750 F2013 FD ballotcirc...NFPA 750 FD BALLOT – CIRCULATION REPORT NFPA 750 (F2013) 30 Members...

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M TO: NFPA Technical Committee on Water Mist Fire Suppression Systems FROM: Elena Carroll, Administrator, Technical Projects DATE: September 4, 2012 SUBJECT: NFPA 750 First Draft TC Circulation Ballot (F2013)

The August 31, 2012 date for receipt of the NFPA 750 FD letter ballot has passed. The preliminary FD ballot results are as follows: 30 Members Eligible to Vote 5 Not Returned (Devlin, Froh, Lakkonen, Reilly, and Stilwell) In accordance with the NFPA Regulations Governing the Development of NFPA Standards, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included, if received. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or before September 5, 2012. Members who have not returned a ballot may do so now. Such changes should be sent to Elena Carroll via either e-mail to [email protected] or via fax to 617-984-7110. You may also mail your ballot to the attention of Elena Carroll at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing the Development of NFPA Standards

NFPA 750 FD BALLOT – CIRCULATION REPORT

NFPA 750 (F2013)

30 Members Eligible To Vote

5 Not Returned (Devlin, Froh, Lakkonen, Reilly, Stilwell)

17 Affirmative on All

8 Negative on one or more First Revisions (Houin, Hubert, Kasiski, Magnone, Owen, Puchovsky, Stubblefield, Wiegand)

0 Abstentions

NFPA 750 FR9

Eligible To Vote: 30 Affirmative: 21 Negative: 4 (Kasiski, Magnone, Puchovsky, Wiegand) Abstain: 0

Not Returned: 5

Not Returned: Devlin, Froh, Lakkonen, Reilly, Stilwell

Kasiski: The category would be best identified as "Open space/compartment water mist systems" not "Automatic Sprinkler Alternative Water Mist Systems". Usage of this terminology will cause confusion to the end‐user.

Magnone: The lengthy history of successful real world applications of automatic sprinklers provides significant support for the benefits, tradeoffs, and savings provided in the building codes when automatic sprinkler systems are installed. By defining a water mist system designed in accordance with NFPA 750 as an alternative to a sprinkler system designed in accordance with NFPA 13, the implication is that it provides an equivalent level of performance to a sprinkler system for the same application. The obligation in claiming “equivalency” is to demonstrate “equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed” by NFPA 13 (see NFPA 13 1.5 “Equivalency” definition). The submitter of the proposals for NFPA 750 does not provide adequate technical data or substantiation to meet the above definition of “equivalency”.

The public consensus process used to develop the prescriptive standard for design and installation of automatic sprinklers (NFPA 13) provides for oversight and criticism of the details of the design and installation process. Water mist technology and its governing performance based standard NFPA 750 are fundamentally different than that of sprinkler technology. Therefore, water mist technology should be applied on its own technological merits ‐ not those of another technology covered by a separate NFPA standard. Mirroring the approach already utilized by NFPA 13, the generic technical definitions of wet pipe, dry pipe, and deluge water mist systems would be more the adequate to properly define the various types of systems than what has been proposed.

Puchovsky: This term and definition are not necessary. They will add confusion regarding the consideration

and use of water mist systems. Any water mist system could be considered as an alternative to a sprinkler

system. It is also not clear why there is a need to associate water mist systems with sprinkler systems. Why

does a complete building water mist system need to be referred to as an alternative to a sprinkler system?

Such systems will have there own performance and evaluation criteria which in certain cases might exceed

or be more appropriate than those of other systems. The appropriateness and effectiveness of water mist

systems need to be established on their own merits.

Wiegand: Building code trade‐offs that have been established for fire sprinkler systems are based on the reliability and field experience of fire sprinkler systems in a wide variety of real world situations that are very different from laboratory conditions. the safety factors involved in sprinkler system design, while not easily quantifiable, have proven to be affective for more than 100 years. Water mist systems, while successful in laboratory testing, do not have quantifiable safety factors nor to do they have the field experience to show equivalency with fire sprinklers. Field conditions such as ventilation, commodity arrangement, and protection gaps caused by nozzle failure.

In addition fire sprinkler systems are given credit for cooling surfaces near fires by direct water spray and for

creating water curtains to prevent the travel of heat and smoke. Water mist systems have not proven to

provide this same level of protection. As such many of the trade ups that are allowed by the building code

for sprinkler systems would not necessarily be appropriate for water mist systems.

NFPA 750 FR10

Eligible To Vote: 30 Affirmative: 23 Negative: 2 (Houin, Hubert) Abstain: 0 Not Returned: 5


Houin: Prior to this revision Water Mist Systems were approved as "Pre‐Engineered" where hydraulic

calculations were required to ensure the proper flow and pressure at the nozzles because the pipe sizing and

fittings allowed, provided too many (thousands) of combinations of them that would provide the required

(Approved) pressure at the nozzle. Changing this would eliminate the current use of some presently

approved Systems by requiring increases in Air and Water quantities available by a factor of six (6).

Hubert: There are currently FM approved "pre‐engineered" water mist systems with pre‐determined

maximum protected hazard volumes with maximum heights and areas, fixed nozzles with fixed pressures,

orifices (and obviously, flow rates) and locations, along with established water storage quantities, that are

allowed to have variable pipe sizes and arrangements verified to meet performance criteria via friction loss

calculations by either applying the Hazen‐Williams or Darcy‐Weisbach calculation method. The hazard

protection criteria is fixed and therefore considered "pre‐engineered" but does apply hydraulic calculations.

NFPA 750 FR13

Eligible To Vote: 30 Affirmative: 25 (w/comment: Bell, Wiegand) Negative: 0 Abstain: 0 Not

Returned: 5


Bell: The term defined should be for “Design Pressure” rather than “System Design Pressure”.

Wiegand: The term defined should be for "Design Pressure" rather than "System Design Pressure". The

definition is meant to pertain to components of systems as well as whole systems. Hence the subcommittee

in its original submittal had used the term "Design Pressure".

NFPA 750 FR16

Eligible To Vote: 30 Affirmative: 23 Negative: 2 (Kasiski, Wiegand) Abstain: 0 Not Returned: 5


Kasiski: Inclusion of [5.3.2] Ordinary Hazard (Group 2) and [5.4] Extra Hazard Occupancies infers water mist systems can provide protection for these occupancies. There are neither water mist systems listed for these classifications of occupancy nor testing criteria/requirements established to validate their performance.

Wiegand: These hazard classifications are the NFPA 13 hazard classifications for fire sprinkler systems. Water mist systems are not designed specifically to these hazards. There are other variables involved in designing a water mist system. When an area is of a light hazard classification, a specific water density can be supplied to a fire sprinkler system and it will be affective. Room volume, air movement, room height, and other variables aside from combustible loading also affect design requirements for a water mist system. So to provide classifications solely based on fire loading is not beneficial for classifying water mist systems and could lead to confusion between water mist systems and fire sprinkler systems. Also some of the occupancy classification rules for fire sprinkler systems would not be applicable to water mist systems. For instance, an area where there is significant shielding is considered an extra hazard group two occupancy. This is appropriate for a fire sprinkler system, but does not necessarily have any correlation to water mist systems.

NFPA 750 FR28 Eligible To Vote: 30 Affirmative: 24 Negative: 1 (Owen) Abstain: 0 Not Returned: 5


Owen: Water mist piping should be rigidly secured rather than being supported with hangers. Water mist systems typically have more nozzle pressure and reactive forces than sprinkler systems.

NFPA 750 FR26

Eligible To Vote: 30 Affirmative: 25 (w/ comment: Hubert) Negative: 0 Abstain: 0 Not Returned: 5


Hubert: We recognize that there is a complete section 6.4.1.2 (new numbering) on Conversion Fittings but

recommend that a definition for "conversion fittings" also be added.

NFPA 750 FR94

Eligible To Vote: 30 Affirmative: 25 (w/comment: Bell) Negative: 0 Abstain: 0 Not Returned: 5


Bell: For both 6.4.3.1 and 6.4.3.2, the term "system design working pressure" should be "design pressure".

NFPA 750 FR34

Eligible To Vote: 30 Affirmative: 24 Negative: 1 (Wiegand) Abstain: 0 Not Returned: 5


Wiegand: These hazard classifications are the NFPA 13 hazard classifications for fire sprinkler systems.

Water mist systems are not designed specifically to these hazards. There are other variables involved in

designing a water mist system. When an area is of a light hazard classification, a specific water density can

be supplied to a fire sprinkler system and it will be affective. Room volume, air movement, room height, and

other variables aside from combustible loading also affect design requirements for a water mist system. So

to provide classifications solely based on fire loading is not beneficial for classifying water mist systems and

could lead to confusion between water mist systems and fire sprinkler systems. Also some of the occupancy

classification rules for fire sprinkler systems would not be applicable to water mist systems. For instance, an

area where there is significant shielding is considered an extra hazard group two occupancy. This is

appropriate for a fire sprinkler system, but does not necessarily have any correlation to water mist systems.

NFPA 750 FR35


Not Returned: 5


Kasiski: NFPA 750 is deficient in identifying a category for light hazard and ordinary hazard (Group 1). The category would be best identified as "Open space/compartment application systems" not "Automatic Sprinkler Alternative Water Mist Systems".

Magnone: While I agree with the notion that building or occupancy protection is well within the capabilities of water mist systems that are designed, tested, and listed to do so, I disagree with the method that has been used to implement this concept within the document for the reasons discussed in my commentary on FR9. It would be more appropriate to utilize text such as “7.2.4 water mist systems for the protection of buildings or occupancies.” In place of what has been listed here.

Puchovsky: It is not clear why there is a need to associate water mist systems with sprinkler systems. Why





Wiegand: Building code tradeoffs that have been established for fire sprinkler systems are based on the reliability and field experience of fire sprinkler systems in a wide variety of real world situations that are very different from laboratory conditions. the safety factors involved in sprinkler system design, while not easily quantifiable, have proven to be affective for more than 100 years. Water mist systems, while successful in laboratory testing, do not have quantifiable safety factors nor to do they have the field experience to show equivalency with fire sprinklers. Field conditions such as ventilation, commodity arrangement, and protection gaps caused by nozzle failure.





NFPA 750 FR38


Not Returned: 5


Kasiski: Inclusion of area limitations for Ordinary Hazard (Group 2) and Extra Hazard Occupancies infers water mist systems can provide protection for these occupancies. There are neither water mist systems listed for these classifications of occupancy nor testing criteria/requirements established to validate their performance.

NFPA 750 is deficient in identifying a category for light hazard and ordinary hazard (Group 1). The category/section title would be best identified as "Open space/compartment application systems" not "Automatic Sprinkler Alternative Water Mist Systems".

Magnone: The lengthy history of successful real world applications of automatic sprinklers provides significant support for the benefits, tradeoffs, and savings provided in the building codes when automatic sprinkler systems are installed. By defining a water mist system designed in accordance with NFPA 750 as an alternative to a sprinkler system designed in accordance with NFPA 13, the implication is that it provides an equivalent level of performance to a sprinkler system for the same application. The obligation in claiming “equivalency” is to demonstrate “equivalent or superior quality, strength, fire resistance, effectiveness, durability, and safety over those prescribed” by NFPA 13 (see NFPA 13 1.5 “Equivalency” definition). The submitter of the proposals for NFPA 750 does not provide adequate technical data or substantiation to meet the above definition of “equivalency”.

The public consensus process used to develop the prescriptive standard for design and installation of automatic sprinklers (NFPA 13) provides for oversight and criticism of the details of the design and installation process. Water mist technology and its governing performance based standard NFPA 750 are fundamentally different than that of sprinkler technology. Therefore, water mist technology should be applied on its own technological merits ‐ not those of another technology covered by a separate NFPA standard. It is our opinion that significantly more technical justification is necessary in order to adopt many of the concepts that are included as part of this proposal.











NFPA 750 FR42

Eligible To Vote: 30 Affirmative: 25 (w/comment: Bell, Wiegand) Negative: 0 Abstain: 0 Not

Returned: 5


Bell: The term "system design pressure" should be "design pressure"

Wiegand: The term defined should be for "Design Pressure" rather than "System Design Pressure". The

definition is meant to pertain to components of systems as well as whole systems. Hence the subcommittee

in its original submittal had used the term "Design Pressure".

NFPA 750 FR73

Eligible To Vote: 30 Affirmative: 25 (w/comment: Bell, Owen) Negative: 0 Abstain: 0

Not Returned: 5


Bell: The term "system design pressure" should be "design pressure"

Owen: Change text to read, .."less than or equal to the system design pressure." Some relief valves are set

to the maximum design pressure rather than less than the maximum pressure.

NFPA 750 FR45

Eligible To Vote: 30 Affirmative: 22 Negative: 3 (Magnone, Puchovsky, Wiegand) Abstain: 0 Not

Returned: 5


Magnone: See my commentary on FR38 in addition to the following:

The stated proposal implies, particularly in 9.3.2.1, that the requirements of NFPA 13 should apply to water mist systems used to protect buildings or occupancies. It is the opinion of TFP that it is not within the power or responsibility of any NFPA technical committee to adopt either implicitly or explicitly the concept of equivalency in performance or application of one fire protection technology within its existing NFPA design and installation standard with any other technology governed by a separate NFPA design and installation

standard. Doing so creates a conflict wherein the requirements of one standard must apply to the other, whilst each standard is represented by a separate technical body, and may or may not be on a separate revision cycle. Each technology should be governed by its own respective design and installation standard, and the related requirements should be supported by the sole technical merits of said technology alone. This approach will preserve the integrity of each standard, eliminate the potential for conflicts between the actions of separate technical committees, and minimize confusion in the industry regarding the application of each standard in practice.







In addition fire sprinkler systems are given credit for cooling surfaces near fires by direct water spray and for creating water curtains to prevent the travel of heat and smoke. Water mist systems have not proven to provide this same level of protection. As such many of the trade ups that are allowed by the building code for sprinkler systems would not necessarily be appropriate for water mist systems.

These hazard classifications are the NFPA 13 hazard classifications for fire sprinkler systems. Water mist

systems are not designed specifically to these hazards. There are other variables involved in designing a

water mist system. When an area is of a light hazard classification, a specific water density can be supplied

to a fire sprinkler system and it will be affective. Room volume, air movement, room height, and other

variables aside from combustible loading also affect design requirements for a water mist system. So to

provide classifications solely based on fire loading is not beneficial for classifying water mist systems and





NFPA 750 FR46

Eligible To Vote: 30 Affirmative: 24 Negative: 1 (Wiegand) Abstain: 0 Not Returned: 5












NFPA 750 FR113

Eligible To Vote: 30 Affirmative: 22 (w/comment: Kasiski) Negative: 3 (Magnone, Puchovsky, Wiegand)

Abstain: 0 Not Returned: 5


Magnone: A more appropriate course of action would be to remove all references to sprinkler systems in the text, and re‐title the chapter to more accurately meet the stated intent ‐ e.g. "Water mist systems for the protection of buildings or occupancies." Water mist technology should be applied on its own technological merits ‐ not those of another technology covered by a separate NFPA standard.

For more information see FR9, FR38, and FR45.

Puchovksy: It is not clear why there is a need to associate water mist systems with sprinkler systems. Why






In addition fire sprinkler systems are given credit for cooling surfaces near fires by direct water spray and for creating water curtains to prevent the travel of heat and smoke. Water mist systems have not proven to provide this same level of protection. As such many of the trade ups that are allowed by the building code for sprinkler systems would not necessarily be appropriate for water mist systems.

Kasiski: NFPA 750 is deficient in identifying a category for light hazard and ordinary hazard (Group 1). The category would be best identified as "Open space/compartment application systems" not "Automatic Sprinkler Alternative Water Mist Systems".

NFPA 750 FR114



Kasiski: This is not the same Proposal sent on 6‐August, 2012. Section 10.2.1.4 was included and not included in this document. Which is correct? Inclusion of Section 10.2.1.4 identifies Ordinary Hazard (Group 2) and Extra Hazard Occupancies which infers water mist systems can provide protection for these occupancies. There are neither water mist systems listed for these classifications of occupancy nor testing criteria/requirements established to validate their performance.











NFPA 750 FR115

Eligible To Vote: 30 Affirmative: 22 Negative: 3 (Magnone, Puchovsky, Wiegand) Abstain: 0

Not Returned: 5


Magnone: See FR113











NFPA 750 FR53

Eligible To Vote: 30 Affirmative: 24 Negative: 1 (Owen) Abstain: 0 Not Returned: 5


Owen: Getting the AHJ to approve a test plan prior to scheduling of acceptance is not always practical due

to the project completion schedule. The wording should be "An acceptance test plan should be submitted to

the AHJ prior to scheduling of acceptance testing."

NFPA 750 FR72

Eligible To Vote: 30 Affirmative: 22 Negative: 3 (Hubert, Owen, Stubblefield) Abstain: 0 Not

Returned: 5


Owen: Deleting Chapter 15, System Inspection, Testing, and Maintenance as it is currently included from NFPA 750 will cause system users confusion as water mist systems are specialized systems, just as gaseous systems are specialized systems and should be covered by a specific standard. Changing the Inspection, Testing and Maintenance to another standard will also result in cost to the manufacturers as their Design, Inspection and Maintenance manuals reference NFPA 750 not NFPA 25.

Stubblefield: Water Mist System inspection, testing, and maintenance criteria should be developed,

evaluated, and maintained by a committee knowledgeable in water mist technology. Vendors and owners

of water mist systems should not be required to purchase additional NFPA documents to test and maintain

these systems. Water mist experts and proponents may be under‐represented in committees other than the

Technical Committee on Water Mist Systems. NFPA 20 Technical Committee should assign a liaison to the

Water Mist Technical Committee to coordinate issues that are common to both technologies rather than

the opposite; thereby, leaving this information in NFPA 750.

Hubert: Removal of the inspection, testing and maintenance of water mist systems from NFPA 750 and the

relocation of the same in NFPA 25 removes all decision making from the committee of +/‐ 25 technical

experts on NFPA 750 and allows the committee of +/‐ 30 technical experts (of other than water mist

systems) make decisions for what they believe "might" be the best for water mist systems. Currently, we

only recognize four committee members on NFPA 25 that have expertise in water mist. Due to the

overwhelming majority of committee members on NFPA 25 that have minimal or no expertise in regards to

water mist systems, it can be predicted that in any contentious situation that might be "politically" driven

and voted upon, there could be unsuitable results when compared to valid technical justification offered by

the experts of water mist, who are the minority. Secondarily, by making the change, the NFPA 750 TC will

now have to be responsible for the entire NFPA 25 and NFPA 750.

NFPA 750 FR70

Eligible To Vote: 30 Affirmative: 21 Negative: 4 (Kasiski, Magnone, Puchovsky, Wiegand)

Abstain: 0 Not Returned: 5


Kasiski: NFPA 750 is deficient in identifying a category for light hazard and ordinary hazard (Group 1). The category would be best identified as "Open space/compartment application systems" not "Automatic Sprinkler Alternative Water Mist Systems". Usage of this terminology will cause confusion to the end‐user.

Magnone: See FR38, and FR45.






Wiegand: Building code tradeoffs that have been established for fire sprinkler systems are based on the reliability and field experience of fire sprinkler systems in a wide variety of real world situations that are very different from laboratory conditions. the safety factors involved in sprinkler system design, while not easily quantifiable, have proven to be affective for more than 100 years. Water mist systems, while successful in laboratory testing, do not have quantifiable safety factors nor to do they have the field

experience to show equivalency with fire sprinklers. Field conditions such as ventilation, commodity arrangement, and protection gaps caused by nozzle failure.





NFPA 750 FR60

Eligible To Vote: 30 Affirmative: 24 (w/comment: Hubert) Negative: 1 (Wiegand) Abstain: 0

Not Returned: 5












Hubert: FSSA agrees with the opinion that hybrid systems are outside the current scope of NFPA 750 since a primary extinguishing mechanism of the hybrid technology is oxygen reduction by the inert gas component ‐ not “a specific water spray (mist) that absorbs heat, displaces oxygen, or blocks radiant heat” as required under NFPA 750. However, lack of a national standard covering hybrid systems (which currently meet the performance criteria established in NFPA 750 and maintain FM Approval) both hampers the use of such systems even when the hybrid system provides the best option for fire extinguishment in a given hazard area. Further lack of guidance for use of hybrid systems leaves the authorities who wish to utilize the hybrid technology without the definitive guidance provided by a national recognized consensus standard. For the above reasons, the FSSA requests that the NFPA 750 Technical Committee include in their

justification for the rejection of the proposal submitted by Mr. William Reilly, Victaulic Company of America,

label Log # 102 prior to "First Draft", the recommendation that the Standards Council and NFPA establish a

new committee project to write a standard covering hybrid systems that use a combination of inert gas and

very fine water droplets to extinguish fire.

NFPA 750 FR17



Kasiski: Inclusion of Ordinary Hazard (Group 2) and Extra Hazard Occupancies infers water mist systems

can provide protection for these occupancies. There are neither water mist systems listed for these

classifications of occupancy nor testing criteria/requirements established to validate their performance











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