The NASFM Viewpoint?
By Richard Schulte
Schulte & Associates, Evanston, Ill.
Last month's column reviewed excerpts from some of the justifications used by the National Assn. of State Fire Marshals (NASFM) to support their code change proposals to the International Building Code in recent code change cycles. Perhaps two of the most intriguing (and arrogant) statements made in these justifications are the following:
"Public policy places a high value on the safety and security of emergency responders. A person who intentionally endangers a law enforcement officer faces imprisonment and fines. The net effect of reducing the hourly ratings of critical building elements is that firefighters may be at greater risk of death and injury from structural collapse. The fire-resistive construction requirements of critical areas must be restored to the previous levels, and may, along with greater requirements for active protection, require further upward adjustments as more is known about the fuel load in these occupancies." Code Change Proposal G139-04/05
"It makes little sense to await the loss of life and property before we consider returning to proven safety practices. In fact, "waiting and seeing" begs the question: "How many lives must be lost to justify a return to what we know to be safe?" Our intuitive presumption would be that making buildings larger, both in height and area, with less built-in passive fire-resistive protection. The use greater use of combustible materials can only result in greater property loss and the potential for greater loss of life. We all agree that one life lost is one too many. So, let us prevent the loss of that one life." Code Change Proposal G122-06/07
Imagine a group of public servants (e.g., the fire marshals of all 50 states) who believe that if you disagree with them over public policy (e.g., the contents of the International Building Code) you should be fined and thrown in prison. Who needs discussions of public policy or code change hearings when we have 50 state fire marshals who are collectively more knowledgeable about building fire safety than anyone else in the U.S.? Based on many of the statements excerpted in last month's column, it appears quite obvious that the NASFM organization lacks a fundamental understanding of building fire safety and the purpose of the International Building Code. That is more than a little embarrassing. Given NASFM's flippant remark about "imprisonment and fines" for anyone who would disagree with them, it would be in the best interest of both the public and the fire service to ignore this organization until NASFM finds new leadership that can make a cogent argument for its proposals.
While NASFM's "imprisonment and fines" remark exposes the smugness of the organization, the second excerpt above is even more outrageous. Imagine an organization that believes that we can prevent the death of any and all of the citizens of the U.S. If I am not mistaken, we will all die, regardless of the amount of tax money the government throws around trying to prevent our deaths. The statement that "we all agree that one life lost is one too many" reveals that, as far as NASFM goes, cost is no object. Of course, cost is no object to NASFM, which is an organization made up of officials who spend taxpayers' dollars-not their own money.
People who are knowledgeable in the field of fire protection should know that it is simply not possible to prevent every civilian fire fatality and every firefighter fatality. If someone falls asleep while smoking in bed and the cigarette ignites their clothing or the bedding, the only fire protection device that can improve the smoker's chance of surviving the fire is the residential sprinkler. While residential sprinklers may improve the chances of survival, even residential sprinkler protection cannot ensure the survival of a smoker who falls asleep with a lighted cigarette.
Similarly, eliminating non-rated building construction, a stated goal of the NASFM organization, will not eliminate firefighter fatalities. Statistics collected by the National Fire Protection Assn. (NFPA) indicate that while there are numerous causes of firefighter fatalities, the leading cause is sudden cardiac death (heart attacks). The risk factors for heart disease are well known-smoking, being overweight, high blood pressure, being a male over 40 years of age or a female over 50 years of age, but firefighters with known risk factors for heart disease continue to be involved in firefighting. Until everyone in the fire service acknowledges that firefighters with known risk factors have no business on the fire ground, firefighter fatalities caused by sudden cardiac death will continue to occur.
Even if non-rated building construction were eliminated, this still won't eliminate firefighter fatalities connected with interior manual fire fighting operations. Far too many firefighter fatalities occur simply because of poor command decisions by the fire service. Today's firefighting protective gear makes some firefighters feel invincible. The best way to eliminate firefighter fatalities due to structural collapse is to avoid interior manual firefighting in buildings with uncontrolled fires and the most effective way to do that is through the use of sprinkler protection. Sprinkler protection is a far more-effective structural fire fighter than dozens of firefighters with self-contained breathing apparatus, protective clothing, hose and an engine.
Of course, if you read NASFM's justification for their code change proposals you would know that sprinkler protection isn't always effective. NASFM continuously makes that point, however, according to NFPA, two-thirds of the sprinkler system failures are due to closed water supply control valves. Part of the fire services' job includes fire-prevention activities, which includes the inspection of sprinkler system water supply valves.
The International Fire Code (IFC), the companion code to the International Building Code, mandates that sprinkler protection be maintained. It also indicates that the fire official is responsible for enforcing the IFC. If a sprinkler water supply valve is closed, it's not only a violation of the fire prevention code by the building owner, but also a failure to enforce the code. Making sure that a sprinkler system is in operable condition and adequate for the hazard protected prior to a fire in a sprinklered building is as much part of the job of being a firefighter as dragging hose into a building protected by a sprinkler system that has failed.
The comment that "we all agree that one life lost is one too many" also clearly shows that NASFM lacks a perspective on life safety issues. According to NFPA estimates, only 50 civilian fire fatalities occurred all of the commercial (nonresidential) buildings in the U.S. in 2005, however, the National Highway Traffic Safety Administration (NHTSA) indicates that 42,642 Americans died in traffic accidents in 2006. Given those two statistics, it seems obvious that any organization interested in life safety would recommend that any additional resources be invested in traffic safety (or other more pressing safety issues), not fire safety in commercial buildings.
A comparison between firefighter fatalities and fatalities of professional truck drivers yields a similar conclusion. According to NFPA, 89 firefighters died while on duty in 2006, while 87 firefighters died while on duty in 2005. (Again, note that many of these fatalities occurred as a result of intense physical exertion by firefighters with known risk factors for sudden cardiac death. In essence, the fatalities were self-inflicted.) According to NHTSA, 804 fatalities occurred in large trucks in 2005, while 805 fatalities occurred in large trucks in 2006. Once again, if life safety is the objective, it would appear that investing resources to reduce the number of fatalities which occur in large trucks would yield far greater dividends than investing resources in firefighter safety.
There are two ways we can reduce fire losses. One way is to throw money at the problem by simply making building codes more restrictive (i.e., eliminating reductions in passive fire protection when sprinkler protection is provided, typically referred to as sprinkler "trade-offs"), but not bother to make sure that the required fire protection features are actually maintained. The other way is to mandate fewer fire protection features, but actually make sure that the mandated fire protection features are being properly maintained. From a common sense standpoint, the second route seems more logical, but the NASFM code change proposals take the "let's throw money at the problem" approach. After all, why should NASFM care? It's not their money that they are talking about spending.
From my experience in fire prevention end of the fire service (fire protection engineer, San Jose, CA, Fire Dept., 1980-82), far too few of the fire services' resources are devoted to fire-prevention activities and the suppression end of the fire service doesn't want anything to do with fire prevention activities. It's my opinion that NASFM should be less involved threatening "imprisonment and fines" for those who disagree with their opinions and should be more involved in getting all of the fire service involved in fire prevention activities. How about imprisonment and fines for members of the fire service who refuse to actively participate in their fire prevention duties? Don't get upset with me about that comment-it's just the next logical extension of NASFM's idea to use "imprisonment and fines."
To conclude this article, one more constructive recommendation for NASFM (as if I haven't already provided enough constructive criticism already). The members and staff of NASFM should study the fire protection and fire safety concepts that were developed in the 1970s and early 1980s (i.e., the GSA conferences on fire protection for high-rise buildings and the NFPA "decision tree"). There is a wealth of information on the technical justification for the sprinkler "trade-offs" now included in the International Building Code from that era.
It is interesting to note the extremely high level of support for sprinkler "trade-offs" provided by the fire service just 30 years ago. Perhaps all of the members of the fire service who so strongly supported sprinkler trade-offs in the 1970s have left the fire service and simply neglected to tell the firefighters who followed them in the profession about the high level of firefighter safety provided by sprinkler protection. According to NFPA, no firefighter fatalities occurred in any building protected by a sprinkler system in 2005 and 2006. You can't, and never will be able to make that statement about passive fire protection.
Members of the fire service who oppose sprinkler trade-offs as a way to encourage the installation of sprinklers have obviously been listening to the Alliance for Fire and Smoke Containment and Control (AFSCC). Some independent study and research into the history of the development of sprinkler "trade-offs" in the early 1970s should change the fire service's current thinking about the need for both "a belt and suspenders." It's my opinion that the notions about "balanced" fire protection and the lack of reliability of sprinkler systems being pushed by the AFSCC are nothing more than a ploy to sell more passive fire protection products and the fire service had fallen for the "bait." Sprinkler system "trade-offs" make as much sense today as they did when the concept of using highly effective active fire protection (sprinklers) as a substitute for ineffective passive fire protection was first proposed 40 (or more) years ago.
Richard Schulte is a 1976 graduate of the fire protection engineering program at the Illinois Institute of Technology. After working in various positions within the fire protection field, he formed Schulte & Associates in 1988. His consulting experience includes work on the Sears Tower and numerous other notable structures. He has also acted as an expert witness in the litigation involving the fire at the New Orleans Distribution Center. He can be contacted by sending e-mail to rschulte@plumbingengineer.com.