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

Tue Jul 19 00:28:41 UTC 2011

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%20combined.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, “otherwise equally” leaves  
a lot of
interpretive room. Also, this section states that the retied bales should be
tied “firmly”. 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 “At 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.”  
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 aren’t 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 “plaster skins
for structural strawbale walls shall be continuously supported along their
bottom edge to facilitate the transfer of loads to the foundation system.” 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 “Strawbale 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.” 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.

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