Technical Committee on Chimneys, Fireplaces, and Venting ... · A presentation will be made by...

Technical Committee on Chimneys, Fireplaces, and Venting Systems for Heat-Producing Appliances

Date: February 12, 2015 To: Technical Committee on Chimneys, Fireplaces, and Venting Systems for Heat-

Producing Appliances From: Eric Nette, P.E. Staff Liaison/Engineer Re: NFPA 211 F2015 Second Draft Meeting Agenda– March 18 & 19, 2015 Enclosed is the agenda package for the March 18 & 19, 2015 meeting for the NFPA 211 Second Draft Meeting. Please ensure that you have reviewed the public comments and the other agenda items in advance to prepare for discussion. The agenda and public input will be posted on the document information pages (www.nfpa.org/211next). Some items to have available during the meeting include:

Agenda package with public comment A copy of NFPA 211 (visit the NFPA 211 Document information pages for your free

committee copy) Any previous copies of the technical committees standard A laptop

Optional items that are sometimes useful include:

Review of NFPA’s Process, www.nfpa.org/regs If you have any questions or comments, please feel free to reach me at (617) 984-7434 or by e-mail at [email protected]. I look forward to our meeting to continue the revision cycle!


AGENDA

Technical Committee on Chimneys, Fireplaces, and Venting Systems for

Heat-Producing Appliances

AGENDA

March 18 & 19, 2015 NFPA Headquarters 1 Batterymarch Park

Quincy, MA 02169

1. Chair’s welcome, call to order, and opening remarks at 8:00 a.m. EST.

2. Self-Introduction of Committee Members and Guests

3. Approval of Minutes from the First Draft meeting held in May 2014. The minutes are available on the NFPA 211 document information page, www.nfpa.org/211next.

4. Staff Liaison Report

A. Committee membership update (For the period Apr 8, 2014 – Dec 1, 2014)

Name Category Change Date Michael Savage E (Principal) Re-appoint 8/11/2014 Thomas Heller E (Principal) Appoint 8/11/2014 Randy Brooks IM (Principal) Re-appoint (indiv) 8/11/2014 James Brewer IM (Principal) From Alt to P 8/11/2014 Richard Peacock RT (Principal) Non-reappoint 11/3/2014 Charles Gibbons SE (Principal) Non-reappoint 11/3/2014 Joseph Hilko M (Principal) Non-reappoint 11/3/2014 Carl Opatrny E (Principal) Non-reappoint 11/3/2014

(Total Voting Members – 25; SE=32%; M = 20%; E=20%; RT=8%; IM=12%; I=4%; C = 4%)

B. NFPA new document revision process, policies and procedures, revision cycle review (Attachment A)

5. Document Revision.

A. Listing of Fireplace Accessories. A presentation will be made by committee member Tom Pierce. The committee should review Public Comments regarding listing of masonry fireplace accessories (Attachment B) and create Second Revisions as appropriate.

B. The committee should review the remaining Public Comments (Attachment C) and create Second Revisions as appropriate.


AGENDA

6. Old Business.

A. Task group on rain cap height. (T. Stroud, Chair; N. Dawe, R. Edwardsl, R. Rucker) The task group scope was expanded to address any devices that could excessively impede airflow at the termination point. NFPA staff submitted a Research Foundation code fund request for a literature search specific to flow resistance of chimney terminations, such as rain caps, exhaust terminations, chimney-top dampers and decorative shrouds. The final report will be published in the first quarter of 2014. The committee will receive the report under separate cover. The committee should review Committee Input No. 2 (Attachment D) and create Second Revisions as appropriate.

B. Task group on Chapter 9 (R. Brooks, Chair; J. Brewer, G. Edgar, R. Edwards, C. Gibbons, T. Pierce, and T. Stroud). The task group recommendations were approved by the committee in First Revisions 10 and 14. The committee should close the task group or provide further instruction based on the review of related Public Comments.

C. Task group on free-standing appliance cleanouts. (M. DeBlasio, Chair; D. Hersey, N. Wittasek). The task group should report on any progress on this topic.

D. Task group on Masonry Heaters (T. Seaton, Chair; R. Curkeet, V. Hodges, M. Savage, T. Seaton, T. Stroud, and R. Zander) The task group remains open to continue consideration of more detailed requirements in NFPA 211.

E. NFPA 211/NFPA31/NFPA 54 Coordination. In the May 2014 meeting, a task group was established to look at coordination issues between NFPA 211, NFPA 31, and NFPA 54. Members of the task group are: M. Wilbur, Chair; J. Batey (rep NFPA 31); Jim Brewer; G. Edgar; D. Feb; D. Hersey; M. Kulik; and H. Ornstein. The task group has not met, but will continue their work in preparation for the 2019 edition.

8. New Business. Glossary (Chapter 3) Review. NFPA policy states that only terms used in the mandatory text can be defined in chapter 3. NFPA staff recommends that the committee establish a task group for the 2019 edition to review chapter 3 and identify terms not currently used in the mandatory text, such as the many incinerator sub-definitions.

9. Date/Location of Next Meeting. NFPA 211 is in the Fall 2015 revision cycle. This completes the work of the committee for this revision cycle. The next meeting will be scheduled as needed.

10. Adjournment.

Attachments:

A. NFPA Process – Quick Reference Guide for Second Draft Meeting

B. Public Comment on Masonry Fireplace Accessories

C. All Other Public Comments

D. CI No. 2: Rain Cap Heights

Attachment A: NFPA Process – Quick Reference Guide for Second Draft Meeting

New Process (Second Draft Stage) – Quick Reference Guide For additional information on the New Regulations visit: www.nfpa.org/NewRegs

A Technical Committee (TC) can take these actions at the Second Draft (ROC) meeting:

1. Resolve a Public Comment

Accept

Reject, But See Related Second Revision

Reject

Reject But hold 2. Create a Second Revision

NOTE: All actions require a Committee Statement.

Resolve Public Comment (TC needs to act upon all the Public Comments)

Accept

The TC takes the text exactly as submitted by the public comment and creates a second revision.

Sample Motion: “I move to accept PC#_.”

Approval by meeting vote (simple majority) and final approval through ballot.

Reject but See

The TC agrees with the concept of the PC in whole or part but wants to edit the text to create a second revision.

Sample Motions: i. “I move to reject PC#__, but create a second revision using it as a basis.” ii. “I move to make a second revision using PC#__ as a basis.”


Reject

The TC disagrees with the proposed changes in the public comment.

Sample Motion: “I move to reject PC#__.”

Approval by meeting vote (simple majority). Not subject to ballot.

Reject, but Hold.

The TC may hold any comment until the public input stage of the next revision cycle meeting any of the following criteria:

i. New concept that has not had any public review ii. The changed text would require the technical committee to restudy the

change iii. The proposed concept cannot be handled in the second draft timeframe

Sample Motion: “I move to hold PC#__.”

Approval by meeting vote (simple majority). Not subject to ballot. Create a Second Revision (change to the document)

TC must create a Second Revision (SR) for each change they wish to make to the document. The TC can either choose to use a Public Comment for the basis of the change or not.

Using Public Comment for basis: i. See above for ACCEPT or REJECT BUT SEE.

Without using Public Comment for basis i. Sample Motion: “I make a motion to revise section __ as follows___.”


Comparison to Previous Process:

PREVIOUS ACTIONS NEW PROCESS ACTIONS Sample Motion

Accept

1) Committee generates a Second Revision and Substantiation (CS) for change 2) Committee provides response (CS) to each PC.

1) “I move to accept PC#__.”

Any variation of Accept (APA, APR, APP) on a public comment

1) Committee rejects the comment, but creates a Second Revision 2) Committee provides response (CS) to each PC that is associated with the revision

1) “I move to revise section __ using PC#_ as the basis for change.” 2) “I move to reject PC#__, but create a second revision using it as a basis.”

Rejected Public Comment

1) Committee rejects the comment 2) Committee provides response (CS) to PC

“I make a motion to reject PC#_ with the following committee statement__.”

Accepted Committee Comment Committee generates a Second Revision and Substantiation (CS) for change

“I make a motion to revise section __ as follows___.” Committee generates a statement for reason for change.

Notes: 1) All meeting actions require a favorable vote of a simple majority of the members present. 2) All Second Revisions will be contained in the ballot and will require a 2/3 affirmative vote

to confirm the meeting action. 3) Only the Second Revisions will be balloted. PCs will be contained in the report but will not

be balloted.

New Terms:

NEW TERM OLD TERM

Input Stage ROP Stage

Public Input (PI) Proposal

First Draft Meeting ROP Meeting

Committee Input Committee Proposal that Fail

Ballot

Committee Statement (CS)

Committee Statement

First Revision (FR) Committee Proposal or Accepted

Public Proposal

First Draft Report ROP

First Draft ROP Draft

Comment Stage ROC Stage

Public Comment Public Comment

Second Draft Meeting ROC Meeting

Committee Comment Committee Comment that Fail

Ballot

Committee Action Committee Action

Second Revision Committee Comment or Accepted

Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Note: The highlighted terms are the ones that will be most applicable at the Second Draft Meeting.

Attachment B: Public Comment on

Masonry Fireplace Accessories

Public Comment No. 31-NFPA 211-2014 [ Global Input ]

Delete sections 3.3.2.1, 3.3.2.2, 11.1.5, 11.2.10, 14.7.1.1, 14.7.1.2

Statement of Problem and Substantiation for Public Comment

Having served as past president of the national Chimney Sweep Guild and the Chimney Safety Institute I feel the issues or recommended changes have come to light before and continue to surface every few years. Over the years proof of problems associated with aftermarket, OEM products related to factory-built fireplaces has never materialized even after much debate for over twenty fire years. As a business owner for over 38 years, I maintain that many times we have have made systems much safer by installing OEM chimney caps and screening that keep birds and other animals out. In addition, many factory built fireplace manufacturers have either went out of business or no longer make parts for systems that may be just 10 years old. Asking the consumer to replace an entire fireplace system due to something as simple as a rusted out screen places an unfair burden on the homeowner and is almost criminal. Many years of extended life to a factory built system can be gained with proper maintenance and basic OEM property manufactured and installed parts.

In regards to the changes related to masonry fireplaces, I question the thought process as to why or the reasoning. Setting aside the items many int he service industry sell, I question if or how the AHJ will handle the calls from the homeowner when they purchase a new grate, andirons or other simple accessories they may purchase at a big box store. the proposed changes are simply unrealistic in the real world.

Related Item

First Revision No. 11-NFPA 211-2014 [Section No. 11.1]

Submitter Information Verification

Submitter Full Name: Victor Imgarten

Organization: Clean Sweep Chimney Service

Street Address:

City:

State:

Zip:

Submittal Date: Mon Oct 27 14:38:31 EDT 2014

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

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COMMENT - IHP/PENNINGTON

NOTE - My recommendations have and-or logic in the "SPECIFICALLY" section, below.

GENERALLY -

I propose deleting "gas log decorative appliances," from both A.3.3.2.1 and A.3.3.2.2, and/orremoving the requirement for "specific" model associations in the listing.

Rationale - Taken in concert with the definitions in 3.3.2, including 3.3.2.1* and 3.3.2.2*, this exposesgas log decorative appliances in Chapter 11 at 11.1.5, and in the maintenance chapter 14 at 14.7.1.1and 14.7.1.2 to requirements that these accessories be tested and/or listed or approved for use withthe specific models of factory built chimneys (14.7.1.1), and/or factory-built fireplace systems(14.7.1.2), and/or factory-built fireplace (11.1.5 (1) ) and/or masonry fireplaces or chimneys (3.3.2.2*).

There are standards already in place to allow use of combinations of listed gas log decorativeappliances and listed chimneys, fireplaces, and fireplace systems aforementioned, and theallowance is general vs. the requirement for specific models in the current draft language. Perhapsthe intention was that this general listing practice be continued, since it is based on "generic"claims, allowing use over a bounded product type rather than each individual and specific model ofapplied device having to be identified and approved in a listing. Contrary to that, however, the draftlanguage would require every specific model of fireplace to be tested and listed for each gas logdecorative appliance, and that will be catastrophically burdensome. My recommendations areintended to avoid this latter scenario.

SPECIFICALLY -

I recommend to:

1. remove "gas log decorative appliances," in A.3.3.2.1 and A.3.3.2.2, and/or

2. replace "the specific model" with "appropriately listed models" in 11.1.5 (1), and

3. replace "the specific model" with "appropriately listed models" in 14.7.1.1 and 14.7.1.2


Rationale - Taken in concert with the definitions in 3.3.2, including 3.3.2.1* and 3.3.2.2*, this exposes gas log decorative appliances in Chapter 11 at 11.1.5, and in the maintenance chapter 14 at 14.7.1.1 and 14.7.1.2 to requirements that these accessories be tested and/or listed or approved for use with the specific models of factory built chimneys (14.7.1.1), and/or factory-built fireplace systems (14.7.1.2), and/or factory-built fireplace (11.1.5 (1) ) and/or masonry fireplaces or chimneys (3.3.2.2*).

There are standards already in place to allow use of combinations of listed gas log decorative appliances and listed chimneys, fireplaces, and fireplace systems aforementioned, and the allowance is general vs. the requirement for specific models in the current draft language. Perhaps the intention was that this general listing practice be continued, since it is based on "generic" claims, allowing use over a bounded product type rather than each individual and specific model of applied device having to be identified and approved in a listing. Contrary to that, however, the draft language would require every specific model of fireplace to be tested and listed for each gas log decorative appliance, and that will be catastrophically burdensome. My recommendations are intended to avoid this latter scenario.

Related Item

First Revision No. 6-NFPA 211-2014 [New Section after 3.3.1.1]


Submitter Full Name: MICHAEL PENNINGTON

Organization: IHP


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Street Address:

City:

State:

Zip:



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I am not in favor of the proposed changes to NFPA 211 which would ban all aftermarket replacementparts for factory-built fireplaces - of which there are many across the United States. This changewould mean that if we came out and inspected a factory-built fireplace and the chimney cap wasmissing or damaged, or if we found a refractory panel was cracked, or if a grate was worn out, oreven if a firescreen was warped, we would NOT be allowed to replace those components withsimilar aftermarket parts. ONLY parts directly from the manufacturer or those parts that arespecifically approved by your Local Code Authority would be allowed.

Here's the problem in several different examples:

1. MANY manufacturers of factory-built fireplaces are out of business. We can't even get thoseparts. You would be required to REPLACE your fireplace if it needs parts. NO EXCEPTIONS.

2. MANY manufacturers of factory-built fireplaces don't support older units with parts. You would berequired to REPLACE your fireplace if it needs parts. NO EXCEPTIONS.

3. Without exception, ALL manufacturers of factory-built fireplaces are a nightmare to deal with toeven order parts. Sometimes, they will only sell to an authorized dealer. Sometimes an authorizeddealer will not sell parts to anyone - even if they don't have their own service department. If there isno authorized dealer in the area, we would have to attempt to order factory-supplied parts. If wecan't get parts, you would be required to REPLACE your fireplace if it needs parts. NOEXCEPTIONS.

4. Most masonry fireplace accessories are not listed either because there is not an appropriatestandard or because the products involved (i.e. glass doors for masonry fireplaces) are impossibleto certify. The fireplace accessory standard (UL 907) specifies a fireplace design and test process(radiant and brand firing conducted to equilibrium) that the fireplace alone will not pass.

5. The local code authorities have no training and have no intention of spending the time andresources to approve individual replacement parts for these factory-built fireplaces.

6. The consumer would be burdened tremendously by the requirement that you would have toreplaceyour fireplace if it needs parts if no parts are available. This can easily be a cost of $5,000and up to do a factory-built firpelace replacement. The consumer's only other choice would be tocompletely discontinue use of their factory-built fireplace.

I have been employed in the hearth industry since 1979. From what I have seen, there is absolutelyno proof that parts replacement with similarly-engineered parts on a factory-built fireplace hascaused any structure fire of any kind. I challenge the NFPA 211 committee to producedocumentation of this on which they are basing these proposed changes.

There IS proof that improper installation of factory-built fireplaces and improper use of factory-builtfireplaces and improper modification of factory-built fireplaces has caused structure fires.

Think of it like this: This would be the same as requiring that you install ONLY factory-suppliedautomotive parts on your car. You would have to REPLACE YOUR CAR if you couldn't get factory-supplied parts for it.

This change in the standard is uncalled for, it's not supported by the industry, and it's toofar-reaching.

We regularly service factory-built fireplaces that are 40 years old or older. We thoroughly inspectthe system and if there are defects or damage that require replacement, we recommend the clientdo so. We also inspect many factory-built fireplaces that are of the same age period and are ingood shape, but might only need a new grate or a new replacement refractory panel or even a newchimney cap. It is without merit that the simple replacement of some of these components wouldno longer be allowed when similar aftermarket parts are an excellent option for the end consumer.

I urge the committee to NOT make the proposed changes regarding aftermarket parts and


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components.

Sincerely,A. Bart Ogden, PresidentHome Safe Hearth & Chimney, Inc.Wichita,KS

CSIA Certified Chimney SweepCSIA Certified Dryer Exhaust TechnicianNFI Master Hearth Professional, Certified in Wood, Gas, and Pellet


I am not in favor of the proposed changes to NFPA 211 which would ban all aftermarket replacement parts for factory-built fireplaces - of which there are many across the United States. This change would mean that if we came out and inspected a factory-built fireplace and the chimney cap was missing or damaged, or if we found a refractory panel was cracked, or if a grate was worn out, or even if a firescreen was warped, we would NOT be allowed to replace those components with similar aftermarket parts. ONLY parts directly from the manufacturer or those parts that are specifically approved by your Local Code Authority would be allowed.

Please see my full comments.

Sincerely,A. Bart Ogden, PresidentHome Safe Hearth & Chimney, Inc.Wichita,KS

CSIA Certified Chimney SweepCSIA Certified Dryer Exhaust TechnicianNFI Master Hearth Professional, Certified in Wood, Gas, and Pellet

Related Item

Public Input No. 9-NFPA 211-2013 [Section No. 3.3.68]

Public Input No. 11-NFPA 211-2013 [New Section after 11.1]

Public Input No. 12-NFPA 211-2013 [New Section after 6.1.1]


Submitter Full Name: BART OGDEN

Organization: HOME SAFE HEARTH AND CHIMNEY

Street Address:

City:

State:

Zip:

Submittal Date: Sun Nov 09 22:09:01 EST 2014


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Our company is asking that the NFPA 211 Committee rejects the proposed changes in regards to after-market parts for masonry and factory built fireplaces.


As a CSIA Certified Sweep and Small Business Owner, I agree with the CSIA’s position that the research they are doing needs to be completed before aftermarket parts are disqualified as acceptable replacements by manufacturers.

We have been installing aftermarket factory-built refractory panels and spark screens for many years. Most of these fireplaces are over 20 years old. We have no known problems with these parts. I have also investigated fires originating from factory-built fireplaces where the homeowner has installed parts never intended for use with these fireplaces. Mostly, these parts are glass doors intended for masonry fireplace use only. I have also seen smoking problems with customers using an improperly sized replacement grate, because they were not able to find one at a retail store listed for their factory-built fireplace. Many of the aftermarket parts are far superior to the original components. Many of the OEM parts are poorly engineered. One example is with chimney caps. We see many OEM caps and air-cooled chimneys full of animal nesting material because of poor design.

It often creates a dangerous situation when consumers attempt to fix their old factory-built fireplaces with parts not intended for this purpose. We support the manufacturers that allow us to service our customers with aftermarket parts and keep their homes safe. I believe as sweeps and hearth professionals, it is our duty to educate consumers and support manufacturers that will be providing the repair parts we need.

Related Item

First Revision No. 5-NFPA 211-2014 [Section No. 3.3.68]


Submitter Full Name: Steven Lantry

Organization: Mid Carolina Chimney Service

Street Address:

City:

State:

Zip:

Submittal Date: Wed Nov 12 10:53:37 EST 2014


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Public Comment No. 91-NFPA 211-2014 [ Section No. 3.3.2 ]

3.3.2 Accessories. Accessory. Supplementary part or device added to an appliance in order to make itmore useful, versatile, attractive, etc.

3.3.2.1 * Factory-Built Fireplace System Accessories.

Accessories intended for field installation into or attachment to factory-built fireplace systems fireplaces .

3.3.2.2 * Masonry Fireplace and Chimney Accessories.

Accessories intended for field installation into or attachment to masonry fireplaces or chimneys .


Adding a definition of the term "accessory" is needed as part of a solution to confusion surrounding proposed changes regarding fireplace accessories (something added for enhancement as defined here) and components (defined in my Public Comment 78 [New Section after 3.3.14.2] as a constituent part of a hearth appliance or chimney subject to safety testing and listing). In addition, the proposed definitions here of factory-built and masonry fireplace accessories both incorrectly imply that there are accessories that can be added to chimneys. Removing the word "systems" from 3.3.2.1 and "or chimneys" from 3.3.2.2 leaves the definitions correctly applicable to the firebox of each type of fireplace.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 78-NFPA 211-2014 [New Section after 3.3.14.2]

Related Item




Submitter Full Name: Benjamin Weathersby

Organization: Hearth, Patio & Barbecue Association

Affilliation: Hearth, Patio & Barbecue Association

Street Address:

City:

State:

Zip:

Submittal Date: Thu Nov 13 09:53:25 EST 2014


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Public Comment No. 108-NFPA 211-2014 [ Section No. 3.3.2.1 ]

3.3.2.1* Factory-Built Fireplace System Accessories.

Accessories intended for field installation into or attachment to factory-built fireplace systems fireplaces .


UL 127 is the Standard for testing and approval of Factory Built Fireplaces. Nowhere is the word “System” used, neither is “System” a common industry term in relation to fireplaces. Casual word usage and coining terminology will likely lead to confusion among the users of NFPA 211. Moreover, high efficiency Factory-Built fireplaces, which are tested for use with a variety of chimney products, would fall outside the general classification of a “system.”



Public Comment No. 109-NFPA 211-2014 [Section No. 11.1.5]

Related Item



Submitter Full Name: Charles R. Brewster, Jr.

Organization: Accent Sales and Marketing

Street Address:

City:

State:

Zip:

Submittal Date: Fri Nov 14 10:51:32 EST 2014


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Accessories intended for field installation into or attachment to factory-built fireplace systems.


opposed to any change in the language because there is no field data nor documentation that supports these changes. Additionally, the CSIA has conducted testing on aftermarket parts and found no safety hazards noted. In fact, one test LOWERED the exterior temperatures.

Related Item



Submitter Full Name: Jeremy biswell

Organization: [ Not Specified ]

Affilliation: president of national chimney sweep guild

Street Address:

City:

State:

Zip:



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Accessories intended for field installation into or attachment to factory-built fireplace systems. Thisdefinition does not include Vented Gas Log Decorative Appliances and Vent-free Gas Log Heaters.


The biggest issue with this and other NFPA 211-2014 changes is that they are “solutions” in search of a problem. Factory-Built fireplaces, designed, tested and listed to UL127, are designed to a very high heat standard so as to be safe for burning wood, which is an uncontrolled, albeit contained, fire, with wide swings in intensity during the life of a fire (kindling, building the fire to be roaring, dying down, restoking to a roar, process repeated many times). Both Vented Decorative Gas Logs and Vent-Free Gas Log Heaters are controllable fires burned at much, much less intensity than wood fires. This has led to the hearth industry’s rule of thumb “if it is safe to burn wood, it is safe to burn a gas log.” Accordingly, any restrictions on gas burning appliances used inside of woodburning fireplaces are unnecessary, overly restrictive and restraints to commerce and business.

Related Item



Submitter Full Name: Constance Maier

Organization: Hearth and Home Shoppe, Mechanicsville, VA

Street Address:

City:

State:

Zip:



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No credible evidence of the need for drastic changes putting undue financial burden on the consumer with no documentation of a safety issue or fire hazard. The proposed new definition includes shrouds, glass or screen doors, grates, blowers, log lighters, gas logs and caps.

Related Item



Submitter Full Name: JAMES TASSO

Organization: TASSO CHIMNEY SWEEP

Street Address:

City:

State:

Zip:

Submittal Date: Thu Oct 09 09:57:03 EDT 2014


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The biggest issue with this and other NFPA 211-2014 changes is that they are "solutions" in search of a problem. Factory-Built fireplaces, designed, tested and listed to UL127, are designed to a very high heat standard so as to be safe for burning wood, which is an uncontrolled, albeit contained, fire, with wide swings in intensity during the life of a fire (kindling, building the fire to be roaring, dying down, restoking to a roar, process repeated many times). Both Vented Decorative Gas Logs and Vent-Free Gas Log Heaters are controllable fires burned at much, much less intensity than wood fires. This has led to the hearth industry's rule of thumb "if it is safe to burn wood, it is safe to burn a gas log." Accordingly, any restrictions on gas burning appliances used inside of woodburning fireplaces are unnecessary, overly restrictive and restraints to commerce and business.

Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. We have never, ever been sued for a fire caused by our gas log sets. In today's litigious society, we would be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never happened. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.

Related Item



Submitter Full Name: Rett Rasmussen

Organization: Rasmussen Gas Logs & Grills

Street Address:

City:

State:

Zip:



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The proposed new text is broad and overreaching when viewed in context with the related annex note. The proposed new definition (3.3.2.1) for accessories includes shrouds, glass or screen doors, grates, blowers, log lighters, gas logs, and caps. The proposed change to Section 11.1.5 requires that accessories be specifically listed or approved by the AHJ. Since these items are generally not listed for the specific model of fireplace then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think that the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. There is a long standing history of after market parts and there was no credible evidence presented that the use of after market parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers. There are many brands and models of fireplaces where OEM parts are no longer available so the consumer is forced with spending thousands of dollars for a new fireplace simply because they need a cap or grate. AHJ’s are not going to give approval and service techs/installers are going to look and sound like crooks when they try to sell a new fireplace simply because the current fireplace needs a new cap or grate. Another concern here is the inclusion of “gas log decorative appliances” in the definition. Under these proposed new requirements gas logs will now have to be specifically listed for each model of fireplace they are to be installed in. Gas logs are tested under a separate standard but they are not tested for each model of fireplace that they may be installed in, and there is no evidence to suggest that this should now be required. Where is the evidence to suggest these proposed changes are necessary. Code writers should not create costly new requirements unless there is a proven safety problem that needs to be addressed. How will insurance companies respond when presented with an expensive bill to replace an entire fireplace & chimney system simply because a sudden occurrence like a hurricane blew the chimney cap off an otherwise serviceable system?

Related Item



Submitter Full Name: James Brewer

Organization: Magic Sweep Corporation

Affilliation: National Chimney Sweep Guild

Street Address:

City:

State:

Zip:



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Accessories intended for field installation into or attachment to factory-built fireplace systemsI feel this restritiv language should not be added to the 211 standard, this is based upon my experience in thefield as an installer, inspector, maintenance person or as an expert witness. To date I have seen no data ordocumentation that provides that this code change is a needed provision. I feel that this does not add anymeasure of safety to consumers as it does not assist in the most common cuses of incidents realted to thiswhich would included failure to follow manufactuter's installation instructions most specifically in regards theclearances as stated in the manuals provided with the units, I do not see this provision in any way loweringfire and incident risks .


It is my belief based on my industry experience that this change to the standard is unneeded and has not data to support the need.



Public Comment No. 74-NFPA 211-2014 [Section No. 11.1.5]

Related Item



Submitter Full Name: jerry isenhour

Organization: CVC Coaching

Street Address:

City:

State:

Zip:



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Accessories intended for field installation into or attachment to masonry fireplaces or chimneys.


no additions necessary. no changes nor additions needed to current language.

Related Item





Affilliation: president ncsg

Street Address:

City:

State:

Zip:



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Accessories intended for field installation into or attachment to masonry fireplaces or chimneys. Thisdefinition does not include Vented Gas Log Decorative Appliances and Vent-free Gas Log Heaters.


The biggest issue with this and other NFPA 211-2014 changes is that they are “solutions” in search of a problem. Masonry fireplaces, are made of non-combustible materials and are designed to a very high heat standard so as to be safe for burning wood, which is an uncontrolled, albeit contained, fire, with wide swings in intensity during the life of a fire (kindling, building the fire to be roaring, dying down, restoking to a roar, process repeated many times). Both Vented Decorative Gas Logs and Vent-Free Gas Log Heaters are controllable fires burned at much, much less intensity than wood fires. This has led to the hearth industry’s rule of thumb “if it is safe to burn wood, it is safe to burn a gas log.” Accordingly, any restrictions on gas burning appliances used inside of woodburning fireplaces are unnecessary, overly restrictive and restraints to commerce and business.

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3.3.2.2* Masonry Fireplace and Chimney Accessories.

Accessories intended for field installation into or attachment to masonry fireplaces or chimneys. Thisdefinition does not include Vented Gas Log Decorative Appliances and Vent-free Gas Log Heaters.


The biggest issue with this and other NFPA 211-2014 changes is that they are "solutions" in search of a problem. Masonry fireplaces, are made of non-combustible materials and are designed to a very high heat standard so as to be safe for burning wood, which is an uncontrolled, albeit contained, fire, with wide swings in intensity during the life of a fire (kindling, building the fire to be roaring, dying down, restoking to a roar, process repeated many times). Both Vented Decorative Gas Logs and Vent-Free Gas Log Heaters are controllable fires burned at much, much less intensity than wood fires. This has led to the hearth industry's rule of thumb "if it is safe to burn wood, it is safe to burn a gas log." Accordingly, any restrictions on gas burning appliances used inside of woodburning fireplaces are unnecessary, overly restrictive and restraints to commerce and business.

Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. We have never, ever been sued for a fire caused by our gas log sets. In today's litigious society, we would be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never happened. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.

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3.3.2.2 * Masonry Fireplace and Chimney Fireplace Accessories.

Accessories intended for field installation into or attachment to existing masonry fireplaces or chimneys. . These include such items as heat exchangers, door assemblies, tubular grates, and blowers.


This change is not needed, and the expanded coverage of the Annex text creates sweeping new requirements that will require basically all items added to a masonry fireplace to be listed or approved by the AHJ. There was no justification provided that these changes are necessary to insure public safety.

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3.3.2.2* Masonry Fireplace and Chimney Accessories.

Accessories Heat exchanging accessories intended for field installation into or attachment to masonryfireplaces or chimneys such as tubular air grates and fan powered heat exchangers .


This portion of the standard is overly restrictive and burdensome. Most masonry site built fireplaces are built to "code", not tested and listed. This section implies that all accessories for masonry fireplaces ( doors, screens, log grates, ash dumps, dampers and air supply mechanisms) can be listed to a standard that will comply with the fireplace listing. They can not. Certain fireplace accessories such as heat exchangers and tubular air circulation grates can be listed to UL 907 for use in a masonry fireplace and therefore should be the only accessories that must be listed for use. The only documented testing I have seen done with a masonry fireplace is the testing completed in 1994 by the Canadian Mortgage and Housing Corporation " The Effects Of Glass Doors On Masonry Fireplace Spillage and Surface Temperatures". This protocol did not test other products for use with the fireplace only the effect glass doors had on spillage and temperature. In summary the test had only minimal effect on the temperature of buried members with the addition of glass doors, either sealed or not.

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Submitter Full Name: Gary Wilkening

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Public Comment No. 79-NFPA 211-2014 [ Chapter 11 ]

Chapter 11 Fireplaces 11.1 Factory-Built Fireplaces.

11.1.1

Factory-built fireplaces shall be listed and installed in accordance with the terms of the listing and themanufacturer’s instructions.

11.1. 2

Hearth extensions shall be provided in accordance with the manufacturer’s instructions or be of masonry onnoncombustible construction in accordance with Section 11 12 .3 .

11.1. 3

Factory-built fireplaces shall be secured to the floor or structural framing of the building in order to preventshifting.

11.1. 4

Only listed decorative shrouds at the termination of a factory-built fireplace chimney shall be permitted.

11.

1.5

5 Combustion air ducts for factory-built fireplaces shall be a listed component of the fireplace and installedaccording to the manufacturer's instructions.

11.6

Factory-built fireplace system accessories shall be one of the following:

(1) Listed for use with the specific factory-built fireplace fireplaces and installed in accordance with theterms of their listing

(2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’sinstallation instructions

11.2 * Chapter 12. Masonry Fireplaces.

11 12 .2. 1 Construction.

11 12 .2. 1.1

Fireplaces shall be constructed of solid masonry units or of reinforced Portland or refractory cementconcrete.

11 12 .2 .1.2

Masonry fireplaces shall be supported on foundations of one of the following:

(1) Masonry

(2) Reinforced Portland cement concrete

(3) Refractory cement concrete

(4) Other noncombustible construction having a fire resistance rating of not less than 3 hours, providedsuch supports are adequate for the load

11 12 .2. 1.2.1

Footings for masonry fireplaces and their chimneys shall be constructed of concrete or solid masonry atleast 12 in. (305 mm) thick and shall extend at least 6 in. (152 mm) beyond the face of the fireplace orfoundation wall on all sides.

11 12 .2. 1.2.2

Footings shall be founded on natural undisturbed earth or engineered fill below frost depth.

11 12 .2. 1.2.3

In areas not subject to freezing, footings shall be at least 12 in. (305 mm) below finished grade.

11 12 .2. 1.3

The firebox of a concrete or masonry fireplace shall have a minimum depth of 20 in. (508 mm).

11 12 .2. 1.3.1

The throat shall not be less than 8 in. (203 mm) above the fireplace opening.


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11 12 .2. 1.3.2

The throat opening shall not be less than 4 in. (102 mm) in depth.

11 12 .2. 1.3.3

The cross-sectional area of the passageway above the firebox, including the throat, damper, and smokechamber, shall not be less than the cross-sectional area of the flue.

11 12 .2. 1.3.4

Rumford fireplaces shall be permitted, provided that the depth of the fireplace is at least 12 in. (305 mm)and at least one-third the width of the fireplace opening, and the throat is at least 12 in. (305 mm) above thelintel and at least one-twentieth the cross-sectional area of the fireplace opening.

11 12 .2. 1.4

Where a lining of low-duty fireclay brick (ASTM C27, Standard Classification of Fireclay and High-AluminaRefractory Brick), firebox brick (ASTM C1261, Standard Specification for Firebox Brick for ResidentialFireplaces), or the equivalent, at least 2 in. (51 mm) thick laid in medium-duty refractory mortar (ASTMC199, Standard Test Method for Pier Test for Refractory Mortars), or the equivalent, or other approvedlining is provided, the total thickness of back and sides, including the lining, shall be not less than 8 in. (203mm).

11 12 .2. 1.5

All joints and intersections between the hearth extension/fireplace facing and the fire chamber (firebox)shall be fully sealed with medium-duty refractory mortar (ASTM C199, Standard Test Method for Pier Testfor Refractory Mortars). Gaps or voids at supporting lintels and joints between steel fireplace units and thefireplace face or between the frames of dampers and the fireplace face shall be sealed with the samematerial or with a high-temperature [2000°F (1093°C) service rating] insulating mortar.

11 12 .2. 1.6

Where the lining described in 11.2.1.4 is not provided, the thickness of the back and sides of the fireplaceshall be not less than 12 in. (305 mm).

11 12 .2. 1.7

Where the masonry supporting a fireplace is designed to support vertical loads from the building andcorbels are used to support beams or girders, corbeling shall be in accordance with 7.1.2 for masonrychimneys.

11 112 .2. 1.8

Masonry over a fireplace opening shall be supported by a lintel of noncombustible material.

11 12 .2. 1.8.1

The minimum required bearing length on each end of the fireplace opening shall be a nominal 4 in. (102mm).

11 12 .2. 1.8.2

The fireplace throat or damper shall be located a minimum of 8 in. (203 mm) above the top of the fireplaceopening.

11 12 .2. 1.9

Where a lining of low-duty fireclay brick (ASTM C27, Standard Classification of Fireclay and High-AluminaRefractory Brick), firebox brick (ASTM C1261, Standard Specification for Firebox Brick for ResidentialFireplaces), or the equivalent, at least 2 in. (51 mm) thick laid in medium-duty refractory mortar (ASTMC199, Standard Test Method for Pier Test for Refractory Mortars), or the equivalent, or other approvedlining is provided, the total thickness of the smoke chamber walls, including the lining, shall be not less than6 in. (152 mm).

11 12 .2. 1.10

Where unlined, the smoke chamber wall thickness shall be not less than 8 in. (203 mm).

11 12 .2. 1.11

The smoke chamber height shall not be greater than the inside width of the fireplace room opening.


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11 12 .2. 1.12

The smoke chamber depth shall not be greater than the depth of the fireplace fire chamber. (See Figure11.2.1.12.)

Figure 11 Figure 12 .2. 1.12 Sectional View of Fireplace Showing Smoke Chamber.

11 12 .2. 1.13

The inner surfaces of the smoke chamber shall be parge coated smooth, with an insulating refractorymortar, and not inclined more than 45 degrees from vertical.

11 12 .2. 1.14

Masonry fireplaces shall be provided with chimneys designed and constructed in compliance with one ofthe following:

(1) In accordance with the requirements for construction of masonry chimneys (See Section 7.2.)

(2) Where permitted by the individual listing, with approved factory-built chimneys having approvedadapters in accordance with the requirements for factory-built chimneys (See Chapter 5.)

11 12 .2. 1.15 Hearth Thickness.

The minimum thickness of fireplace hearths shall be 4 in. (102 mm).

11 12 .2.2 Seismic Reinforcing.

11 12 .2.2. 1

Reinforcement shall not be required in Seismic Design Category A, B, or C.

11 12 .2.2.2

In structures of Seismic Design Category D, fireplaces with chimneys up to 40 in. (1016 mm) wide, four No.4 continuous vertical bars, anchored in the foundation, shall be placed in the concrete, between wythes ofsolid masonry or within the cells of hollow unit masonry and grouted in accordance with ASTM C476,Standard Specification for Grout for Masonry.

11 12 .2.2.2. 1

For fireplaces with chimneys greater than 40 in. (1016 mm) wide, two additional No. 4 vertical bars shall beprovided for each additional 40 in. (1016 mm) in width or fraction thereof.

11 12 .2.2.2.2

Vertical reinforcement shall be placed enclosed within 1⁄4 in. (6.4 mm) ties or other reinforcing of equivalentnet cross-sectional area, spaced not to exceed 18 in. (457 mm) on center in concrete, or placed in the bedjoints of unit masonry at a minimum of every 18 in. (457 mm) of vertical height.

11 12 .2.2.2. 3

Two such ties shall be provided at each bend in the vertical bars.

11 12 .2.2.2. 4

In structures of Seismic Design Category E or F, masonry and concrete chimneys shall be reinforced inaccordance with the requirements of Sections 43.1 through 43.8 of NFPA 5000.

11 12 .2. 3 Seismic Anchorage.

11 12 .2. 3.1

Seismic anchorage shall not be required in Seismic Design Category A, B, or C.


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11 12 .2. 3.2

In structures of Seismic Category D, masonry and concrete chimneys shall be anchored at each floor,ceiling, or roof line more than 6 ft (1.8 m) above grade except where constructed completely within theexterior walls.

11 12 .2. 3.3

Two 3⁄16 in. by 1 in. (4.8 mm by 25 mm) straps shall be embedded a minimum of 12 in. (305 mm) into thechimney.

11 12 .2. 3.3.1

Straps shall be hooked around the outer bars and extend 6 in. (152 mm) beyond the bend.

11 12 .2. 3.3.2

Each strap shall be fastened to a minimum of four floor joists with two 1⁄2 in. (12.7 mm) bolts.

11 12 .2.4 Steel Fireplace Units.

11 12 .2.4.1

Steel fireplace units incorporating a firebox liner of not less than 1⁄4 in. (6.4 mm) thick steel and an airchamber shall be installed with masonry to provide a total thickness at the back and sides of not less than 8in. (203 mm), not less than 4 in. (102 mm) of which shall be solid masonry.

11 12 .2.4.2

Listed firebox liners shall be installed in accordance with the terms of the listing.

11 12 .2.4.3

Warm-air ducts employed with steel fireplace units of the circulating air type shall be constructed of metal ormasonry.

11 12 .2.5 Clearance.

11 12 .2.5.1

All wood beams, joists, studs, and other combustible material shall have a clearance to masonry fireplacesas follows:

(1) Not less than 2 in. (51 mm) from the front faces and sides

(2) Not less than 4 in. (102 mm) from the back faces of masonry fireplaces (See Figure 11.2.5.1.)

Figure 11 Figure 12 .2.5.1 Fireplace Clearance to Combustible Material.

11 12 .2.5.2

Spaces between headers or trimmers of combustible material and masonry fireplaces shall be firestoppedwith one of the following noncombustible materials:

(1) Galvanized steel not less than 26 gauge [0.019 in. (0.483 mm)] in thickness

(2) Noncombustible sheet material not more than 1⁄2 in. (12.7 mm) thick

11 12 .2.5.3

Woodwork, such as wood trim, mantels, and other combustible material, shall not be placed within 6 in.(152 mm) of a fireplace opening.


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11 12 .2.5.4

Combustible material above and projecting more than 1 1⁄2 in. (38 mm) from a fireplace opening shall not beplaced less than 12 in. (305 mm) from the top of the fireplace opening. (See Figure 11.2.5.4.)

Figure 11 Figure 12 .2.5.4 Fireplace Clearance to Combustible Material.

11 12 .2.6 Accessibility.

For cleaning purposes, means shall be provided for access to the venting area above and immediatelybehind any movable damper valve plate in masonry fireplaces and steel fireplace units by one of thefollowing methods:

(1) A damper plate that can be removed with common hand tools

(2) A cleanout opening located to provide access to the smoke chamber area

11 12 .2.7 Cleanout Openings.

Cleanout openings shall be equipped with ferrous metal, stainless steel, precast cement, or other approvednoncombustible doors and frames arranged to remain tightly closed and secured when not in use.

11 12 .2.8 Ash Dumps.

Cleanouts, if provided, shall be accessible and located so that ash removal will not create a hazard tocombustible materials.

11 12 .2.9 Dampers.

11 12 .2.9.1

Masonry fireplaces shall be equipped with a ferrous metal damper located at least 8 in. (203 mm) above thetop of the fireplace opening.

11 12 .2.9.2

Dampers shall be installed in the fireplace or at the top of the flue venting the fireplace and shall beoperable from the room containing the fireplace.

11 12 .2.9.3

A nonferrous metal damper shall be permitted to be installed at the top of the flue specified in 11.2.9.2.

11 12 .2.9.4

Damper controls shall be permitted to be located in the fireplace.

11 12 .2.10* Masonry Fireplace Accessories.

Fireplace accessories shall be one of the following:

(1) Listed and installed in accordance with the terms of their listing

(2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer'sinstallation instructions

11 12 .3 Hearth Extensions.

11 12 .3.1

Masonry fireplaces shall have hearth extensions of brick, concrete, stone, tile, or other approvednoncombustible material wholly supported by and integral with the chimney structure, and a minimum 4 in.(102 mm) clearance shall be maintained directly below the underside.


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11 12 .3.1.1

Support for the hearth shall be provided by a structural slab or corbeled brickwork.

11 12 .3.1.2

Wooden forms used during the construction of the hearth and hearth extension shall be removed when theconstruction is completed.

11 123 .3. 2

The minimum thickness of the hearth extension shall be 2 in. (51 mm).

11 12 .3.3

Where the fireplace opening is less than 6 ft2 (0.56 m2), the hearth extension shall extend as follows:

(1) At least 16 in. (406 mm) in front of the facing material

(2) At least 8 in. (203 mm) beyond each side of the fireplace opening (See Figure 11.3.3.)

Figure 11 Figure 12 .3.3 Fireplace Hearth Extension Requirements.

11 12 .3.4

Where the fireplace opening is 6 ft2 (0.56 m2) or larger, the hearth extension shall extend as follows:

(1) At least 20 in. (508 mm) in front of the facing material

(2) At least 12 in. (305 mm) beyond each side of the fireplace opening (See Figure 11.3.3.)

11 12 .3.5

Where a fireplace is elevated above or overhangs a floor, the hearth extension also shall extend over thearea under the fireplace.

11 12 .4 Combustion Air Ducts.

11 12 .4.1

Where installed, combustion air ducts shall be installed in accordance with this section.

11 12 .4.1.1

Combustion air ducts for factory-built fireplaces shall be a listed component of the fireplace and installedaccording to the manufacturer’s instructions.

11.4.1.2

Listed combustion air duct systems for masonry fireplaces shall be installed according to the terms of theirlisting and the manufacturers’ instructions.

11 12 .4.2

Combustion air ducts shall extend as directly as practicable from the outdoors (inlet) to a terminationoutside the fire chamber (outlet).


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11 12 .4.3

Combustion air ducts shall be constructed of one of the following:

(1) Masonry

(2) Galvanized steel with a thickness not less than 26 gauge [0.019 in. (0.483 mm)]

(3) Other approved noncombustible material

11 12 .4.4

Combustion air ducts shall be equipped with a damper that is capable of being fully closed.

11 12 .4.5

Combustion air ducts that terminate outside the fire chamber but within 6 in. (152 mm) of the fire chambershall be designed and installed to prevent the direct entry of flame, embers, or ashes from the fire chamberinto the duct.

11 12 .4.6

Unlisted combustion air ducts shall be installed with a minimum 1 in. (25 mm) clearance to combustibles forall parts of the duct construction within 5 ft (1.53 m) of the duct outlet.

11 12 .4.7

The exterior inlet of the combustion air duct shall be screened.

11 12 .4.8

Combustion air ducts shall not originate in any of the following:

(1) Attic

(2) Basement

(3) Garage

(4) Other interior space


The first proposed change here is to divide the current Chapter 11 Fireplaces into two chapters: Chapter 11 Factory-Built Fireplaces and Chapter 12 Masonry Fireplaces. This will not only make the distinctions between the requirements for these two types of fireplace clearer and less likely to misinterpretation, this organizational change will be consistent with the treatment of chimney types in the Standard (Chapter 6 Factory-Built Chimneys and Chimney Units; Chapter 7 Masonry Chimneys; and Chapter 8 Unlisted Metal Chimneys for Nonresidential Applications). This rearrangement also addresses (and improves) part of the purpose originally proposed earlier this year regarding the separation of accessories for masonry and factory-built fireplaces.

Additional proposed revisions:Re-numbering of Chapters and Sections (will also call for re-numbering of subsequent chapters if adopted).

Move and re-number current 11.2 Masonry Fireplaces and current 11.3 Hearth Extensions in their entirety to a new Chapter 12 Masonry Fireplaces for clearer distinctions and increased clarity regarding requirements for the two types of fireplaces.

Move and re-number all of 11.4 Combustion Air Ducts EXCEPT 11.4.1.1 to new Chapter 12 for clearer distinctions and increased clarity regarding requirements for the two types of fireplaces.

Retain and re-number 11.4.1.1 as 11.5 Combustion Air Ducts for clearer distinctions and increased clarity regarding requirements for the two types of fireplaces.

Delete “the specific” and change “fireplace” to “fireplaces” as part of the distinction between accessories and chimneys being suggested in Public Comments 77 (3.3.2), 80 (14.7.1.1 and 2) and 81 (A.3.2.2). To my knowledge, accessories (as defined in my proposals) are not tested and listed for use with specific fireplaces. Components, which are part of testing and listing are covered in the revision in the Maintenance chapter (14.7.1)

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Submittal Date: Tue Nov 11 08:30:38 EST 2014


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Public Comment No. 90-NFPA 211-2014 [ New Section after 11.1.5 ]

Public Comment No. 90 - NFPA 211 - 2014 [Section No. 11.1.5]

Thermo-Rite Manufacturing has been making Glass Fireplace Doors since 1942. We have madethousands of doors for Factory-Built Fireplaces whose original company had gone out of business. In the1980's and 1990's, we had many of our units UL tested on every Factor-Built Fireplace System to ensurethat our Glass Fireplace Doors did not compromise the performance of the original factory-built fireplacesystem.

Thomas Stroud very accurately responded to this matter. See First Revision No. 11 - NFPA 211-2014[Section No. 11.1]

NFPA's proposal would eliminate good viable suppliers of many products, as well as the knowledgeableexperts who work in the field every day installing these products.


General Comments:

Thermo-Rite Manufacturing is the oldest Glass Fireplace Door Manufacturing Company in the United States of America. It was founded in 1942 in Akron, Ohio. The company has been a leading innovator in this segment of the Hearth Products Industry.

Thermo-Rite's patents started in 1946 and ran through 1963.

We created many Zero Clearance Doors for Factory-Built Fire Boxes (many of these companies are no longer in the business) and we have manufactured several thousand Glass Fireplace Doors for these units.

Some of these proposed changes will serve to cause problems for the homeowners who are trying to safely maintain their fireplace units.

Respectfully submitted.

Roy K. AllenChairman & CEO

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Submitter Full Name: ROY ALLEN

Organization: THERMO RITE MFG

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11.1.5


(1) Listed for use with the specific factory-built fireplace and installed in accordance with the terms oftheir listing



I do not feel the public or the industry needs to be burdened with this change. It will not make the public safer because the 'problems' in the past with unlisted parts were done by both homeowners and repair persons that would not follow NFPA 211 anyway. There are plenty of manufacturers that know how to make proper replacement parts for factory built fireplace and are willing to accept the burden of liability with this. And there are plenty of qualified service people that understand the requirements of these units.

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Public Input No. 1-NFPA 211-2013 [Global Input]


Submitter Full Name: just balume

Organization: Blume, The Merry Sweep

Affilliation: NCSG, CSIA, SCCSG, SEHPBSA

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11.1.5



(2) Designed and approved for use with Factory-Built fireplaces



Strike the word “system” as stated in comments relating to section 3.3.2.2. UL 127 is the Standard for Factory-Built Fireplaces and has no mention of “fireplace system.”

The word “accessories” is problematic. An item that is tested and approved (“listed” in NFPA terminology) for use with a Factory-Built fireplace would better be classified as a “component” not an accessory.

It should be noted that products can be tested and approved to UL Standards and not be “listed.” Listing is an optional, for pay service provided by testing laboratories.

The word “Specific” is unnecessary and redundant with the language “according to the terms of their listing.” If NFPA is trying to make a point it needs to be better defined.

Aftermarket products are made to replace OEM parts for fireplaces that are no longer supported by the manufacturer, or that were produced by manufacturers who are no longer in business. They serve a vital function in providing parts to keep Factory-Built fireplaces in safe operating condition. These parts are manufactured to replicate the properties of the OEM part. In most, if not all, cases the aftermarket products are better made than those OEM parts that were made for price. Limiting “accessories”, “components”, “parts”, and the like to those “listed” components fails to recognize the millions of Factory-Built fireplaces that are installed in the field but are no longer supported by a manufacturer. In some cases (for instance a specialized chimney cap that is designed to mitigate a down drafting condition) use of an aftermarket product can result in a safer installation and, perhaps, improved indoor air quality. It is not economically viable for aftermarket manufacturers to test their products to every individual Factory-Built fireplace model and no generic standards exist at this time. For NFPA to require components to be “listed”, while theoretically correct, places specialized aftermarket products in a very grey area. NFPA does allow for the AHJ to approve use of a product but that places a considerable liability on an individual who is likely poorly equipped to make such a determination.



Public Comment No. 108-NFPA 211-2014 [Section No. 3.3.2.1]

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11.1.5





disagree with changes. no evidence or proof of problems. Recommend no changes

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11.1.5


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November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471

Regarding: HPBA Pacific Comments to NFPA 211

The Hearth, Patio & Barbecue Association, Pacific Affiliate (HPBAP) is a not-for-profit trade associationthat represents and promotes the interests of the hearth products industry regionally in California, Nevadaand Hawaii. HPBA is also a not-for-profit trade association which represents manufacturers across NorthAmerica. The regional affiliate represents California entities that include retailers and service companies.

In regards to: Section 11.1.5 adds new requirements for factory-built fireplace system accessoriesas follows:

11.1.5 Factory-built fireplace system accessories shall be one of the following:

(1) Listed for use with the specific factory-built fireplace and installed in accordance with the terms of theirlisting.

(2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’s installationinstructions.

HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gas fireplace logsresult in listings that allow for installation in listed or masonry wood burning fireplaces on a generic (notfireplace model specific) basis. Having only listed and approved gas log sets in these fireplaces wouldimpact gas log sales significantly. There are thousands of gas logs and hundreds of existing factory builtfireplaces, many that are not in current production - it would be impossible for gas log manufacturers tomeet this requirement. Elimination of this option to install gas logs into existing factory built fireplaces fliesdirectly in the face of Air Quality Districts who are promoting these upgrades to minimize wood burning andimprove air quality.

In regards to: Section 14.7.1.1 and 14.7.1.2 add the following new requirements to the maintenancechapter.

14.7.1.1 Only listed or approved components and accessories tested for use with the specific model offactory-built chimney shall be permitted.

14.7.1.2 Only listed or approved components or accessories for use with the specific model of factory-builtfireplace system shall be permitted.

-HPBA Pacific strongly disagrees with these new requirements. The majority of existing factory builtfireplaces were built by manufacturers who are no longer in business and if they are in business they oftendo not supply parts for these models. Limiting repairs and fixes on minor parts like refractory panels,grates, log lighters, caps, glass doors etc. and asking installers to deem the fireplace un-useable becauseof one minor faulty part is condemnable to say the least. For decades now, professional chimney sweepsand installers have replaced worn parts and maintained the safety of the appliance without having toreplace the entire fireplace. Taking this option away from consumers makes no sense. The cost to ahomeowner to remove and replace a fireplace is extremely high. In most homes in California the fireplacewould need to be a Direct vent gas or EPA certified wood burning fireplace costing homeowners thousandsof dollars.

Over the past 20 years, many fireplace manufacturers have gone out of business, or have been acquiredby other manufacturers who do not support the prior models. Aftermarket products have been used foryears with success when it comes to hard to find or out of business fireplace manufacturers. Taking thiscost effective change away from consumers is short-sighted and unjust to consumers.

We believe that if UL tested and listed aftermarket parts are available then they should be allowed as theymeet the testing standard.

Thank you,


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HPBA Pacific, Board of Directors

Tom Karow, Woodstove & Sun

Bill Lentz, Pugh & Associates

Bill Harris, Mason Lite Industries

Amie Ryan, Ryan Brothers Chimney Sweeping

Bil Orlando, Jotul

Peter Ross, Home & Hearth

Gabe Cottle, West End Brick N Fire

Mike Fletcher, Burntech Fireplace Solutions

Patrick Nuno, Quality Fireplace

Mario Allen, Associated Energy Systems

HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren


In regards to: Section 11.1.5 adds new requirements for factory-built fireplace system accessories as follows:

11.1.5 Factory-built fireplace system accessories shall be one of the following: (1) Listed for use with the specific factory-built fireplace and installed in accordance with the terms of their listing. (2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’s installation instructions.

HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gas fireplace logs result in listings that allow for installation in listed or masonry wood burning fireplaces on a generic (not fireplace model specific) basis. Having only listed and approved gas log sets in these fireplaces would impact gas log sales significantly. There are thousands of gas logs and hundreds of existing factory built fireplaces, many that are not in current production - it would be impossible for gas log manufacturers to meet this requirement. Elimination of this option to install gas logs into existing factory built fireplaces flies directly in the face of Air Quality Districts who are promoting these upgrades to minimize wood burning and improve air quality.

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Submitter Full Name: Kaity Rosengren

Organization: HPBA Pacific

Affilliation: HPBA Pacific

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City:

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11.1.5




November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471


The Hearth, Patio & Barbecue Association, Pacific Affiliate (HPBAP) is a not-for-profit trade association thatrepresents and promotes the interests of the hearth products industry regionally in California, Nevada andHawaii. HPBA is also a not-for-profit trade association which represents manufacturers across NorthAmerica. The regional affiliate represents California entities that include retailers and service companies.

In regards to: Section 11.1.5 adds new requirements for factory-built fireplace system accessories asfollows:




HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gas fireplace logsresult in listings that allow for installation in listed or masonry wood burning fireplaces on a generic (notfireplace model specific) basis. Having only listed and approved gas log sets in these fireplaces wouldimpact gas log sales significantly. There are thousands of gas logs and hundreds of existing factory builtfireplaces, many that are not in current production - it would be impossible for gas log manufacturers to meetthis requirement. Elimination of this option to install gas logs into existing factory built fireplaces flies directlyin the face of Air Quality Districts who are promoting these upgrades to minimize wood burning and improveair quality.




-HPBA Pacific strongly disagrees with these new requirements. The majority of existing factory builtfireplaces were built by manufacturers who are no longer in business and if they are in business they oftendo not supply parts for these models. Limiting repairs and fixes on minor parts like refractory panels, grates,log lighters, caps, glass doors etc. and asking installers to deem the fireplace un-useable because of oneminor faulty part is condemnable to say the least. For decades now, professional chimney sweeps andinstallers have replaced worn parts and maintained the safety of the appliance without having to replace theentire fireplace. Taking this option away from consumers makes no sense. The cost to a homeowner toremove and replace a fireplace is extremely high. In most homes in California the fireplace would need to bea Direct vent gas or EPA certified wood burning fireplace costing homeowners thousands of dollars.

Over the past 20 years, many fireplace manufacturers have gone out of business, or have been acquired byother manufacturers who do not support the prior models. Aftermarket products have been used for years


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with success when it comes to hard to find or out of business fireplace manufacturers. Taking this costeffective change away from consumers is short-sighted and unjust to consumers.


Thank you,






Bil Orlando, Jotul






HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren


In regards to: Section 11.1.5 adds new requirements for factory-built fireplace system accessories as follows:

11.1.5 Factory-built fireplace system accessories shall be one of the following: (1) Listed for use with the specific factory-built fireplace and installed in accordance with the terms of their listing. (2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’s installation instructions.

HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gas fireplace logs result in listings that allow for installation in listed or masonry wood burning fireplaces on a generic (not fireplace model specific) basis. Having only listed and approved gas log sets in these fireplaces would impact gas log sales significantly. There are thousands of gas logs and hundreds of existing factory built fireplaces, many that are not in current production - it would be impossible for gas log manufacturers to meet this requirement. Elimination of this option to install gas logs into existing factory built fireplaces flies directly in the face of Air Quality Districts who are promoting these upgrades to minimize wood burning and improve air quality.

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No credible evidence of the need for drastic changes putting undue financial burden on the consumer with no documentation of a safety issue or fire hazard.

11.1.5 requires accessories be specifically listed or approved by the AHJ.

Since these items are generally note listed for the specific model or fireplace, then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. In many areas there are no AHJs to review or approve of the installations.

There is a long standing history of aftermarket parts and there was no credible evidence presented that the use of aftermarket parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers.

There are many brands and models of fireplaces where OEM parts are no longer available so the consumer is forced to spend thousands of dollars for a new fireplace simply because they need a cap or grate.

AHJs are not going to give approval and service techs or installers are going to look and sound like crooks when they try to sell a new fireplace simply because the current fireplace needs a new cap or grate.

Another concern is the inclusion of "gas log decorative appliances" in the defintion. Under these proposed new requirements gas logs will now have to be specifically listed for each model of fireplace in which to be installed.

These proposals will put a huge burden on the industry and the consumer. There does not seem to be any logical reason to make these drastic changes. What evidence was presented to the committee that demonstrates a need to require listed or AHJ approved accessories on unlisted field constructed fireplaces and chimneys?

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Submittal Date: Wed Oct 08 05:12:33 EDT 2014


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As written this language does not recognize the millions of Factory-Built fireplaces that were made bymanufacturers who are no longer in business. As a manufacturer of fireplace doors and accessories since1969 Stoll Fireplace Inc. has been asked to make an estimated 50,000 replacement doors for Factory-Builtfireplaces where the OEM replacements are no longer available. Condemning a fireplace for the lack of agrate or a screen, or other component is hardly an acceptable solution. Over the years we have made OEMdoors for various manufacturers and are thoroughly familiar with the requirements. Of all the doors that havebeen produced and installed it is important to note that we have never been made aware of even a singleproduct that has been involved in a overheating situation. Each of these doors is made individually as anexact fit replacement unique to an individual Factory-built fireplace model. In each case we replicate the airinlets provided in OEM doors to prevent overheating of the firebox should an operator close the doors on ahot fire. We chose to err on the side of caution and make the air inlets larger wherever possible. In addition,in the operator instructions that are provided with every door and are available online for download, weclearly state that the doors should remain wide open when the fireplace is burning. We would gladly list ourdoors for Factory-Built fireplaces if a generic standard existed but it does not. Attempting to list to everFactory-Built fireplace model has proven cost prohibitive.


If this change is made than there will be hundreds of fireplaces with no option for updating or repairing and homeowners will opt to try and repair with products not designed or qualified to fit the unit. thus putting the customers home at risk.

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Submitter Full Name: Gary Yoder

Organization: Stoll Fireplace

Affilliation: Stoll Fireplace

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11.1.5




Delete Section


This proposal is a “solution” in search of a problem, and will result in increasing the chance of fires, not preventing them, while seriously threatening the viability of all fireplace accessory manufacturers and the dealers and service people who sell, install and service them. Requiring fireplace accessories to be listed with specific factory-built fireplaces is problematic for the following reasons:

1) Unnecessary. For example, Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. They have never been sued for a fire caused by their gas log sets or a fire in which our products were installed, but other accessories were deemed to be the cause. In today’s litigious society, they would most certainly be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never, ever happened. If a chimney cap, damper mechanism, glass door or other accessory was the cause of a fire, Rasmussen would most certainly be named in the lawsuit if our gas log set was also installed, but this has never, ever occurred. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.

2) Financially untenable and impossible. There are too many fireplaces and accessory combinations to accomplish such a monumentally unnecessary undertaking to test and list ALL accessories with ALL fireplaces by ALL manufacturers.

a) Impossible to accomplish for fireplaces whose manufacturer is no longer in business (there are a lot of fireplace manufacturers who no longer exist).

3) Restraint of trade and commerce. This section will have the effect of delegitimizing products with decades of perfect safety track records and consumer enjoyment. It will threaten the viability of manufacturers, dealers, installers and service people. I expect litigation to be filed to block this section should it be enacted.

4) Effectively condemns all fireplaces in need of repair or any part replacement. Will lead to ignorant, untrained homeowners making repairs themselves to save the expensive and unnecessary cost of replacing the whole fireplace. This is fraught with DIY danger and undesired consequences.

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11.1.5



(2)



Table or delay these proposed changes until the CSIA White Paper is published to see empirical test data/results.

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Submitter Full Name: JAMES BOSTAPH

Organization: BLACK GOOSE CHIMNEY SWEEP

Affilliation: MidAtlantic Chimney Association

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11.1.5



(2) Acceptable to the AHJ and installed as approved and Manufactured and installed in accordancewith the accessory manufacturer’s installation instructions and perform in the same manner as theoriginal equipment manufacturer's listed component


The proposed language is too broad in scope. Requiring that items that are not listed for a specific make and model of a fireplace required be acceptable to the AHJ is impractical. Requiring a mechanical permit to replace a chimney cap, refractory panel or fireplace screen seems unnecessary, especially considering that professional service technician/installer would be more astute in what is an acceptable installation. There has not been empirical data presented that supports the argument that the use of non-listed components is a hazard. Anecdotal evidence is not sufficient, and likely when investigated would determine that a hazard was not the result the of accessory being non-listed but that it did not perform as an OEM listed component. Because there is no evidence that a hazard is created when using accessories that are not specifically listed for a make and model of a fireplace simply due to the fact that they are not listed, these restriction put an unnecessary burden on the consumer when list components are no longer available for a specific make and model of a fireplace. The standard would only allow complete replacement of the fireplace and chimney system when all that may be needed is a chimney cap, fireplace screen or refractory panel.

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Submitter Full Name: STEVEN PIETILA

Organization: AMERICAN CHIMNEY AND MASONRY

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11.1.5




NFPA Response

My name is Patrick Gengler, and I am president of Design Specialties, one of the leading manufacturers ofglass doors for fireplaces. I am very much opposed to Section 11.1.5 of NFPA 211. While I am certain theintentions are good, I think this section will actually have many adverse affects, some directly opposes tothe intention of the policy and others that will be unintended consequences.

I believe the intention of the policy is to maximize safety and prevent fires and other damage. I can attestthat fireplace door manufacturers have been supplying replacement fireplace doors for factory builtfireplaces for well over 20 years. Collectively, we have installed hundreds of thousands of doors to thismarket, and to my knowledge, there has not been one documented case of a safety hazard or a fire withany of our products. In addition, several of us have also supplied upgrade doors for the fireplace OEM’s tosell as part of their line, so we have been through the UL testing and know what is required of the product. The requirement of actually listing the doors for each specific fireplace is problematic. First, the OEM’sobviously prefer selling their product, and they will want to minimize competition as much as possible.Second, the UL testing is expensive and getting our products tested and approved for each of the fireplacemodels we service would be prohibitive. Limiting this to products listed for use by the manufacturer wouldprevent us from participating in this market, and it would limit the choices in terms of quality and priceavailable to the consumer without any enhancement to safety.

If you limit sales to the OEM’s only, then you run into another obstacle. There is a huge number of installedfireplaces where the OEM is either out of business or no longer making replacement doors for certainmodels of fireplaces. Our accessory companies service this end of the market very well. If we areprevented from doing that, the consumer has three choices – stop using the fireplace, tear it out and payfor a new one or burn without doors, which presents the very hazard that this policy is trying to prevent.This is counterproductive to the policy.

Our market exists primarily because the OEM’s focus on their fireplaces, not on the doors. For the mostpart, the OEM doors are rather inexpensive, do not work especially well and are not very attractive. Weoffer upgraded performance and enhanced aesthetics, which the consumers are hungry for. To preventthem from upgrading is to place a burden on the marketplace that is unnecessary and restrictive.

Finally, in an era where we are trying to maximize middle income jobs in the US, why on earth would weimplement a policy that would result in many of us laying off a significant number of our employees? Thisis a huge market for us, and we have served it well and safely for over 20 years. To arbitrarily change thatfor no good reason makes no sense, and it is a destructive policy.

Rather than referring to glass door products that are "listed" for use with a factory built fireplace, I suggestusing a phrase such as the following:

“This door has been configured to fit on factory built fireplaces and to function as required for use onfactory built fireplaces.”

Manufacturers understand why doors for factory built fireplaces need to be designed differently thanmasonry fireplaces. No one would sell a door that is not designed to operate safely. None of us wouldwant to be responsible for a fire. that is why we all design the doors the way we do, and it is why none ofus have ever had a fire incident with our doors. We would all have no problem using the above statementon all doors made for factory built fireplaces. It would prevent those manufacturers who only produce doorsfor masonry fireplaces from having their doors installed on factory built fireplaces, which would provide thefire safety that you are looking for.


Many of the installed base of fireplaces no longer have manufacturers who are still in business or who want to service older products. We will satisfy this need safely and prevent the consumers from burning an unsafe


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fireplace without doors. Other consumers want to upgrade the aesthetics and operation of their fireplaces, and the OEM's do not offer this, but we do.

Adding the proposed statement that makes the consumer aware that the glass door is specifically built to meet the criteria needed for factory built fireplaces will ensure that only properly designed doors are used on these fireplaces, which should eliminate the fire concerns of this body.

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Submitter Full Name: Patrick Gengler

Organization: Design Specialties

Affilliation: HPBA

Street Address:

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11.1.5


(1) Listed for use with the specific factory-built fireplace and installed in accordance with the terms oftheir listing.

(2) Acceptable to and installed by a Certified Hearth Techniican in accordance with the terms of thefireplace listing provided the fireplace's integrity is in no way compromised with its installation.



Rationale for the addition of (2):As written, this clause may prohibit the continued service of an approved factory built fireplace simply because a listed replacement component is no longer available. For example, a log grate has deteriorated or a glass panel on the door has been broken and the manufacturer of the fireplace no longer exists. A Certified Hearth Technician would access and install a comparable substitute albeit not listed for that fireplace. The AHJ may not possess the relative knowledge and therefore not be willing to approve the substitute component. The consumer refuses to accept the notion their fireplace can no longer be used simply because the manufacturer no longer exists and decides to source their own replacement which may or may not be suitable. The rule should provide the most practical direction for the safe operation of the fireplace.

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Submitter Full Name: Dana Moroz

Organization: Wolf Steel Ltd

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11.1.5


1. Listed for use with the specific factory-built fireplace and installed in accordance withthe terms of their listing .

2. Acceptable to and installed by a Certified Hearth Technician (National FireplaceInstitute or Chimney Safety Institute of America certified) in accordance with the terms ofthe fireplace listing provided the fireplace's integrity is in no way compromised with itsinstallation.

3. Acceptable to the AHJ and installed as approved and in accordance with themanufacturer’s installation instructions


Rationale for the addition of (2):

This clause may prohibit the continued service of an approved factory built fireplace simply because a listed replacement component is no longer available. For example, a log grate has deteriorated or a glass panel on the door has been broken and the manufacturer of the fireplace no longer exists. A Certified Hearth Technician would access and install a comparable substitute albeit not listed for that fireplace. The AHJ may not possess the relative knowledge and therefore not be willing to approve the substitute component. The consumer refuses to accept the notion their fireplace can no longer be used simply because the manufacturer no longer exists and decides to source their own replacement which may or may not be suitable. The rule should provide the most practical direction for the safe operation of the fireplace.

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Submitter Full Name: Thomas Stroud

Organization: Hearth, Patio & Barbecue Assoc

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11.1.5





This entire proposed new section should be deleted. The proposed new definition (3.3.2.1) for accessories includes shrouds, glass or screen doors, grates, blowers, log lighters, gas logs, and caps. The proposed change to Section 11.1.5 requires that accessories be specifically listed or approved by the AHJ. Since these items are generally not listed for the specific model of fireplace then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think that the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. There is a long standing history of after market parts and there was no credible evidence presented that the use of after market parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers. There are many brands and models of fireplaces where OEM parts are no longer available so the consumer is forced with spending thousands of dollars for a new fireplace simply because they need a cap or grate. AHJ’s are not going to give approval and service techs/installers are going to look and sound like crooks when they try to sell a new fireplace simply because the current fireplace needs a new cap or grate. Another concern here is the inclusion of “gas log decorative appliances” in the definition. Under these proposed new requirements gas logs will now have to be specifically listed for each model of fireplace they are to be installed in. Gas logs are tested under a separate standard but they are not tested for each model of fireplace that they may be installed in, and there is no evidence to suggest that this should now be required. Where is the evidence to suggest these proposed changes are necessary. Code writers should not create costly new requirements unless there is a proven safety problem that needs to be addressed. How will insurance companies respond when presented with an expensive bill to replace an entire fireplace & chimney system simply because a sudden occurrence like a hurricane blew the chimney cap off an otherwise serviceable system?

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11.1.5


Listed for use with the specific factory-built fireplace and installed in accordance with the terms of theirlisting

Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’s installationinstructions

This change to the standard is out of order and should not be allowed. The 211 committee establishedsome years back that the inspection of exisiting systems and the construction standards of newconstruction differed, hence the insertion of the maintenance chapter in 1992. The requirment of requiringonly listed components is one that the drafter of this provisions full well realizes is impossible and willrequire that many consumers spend money to reach a magic platform of safety when in fact this isimpossible to attain this magic platform. This is also a case of a requirment being entered that hs not datato support the language.


This change to the standard has no data to back up the need.



Public Comment No. 70-NFPA 211-2014 [Section No. 3.3.2.1] FR 6

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Submittal Date: Mon Nov 10 20:51:42 EST 2014


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11.1.5




[Section Deleted]


This proposal is a "solution" in search of a problem, and will result in increasing the chance of fires, not preventing them, while seriously threatening the viability of all fireplace accessory manufacturers and the dealers and service people who sell, install and service them. Requiring fireplace accessories to be listed with specific factory-built fireplaces is problematic for the following reasons:1) Unnecessary. Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. We have never, ever been sued for a fire caused by our gas log sets or a fire in which our products were installed, but other accessories were deemed to be the cause. In today's litigious society, we would most certainly be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never, ever happened. If a chimney cap, damper mechanism, glass door or other accessory was the cause of a fire, Rasmussen would most certainly be named in the lawsuit if our gas log set was also installed, but this has never, ever occurred. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.2) Financially untenable and impossible. There are too many fireplaces and accessory combinations to accomplish such a monumentally unnecessary undertaking to test and list ALL accessories with ALL fireplaces by ALL manufacturers. a) Impossible to accomplish for fireplaces whose manufacturer is no longer in business (there are a lot of fireplace manufacturers who no longer exist).3) Restraint of trade and commerce. This section will have the effect of delegitimizing products with decades of perfect safety track records and consumer enjoyment. It will threaten the viability of manufacturers, dealers, installers and service people. I expect litigation to be filed to block this section should it be enacted.4) Effectively condemns all fireplaces in need of repair or any part replacement. Will lead to ignorant, untrained homeowners making repairs themselves to save the expensive and unnecessary cost of replacing the whole fireplace. This is fraught with DIY danger and undesired consequences.

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11.1.5



(2) Acceptable to the AHJ and installed as approved and designed specifically for use with factory-builtfireplaces and installed in accordance with the manufacturer’s manufacturer's installationinstructions


Glass Door Manufacturers have developed specific products for factory-built fireplaces which allow for necessary air flow. Well over 100,000 after-market glass doors for factory-built fireplaces have been sold over the last 10 years and I have yet to hear of an incident. Portland Willamette has a significant market share and we have encountered no safety problems or incidents. My concern is that a greater safety issue may arise if the NFPA were to attempt to restrict the availability of quality replacement products, especially in light of the large installed base of factory-built fireplaces for which there is no longer manufacturer support.

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Submitter Full Name: John Boire

Organization: Portland Willamette

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11.1.5




Additional Proposed Changes

File Name Description Approved

NFPA_211_-_Recommended_11.1.5_1_change_in_Word.docx Recommended 11.1.5 (1) Change


Vent-free gas logs and inserts are certified for use with Listed UL 127 factory-built fireplaces, masonry fireplaces, and ventless firebox enclosures. However, they may not be installed in any factory-built fireplace having a product label that specifically excludes them. The word “specific” adds confusion. It would be impossible to certify all vent-free gas logs and inserts with all factory-built fireplaces as that would involve tens of thousands of permutations. This is why the product standard for certification includes worse-case testing in order to cover all combinations. The word "specific" should be deleted.

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Submitter FullName:

Don Denton

Organization: Self

Affilliation:Consultant to the Vent-Free Gas Products Alliance Section of theAir-Conditioning, Heating and Refrigeration Institute

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Public Comment No. 120-NFPA 211-2014 [ Section No. 11.2 ]

11.2 * Masonry Fireplaces.

11.2.1 Construction.

11.2.1.1

Fireplaces shall be constructed of solid masonry units or of reinforced Portland or refractory cementconcrete.

11.2.1.2

Masonry fireplaces shall be supported on foundations of one of the following:

(1) Masonry

(2) Reinforced Portland cement concrete

(3) Refractory cement concrete

(4) Other noncombustible construction having a fire resistance rating of not less than 3 hours, providedsuch supports are adequate for the load

11.2.1.2.1

Footings for masonry fireplaces and their chimneys shall be constructed of concrete or solid masonry atleast 12 in. (305 mm) thick and shall extend at least 6 in. (152 mm) beyond the face of the fireplace orfoundation wall on all sides.

11.2.1.2.2

Footings shall be founded on natural undisturbed earth or engineered fill below frost depth.

11.2.1.2.3

In areas not subject to freezing, footings shall be at least 12 in. (305 mm) below finished grade.

11.2.1.3

The firebox of a concrete or masonry fireplace shall have a minimum depth of 20 in. (508 mm).

11.2.1.3.1

The throat shall not be less than 8 in. (203 mm) above the fireplace opening.

11.2.1.3.2

The throat opening shall not be less than 4 in. (102 mm) in depth.

11.2.1.3.3

The cross-sectional area of the passageway above the firebox, including the throat, damper, and smokechamber, shall not be less than the cross-sectional area of the flue.

11.2.1.3.4

Rumford fireplaces shall be permitted, provided that the depth of the fireplace is at least 12 in. (305 mm)and at least one-third the width of the fireplace opening, and the throat is at least 12 in. (305 mm) abovethe lintel and at least one-twentieth the cross-sectional area of the fireplace opening.

11.2.1.4

Where a lining of low-duty fireclay brick (ASTM C27, Standard Classification of Fireclay and High-AluminaRefractory Brick ), firebox brick (ASTM C1261, Standard Specification for Firebox Brick for ResidentialFireplaces ), or the equivalent, at least 2 in. (51 mm) thick laid in medium-duty refractory mortar (ASTMC199, Standard Test Method for Pier Test for Refractory Mortars ), or the equivalent, or other approvedlining is provided, the total thickness of back and sides, including the lining, shall be not less than 8 in. (203mm).

11.2.1.5

All joints and intersections between the hearth extension/fireplace facing and the fire chamber (firebox)shall be fully sealed with medium-duty refractory mortar (ASTM C199, Standard Test Method for Pier Testfor Refractory Mortars ). Gaps or voids at supporting lintels and joints between steel fireplace units and thefireplace face or between the frames of dampers and the fireplace face shall be sealed with the samematerial or with a high-temperature [2000°F (1093°C) service rating] insulating mortar.


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11.2.1.6

Where the lining described in 11.2.1.4 is not provided, the thickness of the back and sides of the fireplaceshall be not less than 12 in. (305 mm).

11.2.1.7

Where the masonry supporting a fireplace is designed to support vertical loads from the building andcorbels are used to support beams or girders, corbeling shall be in accordance with 7.1.2 for masonrychimneys.

11.2.1.8

Masonry over a fireplace opening shall be supported by a lintel of noncombustible material.

11.2.1.8.1

The minimum required bearing length on each end of the fireplace opening shall be a nominal 4 in. (102mm).

11.2.1.8.2

The fireplace throat or damper shall be located a minimum of 8 in. (203 mm) above the top of the fireplaceopening.

11.2.1.9

Where a lining of low-duty fireclay brick (ASTM C27, Standard Classification of Fireclay and High-AluminaRefractory Brick ), firebox brick (ASTM C1261, Standard Specification for Firebox Brick for ResidentialFireplaces ), or the equivalent, at least 2 in. (51 mm) thick laid in medium-duty refractory mortar (ASTMC199, Standard Test Method for Pier Test for Refractory Mortars ), or the equivalent, or other approvedlining is provided, the total thickness of the smoke chamber walls, including the lining, shall be not lessthan 6 in. (152 mm).

11.2.1.10

Where unlined, the smoke chamber wall thickness shall be not less than 8 in. (203 mm).

11.2.1.11

The smoke chamber height shall not be greater than the inside width of the fireplace room opening.

11.2.1.12

The smoke chamber depth shall not be greater than the depth of the fireplace fire chamber. (See Figure11.2.1.12 .)

Figure 11.2.1.12 Sectional View of Fireplace Showing Smoke Chamber.

11.2.1.13

The inner surfaces of the smoke chamber shall be parge coated smooth, with an insulating refractorymortar, and not inclined more than 45 degrees from vertical.


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11.2.1.14

Masonry fireplaces shall be provided with chimneys designed and constructed in compliance with one ofthe following:

(1) In accordance with the requirements for construction of masonry chimneys (See Section 7.2 .)

(2) Where permitted by the individual listing, with approved factory-built chimneys having approvedadapters in accordance with the requirements for factory-built chimneys (See Chapter 5.)

11.2.1.15 Hearth Thickness.

The minimum thickness of fireplace hearths shall be 4 in. (102 mm).

11.2.2 Seismic Reinforcing.

11.2.2.1

Reinforcement shall not be required in Seismic Design Category A, B, or C.

11.2.2.2

In structures of Seismic Design Category D, fireplaces with chimneys up to 40 in. (1016 mm) wide, fourNo. 4 continuous vertical bars, anchored in the foundation, shall be placed in the concrete, betweenwythes of solid masonry or within the cells of hollow unit masonry and grouted in accordance with ASTMC476, Standard Specification for Grout for Masonry .

11.2.2.2.1

For fireplaces with chimneys greater than 40 in. (1016 mm) wide, two additional No. 4 vertical bars shall beprovided for each additional 40 in. (1016 mm) in width or fraction thereof.

11.2.2.2.2

Vertical reinforcement shall be placed enclosed within 1 ⁄ 4 in. (6.4 mm) ties or other reinforcing ofequivalent net cross-sectional area, spaced not to exceed 18 in. (457 mm) on center in concrete, or placedin the bed joints of unit masonry at a minimum of every 18 in. (457 mm) of vertical height.

11.2.2.2.3

Two such ties shall be provided at each bend in the vertical bars.

11.2.2.2.4

In structures of Seismic Design Category E or F, masonry and concrete chimneys shall be reinforced inaccordance with the requirements of Sections 43.1 through 43.8 of NFPA 5000 .

11.2.3 Seismic Anchorage.

11.2.3.1

Seismic anchorage shall not be required in Seismic Design Category A, B, or C.

11.2.3.2

In structures of Seismic Category D, masonry and concrete chimneys shall be anchored at each floor,ceiling, or roof line more than 6 ft (1.8 m) above grade except where constructed completely within theexterior walls.

11.2.3.3

Two 3 ⁄ 16 in. by 1 in. (4.8 mm by 25 mm) straps shall be embedded a minimum of 12 in. (305 mm) intothe chimney.

11.2.3.3.1

Straps shall be hooked around the outer bars and extend 6 in. (152 mm) beyond the bend.

11.2.3.3.2

Each strap shall be fastened to a minimum of four floor joists with two 1 ⁄ 2 in. (12.7 mm) bolts.

11.2.4 Steel Fireplace Units.

11.2.4.1

Steel fireplace units incorporating a firebox liner of not less than 1 ⁄ 4 in. (6.4 mm) thick steel and an airchamber shall be installed with masonry to provide a total thickness at the back and sides of not less than8 in. (203 mm), not less than 4 in. (102 mm) of which shall be solid masonry.

11.2.4.2

Listed firebox liners shall be installed in accordance with the terms of the listing.

11.2.4.3

Warm-air ducts employed with steel fireplace units of the circulating air type shall be constructed of metalor masonry.


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11.2.5 Clearance.

11.2.5.1

All wood beams, joists, studs, and other combustible material shall have a clearance to masonry fireplacesas follows:

(1) Not less than 2 in. (51 mm) from the front faces and sides

(2) Not less than 4 in. (102 mm) from the back faces of masonry fireplaces (See Figure 11.2.5.1 .)

Figure 11.2.5.1 Fireplace Clearance to Combustible Material.

11.2.5.2

Spaces between headers or trimmers of combustible material and masonry fireplaces shall be firestoppedwith one of the following noncombustible materials:

(1) Galvanized steel not less than 26 gauge [0.019 in. (0.483 mm)] in thickness

(2) Noncombustible sheet material not more than 1 ⁄ 2 in. (12.7 mm) thick

11.2.5.3

Woodwork, such as wood trim, mantels, and other combustible material, shall not be placed within 6 in.(152 mm) of a fireplace opening.

11.2.5.4

Combustible material above and projecting more than 1 1 ⁄ 2 in. (38 mm) from a fireplace opening shallnot be placed less than 12 in. (305 mm) from the top of the fireplace opening. (See Figure 11.2.5.4 .)

Figure 11.2.5.4 Fireplace Clearance to Combustible Material.


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11.2.6 Accessibility.

For cleaning purposes, means shall be provided for access to the venting area above and immediatelybehind any movable damper valve plate in masonry fireplaces and steel fireplace units by one of thefollowing methods:

(1) A damper plate that can be removed with common hand tools

(2) A cleanout opening located to provide access to the smoke chamber area

11.2.7 Cleanout Openings.

Cleanout openings shall be equipped with ferrous metal, stainless steel, precast cement, or other approvednoncombustible doors and frames arranged to remain tightly closed and secured when not in use.

11.2.8 Ash Dumps.

Cleanouts, if provided, shall be accessible and located so that ash removal will not create a hazard tocombustible materials.

11.2.9 Dampers.

11.2.9.1

Masonry fireplaces shall be equipped with a ferrous metal damper located at least 8 in. (203 mm) abovethe top of the fireplace opening.

11.2.9.2

Dampers shall be installed in the fireplace or at the top of the flue venting the fireplace and shall beoperable from the room containing the fireplace.

11.2.9.3

A nonferrous metal damper shall be permitted to be installed at the top of the flue specified in 11.2.9.2 .

11.2.9.4

Damper controls shall be permitted to be located in the fireplace.

11.2.10 * Masonry Fireplace Accessories.





no changes suggested to old language. the proposals will put a huge burden on the industry. no evidence for changes

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Public Comment No. 92-NFPA 211-2014 [ New Section after 11.2.10 ]

Public Comment No. 92 - NFPA 211-2014 [ Section No. 11.2.10

Statement of Problem and Substantiation for Public Comment.

The vast majority of Fireplaces built in the United States are not listed products; but, rather units that arebuilt to code. Accessories that go into them are not listed products either.

The submittal of Thomas Stroud on this matter is very accurate.


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11.2.10* Masonry Fireplace Accessories.


(1) Listed and installed in accordance with the terms of their listing Designed for use with masonryfireplaces.



Section 11.2.10 is a cut and paste error. Formerly fireplace accessories were defined in section 11.4 of NFPA 211-2013 and did not differentiate between masonry and factory built fireplaces. The language was essentially correct but confusing. While it is appropriate to define masonry and Factory-Built fireplace individually, the proposed language fails to recognize that there are no standards for open masonry fireplaces (as separate from Masonry Heaters defined in Section 12) nor for the components thereof, to which manufacturers could test their products. The proposed language will inevitably lead to confusion in the field by users of NFPA 211.

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11.2.10 * Masonry Fireplace Accessories .


(1) Listed and installed in accordance with the terms of their listing .

(2) Acceptable to and installed by an Experience Hearth Technician or Installer in accordance with themanufacturer’s installation instructions for the accessory.

(3) Acceptable to the AHJ and installed as approved and in accordance with the

manufacturer's

(1) manufacturer’s installation instructions


1) Most fireplace accessories are not listed products, but the absence of a listing does not make them unsafe, just unlisted.

2) Most AHJs probably are not expert or even familiar with fireplaces and their accessories.

3) Many people are experienced in the installation of fireplace accessories. Not all are certified. I am a hearth store owner. My business has been installing gas logs for over 25 years. I do not hold any type of Certified Hearth Technician credentials, but my installers are very experienced in all aspects of gas logs and would be a prudent choice for installing a gas log set. Same applies for many other hearth dealers and installers, who have made a business decision, base on time, financial resources or lack of local need, to not earn or maintain such certifications. Such experience must not be discounted or prohibited

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There is no empirical data that supports the assertion that the use of non-listed components in a masonry fireplace presents a hazard. Requiring an AHJ to inspect every installation of a damper, log grate, fireplace screen, chimney cap, etc. is impractical and places an undue burden on the consumer, installer and the AHJ. There is not sufficient (if any) evidence that developing and testing to a UL Listing for these accessories would eliminate any hazards.

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( 1) Listed and installed in accordance with the terms of their listing if a listed product rather than a codebuilt fireplace

2) Acceptable to and installed by a Certified Hearth Technician (National Fireplace Institute or ChimneySafety Institute of America certified) in accordance with the terms of the fireplace listing provided the fireplace'sintegrity is in no way compromised with its installation.



The vast majority of fireplaces built in the US are not listed products, rather they are code built fireplaces. Products that go into them, such as gas logs, log lighters, dampers, chimney caps and ash dumps are not listed products.

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(1) Not adversely affecting the minimum requirements of this standard




By adding the additional language; "(1) Not adversely affecting the minimum requirements of this standard", It would allow for the accessaries like but not limited to, wood grates, chimney cap / spark arrestors, fireplace spark screens, ash dump doors and top sealing dampers that are not listed but in some cases otherwise addressed in the standard to be installed without approval of the AHJ.

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Submitter Full Name: Randy Brooks

Organization: Brooks Chimney Sweeping

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Submittal Date: Wed Aug 27 18:58:04 EDT 2014


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(2) Acceptable to and installed by a Certified Hearth Technician in accordance with the terms of thefireplace listing provided the fireplace's integrity is in no way compromised with its installation.



As written, this clause may prohibit the continued service of an approved factory built fireplace simply because a listed replacement component is no longer available. For example, a log grate has deteriorated or a glass panel on the door has been broken and the manufacturer of the fireplace no longer exists. The AHJ may not possess the relative knowledge and therefore not be willing to approve the substitute component. The consumer refuses to accept the notion their fireplace can no longer be used simply because the manufacturer no longer exists and decides to source their own replacement which may or may not be suitable.

A Certified Hearth Technician would access and install a comparable substitute albeit not listed for that fireplace.

The rule should provide the most practical direction for the safe operation of the fireplace.

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Submittal Date: Tue Oct 28 16:23:49 EDT 2014


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(2) Acceptable to the AHJ and installed as approved and Installed in accordance with themanufacturer's installation instructions


We agree with negative comment by Mr. Edgar. The AHJ should not be approving this situation over the manufacturer’s instructions.

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Submitter Full Name: Jim Muir

Organization: Clark County, Washington, Building Safety Division

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

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Submittal Date: Fri Oct 31 13:07:12 EDT 2014


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(1) Listed and installed in accordance with the terms of their listing.

(2) Acceptable to and installed by an Experience Hearth Technician or Installer in accordance with themanufacturer's installation instructions for the accessory.



1) Most fireplace accessories are not listed products, but the absence of a listing does not make them unsafe, just unlisted.2) Most AHJs probably are not expert or even familiar with fireplaces and their accessories.3) Many people are experienced in the installation of fireplace accessories. Not all are certified. For example, I am 54 years old and have been designing gas log sets for the past 27 years and installing them since I was 14 years old. I do not hold any type of Certified Hearth Technician credentials, but I am very, very experienced in all aspects of gas logs and would be a prudent choice for installing a gas log set. Same applies for many hearth dealers and installers, who have made a business decision, base on time, financial resources or lack of local need, to not earn or maintain such certifications. Such experience must not be discounted or prohibited.

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Submittal Date: Sat Nov 08 18:07:07 EST 2014


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These proposals will put a huge burden on the industry. 3.3.2.2 defines a long list of items as masonry fireplace and chimney accessories. This list includes heat exchangers, glass or screen doors, grates, blowers, log lighters, firebacks, gas logs, chimney caps and ash dump doors. 11.2.10 states these items must be listed or approved by the AHJ. Since these items often are not listed consumers and installers will need to consult the AHJ for approval each time they install one of these items. Does the AHJ have the time or experience to make these evaluations? Additionally, no criteria are provided for the AHJ to evaluate and determine if a product is acceptable. There also does not seem to be any logical reason to make this drastic change. What evidence was presented to the committee that demonstrates a need to require listed or AHJ approved accessories on unlisted, field constructed fireplaces and chimneys?

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(2)



This portion of the standard is overly restrictive and burdensome. Most masonry site built fireplaces are built to "code", not tested and listed. This section implies that accessories for masonry fireplaces ( doors, screens, log grates, ash dumps, dampers and air supply mechanisms) can be listed to a standard that will comply with the fireplace listing. They can not. Certain fireplace accessories such as heat exchangers and tubular air circulation grates can be listed to UL 907 for use in a masonry fireplace and therefore should be the only accessories that must be listed for use. The only documented testing I have seen done with a masonry fireplace is the testing completed in 1994 by the Canadian Mortgage and Housing Corporation " The Effects Of Glass Doors On Masonry Fireplace Spillage and Surface Temperatures". This protocol did not test other products for use with the fireplace only the effect glass doors had on spillage and temperature. In summary the test had only minimal effect on the temperature of buried members with the addition of glass doors, either sealed or not.

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Submitter Full Name: Gary Wilkening

Organization: Wilkening Fireplace Co

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(1) Listed and installed in accordance with the terms of their listing Designed for use with masonryfireplaces



Masonry fireplaces are not listed and neither are most accessories with the possible exception of gas logs. Portland Willamette has sold thousands of glass doors for masonry fireplaces and I am not aware of any safety issues or instances. As long as the glass doors are installed and used in accordance with the manufacturer's instructions there should be no safety issues and the product provides a significant environmental benefit by restricting heat loss up the chimney when the fireplace is not in use.

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Submitter Full Name: John Boire

Organization: Portland Willamette

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14.7.1

Chimneys, vents, and fireplaces shall be inspected, cleaned, and repaired if there is any evidence ofdamage to the chimney, fireplace, or vent or to the surroundings.

14.7.1.1

Only listed or approved components and accessories tested for use with the specific model of factory-builtchimney shall be permitted.

14.7.1.2

Only listed or approved components or accessories for use with the specific model of factory-built fireplacesystem shall be permitted.


changes are impractical and no evidence or proof supporting changes. suggest no change to current language

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Public Comment No. 93-NFPA 211-2014 [ New Section after 14.7.1.1 ]

Public Comment No.93 - NFPA 211 - 2014 [Section No. 14.7.1.1]


Manufacturers who have gone out of business have made products that were never listed products orapproved components, thus trained specialists need to be able to select replacement parts as is necessaryto provide maintenance for the unit. We want qualified people doing this work and not unqualifiedhomeowners.


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First Revision No. 3-NFPA 211-2014 [New Section after 14.7.1]




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14.7.1.1



This language is redundant with the language in 11.1.5. Creating new sections in Chapter 14 is unnecessary. It does nothing to improve the understanding of users of NFPA 211.

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14.7.1.1









In regards to: Section 14.7.1.1 and 14.7.1.2 add the following new requirements to the maintenance chapter. 14.7.1.1 Only listed or approved components and accessories tested for use with the specific model of factory-built chimney shall be permitted. 14.7.1.2 Only listed or approved components or accessories for use with the specific model of factory-built fireplace system shall be permitted.

-HPBA Pacific strongly disagrees with these new requirements. The majority of existing factory built fireplaces were built by manufacturers who are no longer in business and if they are in business they often do not supply parts for these models. Limiting repairs and fixes on minor parts like refractory panels, grates, log lighters, caps, glass doors etc. and asking installers to deem the fireplace un-useable because of one minor faulty part is condemnable to say the least. For decades now, professional chimney sweeps and installers have replaced worn parts and maintained the safety of the appliance without having to replace the entire fireplace. Taking this option away from consumers makes no sense. The cost to a homeowner to remove and replace a fireplace is extremely high. In most homes in California the fireplace would need to be a Direct vent gas or EPA certified wood burning fireplace costing homeowners thousands of dollars.

Over the past 20 years, many fireplace manufacturers have gone out of business, or have been acquired by other manufacturers who do not support the prior models. Aftermarket products have been used for years with success when it comes to hard to find or out of business fireplace manufacturers. Taking this cost effective change away from consumers is short-sighted and unjust to consumers.

We believe that if UL tested and listed aftermarket parts are available then they should be allowed as they meet the testing standard.


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14.7.1.1

Only listed or approved components and accessories tested for use with the specific model of factory-builtchimney shall be permitted. Delete this section.


This proposal is a “solution” in search of a problem, and will result in increasing the chance of fires, not preventing them, while seriously threatening the viability of all fireplace accessory manufacturers and the dealers and service people who sell, install and service them. Requiring fireplace accessories to be listed with specific factory-built fireplaces is problematic for the following reasons:

1) Unnecessary. Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. We have never, ever been sued for a fire caused by our gas log sets or a fire in which our products were installed, but other accessories were deemed to be the cause. In today’s litigious society, we would most certainly be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never, ever happened. If a chimney cap, damper mechanism, glass door or other accessory was the cause of a fire, Rasmussen would most certainly be named in the lawsuit if our gas log set was also installed, but this has never, ever occurred. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.



3) Restraint of trade and commerce. This section will have the effect of delegitimizing products with decades of perfect safety track records and consumer enjoyment. It will threaten the viability of manufacturers, dealers, installers and service people. I expect litigation to be filed to block this section should it be enacted.


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14 . 7.1.1

Only listed

Factory-built chimney components and accessories shall be one of the following

1. Listed or approved components and accessories tested for use with the specific model of factory-builtchimney shall be permitted when available .

2. Acceptable to and installed by a Certified Hearth Technician (National Fireplace Institute or ChimneySafety Institute of America certified) in accordance with the terms of the chimney listing provided thechimney's integrity is in no way compromised with its installation.

3. As approved by the AHJ


This is a maintenance chapter. If trained specialists are not allowed to do repair work on existing chimney's whose manufacturer has gone out of business and have as their only choice to condemn the installation, we will find homeowners doing their own maintenance work and causing a worse situation than we are trying to fix.

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14.7.1.1

Only listed or approved components and accessories tested for use with the specific model of factory-builtchimney shall be permitted. [Section Deleted]



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Public Comment No. 137-NFPA 211-2014 [ Sections 14.7.1.1, 14.7.1.2 ]

Sections 14.7.1.1, 14.7.1.2

14.7.1.1



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14.7.1.2


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November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471














Thank you,





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Bil Orlando, Jotul






HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren






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Sections 14.7.1.1, 14.7.1.2

14.7.1.1


14.7.1.2



Table or delay these proposed changes until the CSIA White Paper is published to see empirical test data/results.

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Submitter Full Name: JAMES BOSTAPH

Organization: BLACK GOOSE CHIMNEY SWEEP

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Sections 14.7.1.1, 14.7.1.2

14.7.1.1


14.7.1.2



Since these items are generally not listed for the specific model of fireplace, then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. In many areas there are no AHJs to review or approve of the installations.

There is a long standing history of aftermarket parts and there was no credible evidence presented that the use of aftermarket parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers.

There are many brands a d models of fireplaces where OEM parts are no longer available so the consumer is forced to spend thousands of dollars for a new fireplace simply because they need a cap or grate.

AHJs are not going to give approval and service techs or installers are going to look and sound like crooks when they try to sell a new fireplace simply because the current fireplace needs a new cap or grate.

Another concern is the inclusion of "gas log decorative appliances" in the definition. Under these proposed new requirements gas logs will now have to be specifically listed for each model of fireplace in which to be installed.

These proposals will put a huge burden on the industry and the consumer. There does not seem to be any logical reason to make these drastic changes. What evidence was presented to the committee that demonstrates a need to require listed or AHJ approved accessories on unlisted field constructed fireplaces and chimneys?

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Sections 14.7.1.1, 14.7.1.2

14.7.1.1


14.7.1.2



Both proposed new sections should be deleted. Since common replacement items are generally not listed for the specific model of fireplace or chimney then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think that the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. There is a long standing history of after market parts and there was no evidence presented that the use of after market parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers. There are many brands and models of fireplaces and chimneys where OEM parts are no longer available so the consumer is forced with spending thousands of dollars for a new fireplace or chimney simply because they need a cap or grate. AHJ’s are not going to give approval and service techs/installers are going to look and sound like crooks when they try to sell a new fireplace or chimney simply because the current fireplace needs a new cap or grate. Where is the evidence to suggest these proposed changes are necessary. Code writers should not create costly new requirements unless there is a proven safety problem that needs to be addressed. How will insurance companies respond when presented with an expensive bill to replace an entire fireplace & chimney system simply because a sudden occurrence like a hurricane blew the chimney cap off an otherwise serviceable system?

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Sections 14.7.1.1, 14.7.1.2

14.7.1.1


14.7.1.2

Only listed or approved components or accessories for use with the specific model of factory-built fireplacesystem shall be permitted This requested change to the standard is anothe example of a suggested changeto the standard that has no data to back up the need. A maor change such as this should only be considerdif there is field data to denote a major safety issue, of whcuh there is not sufficent data presented to date .


The proposed change as submitted has no field data to show that a problem exists that this would correct, this only serves to damage the consumer property value and does nothing to promote safe fireplace construction or use to a consumer

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Submittal Date: Mon Nov 10 21:20:47 EST 2014


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Sections 14.7.1.1, 14.7.1.2

14.7.1.1


14.7.1.2

Only listed or approved components or accessories for use with the specific model of factory-built fireplacesystem shall be permitted Constituent components identified in the instructions or labeling of a factory-builtfireplace sytem must be replaced, when necessary, with the fireplace manufacturer's identified componentsor their equivalent in material and design .


I don’t understand the repetition of these two sections, and I don’t think the language is clear (“listed or approved” should follow “accessories” to make sense I think). But the much larger problem is the inclusion of accessories and components together. The separation and definition of these terms in Public Comments 77 (3.3.2) and 78 (New Section after 3.3.14.2) offer the basis for revision of this section to cover only components. It is preferable to remove accessories both because accessories (as newly defined) are not, to my knowledge, tested and listed “for use with [a[ specific model of factory-built fireplace,” and because 11.6 (as proposed to be corrected in Public Comment 79 [Chapter 11]) is the proper reference for accessories.

The language proposed here provides the proper focus on components by defining them as being referenced in manufacturer’s instructions. It also addresses the substantial problem regarding components that are no longer available for factory-built fireplaces, but in so doing does not overstep or significantly contradict the hearth industry safety system by authorizing (and placing full responsibility on) the last professional handling an aftermarket component. I think 211 can offer the hearth industry a reasonable option to pursue (equivalent in material and design). It is not the responsibility of 211 to determine how equivalency is defined or achieved, such as through a voluntary aftermarket component manufacturers’ process to determine criteria and notification.

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Sections 14.7.1.1, 14.7.1.2

14.7.1.1

Only listed or approved components and accessories tested for use with the specific model of factory-builtchimney Aftermarket parts designed to replace original equipment parts shall be permitted.

14.7.1.2



This change would bring the standard in line with what is commonly practiced in the field. Recent testing has shown that there are no significant thermal performance differences between OEM parts and aftermarket parts. The changes made in the First Revision are unnecessary and are not supported by evidence or testing.

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November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471


The Hearth, Patio & Barbecue Association, Pacific Affiliate (HPBAP) is a not-for-profit tradeassociation that represents and promotes the interests of the hearth products industry regionallyin California, Nevada and Hawaii. HPBA is also a not-for-profit trade association which representsmanufacturers across North America. The regional affiliate represents California entities thatinclude retailers and service companies.

In regards to: Section 11.1.5 adds new requirements for factory-built fireplace systemaccessories as follows:


(1) Listed for use with the specific factory-built fireplace and installed in accordance with the termsof their listing.

(2) Acceptable to the AHJ and installed as approved and in accordance with the manufacturer’sinstallation instructions.

HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gasfireplace logs result in listings that allow for installation in listed or masonry wood burningfireplaces on a generic (not fireplace model specific) basis. Having only listed and approved gaslog sets in these fireplaces would impact gas log sales significantly. There are thousands of gaslogs and hundreds of existing factory built fireplaces, many that are not in current production - itwould be impossible for gas log manufacturers to meet this requirement. Elimination of this optionto install gas logs into existing factory built fireplaces flies directly in the face of Air QualityDistricts who are promoting these upgrades to minimize wood burning and improve air quality.

In regards to: Section 14.7.1.1 and 14.7.1.2 add the following new requirements to themaintenance chapter.

14.7.1.1 Only listed or approved components and accessories tested for use with the specificmodel of factory-built chimney shall be permitted.

14.7.1.2 Only listed or approved components or accessories for use with the specific model offactory-built fireplace system shall be permitted.

-HPBA Pacific strongly disagrees with these new requirements. The majority of existing factorybuilt fireplaces were built by manufacturers who are no longer in business and if they are inbusiness they often do not supply parts for these models. Limiting repairs and fixes on minor partslike refractory panels, grates, log lighters, caps, glass doors etc. and asking installers to deem thefireplace un-useable because of one minor faulty part is condemnable to say the least. For decadesnow, professional chimney sweeps and installers have replaced worn parts and maintained thesafety of the appliance without having to replace the entire fireplace. Taking this option away fromconsumers makes no sense. The cost to a homeowner to remove and replace a fireplace isextremely high. In most homes in California the fireplace would need to be a Direct vent gas or EPAcertified wood burning fireplace costing homeowners thousands of dollars.

Over the past 20 years, many fireplace manufacturers have gone out of business, or have beenacquired by other manufacturers who do not support the prior models. Aftermarket products havebeen used for years with success when it comes to hard to find or out of business fireplacemanufacturers. Taking this cost effective change away from consumers is short-sighted and unjustto consumers.

We believe that if UL tested and listed aftermarket parts are available then they should be allowedas they meet the testing standard.

Thank you,





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HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren






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Public Comment No. 94 - NFPA 211 - 2014 [Section No. 14.7.1.2

Most approved units and/or accessories have not been listed products for over 50 years. This proposalwould prohibit the proper maintenance and servicing of a unit just because a replacement part orcomponent is not listed.

Thomas Stroud's response to this matter is very accurate.


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14.7.1.2



This language is redundant with the language in 11.1.5. Creating new sections in Chapter 14 is unnecessary. It does nothing to improve the understanding of users of NFPA 211.

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14.7.1.2


Limiting replacement of factory built parts to only the original manufacturer will be costly to the consumerand does not realisticly address the problem of the wrong parts being installed on a listed appliance. Mostproblems I see are done by homeowners or 'jack leg repair people' who don't even understand how thecooling and operating systems of one of these units work, let alone what NFPA 211 is. Properly trained andeducated technicians can rightly choose an aftermarket part to replace a worn out part on a system. Iseriously question what the reason for this proposed change is for and who it actually would benifit. Irespectfully submit that it is not to make the public safer but to inhance and benifit certain 'expert'occupations within the industry.


Limiting replacement of factory built parts to only the original manufacturer will be costly to the consumer and does not realisticly address the problem of the wrong parts being installed on a listed appliance. Most problems I see are done by homeowners or 'jack leg repair people' who don't even understand how the cooling and operating systems of one of these units work, let alone what NFPA 211 is. Properly trained and educated technicians can rightly choose an aftermarket part to replace a worn out part on a system. I seriously question what the reason for this proposed change is for and who it actually would benifit. I respectfully submit that it is not to make the public safer but to inhance and benifit certain 'expert' occupations within the industry.

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Submitter Full Name: just balume

Organization: Blume, The Merry Sweep

Affilliation: SCCSG

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14.7.1.2


November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471


The Hearth, Patio & Barbecue Association, Pacific Affiliate (HPBAP) is a not-for-profit trade association thatrepresents and promotes the interests of the hearth products industry regionally in California, Nevada andHawaii. HPBA is also a not-for-profit trade association which represents manufacturers across NorthAmerica. The regional affiliate represents California entities that include retailers and service companies.

In regards to: Section 11.1.5 adds new requirements for factory-built fireplace system accessories asfollows:




HPBA Pacific strongly disagrees with these new requirements. The ANSI standards for gas fireplace logsresult in listings that allow for installation in listed or masonry wood burning fireplaces on a generic (notfireplace model specific) basis. Having only listed and approved gas log sets in these fireplaces wouldimpact gas log sales significantly. There are thousands of gas logs and hundreds of existing factory builtfireplaces, many that are not in current production - it would be impossible for gas log manufacturers to meetthis requirement. Elimination of this option to install gas logs into existing factory built fireplaces flies directlyin the face of Air Quality Districts who are promoting these upgrades to minimize wood burning and improveair quality.




-HPBA Pacific strongly disagrees with these new requirements. The majority of existing factory builtfireplaces were built by manufacturers who are no longer in business and if they are in business they oftendo not supply parts for these models. Limiting repairs and fixes on minor parts like refractory panels, grates,log lighters, caps, glass doors etc. and asking installers to deem the fireplace un-useable because of oneminor faulty part is condemnable to say the least. For decades now, professional chimney sweeps andinstallers have replaced worn parts and maintained the safety of the appliance without having to replace theentire fireplace. Taking this option away from consumers makes no sense. The cost to a homeowner toremove and replace a fireplace is extremely high. In most homes in California the fireplace would need to bea Direct vent gas or EPA certified wood burning fireplace costing homeowners thousands of dollars.

Over the past 20 years, many fireplace manufacturers have gone out of business, or have been acquired byother manufacturers who do not support the prior models. Aftermarket products have been used for yearswith success when it comes to hard to find or out of business fireplace manufacturers. Taking this costeffective change away from consumers is short-sighted and unjust to consumers.



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Bil Orlando, Jotul






HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren






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14.7.1.2


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November 13, 2014

NFPA 211 Committee

1 Batterymarch Park

Quincy, MA 02169-7471














Thank you,





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Bil Orlando, Jotul






HPBA Pacific Staff

Kaity Van Amersfort

Pat Rosengren






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14.7.1.2

Only listed or approved components or accessories for use with the specific model of factory-built fireplacesystem shall be permitted. Delete this section.


This proposal could potentially result in increasing the chance of fires, not preventing them, while seriously threatening the viability of all fireplace accessory manufacturers and the dealers and service people who sell, install and service them. Requiring fireplace accessories to be listed with specific factory-built fireplaces is problematic for the following reasons:

1) Unnecessary. Rasmussen Iron Works, Inc. has been a manufacturer of gas log sets since 1958. We have never, ever been sued for a fire caused by our gas log sets or a fire in which our products were installed, but other accessories were deemed to be the cause. In today’s litigious society, we would most certainly be named in a lawsuit of any fire surrounding a fireplace, regardless of the cause, and this has never, ever happened. If a chimney cap, damper mechanism, glass door or other accessory was the cause of a fire, Rasmussen would most certainly be named in the lawsuit if our gas log set was also installed, but this has never, ever occurred. Again, NFPA 211-2014 is a poor, dangerous solution for which no problem exists.



3) Restraint of trade and commerce. This section will have the effect of delegitimizing products with decades of perfect safety track records and consumer enjoyment. It will threaten the viability of manufacturers, dealers, installers and service people. We expect litigation to be filed to block this section should it be enacted.


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Organization: Hearth and Home Shoppe

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14.7.1.2


I find the proposed change to OEM parts only, a big step backwards and not in the best interest of safetyfor homeowners. Many times OEM parts are not available and the homeowner will continue to use theirprefabricated fireplace system by ignoring recommendations or worse by trying to fabricate a partthemselves to avoid paying thousands of dollars for a replacement fireplace for what they perceive as aninsignificant part of the system.

Another concern with the proposed change to OEM listed parts only is there is no data to support aproblem exists in the industry concerning aftermarket parts when they are installed for their intendedpurpose. If the same proposed standard were applied to other consumer products of only OEM partsdesigned for a specific make and model the world’s scrap yards would be full of cars, furnaces, andappliances. Or worse, consumers would try to rig up something on their own with what they had layingaround.

The proposed change will put the homeowner at a greater risk and cause lack of trust in the chimneyservice industry as a bunch of crooks looking to sell homeowners new fireplaces because of a percievedinsignificant OEM part that is no longer available. The distrust will be far reaching to include theperception of NFPA's credibility for supporting such an extreme standard of care that does nothing toimprove homeowner safety.

I applaud NFPA for adopting the three levels of inspection of a fireplace, stove or other venting system.The proposed change concerning aftermarket parts would present a huge financial burden and changeprocedures dramatically for the service and inspection of these systems. Many of the components used fora fireplace or venting system do not have readily accessible or even accessible markings to identify if theyare OEM parts. Some of the prefabricated parts that commonly do not have markings or have worn off arecaps, grates, firebox refractory panels, or fire screens. The proposed change would require a servicetechnician to become an engineer to determine if a part was OEM or aftermarket turning an inspection intoa forensic project costing hundreds if not thousands of dollars in financial burden to each homeownersfireplace.

These proposed changes will in effect take the chimney and fireplace service person out of the decisionmaking process for replacement parts. As stated many parts are not marked or visible to identify as OEMcomponents. The potential for liability will cause many chimney and hearth professionals to simply refuseto take on the liability risk of looking at an existing system for opinion. This will create a liability litigationmind set of "who touched it last, they own the system" and paint a huge target on service professionals.The end result will be alienation of hearth and chimney Inspectors as no one will want to assume theliability of not being able to identify unlabeled existing system parts.


Homeowners will be safer by not forcing the service technician to recommend unreasonable standards ie: replace entire fireplace system no cap available-replace entire fireplace system no refractory panel available, replace entire fireplace system no bracket or screw available. All parts are not currently marked for service technicians to be able to identify.

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Public Input No. 15-NFPA 211-2014 [New Section after 10.7.3.3]


Submitter Full Name: Howard Rowell


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14.7.1.2

Only listed Factory-built fireplace components or accessories shall be one of the following;

1. Listed or approved components or accessories for use with the specific model of factory-built fireplacesystem

shall be permitted..

2.Components a cceptable to and installed by a Certified Hearth Technician (National Fireplace Institute orChimney Safety Institute of America certified) in accordance with the terms of the fireplace listing providedthe fireplace's integrity is in no way compromised with its installation.

3. As Approved by the AHJ


This clause would prohibit the continued service of an approved factory built fireplace simply because a listed replacement component is no longer available. For example, a log grate has deteriorated or a glass panel on the door has been broken and the manufacturer of the fireplace no longer exists. A Certified Hearth Technician (National Fireplace Institute or Chimney Safety Institute of America certified) would access and install a comparable substitute albeit not listed for that fireplace. The AHJ may not possess the relative knowledge and therefore not be willing to approve the substitute component. The consumer refuses to accept the notion their fireplace can no longer be used simply because the manufacturer no longer exists and decides to source their own replacement which may or may not be suitable. The rule should provide the most practical direction for the safe operation of the fireplace.

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14.7.1.2


This statement should be removed. as it would prohibit the installation of gas logs and inserts that havebeen approved for the general installation into factory built fireplaces but not specific models. This clausewould also prohibit the continued service of an approved factory built fireplace simply because a listedreplacement component is no longer available. For example, a log grate has deteriorated or a glass panelon the door has been broken and the manufacturer of the fireplace no longer exists.


This statement as written prohibits the installation of gas logs and inserts that have been approved for the general installation into factory built and masonry fireplaces but not specific models. This clause would also prohibit the continued service of an approved factory built fireplace simply because a listed replacement component is no longer available. For example, a log grate has deteriorated or a glass panel on the door has been broken and the manufacturer of the fireplace no longer exists.

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Submittal Date: Tue Oct 28 16:56:19 EDT 2014


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14.7.1.2

Only listed or approved components or accessories for use with the specific model of factory-built fireplacesystem shall be permitted. [Section Deleted]



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Public Comment No. 95-NFPA 211-2014 [ New Section after A.3.3.2.1 ]

Public Comment No. 95 - NFPA 211 - 2014 [Section No. A.3.3.2.1]


Thomas Stroud's explanation on why this proposal needs a lot of work is very accurate.


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Public Comment No. 106-NFPA 211-2014 [ Section No. A.3.3.2.1 ]

A.3.3.2.1 Factory-Built Fireplace System Accessories.

These accessories include, but are not limited to, such items as decorative shrouds, glass or screen doorassemblies, grates , blowers, log lighters intended for the ignition of solid fuel, gas log decorativeappliances, spark arrestors, and chimney caps.

A.3.3.2.1 Factory Built Fireplace System Accessoies

These accessories include, but are not limited to items, as decorativie shrouds, glass or screen doorassembies, blowers, only Log Lighters that are not CSA certified intended for igniting firewood in woodburning fireplaces, gas log decorative appliances, spark rrestors and chimney caps.



CSA_CERT_FULL_REPORT_LOG_LIGTHERS.pdf

The CSA certification of the Blue Flame log lighters. We request that log lighters which are CSA certified are not included in the UL Testing. Only Log Lighters that are NOT CSA certified

CSA_8.93.pdfTHE CSA certification standards which Log Lighters for wood burning fireplaces are required to comply with 8-93.

BF_Installation_Guide.pdfinstallation guide for the Blue Flame Log LIghter

BF_BuildersLogLighterFlyerSDA_print.pdfphoto and Description of the CSA certified Blue Flame Log Lighter, which is the ONLY CSA certified log lighter on the market

Canterbury_Enterpries_UL_Leter_11-14-14.docxRequesting that Grates nor CSA certified log lighters are included in sections 3.3.2.1 and 3.3.2.2


We are requesting that the language is changed to reflect that if log lighters for wood burning fireplaces are CSA certified that they are exempt from being included in the Accessories. To specify that only log lighters which are NOT CSA certified, need to be tested with UL. CSA has written a standard 8-93 which outlines all the testing which log lighters must comply with in order to ensure Safety to the end user. Our products have been sold for over 60 years and there are millions out there and never once have we had any liability nor safety issue with the log lighters because we comply with the Standard.We also request that GRATES are eliminated from the sections also 3.3.2.1 and 3.3.2.2, since grates are only products which support the firewood in fireplaces and nothing to test.

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Submitter Full Name: lisa leighton

Organization: Canterbury Enteprises

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These accessories include, but are not limited to, such items as decorative shrouds, glass or screen doorassemblies, grates, blowers, log lighters intended for the ignition of solid fuel, gas log decorativeappliances, spark arrestors, and chimney caps.


The additional language is unnecessary. This proposed list of accessories is long, but not exhaustive. It includes decorative shrouds which is already covered in Section 6.1.5 and in Section 11.1.4. Further, it does not include refractory panels which is likely one of the most common components that are replaced in these units. The existing language is adequate and not confusing.

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These accessories include, but are not limited to, such items as decorative shrouds, glass or screen doorassemblies, grates, blowers, log lighters intended for the ignition of solid fuel, gas log decorativeappliances, spark arrestors, and chimney caps.


The proposed new text is broad and overreaching when viewed in context with the related annex note. The proposed new definition (3.3.2.1) for accessories includes shrouds, glass or screen doors, grates, blowers, log lighters, gas logs, and caps. The proposed change to Section 11.1.5 requires that accessories be specifically listed or approved by the AHJ. Since these items are generally not listed for the specific model of fireplace then the only way to comply with this requirement will be to have each installation approved by the AHJ. It is impractical to think that the AHJ would ever give such approval because they do not have the time or experience to make these evaluations. There is a long standing history of after market parts and there was no credible evidence presented that the use of after market parts creates a hazard. This proposal creates a costly and unnecessary burden on consumers. There are many brands and models of fireplaces where OEM parts are no longer available so the consumer is forced with spending thousands of dollars for a new fireplace simply because they need a cap or grate. AHJ’s are not going to give approval and service techs/installers are going to look and sound like crooks when they try to sell a new fireplace simply because the current fireplace needs a new cap or grate. Another concern here is the inclusion of “gas log decorative appliances” in the definition. Under these proposed new requirements gas logs will now have to be specifically listed for each model of fireplace they are to be installed in. Gas logs are tested under a separate standard but they are not tested for each model of fireplace that they may be installed in, and there is no evidence to suggest that this should now be required. Where is the evidence to suggest these proposed changes are necessary. Code writers should not create costly new requirements unless there is a proven safety problem that needs to be addressed. How will insurance companies respond when presented with an expensive bill to replace an entire fireplace & chimney system simply because a sudden occurrence like a hurricane blew the chimney cap off an otherwise serviceable system?

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These accessories include, but are not limited to, such items as decorative shrouds, glass or screen doorassemblies, grates, blowers, log lighters intended for the ignition of solid fuel, gas log decorativeappliances, spark arrestors, and chimney caps non-integral grates and vented gas log sets .


I think that most of the examples here are either clearly components rather than accessories (as newly defined in Public Comments 77 [3.2.2] and 78 [New section after 3.3.14.2]), or it is debatable whether they are accessories or components. (In the case of decorative shrouds, I think this term has changed from its original meaning in the 1992 Edition of 211 [decorative shroud then I think meant a panel surrounding a fireplace insert] to a type of chimney termination [defined in 2013 edition 3.3.52] that is prohibited for factory-built chimneys unless listed [2013 6.1.5] that clearly should not be listed here.) I can provide detailed substantiation for each example if needed; basically my criteria has been based on consistency with UL127 Factory Built Fireplaces requirements for fireplace system parts.

I can only provide two examples that are relatively clearly accessories (in the case of grates, UL 127 (2011 7.14) calls specifically for the manufacturer’s model for integral grates that are attached to the bottom of the firebox).

Another option would be to delete this informational reference altogether. If accessories are re-defined and distinguished from components for factory-built fireplaces, I’m not sure this information is greatly needed or particularly helpful unless it’s needed to distinguish from masonry fireplace accessories (which I am deferring to someone more knowledgeable about accessories and their listings).

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Public Comment No. 96-NFPA 211-2014 [ New Section after A.3.3.2.2 ]

Public Comment No. 96 - NFPA 211 - 2014 [Section No. A.3.3.2.2]

Masonry Fireplace and Chimney Accessories

Our Fireplace Doors are not designed to be in a closed position while a wood fire is burning or while gaslogs are burning. This is an unsafe practice.

This NFPA Proposal raises more issues than it solves.


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A.3.3.2.2 Masonry Fireplace and Chimney Accessories.

These accessories include, but are not limited to, such items as heat exchangers, glass or screen doorassemblies, grates , andirons, blowers, log lighters intended for the ignition of solid fuel, fire backs intendedto reflect heat or reduce heat exposure, dampers, gas log decorative appliances, spark arrestors, chimneycaps, and ash receptacle doors.

A.3.3.2.2 Masonary fireplace and chimney accessories

These accessories include, ut are not limited to such itmes such as , heat exchangers, glass or screendoor assemblies, andrions, blowers, Log lighters for wood burning fireplaces that Are NOT CSAcertified.......



CSA_CERT_FULL_REPORT_LOG_LIGTHERS.pdf Blue Flame Log lighters CSA certifications

CSA_8.93.pdfCSA 8-93 standard for log lighters for wood burning fireplaces

BF_Installation_Guide.pdfinstallation instructions for Blue Flame log lighters for wood burning fireplaces

BF_BuildersLogLighterFlyerSDA_print.pdf Blue flame Log lighter photo and descriptions

Canterbury_Enterpries_UL_Leter_v1_11-14-14.docxletter requesting revision of the exemptions of GRATES and CSA certified Log Lighters for sections 3.3.2.1 and 3.3.2.2


Our Log Lighters comply with the CSA 8-93 standard which was written for Log Lighters which ignite firewood in wood burning fireplaces. This ensures safety to the end user and we have been manufacturing Blue Flame Log LIghters since 1954 and have millions in homes. We have never had a liability issue with regard to our Log Lighters as the standard testing does ensure Safety of the product. Therefore, we ask the change in sections 3.3.2.1 and 3.3.2.2 to state that CSA Certified Log Lighters are exempt from UL Testing. Also we request that Grates which hold firewood in fireplaces are exempt from 3.3.2.1 and 3.3.2.2 since they sole purpose is to support firewood. Thank you very much

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Submitter Full Name: lisa leighton

Organization: Canterbury Enteprises

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These accessories include, but are not limited to, such items as heat exchangers, glass or screen doorassemblies, grates, andirons, blowers, log lighters intended for the ignition of solid fuel, fire backs intendedto reflect heat or reduce heat exposure, dampers, gas log decorative appliances, spark arrestors, chimneycaps, and ash receptacle doors.


The additional language (a long list of accessories) is not necessary. Also, when does an integral component of the fireplace such as a damper, ash dump door, etc. become an accessory? This adds confusion instead of clarification.

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These accessories include, but are not limited to, such items as heat exchangers, glass or screen doorassemblies, grates, andirons, blowers, log lighters intended for the ignition of solid fuel, fire backs intendedto reflect heat or reduce heat exposure, dampers, gas log decorative appliances, spark arrestors, chimneycaps, and ash receptacle doors.


This entire Annex section should be deleted. These proposals will put a huge burden on the industry. Annex Section 3.3.2.2 defines a long list of items as masonry fireplace and chimney accessories. This list includes heat exchangers, glass or screen doors, grates, blowers, log lighters, firebacks, gas logs, chimney caps and ash dump doors. 11.2.10 states these items must be listed or approved by the AHJ. Since these items often are not listed consumers and installers will need to consult the AHJ for approval each time they install one of these items. Does the AHJ have the time or experience to make these evaluations? Additionally, no criteria are provided for the AHJ to evaluate and determine if a product is acceptable. There also does not seem to be any logical reason to make this drastic change. What evidence was presented to the committee that demonstrates a need to require listed or AHJ approved accessories on unlisted, field constructed fireplaces and chimneys?

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Attachment C: All other Public Comments


1.1 Scope.

This standard applies to the design, installation, maintenance, and inspection of all chimneys, fireplaces,venting systems, and solid fuel–burning fuel burning appliances.


I like as is. Don't change anything.

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Submitter Full Name: Randy Brooks

Organization: Brooks Chimney Sweeping

Affilliation: Member

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Component.

Constituent part of a hearth appliance or chimney; subject as part of the whole to safety testing and listing.


A definition for “component” is needed as part of the process of distinguishing accessory (defined in my Public Comment 77 [3.3.2] as a supplementary part or device added to an appliance in order to make it more useful, versatile, etc. and component, which is an integral part of the hearth system (appliance and/or chimney). These distinctions are important for proposed changes to Chapter 11 in Public Comment 79, 14.7.1 in Public Comment 80, and A.3.3.2.1 in Public Comment 81.



Public Comment No. 91-NFPA 211-2014 [SectionNo. 3.3.2]

Distinguishes differences between accessories andcomponents.

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4.6.2 Rain Cap Height.

The minimum distance from the underside lowest point of the underside of an unlisted single-flue rain capto the top of covered flues shall be the lesser dimension of the width or depth of the covered flue thecovered flue shall be 6 inches (150mm) . Where more than one flue is covered, the lesser dimension of thehighest minimum distance from the lowest point of the underside of an unlisted rain cap to the top of thecovered flue shall be used 6 inches (150mm) .


We like the Committee Input changing the current text. However, using one dimension for single and multiple flues is easier, consistent and results in better enforcement. As proposed in the Committee Input, we are not sure why for multiple flues 6 inches is reduced by one inch. We believe it should remain the same (or even be larger). The unanswered question is what is the benefit to safety for the reduced size for multiple flues?

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Committee Input No. 2-NFPA 211-2014 [Section No. 4.6.2]





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6.4 Installation.

Factory-built chimneys and chimney units installed through insulation or areas to be insulated shall beseparated by a physical barrier to establish and maintain the minimum air space clearance required by thechimney manufacturer.


This is adequately addressed by manufacturers installation instructions. This is often accomplished by a metal shroud as part of the installation instructions. Requiring a “physical barrier” is vague. It could require filling the void, and it does not set the amount of clearance. And it could allow that the “physical barrier” be combustible.

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First Revision No. 7-NFPA 211-2014 [New Section after 6.3]





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7.1.2 * Corbeling.


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Individual and maximum projections of corbels in masonry chimneys shall comply with the requirements ofthis section. [See Figure 7.1.2(a) through Figure 7.1.2(e d ).]

Figure 7.1.2(a) Corbels for Supporting Chimneys.

Figure 7.1.2(b) Corbels to Change Chimney Direction.

Figure 7.1.2(c) Corbels to Increase Chimney Wall Thickness.


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Figure 7.1.2(d) Corbels to Support Flue Lining.

Figure 7 Figure A7 .1.2(e) Corbels 2 Corbels to Incorporate Wall Pass-Through.


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7.1.2.1

Corbeling limitations shall be permitted to be varied for engineered, reinforced, brick masonry construction.

7.1.2.2

Individual corbels occurring at any point within a masonry chimney shall not exceed one-half the individualmasonry unit height or one-third the thickness.

7.1.2.3

The following shall apply to masonry chimney supports:

(1) They shall be permitted to be formed by corbeling from a wall that is not less than 12 in. (305 mm) inthickness to form a maximum total projection of not more than one-half the wall thickness.

(2) Where the corbeling specified in 7.1.2.3 (1) projects equally on each side of the wall, the masonrychimney support shall be permitted to be formed by corbeling from a wall that is not less than 8 in.(203 mm) in thickness to form a maximum total projection on each side of the wall that is not morethan one-half the wall thickness.

7.1.2.4

Corbeling used to change the direction of a masonry chimney shall have a maximum offset so that thecenterline of the upper flue does not fall beyond the center of the lower flue wall. The cross-sectional areaof the flue shall not be reduced throughout the offset.

7.1.2.5

Corbeling used to increase the chimney wall thickness shall have a maximum total projection that does notexceed the thickness of the chimney wall.

7.1.2.6

Corbeled or solid masonry shall be provided in masonry chimneys to support the entire perimeter of flueliners.

7.1.2.7

Where a flue is constructed of two flue liners without a separation, three sides of each flue liner shall besupported entirely on corbeled masonry.

7.1.2.8

Corbels shall be made with solid units, and, where corbels are located on the walls of hollow masonry units,there shall be no fewer than three courses of solid masonry units below the corbels.

7.1.2.9

Corbeling used to incorporate wall pass-through shall be constructed in accordance with 7.1.2 and Figure7.1.2(e).


We agree with the negative comments. This figure is incomplete and needs more dimensions to be added. We also agree with the affirmative comment that the dimensions need to be identified as minimums. As such, we suggest relocating the figure to the Annex until it is more specific.

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7.1.4.1.1

Where the drop from the connector inlet to the base of the chimney flue is less than 12 in., the connectorinlet shall be permitted to be used as the means of access for cleaning


It is understandable that a clean out will not fit in such cases. But the concern is that the removal and reattachment not degrade or compromise the system over cyclic removal. Also delete the "and approved by the AHJ", just add the requirement.

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Committee Input No. 15-NFPA 211-2014 [New Section after 7.1.4.1]





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9.7.4

Connectors for residential-type appliances ( Table 5.2.2.1 , Column I) shall be permitted to pass throughwalls or partitions constructed of combustible material if one of the following is true of the connector:

(1) It is listed for wall pass-through and is installed in accordance with the conditions of the listing.

(2) It is incorporated into the chimney construction in accordance with 7.1.2.9 .


no changes needed. there is no evidence presented that the field constructed methods are inadequate.

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Affilliation: ncsg president

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9.7.4

Connectors for residential-type appliances (Table 5.2.2.1, Column I) shall be permitted to pass throughwalls or partitions constructed of combustible material if one of the following is true of the connector:


(2) It is incorporated into the chimney construction in accordance with 7.1.2.9.


No credible evidence of the need for drastic changes putting undue financial burden on the consumer with no documentation of a safety issue or fire hazard.

Section 9.7.4 revises the wall pass through requirements by eliminating the four field constructed wall pass through systems (Figure 9.7.5 in 2013 edition) and requiring only a listed wall pass through or one alternative field constructed method. There was no evidence presented that the field constructed methods were inadequate.

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9.7.4

Connectors for residential-type appliances (Table 5.2.2.1, Column I) shall be permitted to pass throughwalls or partitions constructed of combustible material if one of the following is true of the connector:


(2) It is incorporated into the chimney construction in accordance with 7.1.2.9.

(3) It is installed in accordance with one of the methods described in Figure 9.7.5 (Also restore Figure9.7.5 from 2013 edition to the Standard.)


The four wall pass through methods described in Figure 9.7.5 (previous editions) were added to the code based on research and testing that indicated they provided acceptable levels of safety. There was no evidence presented to the contrary and these field constructed options should be returned to the Standard.

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10.7.3.4 Maximum Run

Clothes dryer exhaust ducts shall have a maximum length not exceeding 35 feet as measuredfrom the dryer terminal to the outlet. Reductions of 2-1/2 feet shall be made in the maximum lengthof the duct for each 45-degree bend and 5 feet in the maximum length of the duct for each90-degree bend. The transition duct shall not be included in the maximum length of the duct.

10.7.3.4.1 Where the manufacturer’s installation instructions for the dryer is different than the maximumlength specified in 10.7.3.4, the exhaust duct shall be in accordance with the dryer manufacturer’sinstallation instructions.


The TC said it could find no national standard that included a limitation of 35 ft or similar length limitation. The International Mechanical Code 2009 section 504.6.4.1 states: “The maximum length of the exhaust duct shall be 35 feet…”

Again, NFPA reports that in 2010, an estimated 16,800 reported US non-confined or confined home structure fires involving clothes dryers or washing machines resulted in 51 civilian deaths, 380 civilian injuries and $236 million in direct property damage. Clothes dryers accounted for 92% of the fires. The leading cause of home clothes dryer and washer fires was failure to clean (32%).

This proposed revision is in line with NFPA's mission "to reduce the worldwide burden of fire..." Long of exhaust runs will cause a build up of lint as air flow diminishes on longer runs. This ultimately reduces the risk of fire.

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Public Input No. 15-NFPA 211-2014 [New Section after 10.7.3.3]





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Public Comment No. 68-NFPA 211-2014 [ Chapter B ]

Annex B Field Constructed Wall Pass-Through Systems

This annex is not a part of the requirements of this NFPA document but is included for informationalpurposes only.

B.1 General.

Annex B provides information on field-constructed wall pass-through systems. This annex provides amethod by which to identify or compare old systems to ensure that they were installed and maintained inaccordance with the “grandfathered” method, and it is reprinted here for the convenience of those wheresuch systems exist. This annex does not apply to new construction of wall pass-throughs. See 9.7.4 forrequirements on new wall pass-through systems.

B.2

The following applies to existing wall pass-through connectors for residential-type appliances ( Table5.2.2.1 , Column I) with inside diameters less than or equal to 10 in. (254 mm):

(1) The connectors can pass through walls or partitions constructed of combustible material to amasonry chimney, provided the connector system selected or fabricated is installed in accordancewith the conditions and clearances specified in Figure B.2 .

(2) Any unexposed metal that is used as part of a wall pass-through system and is exposed to fluegases must be constructed of stainless steel or other equivalent material that resists corrosion,softening, or cracking from flue gases at temperatures up to 1800°F (982°C).

(3) Insulation material used as part of a wall pass-through system must be of noncombustible material

and have a thermal conductivity of 1.0 Btu-in./hr-ft 2 -°F (0.14 W/m-K).

(4) Any material used to close up an opening for the connector must be of noncombustible material.

(5) A connector to a masonry chimney, except for System B in Figure B.2 , must extend in onecontinuous piece through the wall pass-through system and the chimney wall to the inner face of theflue liner, but not beyond.

Figure B.2 Chimney Connector Systems and Clearances from Combustible Walls for ResidentialHeating Appliances.


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Remove this material from the Annex and return it to the Standard. The four wall pass through methods described in Figure 9.7.5 (previous editions) were added to the code based on research and testing that indicated they provided acceptable levels of safety. There was no evidence presented to the contrary and these field constructed options should be returned to the Standard.

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Attachment D: CI No. 2: Rain Cap Height

Committee Input No. 2-NFPA 211-2014 [ Section No. 4.6.2 ]

4.6.2 Rain Cap Height.

The minimum distance from the lowest point of the underside of an unlisted single-flue rain cap tothe top of the covered flues shall be the lesser dimension of the width or depth of the coveredflue flue shall be 6 inches (150 mm) . Where more than one flue is covered, the lesser dimension ofthe highest flue shall be used minimum distance from the lowest point of the underside of anunlisted rain cap to the top of the covered flue shall be 5 inches (125 mm) .


Submitter Full Name: [ Not Specified ]


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Submittal Date: Wed May 14 12:46:02 EDT 2014

Committee Statement and Meeting Notes

CommitteeStatement:

The committee revised the rain cap height to solicit public comment and to allow for thecompletion of a research project under the auspices of the Fire Protection ResearchFoundation. The values provided are based on common industry practice applicable tometal rain caps on masonry chimneys.

ResponseMessage:


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