To: Florida ICC Voting Members
From: Concrete Coalition of Florida
In Re: Vote No on Tall Wood Buildings ─Items G108-18, G75-18, G80-18, and G84-18
Florida ICC Voting Member:
Please consider this an earnest request to vote to DISAPPROVE code changes permitting the use of cross-laminated timber (CLT) to construct wood buildings up to 18 stories and 120 feet in height. (Proposals G108-18, G75-18, G80-18, and G84-18). The reason is simple: as a new construction material, cross-laminated timber hasn’t been tested, scrutinized, or demonstrated to provide the same level of life safety as current code-recognized materials. CLT isn’t ready for the IBC.
While we will readily admit, thereare materials biases and concerns about competing materials and market share, the major concern of the concrete and masonry industries is fire and life safety of occupants and firefighters in tall buildings. The five fire demonstrations conducted on these materials in no way qualifies CLT to be considered noncombustible or the equivalent of noncombustible materials. This issue shouldn’t come down to wood versus concrete, masonry, or steel – or which system has market share advantages. The issue is simply a question of preserving life safety and property protection through our building codes.
Both the International Association of Fire Chiefs (IAFC) and the National Association of State Fire Marshals (NASFM) have published position papers opposing the adoption of these changes. Both organizations agree that the proposals are not justified in their current form. The five fire demonstrations conducted do not answer all the questions and the proposals “go too far too fast.” The five fire demonstrations conducted for the proposals in no way qualify as “live” fire testing and do not account for real life fire conditions. According to the NASFM:
“In support of our opposition, consider the following aspects of the three proposals:
Similar objections tothe technical aspects of the proposals are statedin the IAFC Position Statement ─Tall Wood Buildings. The IAFC adds the fact that the fire services at current reduced manninglevels cannot adequately fight fires in the proposed buildings. The proposed construction raises concerns about firefighters that may have to enter such buildings during a fire event. The IAFC position paper goes on to say:
As with all other forms of code-recognized construction, proponents of CLT construction should:
Until then, CLT isn’t ready for the IBC, andits addition now is premature.
In closing, please take the option that safeguards the lives of Florida citizens occupying tall buildings, firefighters called upon to fight fires in tall buildings, and increases property protection, and vote for DISAPPROVAL on items G108-18, G75-18, G80-18, and G84-18.
From: Concrete Coalition of Florida
In Re: Vote No on Tall Wood Buildings ─Items G108-18, G75-18, G80-18, and G84-18
Florida ICC Voting Member:
Please consider this an earnest request to vote to DISAPPROVE code changes permitting the use of cross-laminated timber (CLT) to construct wood buildings up to 18 stories and 120 feet in height. (Proposals G108-18, G75-18, G80-18, and G84-18). The reason is simple: as a new construction material, cross-laminated timber hasn’t been tested, scrutinized, or demonstrated to provide the same level of life safety as current code-recognized materials. CLT isn’t ready for the IBC.
While we will readily admit, thereare materials biases and concerns about competing materials and market share, the major concern of the concrete and masonry industries is fire and life safety of occupants and firefighters in tall buildings. The five fire demonstrations conducted on these materials in no way qualifies CLT to be considered noncombustible or the equivalent of noncombustible materials. This issue shouldn’t come down to wood versus concrete, masonry, or steel – or which system has market share advantages. The issue is simply a question of preserving life safety and property protection through our building codes.
Both the International Association of Fire Chiefs (IAFC) and the National Association of State Fire Marshals (NASFM) have published position papers opposing the adoption of these changes. Both organizations agree that the proposals are not justified in their current form. The five fire demonstrations conducted do not answer all the questions and the proposals “go too far too fast.” The five fire demonstrations conducted for the proposals in no way qualify as “live” fire testing and do not account for real life fire conditions. According to the NASFM:
“In support of our opposition, consider the following aspects of the three proposals:
- There is no scientific basis for increasing height and area limits beyond what is currently allowable in code.
- There has been no live fire testing at the limits being proposed.
- There has been no “wind aided” fire testing conducted.
- There is incomplete data regarding the fire loading of test burn buildings.
- “Professional Judgement” is insufficient justification for a change of this magnitude.
- No indication that any seismic testing has been performed or evaluated which goes to the issue of resiliency and sustainability.
- To allow a proliferation of larger, taller wood buildings without proper testing and justification is premature and would impact the fire suppression environment significantly.” (Source: Position Statement Cross-Laminated Timber in the Construction of Tall Wood Buildings G75-18, G80-18, and G84-18, National Association of State Fire Marshals.) (Full NAFM Position Statement follows.)
Similar objections tothe technical aspects of the proposals are statedin the IAFC Position Statement ─Tall Wood Buildings. The IAFC adds the fact that the fire services at current reduced manninglevels cannot adequately fight fires in the proposed buildings. The proposed construction raises concerns about firefighters that may have to enter such buildings during a fire event. The IAFC position paper goes on to say:
- “The proposals provide a greater per floor area increase than what is allowable for buildings constructed of concrete and steel. Technical justification has not been provided to substantiate the increase in these areas.” , and
- “The proposals lack a complete technical basis for height and stories utilized in the changes. There has been discussionthat this type of construction has a fire- resistive rating similar to that of concrete typically used in fire-resistive and noncombustible construction, although it has not been fully justified. The data is derivedfrom the previously mentioned fire demonstrations.” (Source: International Association of Fire Chiefs, Position Statement ─The Use of Cross-Laminated Timber in the Construction of Tall Wood Buildings.)(Full IAFC Position Paper follows.)
As with all other forms of code-recognized construction, proponents of CLT construction should:
- Finish their testing and research on the structural and fire performance attributes of CLT;
- Allow the design and regulatory communities to vet the results of these investigations; and
- Make appropriate and well-informed decisions on how CLT construction is reflectedin the building code.
Until then, CLT isn’t ready for the IBC, andits addition now is premature.
In closing, please take the option that safeguards the lives of Florida citizens occupying tall buildings, firefighters called upon to fight fires in tall buildings, and increases property protection, and vote for DISAPPROVAL on items G108-18, G75-18, G80-18, and G84-18.