Get Involved in the Code Development Process

BY SEAN DeCRANE

As firefighters, we tend to bury ourselves in the performance aspects of our jobs. We probably do not even think about one of the things that most strongly determines what dangers we will face—the building codes. There is a general belief that the codes will get more restrictive each year, thus making buildings less and less dangerous to firefighters. But this may not be the case. The growing trend of allowing sprinkler system trade-offs that allow for the elimination of fire safety redundancies in construction, the use of lightweight construction, and making egress corridors longer and narrower in new structures are increasing the risks for firefighters.

As a firefighter, I strongly support the requirement of sprinklers. In fact, with the number of multiple firefighter fatality deaths in Charleston, South Carolina; Boston, Massachusetts; New York City; Winnipeg, Canada; and, recently, in California, there is a strong argument for requiring sprinklers in all buildings. Adding sprinklers, in my opinion, would directly reduce the number of firefighter fatalities. However, the reality is that we are being forced to discard one form of protection for another type of protection without any concern about what would happen if the one protection system should fail.

INTERNATIONAL BUILDING CODE

Let’s look at the intent of the International Building Code (IBC)¹:

The purpose of this code is to establish the minimum requirements to safeguard the public health, safety and general welfare … and to provide safety to fire fighters and emergency responders during emergency operations.

That paragraph should comfort the firefighting world. But is it reality? In fact, when code change proposals are being debated at the International Code Council’s public hearings, the most common reasons cited for opposing increases in fire safety are costs, cosmetic appearances, design freedom—and, again, costs. Yet, the National Fire Sprinkler Association (NFSA) can supply many compelling arguments that show that sprinklers are a good investment. The failure of a passive or an active fire protection system that has no redundancy can be very costly.

On numerous occasions, one protective property is forced to bargain a trade at the expense of additional protections. This often results in placing excessive reliance on only one safeguard, automatic sprinkler systems—in effect, putting a building occupant’s safety in one basket.

In contrast, the Commentary Edition of the 2003 IBC² states:

Interpretations should not be affected by economics or the potential impact on any party. The only considerations should be protection of public health, safety and welfare, and emergency responder safety.

Should this not be true of the Building Code as a whole? Why should only interpretations be subjected to the test of moral standards, especially in view of the following statement in the National Fire Protection Association (NFPA) Fire Protection Handbook³?

Success is measured by the extent of usage of effectively designed, integrated fire protection systems. No one system should be considered disposable, and no one system should be considered a panacea.

THE “REALITY” GAP

The NFSA has maintained that when properly designed, installed, and maintained, fire sprinklers will save lives and property. It has statistics to back that claim. When stated that way—if everything is properly designed, installed, and maintained—the statement is absolutely correct: However, the NFSA also promotes trade-ups: “… by trading passive protection for active fire suppression, increased fire safety is achieved.”⁴

This may be true in a perfect world, but we do not live in that type of world. I do not believe you will find a firefighter who is anti-sprinkler. Firefighters just naturally want buildings to be built and protected in ways that do not create the potential for an unusual and extreme hazard if something is less than perfect, a condition we know we can expect. We are the ones whose lives are at stake if there is a failure in a designed system, whether it is active or passive; and we would rather not become the victims of that failure.

SPRINKLER RELIABILITY

The available data justify doubting the reliability of fire sprinklers. In a published analysis of sprinkler reliability based on the latest data from the NFPA⁵, Bill Koffel states:

When combining the operational effectiveness and performance effectiveness data as published in the August 2005 NFPA report, the overall reliability of automatic sprinkler systems is 89 percent.6

This one-in-nine failure rate should be a concern to the firefighter who must crawl in a structure compromised by fire where various fire safety features may have been reduced or eliminated as incentives to get the sprinklers installed. In fairness to the sprinkler industry, these failures occur for reasons that mostly are not attributable to the sprinkler hardware itself. The reasons for failure in many of these cases are water shutoff and the system’s inadequacy for the hazard. We have also witnessed many issues regarding the siamese connections.

There are additional reasons for sprinkler system failure. On August 14, 2003, Cleveland and much of the northeastern United States were without power for a couple of days. In Cleveland, the blackout was so severe that we could not generate water pressure in the municipal water system. Here was a city sitting on billions of gallons of water on a Great Lake, and we were calling southern Ohio to have water tankers sent to our shores to supply water. If the hydrants do not have a water supply, then most sprinklers do not. Here was simultaneous impairment to almost every sprinkler in the city. How many other fire departments were affected by this blackout?

Recently, USA Today ran the article “Defective Sprinklers Spur Fire Officials to Push for Backups.”⁷ According to the article, the sprinkler industry identified 45 million defective sprinkler heads that had been installed over the previous seven years. It was determined that one in every 10 sprinkler heads installed since 1991 has the potential for failure. This statistic prompted the National Association of State Fire Marshals (NASFM) to act; it now has a greater presence at the code hearings and has also submitted a number of proposals attempting to reverse previous sprinkler trade-offs.

Recent occurrences of large fire losses where sprinklers have failed should alert us to the fact that the policy of relying on only one fire protection system is fundamentally flawed. In 2004, a 240,000-square-foot auto parts distribution center caught fire. The fire overwhelmed the sprinkler system, resulting in a loss of approximately $100 million. It was the single largest loss of property that year. In Texas, a 100-apartment-unit building suffered $11 million in damage when the sprinklers had been shut down because of a leak. In Maryland, an historic courthouse suffered $8 million in damage; sprinklers were present, but there was no report on their effectiveness.

Of course, other large-loss fires without sprinklers present also help to highlight the value of having a properly designed, installed, and maintained sprinkler system. Just looking at the fact that in 2004 there were 41 structures with more than $5 million in fire loss and only 10 of them were documented to have sprinklers should alert the property owners to reevaluate the cost of sprinklers compared to the devastating effects of a fire without them. Even though we are discussing some failures in the sprinkler systems, if sprinkler systems would have been present in those 25 structures, there is no doubt the damages would have been greatly reduced.

THE EXTENT OF TRADE-OFFS

An example of how far we have gone in trading off redundancy for the installation of sprinkler systems can be seen in the fourth edition of the NFSA’s Fire Sprinkler Guide.⁸ It reports that the 1997 edition of the Uniformed Building Code permitted 225 sprinkler trade-offs and the 2003 edition of the International Building Code allowed for 493 sprinkler trade-offs. This is an incredible increase of more than 100 percent. We should be advocating sprinkler protection without compromising additional aspects of protection.

When sprinklers are installed, the building code permits a designer to reduce the hourly fire rating in many corridors, including exit corridors; lengthen the exit corridors; increase the flammability of surface finishes; limit or attempt to limit elevator lobby protection; and even eliminate rating requirements in many of our schools. The building code presently also allows for the reduction of rated separations between occupancies and has increased the allowable height and area permitted in various types of occupancies.

The reductions in and even elimination of compartmentation in the building code seem to have come at the worst possible time. With the increase of toxicity levels in smoke—such as hydrogen cyanide and other by-products of incomplete combustion, mainly carbon monoxide—compartmentation could help to protect building occupants. In March 2006, the Providence (RI) Fire Department experienced a number of elevated cyanide poisoning cases in its firefighters. Twenty-eight firefighters who responded to structure fires over the weekend were tested; 27 had elevated levels of cyanide. Eight had high levels; one firefighter was in full arrest, which was believed to be from high levels of cyanide. There is also a suspicion that at The Station nightclub fire in Warwick, Rhode Island, cyanide poisoning incapacitated many of the victims, rendering them incapable of self-rescue and leading to CO poisoning and death.

CODE ENFORCEMENT NEEDED

In Building Construction for the Fire Service, Third Edition, (2000)⁹, Francis L. Brannigan wrote: “When a combustible structure is involved in fire, the building is the enemy, and you must know the enemy.” So many factors affect how a building reacts to a fire, including what happened to the building since it was built or last inspected. What happened when the occupants fled? Were fire doors left open? Were the HVAC systems operating correctly? Were windows open or doors locked? Were combustible materials or hazardous materials left exposed to the fire conditions?

The codes can give us a basis for initiating protection against fire, but enforcement is needed to guarantee adherence to the codes. However, enforcement is not a priority in today’s economy, evidenced by the continued reduction of fire prevention personnel in many departments. Knowing that ongoing enforcement is likely to be far less than perfect and complete, relying on one system removes the safety factors on which firefighters depend. Local government officials need to be educated on the importance of investing in enforcement.

“UNREALISTIC” TEST PARAMETERS

Another factor to consider is the difference between testing parameters and the real world. I have attended fire tests; they are very controlled. On the other hand, a computer simulation can account only for the information entered into the parameters. You can never really truly factor in real-life human shortcomings or errors. Yet, individuals making decisions on building protection are using these computer modules as the basis on which to accept or reject the proposed substitutions.

Fire Department of New York Deputy Chief (Ret.) Vincent Dunn, in “Are Architects, Engineers, and Code-Writing Officials Friends of the Firefighter?”¹⁰ focused on the proliferation of lightweight construction.

In fact, we lost four firefighters within two or so months at the end of 2006 because of structural collapse. Lightweight construction has been more liberally permitted in the IBC: unprotected wood and lightweight steel trusses; gusset plates; the elimination of fire-resistive materials; lightweight cold-formed steel; and laminated I-beams, which may have contributed to a firefighter’s death recently in Wisconsin, carry an incredible amount of weight, are easy to work with in the construction field, and are very cost effective, but they are deadly in a firefighter’s work environment. Many times, we do not even know they are present.

In Wisconsin, the firefighters responded to a house fire. It was reported that they tested the floor before entering the structure, only to have the floor collapse beneath them. It turned out to be a heated floor with a 1 1/2-inch concrete thickness, so it felt solid. The problem was the lightweight I-beams, which were being compromised by fire in the basement. The firefighter died of injuries and burns. The lightweight construction industry must do more than educate firefighters. It must seek solutions to prevent a sudden collapse under an adverse condition such as fire.

In recent years, the number of structure fires in the United States has decreased. It would seem natural to assume that with reduced deaths we are also experiencing a reduced amount of risk. Yet, if we look at the deaths per incident, we see a different tale. Looking at the NFPA report U.S. Fire Service Fatalities in Structure Fires, 1977-2000, published in July 2002,¹¹ it turns out that the death rate per incident has been relatively the same for the past 30 years. In the late 1970s, the death rate for firefighters was 5.8 deaths per 100,000 structure fires; in the late 1990s, the rate was 5.7 deaths per 100,000 structure fires. So, firefighters today have the same risk of death as 30 years ago. With improved training and equipment, the logical thought would be that these numbers should have been drastically reduced.

However, we are losing more firefighters per incident to traumatic injury. Traumatic death rates went from 1.8 deaths per 100,000 fires in the late 1970s to almost three deaths per 100,000 fires in the 1990s. A deeper look into these numbers in nonheart attack-related deaths, 63 percent were from smoke inhalation (increased toxicity of smoke), 18.5 percent burns, and 16.1 percent internal injury. The major causes of fireground deaths inside structures were getting lost inside the structure, structural collapse, and flashover and backdraft.

Looking at the decade of the 1990s, 87 firefighter fatalities were attributed to smoke inhalation. Of those 87 deaths, 29 firefighters had gotten lost in the structure, 23 died as a result of the fire’s progressing (backdraft/flashover), and 18 deaths were caused by structural collapse. All firefighters were wearing SCBAs except one, who died trying to save his son in his home. During the same time period, 31 firefighter deaths were caused by burns, 14 by the fire’s progress, and 12 by structural collapse. Internal injuries caused 17 fireground deaths and eight structural collapse deaths. This seems to be an alarming number of deaths from structural collapse. Could more redundancy in the code providing for more structural integrity, sprinkler requirements, smoke and flame containment, or the limited use of lightweight construction have made a difference in these line-of-duty deaths?

THE COST OF FIREFIGHTER INJURIES

Some will argue that we are going to lose firefighters each year regardless of the codes and the quality of construction and that these losses are “statistically insignificant” and not worth the added expense of mandating additional requirements in construction. Let’s look at the costs of firefighter injuries.

In the National Institute of Standards and Technology (NIST) report “Consequences of Firefighter Injuries,” published in 2004,¹² the authors tried to quantify the cost of firefighter injuries each year. What they found—and these numbers can be mind-boggling—is that approximately 80,910 firefighters were injured in 2002. The rate of injury per fire incident remained relatively constant over a period of approximately 15 years, at 25.5 injuries per 1,000 incidents. The rate of injuries per nonfire incidents dropped from 1.43 injuries to about 0.77 injuries per 1,000 incidents. Keep in mind that many exposures to hazardous materials and biohazards do not get reported as injuries.

Since no all-encompassing strategy for determining bottom-line costs was identified, they used a combination of methods to include direct and indirect costs—everything from hospital costs to counseling to additional training and paperwork. They arrived at the conclusion that injuries sustained by firefighters in 2002 have a lifetime cost ranging from $2.8 billion to $7.8 billion. Just imagine if we could divert a portion of those costs into a more redundant fire protection system for structures. It may pay for itself many times over, considering that these costs are incurred each year. The money saved in construction costs for a viable safer building is possibly being transferred to potential loss in other areas, such as increased local taxes, insurance, and workers’ compensation costs. An owner or property management company may incur these additional risk costs and still have a compromised building. Why not invest in the initial construction cost to provide a safer building for occupants and responding firefighters?

FIREFIGHTERS MUST BE INVOLVED

Richard Licht in “The Impact of Building Code Changes on Fire Service Safety”¹³ pointed out that architects, engineers, building owners, and numerous others in industry are dictating the environment in which firefighters work and that firefighters are not involved in the building code process. It was after reading this article that I decided to become more involved.

After attending a couple of code hearings and listening to people who have never been in the fire service, let alone in a fire, tell people what it is like and how I should perform my fire duties, I realized I had to become involved. Our goal in participating in the code activity should be to make the firefighter’s work environment safer. It would be great to see more firefighters get involved in the code revision process and to hear from those who plan on attending. We must have a say in matters that affect our livelihood and safety. Note: The International Code Council’s Code Action Hearing will be held February 18-March 2, 2008, in Palm Springs, California; the Final Action Hearings will be in September.

Has the building code fallen short in some sections relative to the intent of making firefighters and emergency responders safe? We will not know for sure for many years. The buildings being constructed to the IBC are still new. Fifteen to 20 years from now, when the new buildings lose their luster and maintenance levels drop or the occupancy changes, we will begin to see the true effects of the current building code proposals. With the current trend of reducing protection levels, my fear is that firefighters will pay the ultimate price more often. Since our recent increased participation, there have been some positive effects. Representatives from the truss, steel, wood, and structural components industries and the fire service are discussing the implementation of firefighter safety marking systems, and there is legitimate discussion on what is acceptable in the height and area allowed by the building code.

As we revisit Brannigan’s statement concerning knowing our enemy, a recent comment from a friend comes to mind. He asked if the building was our enemy or whether our enemies are those who advocate or allow the compromised building to be built. Only when the fire service is involved in the code-development process will we be able to guide those making the proposals to understand the code’s intent: “to provide safety to firefighters and emergency responders during emergency operations.”

References

1. International Building Code, International Code Council, Club Hills, IL, 2004.

2. International Building Code, commentary, International Code Council, Club Hills, IL, 2004.

3. Fire Protection Handbook, National Fire Protection Association, Quincy, MA, 1997.

4. Endthoff, Gene, ”The sprinkler trade-off concept,” National Fire Sprinkler Association, 1998. Retrieved March 4, 2006, www.nfsa.org

5. Rohr, Kimberly and John R. Hall, Jr., “U.S. experience with sprinklers and other fire extinguishing equipment,” National Fire Protection Association, August 2005.

6. Koffel, William, “Reliability of automatic sprinkler systems: Bringing Back Balance,” Alliance for Fire Smoke Containment and Control, 2004; revised January 2006.

7. Eisler, Paul, “Defective sprinklers spur fire officials to push for backups,” USA Today, February 12, 2006.

8. National Fire Sprinkler Guide, 4th Edition, National Fire Sprinkler Association, 2004.

9. Brannigan, Francis L. Building Construction for the Fire Service. (Quincy, MA: National Fire Protection Association). 2000.

10. Dunn, Vincent, “Are architects, engineers and code-writing officials friends of the firefighter?” New York, NY, 2001, vincentdunn.com/.

11. Fahey, Rita, “U.S. fire service fatalities in structure fires, 1997-2000,” National Fire Protection Association, July 2002.

12. ”The economic consequences of fire fighter injuries and their prevention: Final report,” National Institute of Standards and Technology, Gaithersburg, MD, March 2005.

13. Licht, Richard, “The impact of building code changes on fire service safety,” Fire Engineering, April 2005; 158:223-228.

SEAN DeCRANE is a 16-year veteran of and a battalion chief in the Cleveland (OH) Fire Department, assigned as a training officer at the Cleveland Fire Training Academy. He is a certified Ohio fire safety inspector and the secretary for the Cleveland Fire Fighters Association, IAFF Local #93. He represents the IAFF in the International Code Council process.