In my September column, I predicted that "limited combustible" cable—by some other, yet-to-be-determined name would be a listing in the NEC 2005 and that CMP would be in a very precarious position by publication of NEC 2008. Recently, this saga has seen some very interesting twists.
In previous columns you were introduced to the National Fire Protection Association Technical Committee on Air Conditioning, author of NFPA 90A, the Standard for Air Conditioning and Ventilation Systems; and to The NFPA National Electrical Code Committee. Now we need to meet a few even bigger players.
NFPA Standards Council. The NFPA Standards Council is a committee appointed by the NFPA Board of Directors, to oversee NFPA's codes and standards development activities and the regulations governing committee projects. It's sort of the NFPA's version of the "U.S. Supreme Court."
One of the Standards Council's primary responsibilities is to assure due process during the writing of all NFPA codes and standards. The Standards Council issues all NFPA codes and standards. Following the public input and vote of the NFPA membership, the Standards Council meets, considers any appeals, passes judgment on all outstanding items, and issues the documents.
NEC Technical Correlating Committee. The NEC Technical Correlating Committee is assigned to manage and coordinate code requirements between the various NEC Code Making Panels (CMPs). It's sort of the NFPA's version of a "State Supreme Court."
In September 2003, James W. Carpenter, NEC Technical Correlating Committee chair, "gave direction" to the NEC CMPs regarding the issue of air duct cable, "to address the proposals and comments related to plenum cables based on their technical merits and to not base their decision on the jurisdictional issue being raised by reference to the decision of the Standards Council from 1980."
In his September 25, 2003 letter to Philip DeNeno, NFPA Standards Council chair, Carpenter explained why.
A series of proposals made to NEC CMP 3 and CMP 16, which would separate the present requirements of air-handling spaces into spaces with various names and definitions and create air duct cable, has created significant controversy in NFPA 90A and in the processing of the 2002 and 2005 NEC.
The two code-making panels took different actions on the proposals, and a task group of members from the two panels was established to review the proposals and develop appropriate comments. But the task group bogged down over a turf issue based on the 1980 Standards Council decision 80-60, which stated that the Technical Committee on Air Conditioning has primary jurisdiction over combustibles in plenums.
Secondly, there are various interpretations of Standards Council decision 02-78(d) that appears to direct the Technical Committee on Air Conditioning to harmonize the fire-flammability and smoke-production test requirements for plenum cables so as to produce a single minimum acceptable performance level.
According to minutes from an October 23, 2003 meeting, the Standards Council agreed and decided to set the record straight. From those minutes: "The Council understands the difficulty posed to the NEC project in processing revisions concerning cable in air handling spaces prior to the subject being fully addressed by the TC on Air Conditioning in NFPA 90A. Proceeding to make changes to the NEC, however, that may be inconsistent with the approach soon to be taken in NFPA 90A, does not appear wise or necessary. The Council believes that the best course of action for the NEC project is to generally refrain, unless absolutely necessary, from making revisions that interrelate with NFPA 90A in advance of completion of the latest revision cycle of NFPA 90A, and instead to maintain the status quo in the NEC project on the applicable technical subjects pending the completion of the NFPA 90A revision cycle. The CMPs should, if desired, participate in the development of revisions to NFPA 90A through the submittal of proposals and comments to NFPA 90A during its current revision cycle."
Translation: CMP 3 and CMP 16 are to make no changes to the NEC 2005 on all issues related to NFPA 90A.
Just in case things are not confused enough, there is Standards Council Decision 02-07. In the July 15-19, 2002 Standards Council minutes, the Council stated its concern:
"that the provisions concerning minimum plenum cable requirements in sections (NFPA 90A) 2.3.10.2.6.1 and 2.3.10.6.4.1 are inadvisable, as they create a scheme of two alternative minimums (non- or limited-combustible listing, and listings based on NFPA 262, Standard Method of Test for Flame Travel and Smoke of Wires and Cables for Use in Air-Handling Spaces) that do not appear to be equivalent. The Council, therefore, directs that the Technical Committee, during the next revision cycle, proceed to harmonize the fire flammability and smoke production test requirements for plenum cables so as to produce a single minimum acceptable performance level."
Translation: In NFPA 90A-2002 there are two methods of determining if electrical wires and cables and optical fiber meet the minimum requirement for placement in plenums, but they are not equal.
With the Standards Council directive being interpreted different ways, the October 23, 2003 Standards Council minutes clarify the original intention.
"03-10-11..Nothing the Council said was meant to suggest that it is inappropriate to set different minimum performance levels for different uses or applications. Rather, the Council's decision was merely trying to state what it believes to be generally accepted good code-writing practice, which should not be difficult to understand or apply ..."
Recently I had lunch with a principal member of the NFPA Air Conditioning Committee, who rather smugly explained that the committee was under orders from the NFPA Standards Council to choose one (plenum) cable. (I guess 3-10-11 may not be widely circulated yet.) He went on to explain that he would, of course, have to choose the "safest" cable.
NFPA 90A, 2002 Edition Section 1.1, Scope, states: "This standard shall cover construction, installation, operation, and maintenance of systems for air conditioning and ventilating, including filters, duct, and related equipment, to protect life and property from fire, smoke, and gases resulting from fire or from conditions having manifestations similar to fire."
The scope is the only mention of protecting life and property from gases. Shouldn't testing for the "safest" cable include toxicity? I believe that they should either put the requirements in or take the reference to gas out of the scope. The current scope is misleading the consumer into a false sense of what is "safe".
Donna Ballast is BICSI's standards representative, and a BICSI registered communications distribution designer (RCDD). Send your questions to Donna via e-mail: [email protected]