not be required in lodging or rooming houses in accordance with Chapter 26. 9.6.3.5.5 Visible signals shall not be required in exit stair enclosures. 9.6.3.5.6 Visible signals shall not be required in elevator cars. 9.6.3.5.7* Public mode visual notification appliances in accordance with NFPA 72 shall not be required in designated areas as permitted by Chapters 11 through 43, provided that they are replaced with approved alternative visible means. 9.6.3.5.8* Where visible signals are not required, as permitted by 9.6.3.5.7, documentation of such omission shall be maintained in accordance with 9.13.3. 9.6.3.6 The general evacuation alarm signal shall operate in accordance with one of the methods prescribed by 9.6.3.6.1 through 9.6.3.6.3. 9.6.3.6.1 The general evacuation alarm signal shall operate throughout the entire building other than the locations described in 9.6.3.6.4 and 9.6.3.6.5. 9.6.3.6.2* Where total evacuation of occupants is impractical due to building configuration, only the occupants in the affected zones shall be initially notified, and provisions shall be made to selectively notify occupants in other zones to afford orderly evacuation of the entire building, provided that such arrangement is approved by the authority having jurisdiction. 9.6.3.6.3 Where occupants are incapable of evacuating themselves because of age, physical or mental disabilities, or physical restraint, all of the following shall apply: (1) The private operating mode, as described in NFPA 72 shall be permitted to be used. (2) Only the attendants and other personnel required to evacuate occupants from a zone, area, floor, or building shall be required to be notified. (3) Notification of personnel as specified in 9.6.3.6.3(2) shall include means to readily identify the zone, area, floor, or building in need of evacuation. 9.6.3.6.4 The general evacuation signal shall not be required in exit stair enclosures. 9.6.3.6.5 The general evacuation signal shall not be required in elevator cars. 9.6.3.7 Audible alarm notification appliances shall be of such character and so distributed as to be effectively heard above the average ambient sound level that exists under normal conditions of occupancy. 9.6.3.8 Audible alarm notification appliances shall produce signals that are distinctive from audible signals used for other purposes in a given building. 9.6.3.9

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Automatically transmitted or live voice evacuation or relocation instructions shall be permitted to be used to notify occupants and shall comply with either 9.6.3.9.1 or 9.6.3.9.2. 9.6.3.9.1 Automatically transmitted or live voice evacuation or relocation instructions shall be in accordance with NFPA 72. 9.6.3.9.2* Where permitted by Chapters 11 through 43, automatically transmitted or live voice announcements shall be permitted to be made via a voice communication or public address system that complies with all of the following: (1) Occupant notification, either live or recorded, shall be initiated at a constantly attended receiving station by personnel trained to respond to an emergency. (2) An approved secondary power supply shall be provided for other than existing, previously approved systems. (3) The system shall be audible above the expected ambient noise level. (4) Emergency announcements shall take precedence over any other use. 9.6.3.10 Unless otherwise permitted by another section of this Code, audible and visible fire alarm notification appliances shall comply with either 9.6.3.10.1 or 9.6.3.10.2. 9.6.3.10.1 Audible and visible fire alarm notification appliances shall be used only for fire alarm system or other emergency purposes. 9.6.3.10.2 Emergency voice/alarm communication systems shall be permitted to be used for other purposes in accordance with NFPA 72.

Statement of Problem and Substantiation for Public Input

The Public Input does not require the low frequency technology in buildings without a fire alarm system because

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there are no smoke alarms currently available with an integral sounder capable of producing the low frequency signal. However, it does not prohibit their installation if the product becomes available in the future. The reason the Public Input does require the low frequency signal in sleeping areas within hotels and dormitories with a fire alarm system is because there are numerous manufacturers of system connected smoke detectors with an integral sounder that produces the 520 Hz low frequency signal.

Submitter Information Verification

Submitter Full Name: Vince Baclawski Organization: Nema Street Address: City: State: Zip: Submittal Date: Fri Jun 15 09:55:14 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6583-NFPA 101-2018 Statement: This revision seeks to enhance the waking effectiveness of high risk segments of the population by providing a requirement for the 520 Hz low frequency audible fire alarm signal in sleeping rooms for occupancies where required Chapters 11 through 43. The reason this change is necessary is because NFPA 72 stipulates both the 520 Hz and 3 KHz signal in the sleeping rooms of hotels, dormitories and apartment building bedrooms when smoke alarms are installed in the sleeping room. Specifically, Chapter 18 of NFPA 72 requires audible notification appliances (horns, speakers or smoke detectors with an integral sounder bases) to produce the 520 Hz low frequency signal in all sleeping rooms of buildings with a protected premises fire alarm system. Whereas Chapter 29 of NFPA 72 only requires smoke alarms to produce the 520 Hz low frequency signal for people with hearing loss or provided voluntarily for those with hearing loss. The different requirements within NFPA 72 present a life safety issue because peer-reviewed research has concluded the wakening effectiveness of the 520 Hz low frequency is superior to 3 KHz audible alarm signal awakening high risk segments of the population. Peer-reviewed research has concluded the 520 Hz low frequency is six times more effective than the standard 3 KHz signal at waking high risk segments of the population (people over 65, people who are hard of hearing, school age children and people who are alcohol impaired). The standard 3 KHz audible alarm signal has been used in most fire alarm horns and smoke alarms for the past 30 years. The low frequency signal needs to be provided in areas intended for sleeping to protect people over 65, people who are hard of hearing, school age children and people who are alcohol impaired. The revision does not require the low frequency technology in buildings without a fire alarm system because there are no smoke alarms currently available with an integral sounder capable of producing the low frequency signal. However, it does not prohibit their installation if the product becomes available in the future. The reason the revision does require the low frequency signal in sleeping areas within hotels and dormitories with a fire alarm system is because there are numerous manufacturers of system connected smoke detectors with an integral sounder that produces the 520 Hz low frequency signal.

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Public Input No. 527-NFPA 101-2018 [ New Section after 9.6.4.2 ]

TITLE OF NEW CONTENT Monitor It Yourself (MIY) Systems The use of a MIY system that can transmit directly to an Emergency Forces Call Centre shal not be permitted unless approved by the AHJ.

Statement of Problem and Substantiation for Public Input

With changing technology and the Internet of Things (IoT), it is now possible to have a fire alarm system transmit signals directly from the protected premise to a Emergency Forces Call Centre without being process by a Supervising, Proprietary or Remote Station in accordance with NFPA 72. These are the modern versions of the former tape dialers. There is nothing with the Code at the present time that specifically prohibits their use. These systems have the potential of increasing Unwanted Alarms. This Public Input, if accepted, would only allow the use of these systems to be used if the AHJ for the fire department, fire district or government authority allows their use.

Submitter Information Verification

Submitter Full Name: Shane Clary Organization: Bay Alarm Company Affiliation: Bay Alarm Company Street Address: City: State: Zip: Submittal Date: Wed Jun 27 22:08:53 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6542-NFPA 101-2018 Statement: With changing technology and the Internet of Things (IoT), it is now possible to have a fire alarm system transmit signals directly from the protected premise to a Emergency Forces Call Center without being processed by a Supervising, Proprietary or Remote Station in accordance with NFPA 72. These are the modern versions of the former tape dialers. There is nothing within the Code at the present time that specifically prohibits their use. These systems have the potential of increasing unwanted alarms. This revision would only allow the use of these systems to be used if the AHJ for the fire department, fire district or government authority allows their use.

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Public Input No. 107-NFPA 101-2018 [ New Section after 9.7.2.1.2 ]

9.7.2.1.3 Supervision of valves between connections to water supplies and the protected building shall be permitted to be in accordance with NFPA 13 in lieu of monitoring in accordance with NFPA 72 with a supervisory signal.

Statement of Problem and Substantiation for Public Input

NFPA 13 8.16.1.1.2.1 allows several options for supervision of valves in sprinkler systems, including locking the valve in the correct position. For buildings required to have a supervised automatic sprinkler system, electronic monitoring of the valves in accordance with NFPA 72 should be required in nearly all cases. The valve at the connection to the water supply, however, is often in an underground vault and may be within the public right of way, making electronic supervision difficult and expensive. In these locations, access to the valve is generally limited and the alternative supervision methods in NFPA 13, including locking the valve in the correct position, are appropriate alternatives. (Note that the reference in NFPA 13 will need to be updated once the 2019 edition of NFPA 13 is issued)

Submitter Information Verification

Submitter Full Name: John Rickard Organization: P3 Consulting Street Address: City: State: Zip: Submittal Date: Wed May 23 12:34:18 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: The proposed language would allow locking of any valve, not just inaccessible valves in a vault. NFPA 13 and NFPA 24 already state that roadway boxes are not required to be monitored.

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Public Input No. 353-NFPA 101-2018 [ Section No. 9.10 ]

9.10 Emergency Call Systems for Assisted Living and Independent Living Facilities 9.10.1 Where required in another section of this Code, Emergency Call Systems for Assisted Living and Independent Living Facilities shall be listed to UL 2560. 9.10.2 Standpipe Systems. 9.10.1 3 Where required by another section of this Code, standpipe and hose systems shall be provided in accordance with NFPA 14. 9.10.2 4 Where standpipe and hose systems are installed in combination with automatic sprinkler systems, installation shall be in accordance with the appropriate provisions established by NFPA 13 and NFPA 14.

Statement of Problem and Substantiation for Public Input

An Emergency Call System “listed” to UL 2560 provides 3rd Party tested and audited assurance of safeguards against critical hazards such as fire and electrical shock whereas, a “non-listed” system would not have been independently assessed or audited as providing such assurance. An Emergency Call System that is “not-listed” to an electrical safety standard does not provide the same level of safety and reliability as does one which has been tested, evaluated and “listed” by a Nationally Recognized Testing Laboratory (NRTL).

This proposed change does not require the installation of an Emergency Call System. However, this proposed change does require that when an Emergency Call System is installed that it be listed to a nationally recognized standard.

Submitter Information Verification

Submitter Full Name: Vince Baclawski Organization: Nema Street Address: City: State: Zip: Submittal Date: Tue Jun 26 13:26:04 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: Emergency call systems are already required by other healthcare requirements. This is outside of the scope of Chapter 9. Assisted Living and Independent Living Facilities are not an "occupancy" within NFPA 101. Chapter 9 also does not provide occupancy specific requirements. Requirements would more appropriately be put into an occupancy chapter.

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Public Input No. 174-NFPA 101-2018 [ New Section after 9.12 ]

Active Shooter Detection System Where required by another section of t his Code, active shooter detection and associated mass notification equipment shall be provided in accordance with NFPA 3000.

Statement of Problem and Substantiation for Public Input

Include a pointer to to active shooter detection within NFPA 3000

Submitter Information Verification

Submitter Full Name: Rich Onofrio Organization: Shooter Detection Systems Street Address: City: State: Zip: Submittal Date: Fri Jun 08 16:08:01 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: NFPA 3000 does not address equipment system requirements. The submitter did not provide adequate substantiation for why this should be included in 101.

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Public Input No. 30-NFPA 101-2018 [ Section No. 9.14 ]

9.14 * Risk Analysis for Mass Notification Systems. 9.14.1 Where Required. 9.14.1.1 Where required by Chapters 11 through 43 , a risk analysis for mass notification systems shall be provided in accordance with the requirements of Chapter 24 of NFPA 72 and the provisions of 9.14.2 through 9.14.4 . 9.14.1.2 Where a mass notification system is required by the risk analysis in 9.14.1.1 , the system shall be in accordance with the requirements of Chapter 24 of NFPA 72 . 9.14.2 Purpose. 9.14.2.1 The purpose of the mass notification system shall be to communicate information about emergencies including, but not limited to, fire, human-caused events (accidental and intentional), other dangerous situations, accidents, and natural disasters. 9.14.2.2 The purpose of the emergency action plan for the mass notification system shall be to identify the mass notification system design and performance requirements in accordance with the results of the risk analysis. 9.14.3 Documentation. 9.14.3.1 The emergency action plan, risk assessment report, and accompanying documentation shall be submitted to the authority having jurisdiction by the registered design professional (RDP). The format and content of the documentation shall be acceptable to the authority having jurisdiction. 9.14.3.2 * Where required by the authority having jurisdiction, an independent review of the emergency action plan, risk assessment, and the accompanying documentation by one or more individuals possessing expertise in risk characterization for accidental and intentional hazards shall be performed. 9.14.4 Emergency Action Plan. The completed emergency action plan in accordance with Section 4.8 shall be used for the design of the mass notification/emergency communications system.

Statement of Problem and Substantiation for Public Input

Section 9.14.1.1 states: “Where required by Chapters 11 through 43, a risk analysis for mass notification systems shall be provided in accordance with the requirements of Chapter 24 of NFPA 72 and the provisions of 9.14.2 through 9.14.4.” Chapter 24 of NFPA 72 has the following requirements: 24.3.11.8 The risk analysis shall consider the following types of potential events, which are not all‐inclusive but reflect the general categories that shall be considered in the risk analysis: (1) Natural hazards — Geological events (2) Natural hazards — Meteorological events (3) Natural hazards — Biological events (4) Human caused —Accidental events (5) Human caused — Intentional events (6) Technological — Caused events 24.3.11.9 The risk analysis shall include a review of the extent to which occupants and personnel are notified, based on the anticipated event (potential hazard). 24.3.11.10 The risk analysis shall be used as the basis for development of the ECS provisions of the facility emergency response plan. 24.3.12* Emergency Response Plan Elements. A well‐defined emergency response plan shall be developed in Page 24 of 27

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accordance with NFPA 1600 and NFPA 1620 as part of the design and implementation of a mass notification system.

Any consultant who performs a risk analysis based on the criteria in NFPA 72, 3.11.8 will recommend a mass notification system. If the consultant doesn’t recommend it, they will be liable if a shooting occurs on the property, even if the chances of having a shooting incident are a million to one. No consultant can say that the 6 event types in 24.3.11.8 can’t or won’t happen. Why wouldn’t the consultant recommend a system? It doesn’t cost the consultant anything to make the recommendation and the consultant will take on unnecessary liability if they don’t make the recommendation. It is the owner who will have to pay for the system, not the consultant.

The owner should not be mandated to install a mass notification system that will not prevent evil individuals from shooting people as happened many times in the recent past. Communication by social media (phones) will provide better communication most of the time than the expensive mass notification system that is mandated by this section.

No mass communication system installation would have prevented any of the deaths that happened at Florida in Jan 2018, Aurora, CO. Theater 2012; Columbine 1999; Virginia Tech 2007; or Sandy Hook 2012. Requiring a mass notification system will not prevent these incidents and to mandate a risk analysis that will require a mass notification system will not prevent these types of incidents from occurring.

If an owner wants a mass notification system, nothing prohibits an owner from installing one even with this section deleted from NFPA 101.

Submitter Information Verification

Submitter Full Name: Peter Larrimer Organization: US Department of Veterans Affa Street Address: City: State: Zip: Submittal Date: Tue Feb 27 11:03:24 EST 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6584-NFPA 101-2018 Statement: Many of the existing requirements for mass notification systems are already covered in NFPA 72. This revision seeks to clean up the language, making it easier to find the requirements within 72. A task group worked during the meeting to develop this language and has been assigned to continue working to develop examples of risk analysis levels for the Second Draft meeting.

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Public Input No. 321-NFPA 101-2018 [ New Section after 9.14.1.1 ]

9.14.1.2 Applicable portions of an existing risk analysis shall be permitted to be used when a new building is added to a campus.

Statement of Problem and Substantiation for Public Input

The proposed language already exists in Chapter 28 (28.3.4.4.2). However, since it is only in Chapter 28 there is an implication that the use of existing risk analyses is not permitted in the other occupancies that require a risk analysis. NFPA 72-2019 contains a similar provision that will allow the use of existing risk analyses as a baseline (24.3.12.1.1).

Alternatively, the text from paragraph 28.3.4.4.2 should be added to the other occupancy chapters. It is proposed to be added to Chapter 9 as an easier way to address the issue and one that would apply if additional occupancy chapters require a risk analysis.

Related Public Inputs for This Document

Related Input Relationship Public Input No. 322-NFPA 101-2018 [Section No. 28.3.4.4.2]

Submitter Information Verification

Submitter Full Name: William Koffel Organization: Koffel Associates, Inc. Street Address: City: State: Zip: Submittal Date: Mon Jun 25 15:45:07 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: NFPA 72 provides an allowance reusing applicable portions of an existing risk analysis. This practice is not prohibited anywhere within the codes. Adding this language may lead to people not reviewing existing risk analysis for appropriateness based on the addition of a new building.

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Public Input No. 88-NFPA 101-2018 [ Section No. A.9.7.2.1 ]

A.9.7.2.1 NFPA 72 provides details of standard practice in sprinkler supervision. Subject to the approval of the authority having jurisdiction, sprinkler supervision is also permitted to be provided by direct connection to municipal fire departments or, in the case of very large establishments, to a private headquarters providing similar functions. NFPA 72 covers such matters. System components and parameters that are required to may be monitored should include , but should not be limited to, control valves, water tank levels and temperatures, tank pressure, and air pressure on dry-pipe valves. Where municipal fire alarm systems are involved, reference should also be made to NFPA 1221.

Statement of Problem and Substantiation for Public Input

The deleted text implied that these components were required. They are not necessarily required to be installed or supervised.

Submitter Information Verification

Submitter Full Name: Peter Leszczak Organization: PSL Engineering LLC Street Address: City: State: Zip: Submittal Date: Tue Apr 24 12:08:04 EDT 2018 Committee: SAF-BSF

Committee Statement

Resolution: FR-6543-NFPA 101-2018 Statement: The existing annex note does not provide any additional information that is not already addressed in the body of the Code.

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