Action | Update the Statewide Fire Prevention Code |
Stage | Final |
Comment Period | Ended on 6/29/2018 |
My name is Ernie Little, a retired Battalion Chief and member of the Virginia Fire Chiefs Association, Virginia Fire Prevention Association, and International Code Council. This document is the second part of my comments regarding the proposed amendments to the 2015 SFPC. There are two parts, first dealing with fire and building code development and the second indicating samples of instances where the proposed amendments have instances incorrect references, formatting issues, mismatched section titles that do not appear to relate to what is in the associated code section, typos in what code section is being amended, and other issues that could and should have been caught when the document was proofread.
Code development:
The International Code Council (ICC) family of model codes, which include the IBC and IFC, are developed using a nationally accepted code development process. This process is consensus driven and allows input from a wide variety of stakeholders to “vet” possible code changes and allow the positives and negatives of the changes to be heard by all. These codes, each on their own, are comprehensive, are coordinated and compatible with each other, and are developed according to the same process in the same forum. All codes reference consensus standards developed by Standard Developing Organizations (SDO’s) which keep them current with the most current codes and standards developed by these organizations. The ICC code process has been used by stakeholders representing an assortment of local and state government agencies and other organizations and individuals from Virginia that want to have a safe and sound built environment that they and the citizens and visitors to the Commonwealth can live and visit. The codes that are developed through this process are widely accepted and recognized as being technically correct, correlated, legally sound, and enforceable on the part of building and fire inspectors.
I have spoken to many involved in the 2015 Virginia code development process that have indicated to me that the code development process used in the USBC and SFPC amendments for the state 2015 code cycle was difficult and “rushed” to make allow the various code development work groups to meet the deadlines imposed upon them. I understand, through the same conversations, that the 2015 proposed amendments contain both consensus and non-consensus items from the work groups as well as other changes made by the Virginia Department of Housing and Development staff. With that said it understandable that the proposed amendments could be flawed and contain typos, incorrect references, and disassociated section titles and section material that could can and will cause significant issues dealing with life safety in the buildings and structures located in the Commonwealth. To me this is not acceptable and the proposed amendments need to be reviewed for the abovementioned issues and corrected before final action on the proposed amendments takes place.
In my review of the proposed SFPC amendments I found many instances of where they contain one or more issues dealing with the SFPC and USBC scope, Chapter and section formatting, incorrect references, lack on consistent code language, mismatched section titles, and typos that need correction. I provide the following as sample of the problems I found during my review.
General comments:
Incorrect reference:
Formatting issues:
Lack of consistency:
Mismatched section titles:
I appreciate the opportunity to participate in the SFPC code update process and my support to the positions and comments other fire related organizations, such as the Virginia Fire Chiefs Association, Virginia Fire Prevention Association, Virginia International Association of Arson Investigators, and individuals that share my concerns regarding the SFPC process and proposed amendments. I ask that we remember that building and fire officials, building and fire code inspectors, plans reviewers all have a charge to assure that our building and structures provide a healthy, affordable, safe environment protecting those that live, work, and visit the Commonwealth of Virginia to be safe in them.