2. Bases de presentación de las Cuentas Anuales
2.8. Elementos recogidos en varias partidas
Statement of Problem and Substantiation for Public Comment
• Egress grille assemblies need recognition in the document, since such an application for grille assemblies
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occurs in the marketplace. The language proposed gives inspection authorities both direction and guidance.
• The three options noted for automatically opening a powered vertical-rolling grille assembly under egress provisions, as shown in 7.2.1.16.1 (4), are commonly provided by grille assembly manufacturers. Such
manufacturers are capable of providing fail-safe systems that can open without power and that can allow for direct wiring to a building alarm system per NFPA 72 and/or including exit controls.
• The minimum height requirement to open a vertical-rolling grille assembly, as shown in 7.2.1.16.1 (4), is consistent with egress requirements for grille assemblies in general.
Related Item
• PI 242
Submitter Information Verification
Submitter Full Name: Joseph Hetzel
Organization: Thomas Associates, Inc.
Affiliation: Door & Access Systems Manufacturers Association Street Address:
City:
State:
Zip:
Submittal Date: Mon Apr 29 12:00:09 EDT 2019
Committee: SAF-MEA
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Public Comment No. 122-NFPA 101-2019 [ Section No. 7.2.1.4.1 ]
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7.2.1.4.1* Swinging-Type Door Assembly Requirement.
Any door assembly in a means of egress shall be of the side-hinged or pivoted-swinging type, and shall be installed to be capable of swinging from any position to the full required width of the opening in which it is installed, unless otherwise specified as follows:
(1) Door assemblies in dwelling units, as provided in Chapter 24, shall be permitted.
(2) Door assemblies in residential board and care occupancies, as provided in Chapters 32 and 33, shall be permitted.
(3) Where permitted in Chapters 11 through 43, horizontal Horizontal -sliding or vertical-rolling security grilles or door assemblies that are part of the required means of egress, where permitted in Chapters 11 through 43, shall be permitted, provided that all of the following criteria are met:
(4) Such grilles or door assemblies shall remain secured in the fully open position during the period of occupancy by the general public.
(5) On or adjacent to the grille or door opening, there shall be a readily visible, durable sign in letters not less than 1 in. (25 mm) high on a contrasting background that reads as follows: THIS DOOR TO REMAIN OPEN WHEN THE SPACE IS OCCUPIED.
(6) Door leaves or grilles shall not be brought to the closed position when the space is occupied.
(7) Door leaves or grilles shall be operable from within the space without the use of any special knowledge or effort.
(8) Where two or more means of egress are required, not more than half of the means of egress shall be equipped with horizontal-sliding or vertical-rolling grilles or door assemblies.
(9) Horizontal-sliding door assemblies shall be permitted under any of the following conditions:
(10) Horizontal-sliding door assemblies in detention and correctional occupancies, as provided in Chapters 22 and 23, shall be permitted.
(11) Special-purpose horizontally sliding accordion or folding door assemblies complying with 7.2.1.13 shall be permitted.
(12) Unless prohibited by Chapters 11 through 43, horizontal-sliding door assemblies serving a room or area with an occupant load of fewer than 10 shall be permitted, provided that all of the following criteria are met:
(13) The area served by the door assembly has no high-hazard contents.
(14) The door assembly is readily operable from either side without special knowledge or effort.
(15) The force required to operate the door assembly in the direction of door leaf travel is not more than 30 lbf (133 N) to set the door leaf in motion and is not more than 15 lbf (67 N) to close the door assembly or open it to the minimum required width.
(16) The door assembly complies with any required fire protection rating, and, where rated, is self-closing or automatic-self-closing by means of smoke detection in accordance with 7.2.1.8 and is installed in accordance with NFPA 80.
(17) Corridor door assemblies required to be self-latching have a latch or other mechanism that ensures that the door leaf will not rebound into a partially open position if forcefully closed.
(18) Where private garages, business areas, industrial areas, and storage areas with an occupant load not exceeding 10 contain only low- or ordinary-hazard contents, door openings to such areas and private garages shall be permitted to be horizontal-sliding door assemblies.
(19) Where Vertical-rolling door assemblies shall be permitted in door openings to private garages, business areas, industrial areas, and storage areas with , where such areas and private garages with an occupant load not exceeding 10 contain only low or ordinary hazard contents, door openings to such areas and private garages shall be permitted to be vertical-rolling door assemblies .
(20) Revolving door assemblies complying with 7.2.1.10 shall be permitted.
(21) Existing fusible-link-operated horizontal-sliding or vertical-rolling fire door assemblies shall be permitted to be used as provided in Chapters 39, 40, and 42.
Statement of Problem and Substantiation for Public Comment
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Editorial rewording for consistency in showing the door assembly description in the front part of each numbered section, and for ease of reading by the code user.
Related Item
• PI 96, PI 97
Submitter Information Verification
Submitter Full Name: Joseph Hetzel
Organization: Thomas Associates, Inc.
Affiliation: Door & Access Systems Manufacturers Association Street Address:
City:
State:
Zip:
Submittal Date: Mon Apr 29 11:26:47 EDT 2019
Committee: SAF-MEA
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Public Comment No. 123-NFPA 101-2019 [ Section No. 7.2.1.4.1 ]
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7.2.1.4.1* Swinging-Type Door Assembly Requirement.
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Any door assembly in a means of egress shall be of the side-hinged or pivoted-swinging type, and shall be installed to be capable of swinging from any position to the full required width of the opening in which it is installed, unless otherwise specified as follows:
(1) Door assemblies in dwelling units, as provided in Chapter 24, shall be permitted.
(2) Door assemblies in residential board and care occupancies, as provided in Chapters 32 and 33, shall be permitted.
(3) Where permitted in Chapters 11 through 43, horizontal-sliding or vertical-rolling security grilles or door assemblies that are part of the required means of egress shall be permitted, provided that all of the following criteria are met:
(4) Such grilles or door assemblies shall remain secured in the fully open position during the period of occupancy by the general public.
(5) On or adjacent to the grille or door opening, there shall be a readily visible, durable sign in letters not less than 1 in. (25 mm) high on a contrasting background that reads as follows: THIS DOOR TO REMAIN OPEN WHEN THE SPACE IS OCCUPIED.
(6) Door leaves or grilles shall not be brought to the closed position when the space is occupied.
(7) Door leaves or grilles shall be operable from within the space without the use of any special knowledge or effort.
(8) Where two or more means of egress are required, not more than half of the means of egress shall be equipped with horizontal-sliding or vertical-rolling grilles or door assemblies.
(9) Horizontal-sliding door assemblies shall be permitted under any of the following conditions:
(10) Horizontal-sliding door assemblies in detention and correctional occupancies, as provided in Chapters 22 and 23, shall be permitted.
(11) Special-purpose horizontally sliding accordion or folding door assemblies complying with 7.2.1.13 shall be permitted.
(12) Unless prohibited by Chapters 11 through 43, horizontal-sliding door assemblies serving a room or area with an occupant load of fewer than 10 shall be permitted, provided that all of the following criteria are met:
(13) The area served by the door assembly has no high-hazard contents.
(14) The door assembly is readily operable from either side without special knowledge or effort.
(15) The force required to operate the door assembly in the direction of door leaf travel is not more than 30 lbf (133 N) to set the door leaf in motion and is not more than 15 lbf (67 N) to close the door assembly or open it to the minimum required width.
(16) The door assembly complies with any required fire protection rating, and, where rated, is self-closing or automatic-self-closing by means of smoke detection in accordance with 7.2.1.8 and is installed in accordance with NFPA 80.
(17) Corridor door assemblies required to be self-latching have a latch or other mechanism that ensures that the door leaf will not rebound into a partially open position if forcefully closed.
(18) Where private garages, business areas, industrial areas, and storage areas with an occupant load not exceeding 10 contain only low- or ordinary-hazard contents, door openings to such areas and private garages shall be permitted to be horizontal-sliding door assemblies.
(19) Where private garages, business areas, industrial areas, and storage areas with an occupant load not exceeding 10 contain only low or ordinary hazard contents, door openings to such areas and private garages shall be permitted to be vertical-rolling door assemblies.
(20) Revolving door assemblies complying with 7.2.1.10 shall be permitted.
(21) Existing fusible-link-operated horizontal-sliding or vertical-rolling fire door assemblies shall be permitted to be used as provided in Chapters 39, 40, and 42.
(22) Powered vertical-rolling grille assemblies that are part of the required means of egress, where permitted in Chapters 11 through 43, that open automatically to a minimum height of 80 inches upon actuation of the fire alarm system, upon a loss of power, or by activation of a push-to-exit type control, shall be permitted and shall conform to the following.
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(a) Shall remain in the full open position during the period of occupancy by the general public.
(b) Shall not be brought to the closed position when there are 10 or more persons occupying spaces served by a single exit or 50 or more persons occupying spaces served by more than one exit.
(c) Shall be openable from within without the use of any special knowledge or effort where the space is occupied.
Statement of Problem and Substantiation for Public Comment
Original Reasoning for Related Item Public Input No. 228: Powered vertical-rolling grille assemblies are used in a means of egress in the marketplace, yet there are no provisions addressing them in NFPA 101. The three options noted for automatically opening a powered vertical-rolling grille under egress provisions are commonly provided by grille assembly manufacturers. Such manufacturers are capable of providing fail-safe systems that can open without power and that can allow for direct wiring to a building alarm system per NFPA 72 and/or including exit controls. The minimum height requirement is consistent with egress requirements for other door types.
Public Comment Reasoning:
The Committee gave the following points in support of the original proposal (Related Item Public Input No. 228):
• all options were covered,
• the provisions are already being successfully used, and
• a grille can separate an elevator lobby.
We would like to address the other comments given by the Committee.
• "When without power, the grille must be pushed open upward which is different from a sliding door product."
Response: Grille manufacturers design their products to be manually operable.
• "Additional burden on existing power supply." Response: No proof of this was given. The power needed for a grille is no different than any powered door product. The motor sizes are all usually ½ HP or less.
• "No width restrictions." Response: The grille minimum width is governed by the building code, no differently than any door product.
• "If the grille fails closed, no assurance of being operated." Response: Grille manufacturers design their products to be manually operable. IBC Section 402.8.8 requires that security grilles in a means of egress “shall be openable from within without the use of any special knowledge or effort where the space is occupied.”
• "Type of alarm (fire, security) not specified." Response: We modified the alarm language to read “actuation of the fire alarm system”, which is consistent with the language used in 9.6.2.1 under Signal Initiation in Chapter 9.6 entitled “Fire Detection, Alarm, and Communications Systems”.
• "Need to confirm what Chapters, between 11 and 43, recognize this product." Response: The charging language involving the Chapters should be acceptance since it is already being used in 7.2.1.4.1 (3) for horizontal-sliding or vertical-rolling security grilles or door assemblies.
• "Should be limited to new installations." Response: The product installation scope should be no different than the other products noted in 7.2.1.4.1, since the powered vertical-rolling grille assemblies serve a similar purpose.
The added language, as shown in a, b, and c, is consistent with 2018 International Building Code Section 402.8.8.
Related Item
• PI 228
Submitter Information Verification
Submitter Full Name: Joseph Hetzel
Organization: Thomas Associates, Inc.
Affiliation: DASMA
Street Address:
City:
State:
Zip:
Submittal Date: Mon Apr 29 11:43:04 EDT 2019
Committee: SAF-MEA
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Public Comment No. 94-NFPA 101-2019 [ Section No. 7.2.1.4.3.2 ]
7.2.1.4.3.2
When fully open, any door leaf in a means of egress shall not project more than 7 in. (180 mm) into the required width of an aisle, a corridor, a passageway, or a landing, unless the door leaf is equipped with an approved self-closing device and is not required by the provisions of 7 . 2.1.4.2 to swing in the direction of egress travel.
Statement of Problem and Substantiation for Public Comment
The deletion of this text would accomplish the intent of my Public Input during the Public Input phase of the process. The Committee Statement on my Public Input (PI-466) stated "All doors are permitted to obstruct up to 50% of the required width of a corridor, etc., not only those that are self-closing. This arrangement has been permitted by NFPA 101 for many editions. The exemption for doors that are self-closing applies to the maximum 7 in. projection when the door is fully open. Self-closing doors are exempt from this criterion because the door will be fully open only momentarily. It is unclear what the proposed revision is intended to correct." The intent was to remove the allowance for specific doors to cut in half the egress capacity in any occupancy, regardless of the requirements of the egress path being cut in half. Prior to the 2015 edition, this section prohibited any door from encroaching more than 7 inches into the required egress width when the door is fully open. The 50% allowance was only ever allowed DURING THE SWING OF THE DOOR. With the change that was placed into the code for the 2015 edition, a door can now project up to 50% into the required width of an aisle, corridor, passageway or landing with the door fully open, so long as that door has a self-closing device and is not required by 7.2.1.4.2 to swing in the direction of egress travel. Prior to the 2015 edition, the Code had never allowed a door in the fully open position to reduce egress by 50%. To create an allowance for a door in the full open position to reduce egress by 50% should not be permitted based solely on whether the encroaching door has a self-closing device and isn't required to swing in the direction of exit travel, because those criterion have no relationship to the egress path that is being obstructed. If the egress component being obstructed is such that ANY door in that egress path must swing in the direction of egress travel, it is not reasonable to assume that a door opening into and obstructing 50%
of that path would only obstruct it momentarily just because that door happens to have a self-closing device. This section does not prohibit an arrangement where the encroaching door would to have to swing opposite the direction of egress travel in the egress path being encroached upon in order to close the encroaching door. If all other doors in the path of egress have to swing in the direction of egress travel, it is not logical to allow a door to reduce egress capacity by 50% when fully open and the only way to clear the path is to have that door swing back against the egress travel in the aisle, corridor, passageway or landing that it is partially blocking. Nothing in the current code language prohibits such an arrangement (Please refer to the diagram submitted with PI-466). To allow a 50% reduction of a portion of a means of egress should be based on the requirements of the egress path that is being obstructed.
Related Item
• PI-466 • PI-473
Submitter Information Verification
Submitter Full Name: Ivan Humberson Organization: City of Gaithersburg Street Address:
City:
State:
Zip:
Submittal Date: Wed Apr 03 13:02:18 EDT 2019
Committee: SAF-MEA
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Public Comment No. 216-NFPA 101-2019 [ Section No. 7.2.1.5.3.8 ]
7.2.1.5.3.8
Where permitted by Chapters 11 through 43 , two releasing motions shall be permitted for doors secured against unwanted entry.
Statement of Problem and Substantiation for Public Comment
BHMA is gravely concerned with implications to life safety should NFPA 101 allow up to two releasing motions to release a door for egress. For example, consider these requirements in NFPA 101:
7.2.1.5.10* A latch or other fastening device on a door leaf shall be provided with a releasing device that has an obvious method of operation and that is readily operated under all lighting conditions.
Allowing up to two releasing motions to release a door for egress, would, from a simplistic perspective, allow additional locking / latching hardware to be installed on the door. Unfortunately, simply allowing additional hardware with one more releasing motion also invites unintended consequences.
Only after appropriate additional requirements which address the questions below are included in NFPA 101 Life Safety Code should the occupancy committees consider allowing up to two releasing motions in doors in the means of egress:
• Considering the wide variety of physical and mental abilities of every potential occupant, in every conceivable and inconceivable emergency and non-emergency situation, and in absolute darkness, how can it be assured that each and every potential occupant would know that two releasing motions are required, and be able to accomplish the two releasing motions in order to effect egress?
• If hardware is installed where one releasing motion must occur prior to the second, how can it be assured each occupant will know the required sequence? OR, How can it be assured that not more than two releasing motions are required regardless of the sequence of the motions?
Related Item
• FR 6571
Submitter Information Verification
Submitter Full Name: John Woestman Organization: Kellen Company
Affiliation: Builders Hardware Manufacturers Association Street Address:
City:
State:
Zip:
Submittal Date: Wed May 08 10:48:54 EDT 2019
Committee: SAF-MEA
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Public Comment No. 22-NFPA 101-2019 [ New Section after 7.2.1.5.6.2 ]
Consider adding an exemption to (2) for previously approved signs. As written, the revision would potentially render noncompliant all existing, compliant signs.