I learned a new word this week “Propagation.”
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.
The 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.
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.