[GSBN] Fwd: Fire Marshals propose eliminating SB section in IGCC

Sun Aug 7 10:49:08 UTC 2011

All, 

This GSBN e-mail came to me the day I landed in Haiti for an intense 10 days
continuing our work with straw bale and other sustainable building systems
there.  I was also made aware of it a few days earlier from a code official
from New Jersey.  I'm just now coming up for air after the continued Haiti
work, but I plan to address this in the coming week as the deadline for
Public Comments for the IGCC approaches.

I won't say the comments from the NASFM are without any merit whatsoever,
but they are mostly off base.  Without going point by point, the comments
are ignorant of the ASTM E-119 tests conducted in 2006, upon which the rated
assemblies in the SB section are strictly based.  Also it t refers to "hay
bale fires", and this section is about straw, not hay.

At the Dallas hearings in May, I communicated with an opponent of the fire
section from the Underwriters Laboratory, and after a constructive
discussion we modified the language slightly, and he was in full support.
For procedural reasons the modified language was not included, but I will
propose it in the upcoming Public Comments.  I will also communicate with
the opponents from the the NASFM directly.

Martin Hammer

On 7/18/11 5:28 PM, "ejgeorge at riseup.net" <ejgeorge at riseup.net> wrote:

> Hi all,
> 
> FYI - This came off the Natural Builders NorthEast list - from a
> builder who is also a volunteer firefighter. The text relating to
> strawbales is below, but it is easier to read in it's original format
> on page 2 of the document that should be attached (it is also linked
> below).
> 
> ej
> 
> 
> 
> The National Association of State Fire Marshals is intervening in the
> green building code development process because of legitimate concerns
> about the lack of adequate fire safety considerations in the initial
> code development process, and subsequent to a number of structure
> fires caused by spray and rigid foam and structure collapse due to
> lightweight engineered lumber framing. 
> Because of lack of familiarity with SB construction and some
> experience with hay bale fires, the NASFM is proposing the deletion of
> section 507: Strawbale Construction.
> 
> http://www.greenbuildingfiresafety.org/PDF/NASFM%20comments%20IGCC%20PV2%20com
> bined.pdf
> IGCC
> 
> CODE CHANGE PROPOSAL FORM
> 
>  
> 
> Code Sections/Tables/Figures
> Proposed for Revision 507
> 
>  
> 
> Proponent: Name/Company/Representing: Alan Shuman, President, National
> Association of State Fire Marshals, representing the National Association of
> State Fire Marshals
> 
>  
> 
> Email Address: ashuman at sfm.ga.gov
> 
>  
> 
> Revise as follows: Delete Section 507, Strawbale
> Construction.
> 
>  
> 
> Reason: Section 507 provides relatively
> comprehensive construction criteria for a particular type of construction. It
> is inappropriate and beyond the intent of the IGCC to create a construction
> regulation that includes structural, fire protection, weather protection and
> similar regulations. From the IGCC:
> 
>  
> 
> 101.3
> Intent. The
> purpose of this code is to safeguard the environment, public health,
> safety and
> general welfare through the establishment of requirements to reduce the
> negative potential impacts and increase the positive potential impacts of the
> built environment on the natural environment and building occupants, by
> means of minimum requirements related to: conservation of natural
> resources, materials
> and energy; the employment of renewable energy technologies, indoor
> and outdoor
> air quality; and building operations and maintenance.
> 
>  
> 
> 102.1
> General. This
> code is an overlay to the other International Codes. This code is not intended
> to be used as a stand alone construction regulation document or to abridge or
> supersede safety, health or environmental requirements under other applicable
> codes or ordinances.
> 
>  
> 
> 507.4
> Structure. Buildings
> constructed with straw bales shall comply with Sections 507.4.1
> through 507.4.15
> and the structural provisions of the International Building Code, except
> as otherwise provided for in Sections 507.4.1 through 507.4.15. The type of
> structural system used shall be a type allowed by the International Building
> Code and Sections 507.4.1 through 507.4.15.
> 
>  
> 
> This section clearly conflicts
> with the IBC by setting out alternative structural criteria for
> strawbale construction.
> 
>  
> 
>  From the IBC:
> 
>  
> 
> 101.3 Intent. The purpose of this code is to
> establish the minimum requirements to safeguard the public health, safety and
> general welfare through structural strength, means of egress facilities,
> stability, sanitation, adequate light and ventilation, energy
> conservation, and
> safety to life and property from fire and other hazards attributed to
> the built
> environment and to provide safety to fire fighters and emergency responders
> during emergency operations.
> 
>  
> 
> It is clear that the construction
> criteria contained in Section 507 of the IGCC are within the primary
> scope of the
> IBC. Just because the criteria are material-specific, the IGCC should not be
> given authority to supersede the IBC by creating construction
> requirements that
> are under the purview of the IBC Code Development Committees. The IBC
> regulates
> all other construction materials, and straw bales should be no different.
> 
>  
> 
> In addition to the scoping
> issues, there are several items of concern, including:
> 
>  
> 
> 507.2.3 Ties. This paragraph is confusing,
> vague, and nebulous. Ties shall be 3-6 inches from faces, but
> otherwise equally
> spaced? Equally is understandable; however, ³otherwise equally² leaves
> a lot of
> interpretive room. Also, this section states that the retied bales should be
> tied ³firmly². How firmly retied should the ties be? This is not good code
> language.
> 
>  
> 
> 507.2.4 provides the criteria for moisture
> content of straw bales, and states that ³At least 5 percent of and not less
> than 10 of the bales used shall be randomly selected and tested to
> determine if
> all of the bales for the building are of acceptable moisture content.²
> Moisture
> content is a very serious issue, and straw bales may vary widely in this
> regard. To test the moisture content in only five percent of the bales leaves
> too much to chance. Hay bales can self ignite, or can decompose over time if
> they aren¹t dry enough.
> 
>  
> 
> Section 507.2.5 provides the criteria for the
> density of the bales, and requires that at least 2 percent of the bales to be
> used be tested. Testing only two percent of the bales for the correct density
> presents far too much risk. A baler may adjust the compaction rate at any time
> during the baling process, causing the density to change. What if a
> bale of hay
> fails when two percent are tested? Is the entire stock of bales rejected? Is
> another two percent tested? This section needs work.
> 
>  
> 
> Section 507.4.8.1 states that ³plaster skins
> for structural strawbale walls shall be continuously supported along their
> bottom edge to facilitate the transfer of loads to the foundation system.² To
> our knowledge, plaster skins are not load bearing components of any acceptable
> wall system, and should not be used as such without significant justification.
> 
>  
> 
> Section 507.6 states that ³Strawbale walls
> constructed with plaster finishes in accordance with Sections 507.6.1 through
> 507.6.3 shall be deemed to meet the conditions of acceptance as outlined in
> ASTM Method E119 for fire resistance of non-load bearing walls.² Strawbale
> construction should not be exempt from fire testing assemblies
> required to have
> a fire rating.
> 
>  
> 
> There are many requirements in this section
> that are problematic; those outlined above are good examples. It should be
> pointed out that the submittal to include these construction
> requirements for strawbale
> construction did not include any technical justification for any of them.
> 
>  
> 
> Creating an entirely new class of
> construction within the Green Code is inappropriate on its face; to do
> so without
> technical justification places the entire process at risk.
> 
>  
> 
> ----- End forwarded message -----
> 
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