The Wise Old Fire Protection Engineer (WOFPE) Explains the Hazards of Minimum Code Compliance

Don’t Worry; It Meets the Code

“Hey, Boss,” hailed the Brash Young Fire Protection Engineer (BYFPE) to the Wise Old Fire Protection Engineer (WOFPE). “Can we discuss your comments on my fire protection design brief for the Acme Ajax Distribution Center renovation project?”

“Sure, let’s talk,” said the WOFPE on the way into his office. “What specifically did you want to discuss?” he said as he sat behind the desk.

“Every place I referred to the ‘minimum requirements of the applicable code,’ you put a big question mark,” explained the BYFPE. “I don’t understand your question. Aren’t we supposed to always meet minimum code requirements?”

Taking a marked-up copy of the design brief from the BYFPE, the WOFPE responded, “Of course, we must meet the minimum code requirements, and your design brief explains compliance with the minimum code requirements. What it doesn’t explain is how you are meeting the site-specific needs of the facility based on their operating conditions and fire risk management objectives.”

“Um, I’m not sure what you mean,” admitted the BYFPE. “The project architect is driving every discipline to keep costs as low as possible to meet the project budget. So, I’m just providing them with the minimum level of fire protection specified by code.”

“I understand,” explained the WOFPE, “but does that code-mandated minimum level of protection meet the client’s needs in terms of property protection and protection of the facility’s mission or ability to continue business operations?

The BYFPE responded, “Well, both the client project manager and the architect are happy with the brief because it looks like the project will come in under budget.”?

The WOFPE sighed and questioned, “Do they understand that meeting just the minimum code requirements doesn’t mean their building or continued business operations are protected? Do they understand that buildings meeting minimum code requirements burn down every day? Does the client project manager understand that the day after they get the certificate of occupancy that their building could burn to the ground, and they might be out of business?”

“What do you mean?” asked the BYFPE plaintively. “If it meets the public fire and building codes, it should be protected.”

“No!” exclaimed the WOFPE. “If it meets the PUBLIC fire and building codes, the PUBLIC is protected. The PUBLIC fire and building codes are not written to protect the building and its operations. The PUBLIC codes protect the PUBLIC from the building and its operations. If the building catches fire and burns completely to the ground, but everyone gets out alive and unhurt, and the fire doesn’t spread beyond the property line, every one of the intended fire safety objectives of the PUBLIC codes is met. They protected the PUBLIC from the building. The PUBLIC codes do not address and do not care whether Acme Ajax still has a facility after the fire or whether they are still in business. That little fact often escapes the understanding of most property owners and building designers. Meeting the minimum requirements of the PUBLIC codes does not assure protection of the building or its operations.”

“Well, what about the NFPA codes and standards?” asked the BYFPE defensively.?

“Again, those documents are minimums developed by a committee with varied interests that may or may not align with the best interests of Acme Ajax,” explained the WOFPE. “The best way I can describe it is with a pizza.”

“A pizza?” asked the BYFPE incredulously. “How can you explain the NFPA codes and standards with a pizza.”

“Well, let’s assume,” started the WOFPE, “That we are part of a new NFPA technical committee made up of all different interest groups and that our task is to develop the specifications for the pizzas we are going to eat for dinner tonight. The way the NFPA process works, our committee of twenty to thirty people must come to a two-thirds consensus on the requirements, meaning that two-thirds of our committee members must agree on something before it becomes part of this new standard on pizzas.”

The WOFPE continued, “Now, as our committee begins to deliberate, there are competing interests. For example, we might have a few committee members that don’t like green peppers and onions on their pizza because they get heartburn. There might be some members that are lactose intolerant, so they are going to lobby against extra cheese. Another group might not like anchovies, so they go to the anti-green pepper and onion group and say, if you vote against anchovies, we’ll vote against green peppers and onions. These discussions and deliberations continue throughout the day until we reach a two-thirds consensus of the committee on what type of pizzas to order for dinner. Any idea what kind of pizza we’ll probably eat for dinner tonight?”

“Not a clue,” answered the BYFPE.

“Well, assuming we can reach a consensus,” explained the WOFPE, “we’ll probably be eating plain cheese pizza because, with all the different ideas of the different committee members as to what should be on the pizza we order, the lowest common denominator we can probably agree on is plain cheese pizza.”?

“Just plain cheese?” questioned the BYFPE. “Doesn’t sound like much of a dinner to me.”

“It doesn’t to me either,” agreed the WOFPE, “but it’s the consensus we could reach. I think that a super deluxe, meat lovers’ pizza with extra cheese is a much better option, and I can order that for myself if I want. But the minimum standard is plain cheese pizza. You need to look at every NFPA standard and every other document developed through the consensus committee process as a plain cheese pizza. It’s not necessarily the best; it’s just the minimum. If it doesn’t meet our needs, we are free to go above and beyond the minimum.”

The BYFPE pondered that statement for a moment and said, “I understand, but how does this apply to my design brief?”

“You need to make sure the client understands that compliance with the minimum requirements of the code, wherever it comes from, is like a plain cheese pizza,” explained the WOFPE. “But based on the site-specific needs and conditions of the facility, they might need to go beyond the minimum to ensure meeting their site-specific needs and objectives.”

The WOFPE continued, “For example, if you look in the PUBLIC codes or the applicable NFPA standards for paint spray booths, you’ll find that they require ‘a’ fire suppression system. It might be a sprinkler system, a dry-chemical extinguishing system, or some other approved extinguishing system, but the minimum code requirement is to provide a single system. If that is the case, why do some automotive assembly facilities have three levels of fire suppression in their paint spray booths?”

“Because their need is not only to detect and suppress a fire but to do it before the fire causes sufficient damage to shut the process down,” volunteered the BYFPE confidently. “They know they aren’t selling any cars without paint.”?

“Exactly!” answered the WOFPE. “Before you submit your design brief, you need to talk to the client to find out exactly what their fire risk management objectives and loss tolerance are for the project. If their only objective is to obtain a certificate of occupancy, compliance with the minimum requirements of the applicable codes is probably adequate. However, like the automotive assembly facility, I suspect they have internal fire risk management goals and objectives that require a level of protection exceeding the minimums of the PUBLIC codes and applicable NFPA standards. That’s what you need to explain in your design brief.”

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You can find more conversations between the Wise Old Fire Protection Engineer (WOFPE) and his protégé, the Brash Young Fire Protection Engineer (BYFPE), throughout?Industrial Fire Control Concepts?and in the new?51 Conversations with the Wise Old Fire Protection Engineer?by Jeffrey Moore, PE, FSFPE.

Industrial Fire Control Concepts?is a fire risk management course in a book. Originally written as the textbook for the one-week Industrial Fire Protection Course taught for decades by Industrial Risk Insurers, this 540-page third edition, updated to reflect current technology and fire protection practice, maintains the original purpose of serving as a means of providing not only technical information but also explaining the fire protection decision-making process for those responsible for facility fire protection and fire risk management. The book uses practical examples and extensive color photos and graphics to explain the “hows” and “whys” behind an effective site-specific fire protection and fire control program.?

51 Conversations with the Wise Old Fire Protection Engineer?contains the forty-six conversations between the WOFPE and the BYFPE contained in?Industrial Fire Control Concepts?and?five additional conversations not used in the book. Both books are available on Amazon. The conversations between the WOFPE and the BYFPE provide background information and context behind many common questions and misconceptions, and the methods used to make site-specific fire risk management decisions.?

Electronic versions of both books are also available in the iTunes store for Apple Books. Email?[email protected]?for additional information or to obtain a fifty-page sample of?Industrial Fire Control Concepts.