NFPA is proposing a requirement for anyone who does door checks be certified. As you know, lobbyists for large corporations have unlimited resources to produce and propose additional regulations and requirement language. Most of the time it adds cost and complexity to our work without providing a benefit.
Please take some time to comment on NFPA’s proposed Tentative Interim Amendments (TIAs1801 & 1802). You can use the language below as a base but change the wording a little if possible (ChatGPT is great to help with wording). You’ll just need to reference the TIA you are responding to (there are two) and include whether you accept or OPPOSE. ASHE’s stance is to oppose – see reasoning below.
It’s really simple to do, only takes a couple minutes and could have a great impact on our operations.
NFPA is seeking public comments on two Tentative Interim Amendments (TIAs1801 & 1802). These TIAs would create/replace the general definition of “Qualified Persons” (Below) with definition for rolling steel fire door technicians (in the TIA materials in the link below).
Current general definition:
Qualified Person.
A person who, by possession of a recognized degree, certificate, professional standing, or skill, and who, by knowledge, training, and experience, has demonstrated the ability to deal with the subject matter, the work, or the project.
Proposed amendment:
A technician with documented training and who is qualified through experience with the inspection, testing, and maintenance of rolling steel fire doors.
ASHE’s position:
A door technician doesn’t need to have a specific title to be able to perform Inspection Testing and Maintenance activities. This requirement will lead to not only additional/burdensome documentation but has potential to require increased outsourcing in order to meet the requirement should current technicians not have appropriate documentation or training. Someone that has been doing this work and is technically competent should continue to be able to do that work. The Qualified Person definition adequately achieves this.
We are concerned that this change will set the foundation for future restrictions and will set a precedent for several definitions for those that perform Inspection Testing and Maintenance duties. For those trying to comply with the codes as well as those trying to enforce the codes this consistency helps reduce ambiguity in the interpretations and the application of the requirements is easier to manage if you have a single consistent requirement.
We need your help!
- Visit this website: https://www.nfpa.org/codes-and-standards/nfpa-80-standard-development/80 [nfpa.org]
- Scroll to the section Tentative Interim Amendment (TIA) You can click on view or download to review the amendments (also attached)
- At the bottom of the PDFs, you’ll see a link “SUBMIT A COMMENT”. This will generate an email where you can express your concerns (in your own words) directly to NFPA.
Deadline for comments: October 25, 2024
If you have any questions or additional thoughts, please feel free to send those to me directly. Happy to discuss further.
Here are the attachments as links for your review:
Proposed_TIA_1801_NFPA_80.pdf
Proposed_TIA_1802_NFPA_80.pdf
Add your comments and collaborate with others in real time. You don’t need to download Acrobat or sign up to access the file.
