Archive for the ‘ Code Revisions ’ Category

Rules That Define Fire Permits

Rules and regulations
that define permits derive from two sources: International Building Code (IBC) and International Fire Code (IFC). First, we want to clarify that there can be additional agencies that can impact a regulation, but we are using IBC and IFC for this post.

The first group
that regulates the tent rental company installation process for tents and structures or a temporary building is IBC. The second group, the IFC, deals with what is under our temporary building. Your local municipality may have two agencies governing IBC and IFC: IBC assigned to the building inspector, and the IFC under the Fire Marshals jurisdiction. Again we are keeping this simple; both of these agencies may cross boundaries with each other.

Enter the tent rental company.
You install a temporary building and this falls under IBC’S jurisdiction. You add tables, chairs, and décor under your temporary building, and this falls under the IFC’S jurisdiction. The IFC also regulates the flame certificates for the membrane. Is the membrane part of our temporary building or is it the décor? You pull a permit and who will be coming to inspect your installation a building code official or fire marshal? Confusing, to say the least, but there is hope.

Remember the post
about having coffee with the Fire Marshal? One of the questions you could ask him is which rules are covered by the IBC or IFC. If their answer is “I do not know”, unless you want to antagonize your coffee partner, do not treat this as a “Gotcha Moment”. Your coffee partner may have been handed the current permit and was told to enforce it by their supervisor.

To obtain information about regulations
you can become a member of the ICC and download the IBC and IFC PDF document at a cost of $89.00 apiece. If you are a member of TRAM, we will send you the two documents for free and offer some advice about these regulations, plus suggest a contact person to assist you. Now you have the information to create a compelling argument towards the interpretation of the fire permit regulation.

You still may not win
the dispute but at the very least you have become informed, and the ultimate objective is creating an accident-free event.

Respectfully Yours
Jim Erickson

Be Part of the Solution or a Player

The National Football League Competition Committee
is a group of eight members chosen from the ranks of the NFL team’s head coaches and managers to oversee the competition and suggest rule changes. * Reference wiki/NFL competition committee
The owners
select the NFL rules committee. The committee proposed rules changes and if adopted the referees enforce the new rule changes. The players then follow the guidelines for the new rules, like it or not.
The I-Codes
are a complete set of comprehensive, coordinated building safety and fire prevention codes. Building codes benefit public safety and support the industry’s need for one set of codes without regional limitations. * ICC | International Code Council. (n.d.). Retrieved from
The ICC Committee
consists of a group of officials that oversee the submissions suggesting new or altered codes to their members. The members then vote to accept the ICC’S new or revised codes. As soon as the code is passed, the code is added to the next cycle. The current ICC code cycle is year 2018. Once the fire permits are modified with the updated ICC codes the Fire Marshal can now enforce the code. The tent rental company becomes the players, same as in the NFL, like it or not.
A rule change
in the NFL does not happen overnight. The process is designed to ensure the integrity of the game. To change or add a new code the ICC Committee faces similar challenges and obligations to provide the highest standards and assurance of public safety.
get-involved-150You can become involved
by joining TRAM you then belong to a group that can influence the ICC Committee by creating suitable guidelines for a safe and profitable event.
You have a decision
become part of the solution or remain a player.

Respectfully Yours
Jim Erickson

IFAI $100,000 Tent Label

How can a label affixed to a tent end or mid-section cost $100,000.00?

100000-billFirst, we start with the ICC code Tent label revision:
3104.3  – Membrane structures or tents shall have a permanently affixed label bearing the identification of the size or material type.

The IFIA code proposal:

31040.3  – Tent, membrane structures, sidewall, drop and other decorative materials shall have a permanently affixed label bearing the identification and information as follows: …Continue reading

The condensed IFAI version: …Read the Full Version

If you have a tent or membrane section that equals 800 square feet or larger the section is required to have two labels 6” X 9” affixed to the section. Liners and drapes will have a minimum of XX point shall be sufficient. Decorative materials are exempt. Sidewall or drops comprising 20% of the total space requires a label.

Ten Tent Rental companies are meeting our criteria.

estimateFirst we start with the manufacturers. Each section that meets the requirement has to have two labels. Currently, each section has one label. Our estimation of cost to affix the second manufacturer label with time and materials is $200.00 per new section. This cost will be passed on to the client, which in this scenario is the rental company. In our tent rental companies inventory, we will estimate that the company has 200 sections that equal 800 square feet or larger. The process starts with opening each section affixing a label, sewed or an iron-on label, re-bagged and put away. If this section has a faded or missing a label, you are required to replace the faded label. The estimated cost of time and materials $150.00 per section.

A ten year estimation cycle:

  1. Current inventory 200 sections
  2. Apply label to existing inventory and re-apply label every five years, Cost $60,000
  3. New Purchase 200 sections during cycle with added label, Cost $40,000
  4. Reapply label for New Purchases after a five year period, Cost $30,000.
  5. Estimate Cost — $130,000.00
  6. Apply average cost of $100,000

Choose a proposal or suggest a revision.

ICC or IFAI revisionYou have to look at both proposals as suggested revisions. Our estimation is also just an estimate not backed by a calculated job cost model. Your obligation is to analyze the two proposals and our estimate and then apply these procedures to your operational cost.

The ICC code revision is asking for a label. Our job is to discuss and define the label and its application. The second problem is that as you wash and maintain tent sections the label fades. The discussion needs to address the natural diminishing of a label and create a solution. Without a discussion, you are looking at a $100,000.00 label.

Propagation or Flame Certificate

 I learned a new word this week “Propagation.”

According to Merriam-Webster the definition is “spreading or transmission of something.”

In the current ICC code;  Article 3104.2 states before granting a permit an owner or agent shall issue a flame propagation treatment certificate. The article continues to address laboratory testing of tents, membrane structures, and appurtenances, including floor coverings, bunting, combustible materials for decorating and sawdust. These materials must meet the propagation performance of NFPA 701 and their active period specified by the permit.

A request for revision
There is a request for a revision of Article 3104.2 along with a reason which is required to update or amend an article. The change states for tents and membrane structures that do not require an applied flame retardant to meet the flame propagation of NFPA 701, the owner or agent shall produce a certification for the following:

·        The manufacture fabric and/or materials.

·        The standard applied, such as NFPA or ASTM the material or fabric was tested for and passed.

·        The application test date for material or fabric.

Beginning of a Confusing Conversation
This is a condensed version of the article (Read the full version). Hopefully, I am not alone, and you will understand my confusion.

Tconfusionhe confusion began while discussing Article 3104.2 with two colleagues because I assumed the current code was addressing the 21st Century and did not date back to the Barnum & Bailey days of tent and membrane fabric made out of canvas. I stand corrected; Article 3104.2 is on the books for canvas products. So between the tent rental company and the Fire Marshal, Article 3104.2 has you covered for canvas products. However, a tent rental company would be hard pressed to find a number of tents made of canvas in their warehouse. Of course, there are still some old canvas tents in inventory and new canvas tents being produced. You are covered for canvas products with the current ICC code if you use a flame propagation certificate. But the newly proposed flame certificate revision for Article 3104.2 creates a question, how will this change impact the millions of square feet of vinyl stored in rental warehouses throughout the US?

Step Number One
The first step is scrutinizing our proposal. Once we have approval of our plan, we have completed the first step to amending Article 3104.2. However, if we wait and miss the scheduled deadline and submit our proposal for the following scheduled code review and our revisions present a significant change from the previously amended proposal our proposal may get thrown out. This may allow the second ICC proposal to move forward in which case this proposal may not be in our best interest.

Do Nothing
What if we take the “wait and see” approach. Otherwise, if we accomplish nothing, we could have six years of outdated flame propagation code. Alternatively, if adopted,  the second ICC proposals could contain  three years of objectionable changes because we stood by and watched.

Wait Until the Next Code Cycle 2021
The timeline to begin the next code cycle is 2019, another two years of code reviews. If successful and our proposal is approved, the revisions occur in 2021.

The Next Scheduled Deadline for 2018
The next scheduled DEADLINE FOR 2018 cdpACCESS ONLINE RECEIPT OF CODE CHANGE PROPOSALS is Jan 11, 2016. We still have time to gather information  and submit our proposal, but the deadline is approaching rapidly. So time is crucial in preparing our proposal. The new revisions can affect how you operate your business for years to come.

Share this Conversation
Now is the time to start a conversation, share your thoughts, and discuss flame propagation and flame certificates. Change is difficult, the urgency begins today.

Jim Erickson


Join TRAM and become part of the solution

ICC Code Fire Permit Changes

ICC Code Revisions for 2018

My last post ended with the next topic defining public or private events in relationship to issuing fire permits. Well, “Save that thought.” Instead of a discussing public and private events we are going  to look at a proposal by the ICC Code Committee recommending code changes that will impact future fire permits for tents and membrane structures. Plus to create added drama, there is a second counter proposal that emulates additional interpretations to the original ICC code plan.

We need to start a discussion of the two proposals, what effect updated regulations will have on future fire permits and how these changes will impact private and public events. We need to  analyze the economic consequences if these articles passed.

So what did I miss the first time I glanced over the ICC Code Revisions?

The Code Revisions document posted on is a combination of the ICC proposals and the counter proposal. The counter proposal has underlined text with suggestions on changing the code, and the crossed out text are the portions that would be elimated from the code. Now we can move on to the areas that could affect your business for years to come.

A few items that peaked my interest:
  • Requiring a permit for installing a tent 400 SQ feet or larger
  • Requiring a fire break clearance of 12 feet between tents
  • Occupancy and egress.
  • Inspection of a tent or structure that is erected for more than 30 days
  • Connection corridors
  • If using curtains, exit openings shall be on a sliding metal support
  • Type of flame retardant used, company who applied, date of application and expiration date of application
  • 6”X9” label applied to each tent and sidewall sections under 800 SQ Ft. greater than 800 SQ FT two labels required
Why do we need to start a conversation?

The problem is that once an article or revision is approved, the process takes a minimum of three years to reverse or change the article in question. This requirement is a valid reason for beginning a discussion.

How to start our conversation?

You can begin the conversation by replying to this email with a comment, concern, or a yea or nay. Forward this email to your peers, asking them use the Comment selection to express their opinions. If you are reading this on our Facebook Page TentRenters, Twitter, or LinkedIn account, click Like this post, share, and comment on what concerns you may have regarding the ICC code revisions. If we do not start a conversation today about fire permits proposals, tomorrow could be too late.

Tent Renters Association of the Midwest

Tent Renters Association of the Midwest

Become a member of TRAM because there is strength in numbers. When we work together as an industry, our voice will stand out, and our combined impact will be greater than if you are on your own.

ICC Upper Great Plains Workshop “Tent, Canopies, Clear Span Structure, and Stages”

I was invited to observe a workshop for Fire Marshals presented by the ICC Upper Great Plains Region III in Minneapolis, MN last month. The title of the workshop was “Tent, Canopies, Clear Span Structure, and Stages”. The conceptual premise for the Fire Marshal’s workshop was to outline the importance of proper installation and planning in correlation with manufactures’ specifications and building codes. One of our own, Tom Markel from Bravo Events, was a presenter along with Richard Nix, Division Coordinator for Entertainment Structures Group.

Tom Markel Bravo Events

Tom began the workshop discussing installation procedures for the different styles of tents: Rope and Pole, Tension, and Frame Tents, explaining the degree of difficulty in the installation process between the varying styles of tents. Tom conveyed a growing concern with the terminology in the current ICC building codes between tents and canopies. He also discussed Clear Span Structures with installed membrane along with best practices for installation and ballasting for Clear Spans. Tom conveyed the need for establishing a working relationship between Fire Marshals and tent companies.

Richard Nix Entertainment Structures Group

Richard Nix presented appropriately engineered methods for staging, documentation, and planning. One of Richard’s examples was the Minnesota State Fair. Using the Minnesota State Fair stage, Richard demonstrated what to look for in a lighting and sound diagram. Richard stressed the importance of planning that included vendors and Fire Marshals that were working on the project together. Meetings for a large project such as the State Fair were scheduled months in advance thru the pre-planning stages including the assembling of the structure.  Richard firmly stated that communications between vendors and Fire Marshals throughout the entire process were crucial for a safe and successful event.

Defintion of Tent, Canopies, Stages, and Structures

As an industry, we need to spend some time discussing the definition of tents, canopies, stages, and structures relating to the type of event in which these products are being utilized. For example, the entertainment world that uses stages with beams is classified as a structure. On the tent side, a structure can be defined as a temporary building with beams and membrane. Is a tent without a sidewall classified as a canopy? What if the tent was a 60X120 tension tent without sides; is it a tent or a canopy? Once we have defined these terms, we then can go forward working with code officials to create a fire code for the tent and event industry for the Fire Marshal to enforce.

The players involved in standardizing tent and event codes are the code officials, fire marshals, and tent and event rental companies. The core role in the standardization of tent and event codes becomes the event itself. Without the customer paying the bills, there isn’t an event.

The question becomes, should we treat all events the same?

Our next installment … Permits for Public and Private Events

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ICC Code Revisions

Text with line cross out original code proposal. Text underlined suggested change to the code proposal.

3103.2 Approval required.  Tents and membrane structures having an area in excess of 400 square feet (37 m2) shall not be erected, operation or maintained for any purpose without first obtaining a permit approval from the fire code official if the following condition(s) occur:

  1. If any one of the following:
    1. Tent or membrane structure used for a special amusement building as defined by the International Building Code in Section 411 of 400 square feet or more.
    2. Tent and membrane structure is used for Group-R occupancy of more than 15 persons.
    3. Tents and membrane structures exceeding 800 square feet as individual or the aggregate area of multiple tents and membrane structures placed side by side without a firebreak clearance of 12 feet (3658mm).
    4. Tents and membrane structures being used for cooking utilizing open flame devices with LPG fuel supply greater than 1 lb.
    5. Tents of 100 square feet of more, used for cooking, as an individual or the aggregate area of multiple tents and membrane structures placed side by side without a firebreak clearance of 20 feet from other structures and/or property lines.
  2. If any combination of two or more conditions occur:
    1. Tents and membrane structures as individual or the aggregate area of multiple tents, and membrane structures placed side by side without a firebreak clearance of 12 feet (3658mm) equal to or less than 800 square feet.
    2. Tents, and membrane structures with more than 51% of the nominal perimeter rendered inaccessible to egress by whatever means or reasons, including but not limited to, sides, drops, furniture, chairs etc.
    3. Occupancy load of 50 persons or greater for Group A and E.
    4. Occupancy load of 25 persons or greater for Group R and M.
    5. If more than 2/3 of the available area is utilized by tents, and membrane structures and their appurtenances as an individual or aggregate structure.


  1. Tents used exclusively for recreational camping purposes.
  2. Tents open on all sides which comply with all of the following:

2.1 Individual tents having a maximum size of 700 square feet (65m2).

2.2 The aggregate are of multiple tents placed side by side without a fire break clearance of 12 feet (3658mm), not exceeding 700 square feet (65m2).

2.3 A minimum clearance of 12 feet (3658mm) to all structures and other tents.


3103.7 Inspections.  The entire tent, canopy, air supported, air-inflated, membrane structure or tensioned membrane structure system shall be inspection if erected for more than 30 days at regular intervals, but not less than two times per permit use period once in every additional period of one to thirty days, by the permittee, owner or agent to determine that the installation is maintained in accordance with the chapter.  An inspection is required after any major weather event before the tent or membrane structure is occupied and will constitute an inspection during any additional period.

3103.7.1 Third Party Inspections.  The fire code official may approve third party inspection of any tent or membrane structure. 


3103.8.5  Connecting corridors.  Tent, canopies or and membrane structures are allowed to be joined together by means of corridors or marquee tents. Exits doors shall be provided at each end of such corridor.  On each side of such corridor and approximately opposite each other, there shall be provided openings not less than 12 feet (3658mm) wide.

  1. Corridors and marquee tents shall not be used for occupancy and remain clear of any obstruction.
  2. When using doors at the ends of a corridor or marquee tent then door width shall be a minimum of or combination of doors as required by Table 3103.12.2 and open into the corridor or marquee tent. Exit(s) must be provided along the length of the corridor or marquee tent in accordance with Chapter 10 of the International Fire Code and Section 3103.12.  Egress pathway(s) from the corridor or marquee tent shall be clear of obstructions and appurtenances from tents and membrane structures. 
  3. If egress is planned from multiple tents or a tent and a structure through a corridor or marquee tent, then no door will be allowed at the tent end of the corridor. The width of a or series of corridors and marquee tents shall be consistent with the requirements of Chapter 10 of the International Fire Code and Section 3103.12.

TABLE 3103.12.2



Tent & Canopy Air Inflated/Supported Membrane Structure
1 to 49b 1b 72 36b
50 to 199b 2 72 36b
200 to 499 3 72 72
500 to 999 4 96 72
1000 to 1,999 5 120 96
2,000 to 2,999 6 120 96
Over 3,000a 7 120 96

For SI: 1 inch = 25.4 mm.

  1. When the occupant load exceeds 3,000, the total width of means of egress (in inches) shall not be less than the total occupant load multiplied by 0.2 inches per person.
  2. For air inflated and/or support Membrane Structures the minimum number of exits for 10 to 199 persons is 2 and the minimum width is 36 inches.




3103.12.3   Exit openings from tentsExit openings from tents shall remain open unless cover by a flame-resistant curtain.  The curtain shall comply with the following requirements:

  1. Curtains shall be free sliding on metal support. They shall be a minimum of 80 inches (2032 mm) above the floor level at the exit.  The curtains shall be so arranged that, when open, no part of the curtain obstructs the minimum width of the exit according to Table 3103.12.2.
  2. Curtains, or an area boarding the curtains, shall be of a color, or colors, that contrasts with the color of the tent.


3103.12.6  Exit signsExits shall be clearly marked.  Exit signs shall be installed at required exit doorways, openings and other where otherwise necessary to indicate clearly the location of an exit or the direction of egress when the exit serves an occupant load of 50 or more as follows:

  1. Group A and E occupancies for 50 or more persons.
  2. Group M and R occupancies for 25 or more persons.


3104.2  Flame propagation performance treatment.  Before a permit is granted, the owner or agent shall file the fire code official a certificate executed by an approved testing laboratory certifying that the tents and membrane structures and their appurtenances; sidewalls, drops and tarpaulins; floor coverings; bunting and combustible decorative materials and effects, including sawdust when used on floors or passage ways, are composed of materials meeting the flame propagation performance of NFPA 701 or shall be treated with a flame retardant in an approved manner and meet flame propagation performance criteria of NFPA 701, and such flame propagation performance criteria are effective for the period specified by the permit.


>>> add to 3104.2


3104.2  Flame propagation performance treatment……..

  1. For tents and membrane structures that require a treatment with a flame retardant to meet flame propagation of NFPA 701, the owner or agent shall produce certification for the following:
    • The type of flame retardant used.
    • The date of application
    • The company or agency that applied the flame retardant.
    • The date the application expires on.
  2. For tents and membrane structures that don’t require an applied flame retardant to meet flame propagation of NFPA 701, the owner or agent shall produce certification for the following:
    • The manufacturer of the fabric and/or material
    • The standard applied, such as NFPA or ASTM the material or fabric was tested for and passed.
    • The a date for the manufacture of the tent or membrane structure.
  3. The owner or agent shall file with the fire code official the certification that’s applicable for the tent or membrane structure before the permit is granted.
  4. Additional items shall be certified as flame retardant either by label on the item such as ; sidewalls, drops, bunting, or by certification prior to granting the permit for items such as sawdust, floor coverings, combustible decorative materials and effects that any of these items meet flame propagation of NFPA 701.


Modern tents and membrane structures are made with inherently fire retardant materials that don’t require re-treatment and don’t wear or wash away.  The origin of the was from the Barnum fire where the canvas tent was waterproofed with a paraffin based product and contributed to the disaster.  Where the owner or tent rental companies for example might know which “tent” is to be install, appearances such as sidewalls are very interchangeable and thus should be part of the field inspection and not part of the permit process.  However other items that could pose a fire threat such and decorations should demonstrate the flame retardancy before the event.


3104.3 Label.  Membrane structures or tents shall have a permanently affixed label bearing the identification of the size and fabric or material type.

——– Alternative

3104.3 Label.  Tents, membrane structures, sidewalls, drop and other installed decorative materials, shall have a permanently affixed label bearing the identification and information as follows:

  1. The size of the label shall be a minimum of 6″ by 9” using ASTM XXXXXX.
  2. For tents and membrane structures which are not sectional with a nominal square footage of 800 sqft (       ) only one label is necessary per tent or membrane structure , otherwise two labels opposite to each other are required for tents or sectional tents and membrane structures with nominal square equal to or greater than 800 square feet.
  3. For decorative materials, such as tent liners or drapes, an identifying label sufficient in size with a minimum of xx points of typeface shall be sufficient to identify the section.
    1. For decorative materials a label of ownership shall not be required as defined in 3104.3-6.
  4. For sidewall, drops or similar fabric any section must have a label any sectional sidewall, drop or similar fabric section comprising more than 20 percent of the total area of that piece requires its own label.
  5. Labels shall contain the same information as indicated in 3104.4 for Certification.
  6. A label indicating the owner of, or installer of the tent if different from the user. This should be a second label following ASTM XXXXX of 6” by 9” in size with information including the owner of the tent, address and contact information.  The number and placement of labels shall be consistent with 3104.3-2


Reason:  This clarifies the need and size of the labels.  For sidewalls tent manufactures and rental companies have argued about the size and number of label.  For two piece sidewalls that have a significant “second” piece a label will be required where this was not clear in the past.  Also then need for multiple labels in sections more than 800 square feet is a new requirement.



3104.4 Certification.  An affidavit or affirmation shall be submitted to the fire code official and a copy retained on the premises on which the tent, membrane or air-supported structure is located. The affidavit shall attest to the following information relative to the flame propagation performance criteria of the fabric:

  1. Names and address of the owners of the tent or air-supported structures.
  2. Date the fabric was last treated with flame-retardant solution.
  3. Trade name or kind of chemical used in treatment.
  4. Name of the persons or firm treating the material.
  5. Name of testing agency and test standard by which the fabric was tested.


  1. If the tent, membrane structure or other materials require the application of a flame retardant the following is required:
    1. Names and address of the owners of the tent or air-supported structures.
    2. Date the fabric was last treated with flame-retardant solution.
    3. Trade name or kind of chemical used in treatment.
    4. Name of the persons or firm treating the material.
    5. Name of testing agency and test standard by which the fabric was tested.
  2. If the tent, membrane structure or other materials are inherently flame retardant the following is required:
    1. The manufacturer of the fabric or material, date of manufacture and the standard it was tested under.
    2. The manufacturer of the tent, membrane structure, or decorative material if different from the manufacturer of the fabric material.
    3. The date of manufacturer for the product and the standard the product was tested under.

3104.12 Portable fire extinguishers.  Portable fire extinguishers shall be provided as required by Sections 906.  A Fire extinguisher shall be at or within 6’ of and exit and its location and visibility shall follow NFPA section 10.  Additional fire extinguishers shall be required as set forth in NFPA 10 and/or as requested by the fire code official.  The minimum size of the extinguisher is 10 lb ABC type or as required by the fire code official .