Code Enforcement Training and Support

STATUS REPORT - December 3, 2009

The Working Group has prepared a draft NASFM Pallet and Sprinkler System Training Module and draft Code Application Bulletin. The drafts were submitted to and reviewed by the NASFM Board of Directors. Following that review NASFM received a written communication from iGPS, a plastic pallet manufacturer and former Working Group member that expressed a number of concerns and objections about some of the content in the draft materials. The iGPS concerns were of a nature that NASFM has sent them to the Working Group for consideration. If warranted, appropriate adjustments will be made to the draft materials.

NASFM also received feedback from the International Code Council referring to general information from the ICC's International Fire Code they think should be included in the draft pallet materials. NASFM will be requesting ICC to draft specific language to cover the additions which when received will be sent to the Working Group.

After the Working Group addresses these matters the NASFM Board will review the revised draft pallet materials and in addition NASFM may seek third party review of the draft materials before publication. We want to be certain that the Training Module and related materials are complete and accurate and give proper guidance to the local Authority Having Jurisdiction/code official. We also expect that following publication NASFM will receive comments or suggestions to improve the materials. NASFM welcomes such input from interested parties.

Until this process is completed, the draft pallet materials remain in draft form. The materials will not be posted on the NASFM website until finalized. Until posted any dissemination of the draft materials beyond Working Group members is not authorized by NASFM.

NASFM does not approve, endorse or recommend products or services, or recommend whether or not to use specific products or services, or certify whether or not products or services comply with laws, standards, codes or other requirements. NASFM is not an Authority Having Jurisdiction and has no authority to enforce laws, standards, codes or other requirements.

NASFM Pallet Working Group - August 12, 2009

Jim Narva - NASFM

Loren Caudill - On Board Engineering

LeRoi Cochran - IFCO Systems N.A., Inc

David Deal - CHEP

Tom LaCorte - Chubb Group of Insurance Companies

Thomas McCarty - FM Approvals

Rodney McPhee - Canadian Wood Council

Bruce Scholnick - National Wooden Pallet and Container Association

Dan Steppan - Underwriters Laboratories

Tim Testerman - Procter & Gamble

David Tyler - Alaska State Fire Marshal, NASFM Model Codes Committee

NASFM Pallet Working Group

NASFM Clarifies Working Group Purpose, in Response to Press Releases - July 23, 2009

In April 2009, the National Association of State Fire Marshals (NASFM) formed a Pallet Working Group with the goal of developing a training and education program for use by code enforcement personnel and facility operators when inspecting the adequacy of fire protection of occupancies where pallets are in use. Background on the Working Group and its activities can be found at http://www.firemarshals.org/programs/code-enforcement-training-and-support/. NASFM has been pleased with the cooperative nature of the Working Group interactions and the progress made in developing a balanced and fact-based training program on pallets in relation to fire protection.

Recently, Working Group members issued press releases that referenced the NASFM Working Group and purported to state its opinions or positions. Neither NASFM nor the other members of the Working Group were consulted about being referenced in the press releases. While a member of the Working Group is certainly free to express its own views, no member has been authorized to speak on behalf of the Working Group. This behavior contravenes the spirit of cooperation and consensus in which the Working Group was formed and has operated to date.

Therefore, NASFM is issuing this notice to provide needed clarifications.

NASFM's interest is fire safety and ensuring that the sprinkler protection of a space is adequate to the fuel load present, in accordance with NFPA 13, "Standard for the Installation of Sprinkler Systems."
The only "official" positions of the NASFM Pallet Working Group are those authorized by NASFM. Those positions are developed with input from all Working Group members.
NASFM has not taken any position in agreement, or disagreement, with different segments of the pallet industry, and does not allow its name to be used to imply support of positions expressed by others, whether they are Working Group members or not.
NASFM and its Working Group have not taken a position on fire retardant formulations in pallets.

NASFM plans to re-evaluate the make-up of the Working Group to ensure that its members consist only of those organizations and individuals willing to work cooperatively toward our goals in the interest of fire safety.

NOTE: Any documents posted here regarding Working Group meetings and activities are preliminary to any final action. Postings are intended only to keep interested people informed of Working Group activities.

April 15, 2009, Letter Announcing Formation of NASFM Pallet Working Group and Assignments

May 13, 2009 Pallet Working Group meeting notes

July 7, 2009, Pallet Working Group conference call notes

August 21, 2009 Working Group Memo

Update concerning Draft NASFM Code Application Bulletin, "Pallet Fire Loading Impact on Sprinkler Design"

In response to discussion and input at the well-attended pallet stakeholders meeting held on March 12, 2009 at Underwriters Laboratories, NASFM has agreed to withdraw the DRAFT Code Application Bulletin (CAB) entitled "Pallet Fire Loading Impact on Sprinkler Design" dated September 1, 2008, from public posting on this website. One result of the meeting was to assemble a small working group representing specific constituencies to review additional comments on the draft CAB and work together to resolve any technical issues in the document to ensure its completeness and accuracy prior to publication.

Information from the March 12, 2009, Meeting in Northbrook, IL

UL Presentation: Fire Suppression Performance Testing of Storage Pallets

Final Attendee List from the March 12 meeting in Northbrook, IL

Agenda from the March 12 meeting in Northbrook, IL

March 17, 2009, NASFM Message to All Interested Parties following March 12 Pallet Stakeholder Meeting

The National Association of State Fire Marshals (NASFM) has prepared a "Summary of and Response to Public Comments, Request for Clarification and Next Steps" dated February 11, 2009. Click here for that document.

NASFM also announces the following next steps regarding this issue.

STEP 1: NASFM will reopen the public comment period on the Code Application Bulletin, "Pallet Fire Loading Impact on Sprinkler Design" until close of business (5 pm Eastern) Tuesday, March 10, 2009, to allow for additional information and clarification of points raised above. Comments should be sent, as before, to the email address cab@firemarshals.org.

STEP 2: In coming weeks, NASFM will brief its members and other major organizations of code enforcement officials on progress to date and projected dates and outcomes.

STEP 3: On Thursday, March 12, 2009, from 10 am - 3 pm, NASFM will host a meeting at Underwriters Laboratories headquarters in Building 11 (Fire Protection Laboratory Building) at 333 Pfingsten Road, Northbrook, Illinois.

At that time, NASFM will finalize the Code Action Bulletin and lead a discussion on dissemination of the Bulletin as well as some of the comments that suggested more effective and efficient approaches to the challenges of enforcing pallet fire safety requirements. UL will conduct a demonstration pallet fire test to illustrate some points on Commodity Classification testing of pallets. Seating is limited, available on a first come, first serve basis to registered attendees. We will not be able to accept walk-ins. The agenda will include:

Consensus on the content of the draft Code Action Bulletin.
Consensus on the most effective paths forward to distribute the Bulletin; and to establish a coordinating committee to facilitate this process.
Discussion of a framework of a research program to gather additional data on the fire performance of the full range of pallets in commercial use.
Discussion of a path forward that simultaneously advances public safety with a minimum of commercial disruption, to include discussion of a new requirement that all pallets are listed and discussion of the pros and cons of a single set of fire performance criteria.

Those who are interested in attending the March 12 meeting must RSVP to cab@firemarshals.org by 5 pm Eastern Time on Tuesday, March 10. Please include the name, title, organization and email address of all who plan to attend from your organization.

STEP 4: Training session, progress report and further stakeholders' discussions at the NASFM Annual Conference, June 19-21, 2009, in Redmond, WA.

STEP 5: Subsequent regional sessions as defined by the coordinating committee established in Step 3 above.

NOTICE CONCERNING DRAFT NASFM CODE APPLICATION BULLETIN

"Pallet Fire Loading Impact on Sprinkler Design"
Comments Requested by December 29, 2008

Earlier this year, the Model Codes Committee of the National Association of State Fire Marshals (NASFM) began work on a code enforcement training and support program to help state and local code enforcement agencies improve the quality and effectiveness of their service.

With the unanimous support of the NASFM Directors, the program has been designed with these elements:
• Topics may be suggested by code officials or any interested party, but are then selected by the NASFM Model Codes Committee, which consists entirely of senior state fire code officials.
• Resource documents are created to educate stakeholders on the nature and extent of the risk being managed, the relevant codes and standards and other information which may be helpful to those required to comply or enforce the rules.
• The resource documents then are shared with interested parties who are encouraged to suggest improvements.
• The final document is placed on the NASFM website for code officials and other interested parties.
• The resource documents may be used as part of broader training packages by NASFM or participating agencies.

Numerous topics have been identified and several have been selected, including topics pertaining to the Green Buildings movement, alternative energy and significant trends in industry.

The trend toward greater use of plastics in pallets was among the first topics selected. A resource document, a draft Code Application Bulletin entitled "Pallet Fire Loading Impact on Sprinkler Design," was developed by NASFM Code Consultant Robert J. Davidson and reviewed by the NASFM Model Codes Committee.

A conference call to enable industry input to the draft resource document was scheduled for 3 p.m., Thursday, September 25. The call was postponed for logistical reasons. NASFM regrets any inconvenience this may have caused.

Further, the October 1, 2008, effective date that had previously been announced for incorporating this topic as a standard training module for state and local code enforcement officials has been postponed indefinitely.

The draft resource document is included in this mailing, along with all comments that have been received to date. The draft also has been posted on the NASFM website ( www.firemarshals.org) for public review and written comment by interested parties for a 90-day comment period. The comment period ends on December 29, 2008. All comments will be posted on the NASFM website.

For telephone inquiries, please contact the National Association of State Fire Marshals main office at (202) 737-1226; for written inquiries, please write to Attn: Code Application Bulletin, National Association of State Fire Marshals, 1319 F Street, NW, Ste 301, Washington, DC 20004 or by email at cab@firemarshals.org.

Comments received to date (all comments will be posted):

Richard A. Monteiro (comment dated October 10, 2008)

FM Approvals (comment dated September 29, 2008)

FM Approvals (comment dated September 19, 2008)

iGPS intelligent Global Pooling Systems (comment dated December 22, 2008)

ACS Group (comment dated December 20, 2008)

CHEP (comment dated December 29, 2008)

SABIC Innovative Plastics (comment received December 29, 2008)

National Wooden Pallet and Container Association(comment dated December 29, 2008)

Comments received after December 29, 2008:

GMA, Association of Food, Beverage, and Consumer Products Companies (comment dated January 9, 2009)

Comments received during second comment period ending March 10, 2009:

FM Approvals (comment dated February 25, 2009)

iGPS intelligent Global Pooling Systems (comment dated March 4, 2009)

NWPCA, CHEP Americas, IFCO Systems, PECO Pallet, Inc. (comment dated March 10, 2009)

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