Public Comment No. 32-NFPA 90A-2016 [ Section No. 2.3.2 ]...Public Comment No. 2-NFPA 90A-2016 [...

Public Comment No. 32-NFPA 90A-2016 [ Section No. 2.3.2 ]

2.3.2 ASTM International Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA19428-2959.

ASTM C411, Standard Test Method for Hot-Surface Performance of High-Temperature ThermalInsulation, 2011.

, ASTM D93, Standard Test Methods for Flashpoint by Pensky-Martens Closed Cup Tester,2012 2015a .

, ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials,2013a 2015b .

, ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials,2012a 2016 .

, ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at750°C, 2012 2016 .

, ASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe and DuctInsulation Materials to Assess Surface Burning Characteristics, 2009 2015 .

, ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with aCone-Shaped Airflow Stabilizer, at 750°C, 2012 2016 .

Statement of Problem and Substantiation for Public Comment

date updates

Related Item

First Revision No. 1-NFPA 90A-2015 [Section No. 2.3]

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Wed May 04 17:22:22 EDT 2016

Committee Statement

Committee Action: Rejected but see related SR

Resolution: SR-1-NFPA 90A-2016

Statement: date updates

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

1 of 53 11/9/2016 9:07 AM


2.3.6 UL Publications.

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and Air Connectors, 2013.

ANSI/UL 181A, Standard for Safety Closure Systems for Use with Rigid Air Ducts, 2013.

ANSI/UL 181B, Standard for Safety Closure Systems for Use with Flexible Air Ducts and AirConnectors, 2013.

ANSI/UL 263, Standard for Fire Tests of Building Construction and Materials, 2011, Revised2015.

ANSI/UL 555, Standard for Safety Fire Dampers, 2006, Revised2014.

ANSI/UL 555C, Standard for Safety Ceiling Dampers,2014.

ANSI/UL 555S, Standard for Safety Smoke Dampers, 2014.

ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008,Revised 2013.

ANSI/UL 867, Standard for Safety Electrostatic Air Cleaners, 2011, Revised 2013.

ANSI/UL 900, Standard for Safety Air Filter Units, 2015.

ANSI/UL 1598,Luminaires, 2012.

ANSI/UL 1820, Standard for Safety Fire Test of Pneumatic Tubing for Flame and SmokeCharacteristics, 2004, Revised 2013.

ANSI/UL 1887, Standard for Safety Fire Test of Plastic Sprinkler Pipe for Visible Flame andSmoke Characteristics, 2004, Revised 2013.

ANSI/UL 1995, Standard for Safety Heating and Cooling Equipment, 2015.

ANSI/UL 2024, Standard for Safety for Cable Routing Assemblies and Communications,2014,Revised 2015.

ANSI/UL 2043, Standard for Safety Fire Test for Heat and Visible Smoke Release for DiscreteProducts and Their Accessories Installed in Air-Handling Spaces, 2013.

UL 2518, Outline of Investigation for Air Dispersion System Materials, 2005.

ANSI/UL 2846, Fire Test of Plastic Water Distribution Plumbing Pipe for Visible Flame andSmoke Characteristics, 2005.

ANSI/UL 2846, Standard for Fire Test of Plastic Water Distribution Plumbing Pipe for VisibleFlame and Smoke Characteristics, 2014.

ANSI/UL 60335-2-40, Standard for Safety of Household and Similar Electrical Appliances,Part 2-40: Particular

Requirements for Electrical Heat Pumps, Air-Conditioners and Dehumidifiers . 2012


A reference to ANSI/UL 60335-2-40 is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL and replaced by ANSI/UL 60335-2-40 by the year 2020.


2 of 53 11/9/2016 9:07 AM

Related Item



Submitter Full Name: Ronald Farr

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Mon May 16 13:17:20 EDT 2016

Committee Statement

CommitteeAction:

Accepted


Statement: A reference to ANSI/UL 60335-2-40 is being added as it is anticipated that ANSI/UL1995 will be withdrawn by UL and replaced by ANSI/UL 60335-2-40 by the year 2020.


3 of 53 11/9/2016 9:07 AM


3.3.3* Air Connector.

A conduit for transferring air between an air duct or plenum and an air terminal unit or an airinlet or air outlet. This is a limited use product. Air connectors are not UL listed air ducts.

Additional Proposed Changes

File Name Description Approved

Connector_attached_at_floor.pdf

Air connector attached to a register boot in a second floor wall cavity. No flame penetration test is required for air connectors and this allows for failure of smoke control and drafting into the second floor essentially bypassing the floor assembly.


Justification: UL has a testing protocol for air connectors and air ducts. This consist of 16 test. Air connectors are only required to pass 13 of these 16 test. The three they do not have to pass are flame penetration, puncture, and impact test. Many times air connectors are used connected to a 1 inch collar penetrating a fire/Smoke assembly. Allowing the use of air connectors next to these fire assemblies without passing the flame penetration test allows for smoke to immediately by pass the fire smoke assembly.

Related Item

First Revision No. 2-NFPA 90A-2015 [Section No. 4.3.2]


Submitter Full Name: John Hamilton

Organization: National Energy Management Ins

Street Address:

City:

State:

Zip:

Submittal Date: Fri Feb 26 14:50:07 EST 2016

Committee Statement

CommitteeAction:

Rejected but held

Resolution: This public comment introduces a concept that has not had public review by beingincluded in a related Input or First Revision as shown in the First Draft.


4 of 53 11/9/2016 9:07 AM


3.3.4 Air Distribution System.

A continuous passageway for the transmission of air that, in addition to air ducts, can includeair connectors, air duct fittings, dampers, plenums, fans, and accessory air-handling equipmentbut that does not include conditioned spaces.



Air_Connector_connecting_furnace_return_and_path_to_first_floor.pdf

This diagram shows how fire and smoke can jump floor to floor due to no flame penetration testing required for air connectors.


Why does NFPA require draft stop material around openings when you allow a product that fails with fire immediately and allows smoke and fire to jump floor to floor or into a wall cavity. NFPA requires draft stopping on penetrations but about every 8 feet NFPA allows for air connectors attached to floor boots that do not pass a flame penetration test. These floor boots are about every 8 foot on the perimeter of the floor making a perfect situation to help fire and smoke spread quickly. It is like allowing balloon framing again. Seems so odd that the small cracks around a duct have to be draft stopped but consideration for the inside of the duct is not considered.

Related Item





Street Address:

City:

State:

Zip:

Submittal Date: Tue Mar 01 15:09:24 EST 2016

Committee Statement

Committee Rejected but held


5 of 53 11/9/2016 9:07 AM

Action:



6 of 53 11/9/2016 9:07 AM


3.3.5 Air Duct.

A conduit or passageway for conveying air to or from heating, cooling, air-conditioning, orventilating equipment, but not including the plenum. Flexable air ducts shall meet UL 181.



boot_into_second_floor_air_connector.jpg

This picture shows how the fire and smoke can use the duct system to allow smoke and fire to jump floor to floor. Air connectors do not pass a flame penetration test so air connectors can immediately fail and allow fire and smoke to jump floor to floor or in a wall cavity.

Picture_of_UL_listed_Air_Duct_vs_air_connector_taking_a_flame.pdf

This is the same HVAC duct connection showing one connection with an air duct and one connection with a UL listed air duct. The air connector does not pass the flame penetration test and will


7 of 53 11/9/2016 9:07 AM

allow smoke and fire to jump floors or into a wall cavity quickly.


This diagram shows how fire and smoke have a huge void to allow for fire and smoke to jump to the first floor.


For classification as an air duct UL has developed 16 test. To be classified as an air duct all 16 test must be passed. Currently there is a lot of confusion on what an air connector is and what an air duct is. This will help code officials determine what is an air duct. by allowing air connectors to be called air ducts leads to confusion on what is an air duct and what is and air connector. NFPA defines what an air duct is, then NFPA defines what and air connector is, and NFPA then turns around and says an air connector is an air duct. An air connector is not an air duct as per UL 181 so please don't use the term air duct to describe a air connector.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



8 of 53 11/9/2016 9:07 AM

Public Comment No. 5-NFPA 90A-2016 [ New Section after 3.3.23.4 ]

3.3.23.5 Raised Floor Plenum.

The space between the top of the finished floor and the underside of a raised floor notused to supply air to the occupied area or to return air to or exhaust air from theoccupied area.


There are 2 applications for raised floors. One is used as a supply duct and the other as an access for wiring etc. 2 separate applications should have 2 separate definitions.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



9 of 53 11/9/2016 9:07 AM

Public Comment No. 37-NFPA 90A-2016 [ Section No. 4.2.4.2.1 ]

4.2.4.2.1

The requirements of 4.3.3.1 and 4.3.3.2 shall not apply to equipment tested and listed inaccordance with ANSI/UL 1995, Standard for Safety Heating and Cooling Equipment orANSI/UL 60335-2-40, Standard for Safety of Household and Similar Electrical Appliances, Part2-40: Particular Requirements for Electrical Heat Pumps, Air-Conditioners and Dehumidifiers .


The additional reference to ANSI/UL 60335-2-40 is being added as it is anticipated that ANSI/UL 1995 will be withdrawn by UL by the end of 2020 and replaced by ANSI/UL 60335-2-40. The reference to ANSI/UL 60335-2-40 has been added to 2.3.6, UL Publications.

Related Item



Submitter Full Name: Ronald Farr

Organization: UL LLC

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Accepted


Statement: The additional reference to ANSI/UL 60335-2-40 is being added as it is anticipated thatANSI/UL 1995 will be withdrawn by UL by the end of 2020 and replaced by ANSI/UL60335-2-40. The reference to ANSI/UL 60335-2-40 has been added to 2.3.6, ULPublications.


10 of 53 11/9/2016 9:07 AM

Public Comment No. 7-NFPA 90A-2016 [ Section No. 4.3.1.2 ]

4.3.1.2

Class 0 or Class 1 rigid or flexible air ducts tested in accordance with ANSI/UL 181, Standardfor Safety Factory-Made Air Ducts and Air Connectors , and installed in conformance with theconditions of listing shall be permitted to be used for ducts where air temperature in the ductsdoes not exceed 121°C (250°F) or where used as vertical ducts serving not more than twoadjacent stories in height.



Pictures_of_air_connector_used_on_the_other_side_of_a_1_hour_fire_rarted_ceiling.pdf

This photo shows how it is currently not against any code to use air connectors attached to a short fitting (2") right up tight to a fire rated ceiling. Why bother with a fire rated ceiling if it allowed to have penetrations with air connectors attached to the ceiling. It is not right to have multiple penetrations with no flame penetration test required on products that penetrate a fire wall or


11 of 53 11/9/2016 9:07 AM

ceiling.

Drafting_required_around_air_connector.jpg

The photo is for the irony of it all. Requiring draft stop material around a product that does not pass a flame penetration test. One quick flame on the air connector and wide open hole is in that assembly.

Connector_going_through_several_assembelies.jpg

Allowing the use of air connectors can lead to several assemblies being breached with one HVAC duct run.

Connector_going_throgh_floor_with_a_elbow.jpg

This shows how using air connector can breach a floor assembly easily.

Connector_being_used_to_penatrate_floor_with_short_register_boot.jpg

This is a typical application of using air connectors. About every 8 feet around the perimeter of a building has a floor boot through the floor.


12 of 53 11/9/2016 9:07 AM

Allowing several penetrations for flame and smoke spread.


This illustration shows how a huge hole is in the floor and how air connector can allow fire and smoke spread to go from one area to the other. On a side note for humor "at least the gap around the outside of the duct is draft stopped" :-)


Stop the spread of smoke and fire. UL has a testing protocol for air connectors and air ducts. This consist of 16 test. Air connectors are only required to pass 13 of these 16 test. The three they do not have to pass are flame penetration, puncture, and impact test. Many times air connectors are used connected to a 1 inch collar penetrating a fire/Smoke assembly. Allowing the use of air connectors next to these fire assemblies without passing the flame penetration test allows for smoke to immediately by pass the fire smoke assembly. Air connectors do not pass the UL flame penetration test and should not be used in HVAC duct systems. The IAPMO sub comittee on duct construction is recommending to remove air connectors as a product to be used in HVAC duct systems.

Related Item





Street Address:

City:

State:

Zip:


13 of 53 11/9/2016 9:07 AM


Committee Statement

CommitteeAction:

Rejected but held



14 of 53 11/9/2016 9:07 AM


4.3.1.3 Gypsum Board Air Ducts.

4.3.1.3.1

Gypsum board having a flame spread index not exceeding 25 without evidence of continuedprogressive combustion and a smoke developed index not exceeding 50 when tested inaccordance with ASTM E84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials , or ANSI/UL 723, Standard for Test for Surface Burning Characteristics ofBuilding Materials , shall be permitted to be used for negative pressure exhaust and returnducts where the temperature of the conveyed air does not exceed 52°C (125°F) in normalservice.

4.3.1.3.2

The air temperature limits of 4.3.1.3.1 shall not apply where gypsum board material is usedfor emergency smoke exhaust air ducts.


File Name Description

Email_from_manufacture_saying_no_testing_has_been_done_on_sheet_rock_as_metal_ducts.pdf

There is no standard to build gypsum wall board ducts. No manufactures have done testing on this. What if any standard does one have to follow when constructing HVAC ducts our of gypsum wall board?


Eliminate the fire and smoke hazard created by allowing people to build HVAC ducts how they feel like doing it verses building the ducts to a recognized standard.

Related Item




15 of 53 11/9/2016 9:07 AM



Street Address:

City:

State:

Zip:

Submittal Date: Thu Mar 03 15:33:14 EST 2016

Committee Statement

CommitteeAction:

Rejected but held



16 of 53 11/9/2016 9:07 AM


4.3.1.3.1

Gypsum board having a flame spread index not exceeding 25 without evidence of continuedprogressive combustion and a smoke developed index not exceeding 50 when tested inaccordance with ASTM E84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials , or ANSI/UL 723, Standard for Test for Surface Burning Characteristics ofBuilding Materials , shall be permitted to be used for negative pressure exhaust and returnducts where the temperature of the conveyed air does not exceed 52°C (125°F) in normalservice.


File Name Description Ap

National_Gypsum_Association_stand_on_not_using_gypsum_board_as_HVAC_ductwork.pdf

These are communications from the Gypsum Association and USG on not using gypsum as HVAC ductwork.


All HVAC duct work is built to a national standard except gypsum ductwork. SMACNA leads the way in these standards. Flex duct goes through UL testing to get approved. Phenolic is and has gone through an extensive process to have industry standards. Why can people just use gypsum board anyway they want to for HVAC ducts? There is no standard for building gypsum ducts, that I am aware of or anyone on ASHRAE TC 5.2 Duct construction technical committee know of. What standard are gypsum ducts sealed to? What type of tape is used on these ducts? NFPA requires UL 181 testing for tapes on duct work, but if a person uses gypsum they can use an untested paper tape to seal it up? IF there are standards for gypsum ducts they should be allowed if there are not standards gypsum should not be used until there are standards developed for making HVAC duct work out of gypsum boards. Can people use 1/4 gypsum for ducts? Does it have to be 3/8" thick? Does it have to fire rated? If so why? If not why?

Related Item





Street Address:

City:

State:


17 of 53 11/9/2016 9:07 AM

Zip:


Committee Statement

CommitteeAction:

Rejected but held



18 of 53 11/9/2016 9:07 AM


4.3.1.3.2

The air temperature limits of 4.3.1.3.1 shall not apply where gypsum board material is usedfor emergency smoke exhaust air ducts.


File Name Description Ap

National_Gypsum_Association_stand_on_not_using_gypsum_board_as_HVAC_ductwork.pdf

Communication on the use of gypsum used as HVAC duct work. 3 conditions which must be met, and information there is no national standard on how to build duct work using gypsum.


Eliminate this exemption. The gypsum association technical director says not to use this material and have documented gypsum is not a viable material for HVAC ducts at temperatures above 125 degrees F. Along with gypsum board being a porous surface that absorbs material from the air stream. Toxins from smoke can be absorbed by the gypsum board and stay in the building. These smoke evac shafts are typically in non-accessible areas and to remove them after a smoke evac event is nearly impossible and very expensive. Gypsum wall board cannot be cleaned with any duct cleaning machines on the market today. These smoke evac ducts are used many times during a buildings life. They are not only used once in a catastrophe. Even the toxins from smoke candles can impregnated into the gypsum.

Many of these smoke evac ducts have a very high static pressure. This can be a positive pressure if the fan is located in the building. When the fan is located in the building this static pressure will put even more pressure and along with the heat from the fire/smoke on the gypsum board causing it to fail and the smoke at that point will not be pushed outside of the building. At what point do these ducts fail? At what point can these ducts fail?All code approved duct work is built to a standard. SMACNA leads the way in these standards. There are no standards that these gypsum board ducts systems are built to. To date I have only found one gypsum board company that makes any construction standard when using their wall board as an air shaft and it must be constructed to a 2 hour fire rating with specified bracing and supports. If this is allowed NFPA at a minimum should require the designed system must be built to that company’s standard. I can provide that standard upon request.


19 of 53 11/9/2016 9:07 AM

The gypsum association also recommends that the dew point is never reached inside a gypsum duct. During a event how is this prevented? If any type of water is used or sprayed onto a fire the relative humidity is not controllable and could easily hit dew point inside the gypsum duct.

This exemption goes against all 3 minimum requirements set by the gypsum association1 Negative pressure ducts only2 Control humidity below dew point3 Temperature shall never go above 125 degrees

Remaining questions about the use of gypsum material used as emergency smoke exhaust air ducts:1 Does NFPA have any studies on why this is allowed? 2 Where is the science behind this exception? 3 What is the NFPA standard these gypsum ducts need to be built to?

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



20 of 53 11/9/2016 9:07 AM


4.3.1.4

All air duct materials shall be suitable for continuous exposure to the temperature and humidityconditions of the environmental air in the air duct. Exception gypsum wall board used assmoke evacuation duct.


If 4.3.1.3.2 is not eliminated this exemption should be mentioned here since it says that you can use gypsum for smoke evacuation duct even though it is not supposed to be used for temps above 125 F. No gypsum wall board company allows their product for this application.

Related Item





Street Address:

City:

State:

Zip:

Submittal Date: Wed Mar 02 13:24:00 EST 2016

Committee Statement

CommitteeAction:

Rejected but held



21 of 53 11/9/2016 9:07 AM

Public Comment No. 10-NFPA 90A-2016 [ Section No. 4.3.1.5 [Excluding any

Sub-Sections] ]

The materials, thickness, construction, and installation of ducts shall provide structural strengthand durability in conformance with recognized good practice.


Delete this section “good practice” is not code or standard language. Where can one find the definition of good practice? The following section address what standards duct shall be built to.

Related Item






Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



22 of 53 11/9/2016 9:07 AM


4.3.1.5.1

Air ducts shall be considered to be in compliance with 4.3.1.5 where constructed and installedin accordance with the ASHRAE Handbook — HVAC Systems and Equipment and with one ofthe following as applicable:

(1) NAIMA Fibrous Glass Duct Construction Standards

(2) SMACNA Fibrous Glass Duct Construction Standards

(3) SMACNA HVAC Duct Construction Standards — Metal and Flexible

(4) ANSI/SMACNA HVAC Air Duct Leakage Test Manual

(5) SMACNA Phonolic Duct Construction Standards


With Phenolic duct being used it should be built to a standard. SMACNA is the leader in duct construction standards and should be inserted here.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

Committee Action: Rejected

Resolution: The document is not mentioned/used in the body of the standard.


23 of 53 11/9/2016 9:07 AM

Public Comment No. 29-NFPA 90A-2016 [ New Section after 4.3.1.6 ]

TITLE OF NEW CONTENT

Duct made of other materials other than metal.



ASHRAE_62.1_for_mold_and_duct_erosion_NFPA_90B.docxASHRAE language for ducts made out of other materials


If NFPA is going to allow HVAC ducts to made up of gypsum board and any other materials those materials should at least meet ASHRAE standard 62.1

Related Item

Public Input No. 1-NFPA 90A-2015 [Global Input]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



24 of 53 11/9/2016 9:07 AM


4.3.1.6

Where no standard exists for the construction of air ducts, the ducts shall be constructed towithstand both the maximum positive and the maximum negative pressures of the system atfan shutoff.


All HVAC ducts should be built to a duct construction standard. Having this section allows for anyone to use anything and construct duct anyhow they want to and still claim to meet NFPA 90. NFPA list several duct construction standards about this section which mandate HVAC duct work is built to a recognized standard. UL has standards to built to as well.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



25 of 53 11/9/2016 9:07 AM


4.3.1.6

Where no standard exists for the construction of air ducts, the ducts shall be constructed towithstand both the maximum positive and the maximum negative pressures of the system atfan shutoff.


All duct should be built to a duct construction standard. Having this section allows for anyone to anything and construct duct anyhow they want to and still claim to meet NFPA 90. NFPA list several duct construction standards about this section which mandate HVAC duct work is built to a recognized standard. UL has standards to build ducts to as well.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



26 of 53 11/9/2016 9:07 AM


4.3.1.7

A duct enclosure used for the multiple distribution or gathering of ducts or connectors shall beconstructed of materials and methods specified in 4.3.1.

4.3.1.7.1

Electrical wires and cables and optical fiber cables within a duct enclosure shall comply with4.3.4.


Allowing the use of air connectors that do not pass UL 181 testing can lead to flame and smoke spread. Allowing them in this section is allowing them in a “cluster” area compounding the threat not passing UL 181 flame penetration testing in the “cluster” area.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



27 of 53 11/9/2016 9:07 AM


4.3.1.8 Air Dispersion Systems.

Air dispersion systems shall meet the following criteria:

(1) They shall only be installed in entirely exposed locations.

(2) They shall always operate under positive pressure.

(3) They shall not penetrate fire resistance–rated construction.

(4) They shall not pass through fire resistance–rated construction.

(5) They shall be listed and labeled in accordance with UL 2518, Outline of Investigation forAir Dispersion System Materials.

(6) They shall not connector to a duct penetrating a fire wall or fire assembly.


Allowing air dispersion ducts to attach to a 6 inch metal collar to pass through a fire assembly should only be allowed if a fire damper is installed in the fire wall.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



28 of 53 11/9/2016 9:07 AM


Sub-Sections] ]

Air connectors shall be permitted to be used as limited-use, flexible air ducts that shall not berequired to conform to the provisions for air ducts where they meet the requirements of4.3.2.1.1 through 4.3.2.1.7 .



Air_connector_photo_with_round_and_rectangular_labels.jpg

This photo shows how confusing the manufactures can make identifying a air connector in the field, There are no standards on how air connectors are labeled. A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a


29 of 53 11/9/2016 9:07 AM

flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct.


What air connectors are to engineer, sheet metal installers and contractors. Not a round duct for conveying air.

HVAC-DUCT-_Connector-Ad-LOWRES-JULY_20_air_connector.pdf

What air connectors are to engineer, sheet metal installers and contractors. Not a round duct for conveying air.

HVAC-3202_Silicone_HI-T_TDS_7-27-12_air_connector.pdf

What air connectors are to engineers, sheet metal installers and contractors. Not a round duct for conveying air.

HVAC-3202_Neoprene_TDS-LOW-RES_air_connector.pdf

What air connectors are to engineers,


30 of 53 11/9/2016 9:07 AM

sheet metal installers and contractors. Not a round duct for conveying air.

HVAC-3202_VinylFlex_TDS-LOWRES_air_connector.pdf


HVAC-3202_Residential_Quality_2-3-2_28G_TDS-US_Version_01-10-13_air_connector.pdf


Carlisle_connector_plus.png



Delete the use of air connectors. They are not considered air ducts by UL test 181 and have spawned as a new HVAC product.

Air connectors do not pass the UL 181 test for flame penetration and should not be used in a HVAC duct system.

Air connectors are currently found being used in the wrong application as a UL 181 listed air duct. UL 181 Listed air ducts pass 16 of 16 UL test to be listed as an air duct. Air connectors pass 13 of 16 UL test for being a listed air ducts, failing 3 of the required test for being a listed air duct. The three test that are not required are, puncture, flame penetration, and impact test. Allowing the use of air connectors connected next to a fire wall kind of defeats the purpose of the fire wall since there is no


31 of 53 11/9/2016 9:07 AM

flame penetration test you have an open hole to the other side of the fire wall. Allowing smoke to pass through the opening at the first flame that touches the air connector. Even when installed under the current requirements air connectors are the weak link leading to instant penetration of a HVAC duct system, breaching fire assembles and the HVAC system itself. When the HVAC duct system is breached the HVAC fan will spread smoke and heat to other parts of the building. IAPMO (UMC) did not allow the use of air connectors until a couple years ago. When they allowed the use of them it was a mistake as they thought an air connector was the small piece of flex to eliminate HVAC vibration. Attached are photos of what is viewed as air connectors by engineers, sheet metal workers, and installing contractors.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



32 of 53 11/9/2016 9:07 AM


Sub-Sections] ]

Air connectors shall be permitted to be used as limited-use, flexible air ducts that shall not berequired to conform to the provisions for air ducts where they meet the requirements of4.3.2.1.1 through 4.3.2.1.7 .



Air_connector_photo_with_round_and_rectangular_labels.jpg

Shows how air connectors that can only use a round UL label also has a rectangular label on the air connector which give and appearance of the product being a air duct not an air connector.


There are no standards on how air connectors are labeled. Only how often they must be marked with a rectangular or a round UL listing label. A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

Committee Rejected but held


33 of 53 11/9/2016 9:07 AM

Action:



34 of 53 11/9/2016 9:07 AM


4.3.2.1.1

Air connectors shall conform to the requirements for Class 0 or Class 1 air connectors whentested in accordance with ANSI/UL 181, Standard for Safety Factory-Made Air Ducts and AirConnectors. A ir connectors are only required to pass 13 of the 16 UL 181 test for air ducts.


To aid ASHRAE, IAPMO, and the ICC this language can help AHJ's see the difference between air ducts and air connectors.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



35 of 53 11/9/2016 9:07 AM


4.3.2.1.3

Air connector runs shall not exceed 4 .27 2 m (14 ft 7 inches ) in length.



Carlisle_connector_plus.pngWhat the industry views air connectors as


Air connector by manufacture

FlexConnCatalog2013_LR_air_connector.pdf

Duro Dyne air connector is not flex duct but a flexible air piece that connects to pieces of HVAC air duct.


Air connectors are for vibration elimination and do not need to be longer than 7.8”.

Using them for longer lengths and allows for breaching of the HVAC duct systems in more spots.

ASHRAE TC 5.2 cannot find any information on where this 14 foot limitation came from or any data on why it is allowed to be used for 14 feet.

The IMC and UMC allow 14 feet of air connectors because NFPA says they can be 14 feet. NFPA is essentially providing the design of duct systems with this limitation and mention of air connectors.

ASHRAE has made formal request for this justification of 14 feet from NFPA with no response back to the ASHRAE 5.2 subcommittee on duct construction.

Air connectors were first developed to stop HVAC fan vibration in a building. They would be installed by the furnace, equipment or fan with the sole purpose of eliminating the fan vibrations from transferring though out the duct system. The ASHRAE 5.2 TC has been researching where this 14 foot limitation comes from with no real concrete findings.

The UMC and IMC codes refer back to this NFPA limitation of 14 feet and do not know why or how 14 feet was determined.

How did NFPA determine this 14 foot limitation? Please let ASHRAE know (5.2)

Related Item





36 of 53 11/9/2016 9:07 AM


Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



37 of 53 11/9/2016 9:07 AM


4.3.2.1.4

Air connectors shall not pass through be within 15 feet of passing through any wall,partition, or enclosure of a vertical shaft that is required to have a fire resistance rating of 1hour or more.




Shows how a air connector can be attached close to a outlet going through a floor or into a wall cavity.

Pictures_of_air_connector_used_on_the_other_side_of_a_1_hour_fire_rated_ceiling.pdf

1 hour fire assembly with air connector right next to the diffuser opening. Doesn't make sense to have a fire assembly if using a air connector next to the opening is allowed.


This show how currently a large opening from floor to floor is created by allowing the use of


38 of 53 11/9/2016 9:07 AM

air connectors


Air connectors do not pass the UL flame penetration test. Allowing them to be attached to a short (no limit on length requirement) piece of metal next to or going through the fire assemble allows for a flame to breach right into the fire rated assembly. 15 feet may give enough length of duct with UL listed Duct flame penetration test duct or metal duct to stop the spread of smoke and flame through the floor. When looking from the top view of a floor plan having opening 8 feet apart on the entire floor looks a lot like balloon framing to me except in the occupied space not in wall cavities.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



39 of 53 11/9/2016 9:07 AM


4.3.2.1.5

Air connectors shall not pass be within 15 feet of passing through floors.



Connector_attached_at_floor.pdf Fitting which is attached to a opening in the floor.


When air connector are attached to floor boot registers there is only about 2 inches of metal below the floor. With air connectors not passing the UL 181 flame penetration test this allows for smoke and fire to jump through a floor or into a wall cavity with relative ease. Easier than the smoke drafting material around the outside of the duct.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



40 of 53 11/9/2016 9:07 AM


4.3.2.1.6

An air connector shall not be interrupted by a short collar less than 15 feet or any other fittingon one side and then connected to another air connector on the other side where penetrating afloor or a wall, partition, or enclosure of a vertical shaft that is required to have a fire-resistancerating of 1 hour.




Shows a floor boot going from basement to first floor

Connector_attached_at_floor.pdf

Picture of fitting going through floor.


When using the term “short” what does that mean? If the air connector is used only on one side of the floor or wall can it be used on one side of the fire assembly? With this language it could be. Weather the penetration is connected on the other side of the fitting to another duct or is open it should not matter. Allowing this to penetrate a floor or wall into the occupants space would allow smoke to enter the space quicker.

This language will allow for unlimited numbers or air connectors used on a duct run if connected with “long” collars. How long is a long collar? 1 foot?

Related Item





Street Address:

City:

State:

Zip:


Committee Statement


41 of 53 11/9/2016 9:07 AM

CommitteeAction:

Rejected but held



42 of 53 11/9/2016 9:07 AM


4.3.2.1.7

Multiple air connector runs shall not be spliced together, or be longer that 14 in total, to exceedthe length limitation in 4.3.2.1.3.


Stopping the installation of 14 feet in the basement, 14 feet in the first floor, 14 feet in the second floor, 14 feet in the attic. I have not found any information on why NFPA has this 14 foot limitation, but I am assuming NFPA does not want 14 feet of connector on each level of a home or building. This would help define NFPA's position.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



43 of 53 11/9/2016 9:07 AM


4.3.2.2

Vibration isolation Air connectors in duct systems shall be made of materials having amaximum flame spread index of 25 and a maximum smoke developed index of 50.



Carlisle_connector_plus.png

Manufactures description of a air connector. NFPA defines this product as a Vibration isolator.

HVAC-3202_Residential_Quality_2-3-2_28G_TDS-US_Version_01-10-13_air_connector.pdf


HVAC-3202_VinylFlex_TDS-LOWRES_air_connector.pdf


HVAC-3202_Neoprene_TDS-LOW-RES_air_connector.pdf


HVAC-3202_Silicone_HI-T_TDS_7-27-12_air_connector.pdf




FlexConnCatalog2013_LR_air_connector.pdf



The HVAC industry calls these products air connectors. NFPA calls them Vibration eliminators. Either NFPA should change their definition, or try to have the HVAC industry change their definition. Either way this a disparity that should be address and brought together.

Related Item




44 of 53 11/9/2016 9:07 AM



Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



45 of 53 11/9/2016 9:07 AM


Sub-Sections] ]

Pipe and duct insulation and coverings, duct linings, vapor retarder facings, adhesives,fasteners, tapes, and supplementary materials added to air ducts, plenums, panels, and ductsilencers used in duct systems, unless otherwise provided for in 4.3.3.1.1 or 4.3.3.1.2, shallhave, in the form in which they are used, a maximum flame spread index of 25 without evidenceof continued progressive combustion and a maximum smoke developed index of 50 when testedin accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials, or with ANSI/UL 723, Standard for Test for Surface Burning Characteristics ofBuilding Materials. Pipe and duct insulation and coverings, duct linings and their adhesives, andtapes, except gypsum wall board paper tape, shall use the specimen preparation and mountingprocedures of AASTM E2231, Standard Practice for Specimen Preparation and Mounting ofPipe and Duct Insulation Materials to Assess Surface Burning Characteristics.


Since NFPA allows the use of gypsum wall board as ducts and its tape the paper sheet rock tape should be noted as an exemption.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



46 of 53 11/9/2016 9:07 AM


Sub-Sections] ]

Pipe and duct insulation and coverings, duct linings, vapor retarder facings, adhesives,fasteners, tapes, and supplementary materials added to air ducts, plenums, panels, and ductsilencers used in duct systems, unless otherwise provided for in 4.3.3.1.1 or 4.3.3.1.2, shallhave, in the form in which they are used, a maximum flame spread index of 25 without evidenceof continued progressive combustion and a maximum smoke developed index of 50 when testedin accordance with ASTM E84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials, or with ANSI/UL 723, Standard for Test for Surface Burning Characteristics ofBuilding Materials. Pipe and duct insulation and coverings, duct linings and their adhesives, andtapes shall use the specimen preparation and mounting procedures of AASTM E2231, StandardPractice for Specimen Preparation and Mounting of Pipe and Duct Insulation Materials toAssess Surface Burning Characteristics. Shall meet ASHRAE standard 62.1 for HVAC ductsurfaces.



ASHRAE_62.1_for_mold_and_duct_erosion_NFPA_90.docxASHRAE standard on HVAC duct surfaces


Make the duct last at least a specific length of time as per ASHRAE

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



47 of 53 11/9/2016 9:07 AM


4.3.3.2

Closure systems for use with rigid and flexible air ducts tested in accordance with ANSI/UL 181,Standard for Safety Factory-Made Air Ducts and Air Connectors, shall have been tested, listed,and used in accordance with the conditions of their listings, in accordance with one of thefollowing:

(1) ANSI/UL 181A, Standard for Safety Closure Systems for Use with Rigid Air Ducts

(2) ANSI/UL 181B, Standard for Safety Closure Systems for Use with Flexible Air Ducts andAir Connectors

(3) Except gypsum board ducts


If NFPA is going to allow gypsum board ducts to be used there is no closure standard for them. The sheet rock paper used as tape has not been tested to either standard in this section.

Related Item





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected but held



48 of 53 11/9/2016 9:07 AM

Public Comment No. 30-NFPA 90A-2016 [ Section No. 4.3.11.2.6.10 ]

4.3.11.2.6.10

Air ducts complying with 4.3.1.2 and air connectors complying with 4.3.2 shall be permitted.


Deleting this would make fire rated assemblies safer and meet their design intent.

Air connectors do not pass the UL 181 test for flame penetration and should not be used in a HVAC duct system.Air connectors are currently found being used in the wrong application as a UL 181 listed air duct. UL 181 Listed air ducts pass 16 of 16 UL test to be listed as an air duct. Air connectors pass 13 of 16 UL test for being a listed air ducts, failing 3 of the required test for being a listed air duct. The three test that are not required are, puncture, flame penetration, and impact test. Allowing the use of air connectors connected next to a fire wall kind of defeats the purpose of the fire wall since there is no flame penetration test you have an open hole to the other side of the fire wall. Allowing smoke to pass through the opening at the first flame that touches the air connector. Even when installed under the current requirements air connectors are the weak link leading to instant penetration of a HVAC duct system, breeching fire assembles and the HVAC system itself. When the HVAC duct system is breached the HVAC fan will spread smoke and heat to other parts of the building. IAPMO (UMC) did not allow the use of air connectors until a couple years ago. When they allowed the use of them it was a mistake as they thought an air connector was the small piece of flex to eliminate HVAC vibration. Attached are photos of what is viewed as air connectors by engineers, sheet metal workers, and installing contractors.

There are no standards on how air connectors are labeled. Only how often they must be marked with a rectangular or a round UL listing label.

A round UL label indicates the product is a air connector, a UL rectangular label indicates that the product is a UL listed air duct. Sometimes manufactures put a very small round label on the air connector, and also put a larger rectangular performance label next to the smaller round label. When an inspector looks for a flexible air duct they look for that rectangular label. Well the air connector has that larger rectangular label next to the UL symbol and it is overlooked as an air connector and is passed off as a UL listed air duct.

Related Item





Street Address:

City:

State:

Zip:


49 of 53 11/9/2016 9:07 AM


Committee Statement

CommitteeAction:

Rejected but held



50 of 53 11/9/2016 9:07 AM


6.4.3.1

Smoke detectors provided as required by 6.4.2 shall automatically stop shunt their respectivefan(s) on detecting the presence of smoke.


The desire is for fans to immediately begin to spin down upon detection of smoke to prevent the spread of smoke by the air handler. An example is a 135,000 cfm system that ran for three and a half minutes after the detection indicated smoke. This circulated 472,000 cf of smoke. The intent of this comment is to have the power to the fans immediately shunted, so that the spin down of the air handler begins immediately. This avoids the time it may take to relay through the system to begin shutdown. As noted by the committee’s reason for not utilizing PI 32, it would be nearly impossible to immediately stop the airflow, which was not the intent of PI 32. Having a shunt will immediately begin the process of stopping the air handler, much like the shunting of an elevator upon heat detection.

Related Item

Public Input No. 32-NFPA 90A-2015 [Section No. 6.4.3.1]


Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, Washington

Affilliation: NFPA's Building Code Development Committee (BCDC)

Street Address:

City:

State:

Zip:

Submittal Date: Tue May 10 13:22:52 EDT 2016

Committee Statement

CommitteeAction:

Rejected but held



51 of 53 11/9/2016 9:07 AM

Public Comment No. 38-NFPA 90A-2016 [ Section No. A.3.3.9 ]

A.3.3.9 Air Inlet.

For further discussion of various types of air inlet devices, see ASHRAE Handbook —Fundamentals 2013 , Chapter 32 20 , “Space Air Diffusion.”


Correction to latest version of referenced publication ASHREA Fundamentals. Chapter changed from 32 to 20.

Related Item

Public Input No. 1-NFPA 90A-2015 [Global Input]


Submitter Full Name: John Kennedy

Organization: NAIT

Affilliation: Instructor HVAC

Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Accepted


Statement: Correction to latest version of referenced publication ASHREA Fundamentals.Chapter changed from 32 to 20.


52 of 53 11/9/2016 9:07 AM

Public Comment No. 33-NFPA 90A-2016 [ Section No. C.1.2.3 ]

C.1.2.3 ASTM International Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA19428-2959.

ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials,2015a 2015b .

ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at750°C, 2012 2016 .

AASTM ASTM E2231, Standard Practice for Specimen Preparation and Mounting of Pipe andDuct Insulation Materials to Assess Surface Burning Characteristics, 2015.

ASTM E2652, Standard Test Method for Behavior of Materials in a Tube Furnace with aCone-Shaped Airflow Stabilizer, at 750°C, 2012 2016 .


date updates

Related Item

Public Input No. 11-NFPA 90A-2015 [Section No. C.1.2.3]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Wed May 04 17:27:14 EDT 2016

Committee Statement

Committee Action: Rejected but see related SR


Statement: date updates


53 of 53 11/9/2016 9:07 AM

Public Comment No. 32-NFPA 90A-2016 [ Section No. 2.3.2 ]...Public Comment No. 2-NFPA 90A-2016 [...

Documents

Transcript of Public Comment No. 32-NFPA 90A-2016 [ Section No. 2.3.2 ]...Public Comment No. 2-NFPA 90A-2016 [...