Same deal here in Illinois.  State licensing code for sprinkler contractors 
requires compliance with current 13, 20 etc.  State licensing code for 
healthcare facilities follows the lead of the Feds, which uses the 2000 LSC and 
the 1999 13.
 
As an engineer, I generally require compliance with the current standard and 
also reference the locally adopted one or facility licensing one.  I then 
specify compliance with the more stringent, or the one providing the greater 
level of safety.  So far, no RFI's on conflicts that cannot be resolved in this 
fashion.  For example, if the one says max 130 sq ft and the other says max 100 
sq ft, then give them the 100 sq ft area and that satisfies both.
 
Any specific issues come up?

Dave 

David A. de Vries, P.E., CSP 
Firetech Engineering Incorporated 


--- On Thu, 1/28/10, George Church <[email protected]> wrote:


From: George Church <[email protected]>
Subject: Quandry-design to two editions of 13?
To: [email protected]
Date: Thursday, January 28, 2010, 10:20 AM


I'm close to going postal. It's been over a year since I posed a question to
PA's departments of Health and Labor & Industry, and we've still yet to
receive other than conflicting direction. I'm sure this occurs in other
jurisdictions throughout the US and maybe someone has solved this, it
certainly is not unique to PA.



Summary:

PA DOH enforces compliance with the 1999 edition of NFPA 13 because it is
the referenced edition in the 2000 Life Safety Code used by the Centers for
Medicare and Medicaid Services (Federal Health and Human Services). Both PA
DOH and CMS itself have reiterated clearly that they will accept ONLY
compliance with the 1999 edition; they really don't care if a newer code is
deemed equal or better protection by NFPA, or what edition of NFPA 13 is
referenced by the applicable local building code. 



PA's Dept of Labor and Industry is charged with administration and
enforcement of the PA Uniform Construction Code, now based on the 2009
I-Codes, so NFPA 13-2007 edition is now our standard. Under Pennsylvania
law, all facilities that are regulated by the Health Care Facilities Act
must also comply with the requirements of the Pennsylvania Construction Code
Act and its regulations.



Quandry:

So- how do we design a system to simultaneously comply with both 1999 and
(for now) 2007 editions of NFPA 13?



We cannot comply simply with the more recent standard as equal or better,
that'd be too easy. CMS and DOH have both stated this is unacceptable.



Now we're certainly not the only sprinkler contractor doing work in health
care and nursing homes where CMS mandates apply- i.e., anywhere
reimbursement for services is covered by Medicare and/or Medicaid. And PA is
not the only state adopting a code with post-1999 #13 as the adopted
standard.



What are the rest of you doing to comply? 



George Church

Rowe Sprinkler







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