Comment NumberOL-100587
OrganizationAutomatic Fire Alarm Association
Received05/31/2005 03:24:48 PM
Commenter
First NameLast NameState/Province
ThomasHammerbergFL
AgencyU. S. Department of Justice
Docket IDCRT Docket No. 2004-DRS01
RuleNondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities
AttachmentsNo Attachments

CommentsAnswers to Specific Questions

General Comments
As written: 215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the wiring system shall be designed so that visible alarms complying with 702 can be integrated into the alarm system. The problem: The current wording is not specific as to its intent and is too open-ended. It is not clear as to what the designer and installer must provide and therefore will lead to finger- pointing and cause contractual and enforcement problems. There are many open-ended questions that result from the existing wording, such as: - What is meant by a wiring system? - Where should the wiring terminate? - Are the wiring systems to include backboxes? Where should the backboxes be located? - What size wires are to be provided? - Does the wiring system intended also require equipment to be provided? Power supplies and notification appliance circuits? Space in the fire alarm control panel? - Should the wiring be shielded? - Do the other circuits in the same conduit have to be shielded? (This can be system equipment dependent) Note: as written, the current provision does not reduce the initial construction costs, it will increase them. Because of the unclear language, installers are forced to add "contingency" amounts because they do not know what is expected and what will be required. Requirements should, at least, allow for a consistent and fair way to provide installation pricing. Recommended wording: 215.3 Employee Work Areas. Where employee work areas have audible alarm coverage, the visible notification appliance circuits in the proximity of employee work areas shall be designed with a minimum of 15% spare capacity to account for the potential of adding visible appliances in the future to accommodate hearing impaired employee(s). Substantiation: The recommended wording accomplishes the original intent by providing capacity to expand, while making the requirement clear.