The complaint
The essence of the complaint was that the wrong Technical Committee has been given jurisdiction over the material in Section 6-2 of the Fire Pump Standard. The complaint asked that when the Council issued the new edition of NFPA 20 (which had just completed its cycle), the superscript designation be placed on Section 62 thereof, and that the Council then notify the National Electrical Code Committee that the corresponding superscripts will be deleted from Article 695 in the next revision cycle for NFPA 70. This would allow NEC Code Making Panel 15 to have a free hand in processing amendments in this area during the 1999 revision cycle.
By way of background, the complaint noted the present division of jurisdiction resulted from a Council decision to give the NFPA 20 Committee authority over questions of performance and the NEC Committee jurisdiction over questions of installation. The complaint didn't quarrel with that decision, only the way the term "performance" had been applied. The complaint continued:
There is no question that the Fire Pump
Committee has the authority to
specify a high degree of reliability for
a fire pump system. That is squarely a
performance issue. As to what
electrical installation procedures will
achieve that degree of reliability,
however, is an installation question.
Other NFPA Technical Committees,
including the Fire Pump Committee,
simply lack the technical expertise to
decide what wiring arrangements
achieve the required reliability. The
Standards Council should, by this
complaint, revisit the fundamental
policy issue of exactly what should be
included when it assigns electrical
performance criteria to another
technical committee.
This is not a theoretical
abstraction. In this case there is a clear
consensus of the electrical industry
that the Fire Pump Standard does not
remotely address the full-range of
reliable electrical supply systems,
particularly in campus-style
distributions where buildings are fed
from buildings that are in turn fed
from other buildings...
The only option is to use diesel
engines as the power source, unless
variances are available from the
authority having jurisdiction. The
irony is that many of these industrial
occupancies are using plant
distribution systems precisely because
they are concerned about the relative
reliability of utility sources. In other
words, the steadfast position of the
NFPA 20 Committee has the perverse
effect of decreasing the reliability of
fire pump power supplies.
The complaint observed that when the requirements only appeared in NFPA 20 they were less troublesome due to the relative lack of formal adoption of that standard. In addition, in cases where it was formally adopted, the enforcement would typically be by nonelectrical personnel who would consider medium-voltage distribution systems to be possible service points instead of premises wiring and thereby allow what electrical inspectors must now disallow.
The complaint also pointed to the urgency involved, since if NFPA 20 needed to be revised first, the NEC would carry these issues into the 2002 cycle or even later. This would have a significant impact on the continued adoptability of the NEC.
The hearing before Council
At the hearing, this editor focused on the argument frequently presented by NFPA 20 members that the electrical community's issues are rooted in economics and design convenience and do not adequately provide for public safety as reflected in the survivability of the fire pump. The rebuttal to that argument pointed to some of the supporting letters that had been submitted to support the complaint, including the International Association of Electrical Inspectors and the International Brotherhood of Electrical Workers.
In particular, Steve Mezsick (representing the Chemical Manufacturers Association on CMP 15 but writing for himself) pointed to how his company, Eli Lilly, addressed such issues:
In consultation with our insurer,
personnel safety and loss prevention
are prime considerations. As such, my
company far exceeds the minimum
requirements set forth in standards. In
our campus-type facilities, we have
multiple fire pumps tied together in a
looped water pipe main system. The
largest fire pump can be out of service,
and the remaining pumps will supply
adequate water for our worst case
scenario. Reliable electrical power is
paramount for fire pumps. These
pumps are generally powered from
double-ended loadcenters. Since the
State of Indiana has adopted NFPA 20
as well as NFPA 70, a variance is
required for all of our installations.
Power from a double-ended loadcenter
is far superior to that of a "normal"
low-voltage ([is less than]15kV)
connection from an electric utility.
Each of our Indiana plants have either
multiple 69kV or 138kV services.
Following transformations, each end of a
double-ended loadcenter is fed from an
independent utility source. High
voltage lines have far lower outage
occurrence than low voltage lines.
In addition, the complaint pointed to the broad range of NFPA standards that covered occupancies or loads that required a high degree of reliability for their electrical supplies. Many of these involve direct threats to life safety upon discontinuation of electric power. Nevertheless, the NFPA 20 standard is unique in its service requirements, and many jurisdictions are moving to rewrite the offending provisions of Art. 695 accordingly.
This editor concluded his presentation with a suggestion for compromise if the Council were unwilling to transfer jurisdiction: "Perhaps some type of joint jurisdiction through a reinvigorated task group with clear direction from this Council could be fashioned."
The opponents to the complaint, including T. Jaeger (NFPA 20 Chair), R. Schneider and M. DeLerno (NFPA 20 members) argued that the provisions were in fact performance requirements and should remain under the jurisdiction of NFPA 20. The Council decision summarized their arguments as follows:
They argued that the reliability of
installations is better served through
NFPA 20, since fire pump
survivability is a fundamental concept
to fire-related enforcers, but of a lesser
priority to electrical-related enforcers.
They pointed out the current issue
has, in effect, already been argued
before and decided by the Council in
the July 1995 decision regarding the
extracting from NFPA 20 into the
NEC.
In the question period that followed Mr. DeLerno criticized members of the electrical community for failing to participate in the revision process for NFPA 20. This editor pointed to the progressive demoralization of electrical members of the NFPA 20 Committee over the years,who felt they were always beating their head against a wall. In addition, at the time the Council made the decision on extracting material, the proposal deadline for NFPA 20 had long passed. Although the comment period was open, there was only one proposal and that had significant flaws to the point that appropriate language could not have been introduced at that point.
The decision
The Council denied the complaint and reaffirmed "that the provisions at issue involve fire pump performance criteria that is within the domain of NFPA 20." However, the Council then went on to make certain that the technical issues would be comprehensively addressed, and in a way that is not completely within the control, initially, of the Fire Pump Committee.
As part of this decision, the Council directs
that a task group be established to
review existing fire pump electrical
requirements, and to clarify criteria
that are performance-based versus
installation-based. This task group will
be comprised of three representatives
from each committee/panel and
chaired by a Council member.
Any resulting recommendations would go back, as in the case of proposals generally, to the NFPA 20 Committee for action. If the task group is able to reach substantial consensus, however, its recommendations would probably be very influential to all sides. At press time, the members had not yet been chosen. We will continue to follow this critical issue.
