Representing the Central Virginia Fire Arson Association (CVFAA), please accept these comments on behalf of over 100 members of the fire service community regarding the 2015 Statewide Fire Prevention Code adoption process.

In addition of support to the comments entered by VFCA President, Anthony McDowell and VFPA representative, Linda Hale we are urging you to consider re-evaluating changes proposed in the 2015 Statewide Fire Prevention code. The changes presented are voluminous and nowhere near being vetted to ascertain any of the unintended consequences. Below are just a few code section changes that were recognized as being potential problems. We are certain there are many more because the entirety of these massive changes have not been thoroughly evaluated.

301.3 Occupancy. Within this section change the Board voted to change the last sentence to state, “Where a certificate of occupancy is not available for a building, the owner or owners agent MAY (emphasis added) request that one be issued by the building official and retained on site for reference.”

The use of the word “MAY” is not proper code language and is completely unenforceable.

603.3. Underground Storage of Fuel Oil. Current codes references NFPA 31 as the guiding document for compliance. Under the changes proposed the reference to use NFPA 31 is removed and substituted with the statement, “in accordance with the applicable building code.” This removes any guidance and enforcement to operation requirements and may prevent enforcing standards such as mixing fuels.

901.5.1 Occupancy. This entire section is proposed to be deleted. Currently, this section gives authority to the Fire Marshal to not allow a building to be occupied unless all fire detection and suppression systems have been tested and approved. By deleting this, a building can be stocked, operating and/or occupied before any fire safety systems are functional, and there are no enforcement capabilities for the Fire Marshal to utilize to prevent it.

Throughout many code section changes the statement “maintained in accordance with the applicable building code” is used. This can be very confusing, as the building code does not have any maintenance provisions, and some of those changed sections do not point to the applicable NFPA guidance document, whereas some do. No consistency.

The word “approved” is a defined word and italicized to indicate the defined term. In several sections “approved” is not italicized as should be required.

These are merely a sampling of concerns regarding specific proposed changes. Others have provided even more in their respective comments. Please consider our request for re-evaluation of the slated changes.