IRC Code Issues

Ken Isman, Vice President of Engineering

Jeff Hugo, North Central Region Manager

Overview

• I Codes

• History of Residential Sprinklers in the Codes

• RB114-04/05

I Codes

• Development of the I Codes

• ICC Family

• Jurisdictions

• Code Change Process

International Codes Council (ICC)

• Established in 1994 to developing a single set of comprehensive and coordinated national model construction codes

• Founding Organizations– Building Officials and Code Administrators

International, Inc. (BOCA) – International Conference of Building Officials (ICBO)– Southern Building Code Congress International, Inc.

(SBCCI)

ICC

• First produced 1996 International Plumbing Code and the International Mechanical Code

• Followed by the 2000 Building Code and Residential Code

ICC Family of Codes• International Building Code• International Energy Conservation Code• International Code Council Electrical Code Administrative

Provisions • International Existing Building Code• International Fire Code• International Fuel Gas Code• International Mechanical Code• ICC Performance Code• International Plumbing Code• International Private Sewage Disposal Code• International Property Maintenance Code• International Residential Code• International Urban-Wildland Interface Code• International Zoning Code

States Using the IRC

Uses own Code

Adopted by Local Governments

2000 IRC – May contain State Amendments

2003 IRC – May contain State Amendments

2006 IRC – May contain State Amendments

Code ChangesSubmitted

Code ChangesPrinted & Distributed

Code Development Hearing

Public Hearing ResultsPrinted & Distributed

Public CommentsSought on PublicHearing Results

Public CommentsPrinted & Distributed

Final ActionHearing

Supplement Or NewEdition Published

I-CODE DEVELOPMENTCYCLE

2006/2007 “I” Code Development Cycle

ICC Membership

• The ICC has over 50,000 members in the United States with the majority being voting members.

• The ICC is divided into 7 regions

• The 7 regions has approximately 203 chapters.

• Attached is a handout of local chapters

Voting

Governmental Member• Designate 4 to 12 voting representatives• Number of representatives is based on

population• Employees or officials of that governmental

member• Actively engaged full or part-time in the

administration, formulation or enforcement of laws, regulations or ordinances relating to public health, safety and welfare

Voting Based on Government Population

• 0 – 50,000: 4 total, 1 primary + 3 addt’l

• 50,001 – 150,000: 8 total, 1 primary + 7 addt’l

• 150,001 +: 12 total, 1 primary + 11 addt’l

Voting members must be listed on the ICC application prior to meeting!

IRC Code and Sprinklers

• History

• Orlando

• Rochester, NY

History

• Prior to the formation of the ICC, the CABO One and Two Family Dwelling Code was the document used

• The IRC has been the model code since 2000– Any attempts to modify the CABO or IRC code to

require sprinklers were blocked by the NAHB

• Jurisdictions passed sprinkler requirements at the local level– To date: more than150 local jurisdictions– 17 different states

IRC Recent Activity

• Mandatory residential sprinklers made it into the 2006 IRC in the form of Appendix P.

• At the initial hearing, the committee disapproved adopting Appendix P, but their decision was overturned at the FAH by a 2/3 vote.

• We are at this same point with mandatory sprinkler requirements (RB-114).

• Building and fire officials must perform the same action.

Why Change the 2006 IRC Appendix P?

• The appendices in the “I” codes must be specifically adopted by the jurisdiction.

• This brings the argument to the local level, where opponents can influence local political leaders.

• If RB-114 can be inserted into text on the national level, then removal at the local becomes more difficult.

• Many jurisdictions when looking at the code for local adoption regret taking specific nationally approved text out.

In September of 2006, the following (along with supporting text) was submitted as a code change in Orlando, FL.:

After long testimony by the Home Builders and fire sprinkler and safety advocates , including NFSA presence, the committee decided to turn down this proposed change for the following reasons:

Public Comment

• Freezing pipes• Cost of tap fees• Impact on affordable housing/Cost of housing• Public does not want residential sprinklers• Homes are safe enough• Fire Department really does not need sprinklers• Smoke alarms are enough• Rural homes can’t install sprinklers efficiently• Impact on public and private water supplies• Wait for more cost effective devices• Maintenance is a problem• Mold• Appendix P is good enough

Anti-Sprinkler Testimony & Rebuttal

Systems freeze in cold climates

Opponents of residential sprinklers assert that system freeze-ups will cause lots of problems in cold climates

Response:• Sprinklers pose no greater risk of freezing

than domestic plumbing• System must be properly designed and

installed• Sprinkler systems in cold climates are not

predisposed to freezing.

Systems freeze in cold climates

• Many jurisdictions in severely freezing climates (New York to Alaska) have adopted residential sprinkler ordinances

• Ordinances would have been repealed if freezing problems were widespread

• Occasional anecdotal stories about freeze-ups caused by faulty installations

• Options are available – Use sidewall sprinklers with pipes in warm walls,

soffits, closets and crawl spaces– Properly install piping beneath the insulation in attics– Install dry-pipe or preaction systems in unheated

spaces (a new technology)

Systems freeze in cold climates

• Sprinkler systems are required in all residential occupancies governed by the IBC, which include group homes and townhouses exceeding 3-stories in height

• Residential sprinkler systems have been installed in homes located in freezing climates for many years

• If freeze concerns are being addressed in these cases, then homes sprinklered in accordance with the IRC can and will be handled in the same manner.

Cost impact of inflated tap fees

Opponents of residential sprinklers argue that sprinklers costs will skyrocket in jurisdictions where local water purveyors inflate the cost of larger water taps

Response:• This is not a building code issue• Local fees should not serve as an impediment to

an IRC requirement• Can sometimes avoid the use of a larger meter,

by applying alternative design approaches already permitted by NFPA 13D

Cost impact of inflated tap fees

Alternate Design Approach– Use reduced sprinkler spacing (9 gpm per

sprinkler) for rooms with more than 1 sprinkler– Total demand of 18 gpm– Can be supplied by many municipal systems

using a standard 5/8-inch meter– Sprinklers with larger spacing can still be

used in rooms requiring only a single sprinkler– Not the best choice for every case, but good

for smaller homes at the entry/affordable housing level

Cost impact of inflated tap fees• If the tap fees for larger supplies are

substantially out of line, install a small pump/tank system

– There is an associated cost– Provides an upper limit to the potential

impact of high tap fees• Fight unfair high tap fees

– Fees should be reduced when meters are for fire sprinkler systems

– Mandating sprinklers puts builders and code officials on the same side of this issue

Cost impact of inflated tap fees

• Increasing meter/tap sizes for sprinklers does not increase the demand on a public water system

• Residential sprinklers actually reduce demand

– Sprinklers only flow water when a fire occurs– Water used by sprinklers is only a fraction of

what firefighters use to extinguish fires in unsprinklered properties

Impact on affordable housing/Cost of Housing

Opponents of residential sprinklers argue that the cost of sprinklers is not justified and that it eliminates the possibility of affordable housing for a segment of the population

Response:• Construction costs do not drive the price of homes

in most markets • Prices are established based on an analysis of what

the market will bear– Sales prices continue to rise as long as there are

buyers who are willing to pay the asking price

Costs

• A competitive market place greatly reduces sprinkler system costs

• Scottsdale Example– Required residential sprinklers roughly 20 years ago– Costs recently quoted as $0.55 to $0.75 per square

foot– Well over 40,000 sprinklered homes in the city.

• Not every jurisdiction will match Scottsdale’s cost structure, but Scottsdale’s experience clearly demonstrates that a competitive marketplace greatly reduces sprinkler costs

Costs• Technology, creative design approaches and labor

charges also impact costs– Use of combined plumbing-sprinkler systems is being

pursued in some jurisdictions as a way to minimize the cost

– Multipurpose systems (already permitted by NFPA 13D) may be particularly well suited in affordable housing/entry-level homes

– Recent surveys of sprinkler costs for affordable homes of 1,000 to 1,200 sq ft showed that the added cost of materials related to sprinkler protection was $0.25 to 0.30 per sq ft, and the sprinkler installation required less than 8 hours of additional labor

• Sprinklers only add about $4/month to a 30-year mortgage, not including any insurance or tax credit

Costs

• Cost of sprinklers in larger homes• Hypothetical $3,000 sprinkler system in a

$300,000 home– 6.5% mortgage– 5% credit on a $2,000/year insurance bill– Combined Federal/State income tax rate of 33%– Net cost of fire sprinklers, after mortgage related tax

deductions, would be $4.37 per month– A 0.23% increase in the monthly payment– Roughly equates to the cost of a premium beverage

at Starbucks

Costs

• NFSA Study proves that sprinklering all one and two family dwellings provides a net savings to society

• See Sprinkler Quarterly article on the subject in the handouts

Costs

• The true impact on the housing market associated with requiring residential sprinklers will be far less than what opponents of residential sprinklers would like code officials to believe.

• Where residential sprinklers are required now, the housing market is not affected by fire sprinklers.

• Once the IRC requires residential sprinklers– Home building will continue as it always has– Home prices will fluctuate based on the law of supply

and demand– Home buyers will continue to buy homes.

Public Desire for Sprinklers?Opponents of residential sprinklers suggested that the

general public would oppose residential sprinklers

Response:• A recent national survey of over 1000 adults indicates

this is not true– 45% of homeowners said that a sprinklered home is

more desirable than an unsprinklered home– 69% of homeowners said that having a fire sprinkler

system increases the value of a home– 38% of homeowners said that they would be more

likely to purchase a home with fire sprinklers than without

• There appears to be an unfounded fear of water damage. 48% of homeowners cited water damage as the reason they would not want a sprinkler system

Correlation between a home’s age and fire risk…aren’t homes

built to the IRC already safe enough?:

Opponents of residential sprinklers would like to convince us that residential fire deaths are a function of a home’s age and that new homes, built in accordance with the IRC, are safe. Many people buy these arguments because, on the surface, they seem to make sense

Correlation between a home’s age and fire risk…aren’t homes

built to the IRC already safe enough?:

Response:• Most fires are caused by people• Compliance with the IRC doesn’t prevent these

types of fires • Once a fire starts, compliance with the IRC will

not slow its spread• The speed by which a fire spreads in a home

is a function of contents and room geometry

Age of Home Response• A simplistic correlation of residential fire deaths

with the age of homes ignores several variables– Socioeconomic status of the occupants, – Density of occupants, – Age of occupants– Presence of smoke detectors (discussed

separately)• These factors are far more likely to be contributory

factors in fire deaths than the age of a structure• If more fire deaths do occur in “older” homes it

may be related to the fact that the median age of homes in the U.S., according to a recent HUD study, is 32 years

– Many people live in older homes

Since only a small percentage of fire department responses are for actual structure fires, does the fire service really need residential sprinklers?

Response:• The statistics submitted with Proposal RB114

clearly demonstrate the scope and magnitude of the residential fire problem in the United States

• Residential structure fires are a small fraction of overall fire department responses

• 45% of firefighter deaths occur at 1- and 2-family dwelling fires

Fire Department Need for Sprinklers

• Dwelling fires have three characteristics that present disproportionate risks as compared to fires in other occupancies:1. Well developed, post-flashover fires by the time the

fire department arrives. 2. Often occur at night.3. Often involve a real or perceived need to perform

search and rescue operations.

• Dwelling fires represent a small percentage of emergency responses but account for a very large percentage of firefighters who are killed in the line of duty.

FD Need for Sprinklers• The ability of the fire service to respond to

residential fires has declined significantly in recent years, and the situation isn’t getting better

• The public has a relatively simple expectation with respect to the fire department when a fire happens– They call 911– The FD responds to rescue trapped occupants– The FD puts out the fire

• Unfortunately, that expectation isn’t being effectively met in many parts of the country because of dwindling resources.

FD Need for Sprinklers• Nationally, volunteer firefighters

– Comprise 73% of the American fire service– Protect the vast majority of the geographic area of

the United States– Are becoming harder and harder to retain

• In New York alone– Volunteer firefighters have declined from 110,000 in

the early 1990s to approximately 85,000 today– All-volunteer fire departments protect 95% of NY

communities with a population of less than 10,000– What will happen when there are no longer enough

firefighters to respond to 911 calls?

Aren’t smoke alarms enough?

Opponents of sprinklers suggest that smoke alarms are good enough to protect the public and that residential sprinklers aren’t justified.

Response:• Agree that smoke alarms save lives• On their own, they do nothing to stop the spread

of fire, protect property or protect firefighters

• As smoke alarms age, their reliability declines– Expiration date on each unit indicates a 10-year life

• How many alarms will be replaced in 10 years?• What happens to the alarms that are not replaced?• An estimated 96% of U.S. homes with telephones

have at least one smoke alarm– In ¼ of reported fires in smoke alarm equipped

homes, the devices didn’t work• In contrast, residential sprinkler systems

– Have a life expectancy of 50-years– Require little maintenance

Smoke Alarms

• In a study that was just completed in 2006– Only 58% of a test group of children ages 6-12

awakened when a standard smoke alarm sounded– Only 38% of the test group successfully evacuated– The median time to awaken was 3 minutes– The median time to escape was the maximum

allowed 5 minutes– Way too late in a house fire!

• Another study revealed that a surprising 34% of fire deaths in one- and two-family dwellings during the 2000-2004 period occurred in homes with a working smoke detector

Smoke Alarm Studies

What about homes without a public water supply?

Opponents of residential sprinklers have suggested that it is impractical and too expensive to require sprinklers in homes that will use a well as the water supply

Response:

• Design options are available that make wells a viable water supply

• Recharge Rate– Wells may not be capable of keeping up with the

demand of a sprinkler system, which may be 20 gpm or more.

– Many automatically assume that a tank and a secondary pump are necessary in these cases, but a lesser known yet simple approach called “developing the well” is a much better solution.

• Creates an underground cistern that replaces the need for a tank

• Dig the well substantially below the water table• Allow the hole to fill with water• Retain the needed capacity underground

Wells as Water Supplies

• For deeper wells, there are two options– Use a well pump that can meet system

demand (capacity of well will need to hold duration)

– Use a tank and pump • Common arrangement utilized for deep wells

supplying domestic service• Tank generally needs about 300 gal to meet

system demand

Wells as Water Supplies

• Some have suggested that the IRC should not require homes on wells to have fire sprinklers

• But homes in rural areas, usually corresponding to homes served by wells, are the homes that are least likely to survive a fire because of long or inadequate responses by the fire service

• The solution is instead educating contractors on cost-efficient design options for well systems.

Wells as Water Supplies

Impact of residential sprinklers on public and private water

systems:

It was suggested by one builder during testimony at the Orlando hearing that operation of residential sprinklers connected to a small water system in a Michigan jurisdiction resulted in the jurisdiction having to drain and decontaminate the entire water system

Impact of residential sprinklers on public and private water

systems:

Response:• The event occurred on a private system• The event was linked to the use of fire hydrants

during suppression activities, not the sprinkler system

• The fire actually started outside of this building, spread to the interior, and sprinklers still helped to stop the fire’s progress

Impact on Water Systems

• Residential sprinklers decrease the demand on water systems because residential sprinklers use far less water than firefighters to extinguish a fire

• Scottsdale, Arizona’s experience provides data to support this claim– Scottsdale found that the average estimated water

usage per residential fire incident was 341 gallons– As compared to an estimated manual suppression

usage of 2,935 gallons in unsprinklered residential fires

Wait for more cost-effective approaches to residential sprinkler

protection before adopting a requirement in the IRC.

Opponents of residential sprinklers suggest that we should hold off on requiring such systems in dwellings until improvements in technology make the systems more cost effective

Response: • Improvements in sprinkler technology have

largely improved cost effectiveness already

• Some have suggested that we should wait for NFPA 13D to permit the use of a single operating sprinkler as a design basis, (as opposed to the two sprinkler design), before requiring sprinklers in the IRC

• Some have also suggested that we should revisit whether sprinklers are really needed everywhere NFPA 13D requires them before requiring residential sprinklers in the IRC

• The best way to encourage research and discussion on both of these ideas is to pass the IRC requirement now

• Market demand will drive the research as interest in sprinklers grows

• Market demand will also drive the creation of design tools that will simplify the exercises of locating sprinklers and sizing pipe

Reform NFPA 13D?

Required maintenance:

Opponents of residential sprinklers stated in Orlando that residential sprinkler systems need regular maintenance and questioned who would perform this service. Someone suggested that local fire departments will have to perform or verify maintenance, potentially raising concerns regarding right of entry.

• Residential sprinkler systems are essentially maintenance free– Occasional alarm test if device is on system– Mostly a list of things not to do

• No maintenance needs to be performed or witnessed by the fire department

Maintenance

Trained labor/inspectors

Opponents of residential sprinklers suggested in Orlando that, if the IRC were to require residential sprinklers, there would be a shortage of trained labor and trained inspectors to install and inspect these systems

Response:• The industry and code officials will respond once

the IRC has been revised, and there will be several years to ramp up before the 2009 IRC begins to have an impact

• This is exactly what has happened in the many local jurisdictions that have passed sprinkler ordinances

Organizations are already recognizing the need for trained individuals to design, install and inspect sprinkler systems in one and two family dwellings including the ICC and the American Society of Sanitary Engineers

Trained labor/inspectors

Leakage and mold damage:

In Orlando, opponents of residential sprinklers expressed fear that sprinklers would leak and cause mold damage, which could make a home uninsurable

Response:• Residential sprinklers systems are no different

than residential plumbing• Quality products that are properly installed won’t

leak

• Sprinkler system components are higher quality and more thoroughly tested than domestic piping and fixtures. – Sprinklers are tested to

• 700 psi for hydrostatic strength• 500 psi for leakage resistance• 100,000 cycles for water hammer resistance• 35-125°F for temperature cycling• Freeze performance to 20°F below for 24 hours.

• Sprinkler piping and components are rated for a pressure of 175 psi, while plumbing water supply systems are rated for only 80 psi.

Mold

Appendix P, good enough for now?

Opponents of residential sprinklers suggested in Orlando that, with the IRC having just accepted Appendix P, maybe it would be best to leave the sprinkler requirements in the appendix for a while to see what happens with it. The debate can happen at the local level.

Response:• Putting the sprinkler requirement into the body of the IRC

certainly won’t end the local debate• Puts the burden on the home building industry to justify

taking sprinklers out• Local code officials would then have a respectable

chance of keeping the sprinkler requirement.

HBA Public Comment to RB-114

• The Homebuilders have submitted a Public Comment to continue with the decision of the committee– Allow the debate at the local level– Don’t want to put jurisdictions in the position of

amending the code to take out a requirement– Sprinkler proponents want the item in the

Appendix

• Response: They’re wrong

Final Action Hearings (FAH) in Rochester, NY

• Convince local officials and building/fire associations to vote for the reversal of the committee’s action.

• Advocate fire sprinklers and RB-114 and disregard the HBA’s rhetoric

• Homebuilders have a record of fighting just about every initial effort to improve dwelling safety

• They initially fought against smoke detectors, ground fault interrupters and mandatory sprinklers in multi-family residential occupancies.

• On each of these topics, code officials heard the same predictions of gloom and doom, but once the codes moved forward to require these features, home building proceeded with no problem

• Prices for all of these features have declined• The scenario for residential sprinklers will play out

in exactly the same way

Homebuilders and Code Changes

• Urge our local officials to become one of the designated representatives of their community

• Make sure these local officials go to Rochester for the FAH

• Once in the Rochester meeting, urge our code officials to vote AGAINST the standing motion, which will be the committee’s recommendation for disapproval, and FOR the follow-up motion of APPROVAL AS MODIFIED by the public comment, which will be made once the standing motion has been defeated

What can we do?

Association Resolution to Support Residential Sprinklers in NY

• This resolution is for all building and fire organizations who will support RB-114.

• Several state, national, and local building and fire official groups are on board.

• We urge you to take copies of these to your local groups. The participating groups will be announced at the hearing as supporting RB-114.

• A copy is in the handouts section

All original signatures must be sent to:

Jeffrey M. Shapiro, P.E., FSFPEInternational Code Consultants8207 Asmara DriveAustin, TX  78750

(512) 795-2900   

Fax: (512) 795-2903

email: Jeff.Shapiro@IntlCodeConsultants.com

NFSA thanks Mr. Jeffrey Shapiro for his efforts in this drive. Please let him know our gratitude!

What can we do?• Since the only people who can vote at

the IRC hearings are public code officials (Building Officials, Fire Officials, Plumbing Inspectors, etc.), we need to lobby these people at the local level

• Educate ourselves on the IRC development process and the reasons why mandatory sprinkler requirements for all new one and two family dwellings are important and necessary

What can we do?• We can set up meetings with our local code

officials to convince them to go to Rochester and vote in favor of the sprinkler requirement (after verifying that they can represent their jurisdiction)

• Have NFSA staff members in Rochester to act as facilitators who can answer any final questions and make sure that the code officials that come to vote know when the vote will occur and when to speak up and be counted

Conclusion

Now that you’ve attended this short presentation, you now can go out and convince your local officials to go to the Final Action Hearings in Rochester, NY and vote in favor.

Please feel free to involve any of NFSA staff, including regional managers to assist you. Contacts can be found at www.nfsa.org

Registration to this event can be found on ICC’s website: www.iccsafe.org

Useful Handouts

• One Sentence . . . (letter written by Jeff Shapiro that addresses everything we’ve discussed today

• Resolution supporting sprinklers

• RB-114 Text

• NFSA Cost/Benefit Analysis