Icc Codes - Public Comment Form s1

ICC CODES - PUBLIC COMMENT FORM FOR PUBLIC COMMENTS ON THE 2012 REPORT OF THE PUBLIC HEARINGS ON THE 2012 EDITIONS OF:

International Building Code© Fire Safety (FS) General (G) Means of Egress (E) Structural (S) International Fuel Gas Code© (FG) International Mechanical Code© (M) International Plumbing Code© (P) International Private Sewage Disposal Code© (PSD)

CLOSING DATE: All Comments Must Be Received by: August 1, 2012

1) Please type or print clearly: Public comments will be returned if they contain unreadable information.

Name: Jonathan Siu Date: 6/28/2012 Jurisdiction/Company: City of Seattle, Department of Planning & Development Submitted on Behalf of: Washington Association of Building Officials, Technical Code Development Committee Address: 700-5th Ave, Ste 2000; PO Box 34019 City: Seattle State: WA Zip +4: 98124-4019 Phone: 206-233-5163 Ext: Fax: 206-386-4039 e-mail: [email protected]

2) Copyright Release: In accordance with Council Policy #28 Code Development, all Code Change Proposals, Floor Modifications and Public Comments are required to include a copyright release. A copy of the copyright release form is included at the end of this form. Please follow the directions on the form. This form as well as an alternative release form can also be downloaded from the ICC website at www.iccsafe.org. If you have previously executed the copyright release, please check the box below: X 2012-2014 Cycle copyright release on file

3) Code Change Proposal Number: Indicate the Code Change Proposal Number that is being addressed by this Public Comment: __G110-12

4) Public Comment: The Final Action requested on this Code Change Proposal is: (Check Box) Approved as Modified Approved as Modified by Approved as Modified by Approved as by this Public Comment the Code Committee as Assembly Floor Action as Disapproved (D): Submitted (AS): X (AMPC): Published in the ROH (AM): Published in the ROH (AMF):

Attached Proposed Modifications and/or Reason Statements:

See Attached Individual Consideration Form

PLEASE USE SEPARATE FORM FOR EACH PUBLIC COMMENT SUBMITTAL AS A DOCUMENT ATTACHED TO AN EMAIL IS PREFERRED SEE BACK OF FORM FOR DIRECTIONS ON WHERE TO SEND PUBLIC COMMENTS PUBLIC COMMENTS SHOULD BE SENT TO THE FOLLOWING OFFICE VIA REGULAR MAIL OR EMAIL. AN EMAIL SUBMITTAL IS PREFERRED, INCLUDING AN ELECTRONIC VERSION IN MS WORD. THE ONLY FORMATTING THAT IS NEEDED IS BOLDING, STRIKEOUT OR UNDERLINING. PLEASE DO NOT PROVIDE ADDITIONAL FORMATTING SUCH AS: TABS, COLUMNS, ETC., AS THIS WILL BE DONE BY ICC. ALL PUBLIC COMMENTS RECEIVED WILL RECEIVE AN ACKNOWLEDGEMENT.

IF YOU DO NOT RECEIVE AN ACKNOWLEDGEMENT BY AUGUST 15, 2012, PLEASE CONTACT MANAGER OF CODES AT 888-ICC-SAFE, EXTENSION 4323 OR STAFF ADMINISTRATIVE ASSISTANT AT 4727.

Acronym ICC Code Name (Code change number prefix) Group A Group B Group C Send to: IBC - International Building Code IADMIN – International Administrative Code IgCC – International Green International Code Council IFGC - International Fuel Gas (Chapter 1 of I-Codes except the IRC and Construction Code Chicago District Office Code the IECC, and Referenced Standards Attn: Dynice Broadnax IMC - International Mechanical Updates) 4051 West Flossmoor Road Code IEBC - International Existing Building Code Country Club Hills, IL 60478- IPC - International Plumbing Code IECC - International Energy Conservation 5795 IPSDC - International Private Code Fax: 708/799-0320 Sewage Disposal Code IFC - International Fire Code [email protected] ICC PC - ICC Performance Code IPMC - International Property Maintenance Code IRC - International Residential Code ISPSC – International Swimming Pool and Spa Code IWUIC - International Wildland-Urban Interface Code IZC - International Zoning Code

The following procedures are excerpts from the CP#28 Code Development. The full procedures can be downloaded from the ICC website at www.iccsafe.org.

6.0 Public Comments

6.1 Intent: The public comment process gives attendees at the Final Action Hearing an opportunity to consider specific objections to the results of the public hearing and more thoughtfully prepare for the discussion for Final Action Consideration. The public comment process expedites the Final Action Consideration at the Final Action Hearing by limiting the items discussed to the following:

6.1.1 Consideration of items for which a public comment has been submitted; and 6.1.2 Consideration of items which received a successful assembly action at the public hearing.

6.2 Deadline: The deadline for receipt of a public comment to the results of the public hearing shall be announced at the public hearing but shall not be less than 30 days from the availability of the report of the results of the public hearing (see Section 5.8).

6.3 Withdrawal of Public Comment: A public comment may be withdrawn by the public commenter at any time prior to Final Action Consideration of that comment. A withdrawn public comment shall not be subject to Final Action Consideration. If the only public comment to a code change proposal is withdrawn by the public commenter prior to the vote on the consent agenda in accordance with Section 7.3.4, the proposal shall be considered as part of the consent agenda. If the only public comment to a code change proposal is withdrawn by the public commenter after the vote on the consent agenda in accordance with Section 7.3.4, the proposal shall continue as part of the individual consent agenda in accordance with Section 7.3.5, however the public comment shall not be subject to Final Action Consideration.

6.4 Form and Content of Public Comments: Any interested person, persons, or group may submit a public comment to the results of the public hearing which will be considered when in conformance to these requirements. Each public comment to a code change proposal shall be submitted separately and shall be complete in itself. Each public comment shall contain the following information:

6.4.1 Public comment: Each public comment shall include the name, title, mailing address, telephone number and email address of the public commenter. Email addresses shall be published with the public comments unless the commenter otherwise requests on submittal form. If group, organization, or committee submits a public comment, an individual with prime responsibility shall be indicated. If a public comment is submitted on behalf a client, group, organization or committee, the name and mailing address of the client, group, organization or committee shall be indicated. The scope of the public comment shall be consistent with the scope of the original code change proposal, committee action or successful assembly action. Public comments which are determined as not within the scope of the code change proposal, committee action or successful assembly action shall be identified as such. The public commenter shall be notified that the public comment is considered an incomplete public comment in accordance with Section 6.5.1 and the public comment shall be held until the deficiencies are corrected. A copyright release in accordance with Section 3.3.4.5 shall be provided with the public comment.

6.4.2 Code Reference: Each public comment shall include the code change proposal number and the results of the public hearing, including successful assembly actions, on the code change proposal to which the public comment is directed.

6.4.3 Multiple public comments to a code change proposal. A proponent shall not submit multiple public comments to the same code change proposal. When a proponent submits multiple public comments to the same code change proposal, the public comments shall be considered as incomplete public comments and processed in accordance with Section 6.5.1. This restriction shall not apply to public comments that attempt to address differing subject matter within a code section.

6.4.4 Desired Final Action: The public comment shall indicate the desired final action as one of the following:

1. Approve the code change proposal as submitted (AS), or 2. Approve the code change proposal as modified (AM) by one or more specific modifications published in the Results of the Public Hearing or published in a public comment, or 3. Disapprove the code change proposal (D)

6.4.5 Supporting Information: The public comment shall include in a statement containing a reason and justification for the desired final action on the code change proposal. Reasons and justification which are reviewed in accordance with Section 6.4 and determined as not germane to the technical issues addressed in the code change proposal or committee action may be identified as such. The public commenter shall be notified that the public comment is considered an incomplete public comment in accordance with Section 6.5.1 and the public comment shall be held until the deficiencies are corrected. The public commenter shall have the right to appeal this action in accordance with the policy of the ICC Board. A bibliography of any substantiating material submitted with a public comment shall be published with the public comment and the substantiating material shall be made available at the Final Action Hearing. All substantiating material published by ICC is material that has been provided by the proponent and in so publishing ICC makes no representations or warranties about its quality or accuracy.

6.4.6 Number: One copy of each public comment and one copy of all substantiating information shall be submitted. Additional copies may be requested when determined necessary by the Secretariat. A copy of the public comment in electronic form is preferred.

6.5 Review: The Secretariat shall be responsible for reviewing all submitted public comments from an editorial and technical viewpoint similar to the review of code change proposals (See Section 4.2).

6.5.1 Incomplete Public Comment: When a public comment is submitted with incorrect format, without the required information or judged as not in compliance with these Rules of Procedure, the public comment shall not be processed. The Secretariat shall notify the public commenter of the specific deficiencies and the public comment shall be held until the deficiencies are corrected, or the public comment shall be returned to the public commenter with instructions to correct the deficiencies with a final date set for receipt of the corrected public comment.

6.5.2 Duplications: On receipt of duplicate or parallel public comments, the Secretariat may consolidate such public comments for Final Action Consideration. Each public commenter shall be notified of this action when it occurs.

6.5.3 Deadline: Public comments received by the Secretariat after the deadline set for receipt shall not be published and shall not be considered as part of the Final Action Consideration.

6.6 Publication: The public hearing results on code change proposals that have not been public commented and the code change proposals with public commented public hearing results and successful assembly actions shall constitute the Final Action Agenda. The Final Action Agenda shall be posted on the ICC website at least 30 days prior to Final Action consideration. INDIVIDUAL CONSIDERATION FORM

G110-12 (Insert Code Change Number) 505.3, Table 601

Individual Consideration Agenda

This item is on the agenda for individual consideration because a public comment was submitted.

Public Comment:

Name: Jonathan Siu, City of Seattle Dept of Planning & Development, representing WABO Technical Code Development Committee

Modify the proposal as follows (Only if AMPC is desired. If no modification is requested, enter your reason statement in “Commenter’s Reason”):

Replace proposal with the following (modify Section 505.3 and add footnotes h and i to Table 601):

505.3 Equipment platforms. Equipment platforms in buildings shall not be considered as a portion of the floor below. Such equipment platforms shall not contribute to either the building area or the number of stories as regulated by Section 503.1. The area of the equipment platform shall not be included in determining the fire area in accordance with Section 903. Equipment platforms shall not be a part of any mezzanine and such platforms and the walkways, stairs, alternating tread devices and ladders providing access to an equipment platform shall not serve as a part of the means of egress from the building. Equipment platforms and their supporting construction shall comply with the fire-resistance rating requirements for floor construction in Table 601.

TABLE 601 FIRE-RESISTANCE RATING REQUIREMENTS FOR BUILDING ELEMENTS (HOURS) TYPE I TYPE II TYPE III TYPE IV TYPE V BUILDING ELEMENT A B Ad B Ad B HT Ad B (No change) (No change) (No change) (No change) Floor construction and associated 2h 2h 1 0 1 0 HT 1 0 secondary members (see Section 202)i (No change) a – g. (no change) h. The fire-resistance rating for equipment platforms constructed in accordance with Section 505.3 need not exceed 1 hour. i. Equipment platforms with no occupied space between the platform and the floor/ceiling assembly immediately below are permitted to be of unprotected construction.

Commenter=s Reason:

The code is ambiguous as to the requirements for fire-resistance rated construction for equipment platforms. Interpreting the code to require them to meet the floor construction requirements would mean they would need a 2-hour rating in Types IA and IB construction, which seems to be onerous.

The Fire Safety Committee disapproved the originally submitted proposal consistent with their action on a related proposal for mezzanines (G109-12). The implication is they felt there should be a better relationship to Section 601 (rather than modifying Section 601 in the equipment platform section), and because the original proposal did not deal with heavy timber construction. In response to the committee comments, we are now proposing the allowances for the 1-hour fire resistance rating for equipment platforms be placed in footnote to Table 601. The footnote only applies to Types IA and IB construction, since they are the only types of construction that need the allowance. The result is equipment platforms in types of construction other than Types IA and IB merely conform to the requirements for that particular type of construction. In addition, a second footnote applying to all types of construction is added to allow unprotected construction, if there is no occupiable space immediately below the equipment platform. This allows equipment to be placed on raised platforms without requiring them to be fire-resistance rated, if the platforms are not overhead. This will accomplish the intent of the original proposal in a simple, direct manner.

It is to be noted that the cross-reference to Table 601 in the proposed new text in Section 505.3 is necessary because the current code is not clear that equipment platforms are to be treated as floors for the purposes of type of construction. This proposal does not define equipment platforms as floors—it just says they must have a fire-resistance rating consistent with floor construction.

Note to ICC staff: if G109-12 and G110-12 are both approved as modified, footnote h on each proposal could be editorially combined into one footnote as follows:

h. The fire-resistance rating for mezzanines and equipment platforms constructed in accordance with Section 505.2 or 505.3, respectively, need not exceed 1 hour. COPYRIGHT RELEASE FOR 2012-2014 PROPOSALS, MODIFICATIONS and PUBLIC COMMENTS SUBMITTED ON ICC CODES PRODUCED & PUBLISHED BY THE

INTERNATIONAL CODE COUNCIL

This form is required for all Proposals, Floor Modifications and Public Comments submitted to the International Code Council. Only one signed Copyright release form is required for the entire 2012-2014 Cycle and will be kept on file and can be used for all Proposal, Floor Modification and Public Comment submittals you submit to ICC unless you represent multiple entities. An executed form is required for each entity represented.

I hereby grant and assign to ICC all rights in copyright I may have in any authorship contributions I make to ICC in the 2012-2014 Cycle in connection with any proposal and public comment, in its original form submitted or revised form, including written and verbal modifications submitted in accordance with Section 5.5.2 of CP #28. I understand that I will have no rights in any ICC publications that use such contributions in the form submitted by me or another similar form and certify that such contributions are not protected by the copyright of any other person or entity.

Signature:

Please type or print full name:

Jurisdiction/Company:______

Entity Represented: ______

Contact info: Phone: ______Email:______

Date signed: ______PLEASE FAX OR MAIL THE SIGNED COPYRIGHT RELEASE TO:

Fax: 708-799-0320 Mail: ICC Codes & Standards Development Chicago District Office 4051 W. Flossmoor Road Country Club Hills, IL 60478-5795 [email protected]