STAFF USE ONLY Code Amendment Proposal Application Application no.: Department of Consumer & Business Services Building Codes Division 19 OSSC - 19 1535 Edgewater NW, Salem, Oregon Mailing address: P.O. Box 14470, Salem, OR 97309-0404 Phone: 503-378-4133, Fax: 503-378-2322 Web: oregon.gov/ bcd Instructions: Fill in all the following information, attach any supplementary information you relied on, and mail to the address listed above. For more information, please refer to the Building Codes Division website, oregon.gov/ bcd. APPLICANT INFORMATION Name: Aron Faegre, AIA, PE Date: 1-12-2017 Representing: Oregon Avation Industries Inc. (ORAVI) PROPOSED CODE LANGUAGE This proposed code amendment (check one): Amends (code, edition, section): 412.4.6 Exception 2 Adopts a new section (code, edition): Repeals (code, edition, section): You must provide language for review by the code review committee and advisory board. Failure to provide language will invalidate the application. Please use the following format to show additions and deletions from the code — strike through deleted text, underline and bold new text. Use arrow keys to advance to the next text box. Proposed language: Exception 2. Aircraft hangars that have an aircraft access door height less than 28 feet and do not have provisions for housing aircraft with a tail height over 28 feet, are exempt from foam requirements, provided the building complies with all of the following criteria: 2.1 The building is provided with an automatic sprinkler system throughout with an Extra Hazard Group I NFPA 13 fire sprinkler (typically 0.25 gallons per minute). 2.2. Hangar construction must be Type I or II. 2.3. No hazardous operations are permitted within the hangar, where those are defined as: 2.3.1. Doping. 2.3.2. Hot work including, but not limited to, welding, torch cutting and torch soldering. 2.3.3. Fuel transfer. 2.3.4. Fuel tank repair or maintenance not including defueled tanks, inerted tanks or tanks that have never been fueled. 2.3.5. Spray finishing operations. 2.4. Provide 33 gallon foam cart in each of the four corners of the hangar. Questions below are answered by attachments. Continued 440-2652 (1/17/COM/WEB) APPLICATION CRITERIA Attach to this application written responses to the following questions. If needed, include in the response an explanation why a question does not apply to your proposed code amendment. The code review committee may reject an incomplete application. You must provide a thorough and complete response to all questions, or your application may be considered incomplete. Questions: 1. What does this code proposal do? 2. What problem in the code does this proposal intend to address? 3. Is the problem a fire or life safety matter? If so, explain. 4. Does the problem cause delays in the cost of construction or inconsistency in application of the code? If so, how? 5. How does this proposal solve the problem? 6. Are there other alternatives to this proposal that solve the problem? If so, why is this proposal the best solution? 7. Does this proposal require a change in statute or administrative rule? 8. What fiscal impact does this proposal have? Explain. 9. If there is a fiscal impact, who is affected? 10. Does this proposal enhance statewide consistency and predictability? If so, how? 11. Does this proposal reduce or streamline regulation under the code? If yes, explain how. 12. Has this been proposed at the national model code level? If not, why not? If so, what happened and why was it not adopted there? 13. Does this proposal add to the cost of construction? If so, explain how the added cost contributes to the health and safety of occupants, or is necessary to conserve scarce resources. 14. If this proposal will affect the cost of development of a detached single-family dwelling, please indicate the cost. For the purposes of illustrating the change on the cost, please use a 6,000-square-foot parcel and the construction of a 1,200-square- foot detached single-family dwelling on that parcel. The information on the cost must be sufficient to assist the division in preparing a housing cost impact statement. 15. What assumptions affect the projected costs or savings associated with this proposal? 16. It is important that proposals be shared with people and organizations that will be impacted by them. Was this proposal developed with people or organizations likely to be affected by it? Has it been reviewed or shared with people or organizations likely to be affected by it? If so, who? If not, why not? APPLICANT SIGNATURE 1-12-2017 Signature: Date: Copyright notice: By signing this proposed code amendment application, I understand and acknowledge that the work contained in this application is original, or if not original, I have the right to copy the work. By signing this work, I understand that any rights I may have in this work, including any form of derivative works and compilations, are assigned to the Department of Consumer and Business Services. I also understand that I do not retain or acquire any rights once this work is used in a Department of Consumer and Business Services publication. APPLICATION PROCESSING The code review committee screens proposed amendments to determine whether they meet the requirements of Oregon Administrative Rule (OAR) 918-008-0060. The committee will return proposed code amendments that do not substantially meet the requirements of OAR 918-008-0060, with specific reasons included in the returned application If you submit completed proposed code amendments to the committee before the end of the timetable established under OAR 918- 008-0020, the committee will forward them to the appropriate advisory board for review. The committee will not forward proposed code amendments that are not completed before the end of the timetable. If you complete proposed code amendments but do not submit them before the end of the timetable, you may submit them as completed applications for consideration during the next opportunity given to make amendments to the state building code. Note: The committee is not obligated to examine a proposed code amendment submitted after the end of the timetable. 440-2652 (1/17/COM/WEB) OSSC 2014, 412.4.6 1-9-2017 Proposed code, edition, and section * OSSC 2014, 412.4.6 Oregon Aviation Industries Inc. (ORAVI) Aron Faegre 520 SW Yamhill Street PH1 Portland, Oregon 97204 503-880-1469 [email protected] Proposed language and/or explanation of proposed language * Propose revising Exception 2 to read: Exception 2. Aircraft hangars that have an aircraft access door height less than 28 feet and do not have provisions for housing aircraft with a tail height over 28 feet, are exempt from foam requirements, provided the building complies with all of the following criteria: 2.1 The building is provided with an automatic sprinkler system throughout with an Extra Hazard Group I NFPA 13 fire sprinkler (typically 0.25 gallons per minute). 2.2. Hangar construction must be Type I or II. 2.3. No hazardous operations are permitted within the hangar, where those are defined as: 2.3.1. Doping. 2.3.2. Hot work including, but not limited to, welding, torch cutting and torch soldering. 2.3.3. Fuel transfer. 2.3.4. Fuel tank repair or maintenance not including defueled tanks, inerted tanks or tanks that have never been fueled. 2.3.5. Spray finishing operations. 2.4. Provide 33 gallon foam cart in each of the four corners of the hangar. Application criteria Enter a response for each of the following questions. If needed, include in the response an explanation why a question does not apply to your proposed code amendment. The code review committee may reject an incomplete OSSC 2014, 412.4.6 application. You must provide a thorough and complete response to all questions, or your application may be considered incomplete. Questions: What does this code proposal do? * Essentially return this code section back to the language for what was allowed in the 2007 and 2010 OSSC codes, with clarification that using this exception prohibits hazardous maintenance type operations (which was the prior intent as well). The 2007 version was fully vetted by the State Building Codes review at that time, but was not in the 2014 version. What problem in the code does this proposal intend to address? * There is no history in Oregon of fires in modern non-combustible fire sprinklered aircraft hangars. In particular there have been no pool fires which are what the foam systems are designed to extinguish. Modern large hangars are exceptionally clean and sterile environments to protect the aircraft that are valued at many tens of millions of dollars. Even a drop of brake fluid on the floor is considered unacceptable, as it means the brake system needs attention. Modern aircraft design and operations are the model industry, in developing methods and procedures for planning and maintaining the highest level of safety. Per NFPA publications the foam systems are intended to protect the hangar, not the humans inside the hangar. However, the history of foam systems in hangars is that they are accidentally triggered by human error and system error quite often. The triggering system is an IR eye which is simply looking for a hot spot in the hangar, and is subject to error. Once the foam system is triggered if fills the entire hangar. Then, due to FAA and/or aircraft manufacturer high safety standards and requirements, the aircraft that have been bathed in (and filled inside since aircraft doors are typically open while the aircraft is in the hangar) with foam must be largely disassembled to ensure they are safe for future operation.