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


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