To Whom It May Concern:

My name is Brian McGraw and I am the State Fire Marshal for the Commonwealth of Virginia. As the individual responsible for enforcement of the SFPC in all state facilities and in all portions of the Commonwealth that do not have a local fire official (approximately 63% of the land mass of the Commonwealth) , I would like to add my name to the comments made by the Virginia Fire Chiefs Association.  I would also like to add the following technical concerns to the list already submitted by VFCA.

Table 5605.3 provides the “Minimum Intraline (Intraplant) Separation Distances Between Barricaded Operating Buildings Containing Explosives – Division 1.1, 1.2 or 1.5 Mass-Explosion Hazard”.  As indicated in Section 5605.3, the separation distances in this table also apply to magazine separation distances making this table an important tool for Fire Officials who regulate explosives magazines.  However, references to this table have been deleted in Section 5601.8.1.3 and 5605.6.4.1 in the version published on the Register of Regulations.  However, the deletions did not occur using legislative text, i.e. the references to the tables are not struck out, they simply do not exist.

These deletions do not appear in the “Book 7 FINAL” which is the document that the Board of Housing and Community Development and their associated code committees acted on in September and October of 2017.  In other words, it appears that this is a deletion that occurred after formal action was taken by the Board.  These deletions were not considered during the Work Group Meetings and therefore, are not consenus changes.

Sincerely,

Brian M. McGraw, P.E.

State Fire Marshal

Virginia Department of Fire Programs