Issue View | Council I | 2023 Biennial Meeting

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Amend Food Code - Strike “leaking automatic fire sprinkler heads"

The National Fire Sprinkler Association (NFSA) requests that the wording "leaking automatic fire sprinkler heads" be removed from Pages 66, 111 and 127 in the US FDA 2022 Food Code. This language should be stricken as US fire, building, and property maintenance codes address this matter and are enforced by other code officials and authorities having jurisdiction (AHJ) through nationally adopted model codes and standards. These codes and standards are developed through a full, open, consensus-based process. Language to be changed is here:

FDA 2022 Food Code
Page 66 3-305.12 Food Storage, Prohibited Areas (G) Under leaking water lines, including leaking automatic fire sprinkler heads, or under lines on which water has condensed.

Page 111 4-401.11 Equipment.... (6) Under leaking water lines including leaking automatic fire sprinkler heads or under lines on which water has condensed.

Page 127 4-903.12 Prohibitions. (6) Under leaking water lines including leaking automatic fire sprinkler heads or under lines on which water has condensed.

The FDA Food Code language "leaking automatic fire sprinkler heads" should be stricken from the 2022 Food Code as fire sprinklers are now regulated by available, enforceable, and most pertinent fire protection codes and standards that address leaking sprinklers and all other fire sprinkler equipment. The specific code and standard references are here: IFC (International Fire Code), Section 903.5 (from 2000 to the current 2021 edition) requires the inspection, testing and maintenance of fire sprinklers to be per NFPA 25.

Since 2000, commercial buildings in the United States have been designed, built, maintained, and inspected under the International Building Code (IBC) and the International Fire Code (IFC). These codes and referenced standards require leaking fire sprinkler heads or any leaking fire protection equipment, including piping, to be repaired immediately. These same codes have shifted the inspection, and enforcement of building fire protection maintenance through more direct local and legally required mechanisms - usually fire department/fire marshals.

ICC free code viewer: https://codes.iccsafe.org

NFPA (National Fire Protection Association) 1 Fire Code, Section 13.3.3.4.1.1.1 (from the 1997 to 2021 edition) requires the inspection, testing and maintenance of fire sprinklers to be per NFPA 25.

NFPA (National Fire Protection Association) 25, Section 5.2 (beginning in the 2002 Version), first requires leaking fire sprinkler heads, as well as other leaking equipment, piping, etc. to be replaced.

NFPA (National Fire Protection Association) free code viewer: www.nfpa.org/1 and www.nfpa.org/101

History

The 1986 Conference for Food Protection first developed food safety regulatory rules in 1986 and the processes for all US states to adopt these rules. Conversely, National Building and Fire Protection regulatory rules (by the ICC - International Code Council and NFPA - National Fire Protection Association) were also developed and adopted in the mid-90s and early 2000s. The Conference for Food Protection initially regulated fire protection maintenance concerns around food areas because there was not a nationally accepted building and fire code in prior to the 1990's. Today, several codes and standards require leaking fire sprinklers to be replaced and there is no reason for fire protection to be addressed by the food code.

Today, and since 2000, all editions of the US model construction code, i.e., the IBC, IFC, IPMC (International Property Maintenance Code), NFPA 1 Fire Code, and the NFPA 101 Life Safety Code all reference specific inspection, testing, and maintenance standards (like NFPA 25, the Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems) for all existing buildings and occupancies. This referenced and enforced standard requires leaking sprinklers to be replaced immediately by the building owner through licensed contractors and enforced by local code officials and authorities having jurisdiction (AHJ).

A letter be sent to the FDA requesting the current Food Code be amended as follows:

3-305.12 Food Storage, Prohibited Areas.

FOOD may not be stored:

(A) In locker rooms;

(B) In toilet rooms;

(C) In dressing rooms;

(D) In garbage rooms;

(E) In mechanical rooms;

(F) Under sewer lines that are not shielded to intercept potential drips;

(G) Under leaking water lines, including leaking automatic fire sprinkler

heads, or under lines on which water has condensed;

(H )Under open stairwells; or

(I) Under other sources of contamination

4-401.11 Equipment, Clothes Washers and Dryers, and Storage Cabinets,

Contamination Prevention.

(A) Except as specified in ¶ (B) of this section, EQUIPMENT, a cabinet used for the

storage of FOOD, or a cabinet that is used to store cleaned and SANITIZED

EQUIPMENT, UTENSILS, laundered LINENS, and SINGLE-SERVICE and SINGLE-USE

ARTICLES may not be located:

(1) In locker rooms;

(2) In toilet rooms;

(3) In garbage rooms;

(4) In mechanical rooms;

(5) Under sewer lines that are not shielded to intercept potential drips;

(6) Under leaking water lines including leaking automatic fire sprinkler

heads or under lines on which water has condensed;

(7) Under open stairwells; or

(8) Under other sources of contamination.

4-903.12 Prohibitions.

(A) Except as specified in ¶ (B) of this section, cleaned and SANITIZED EQUIPMENT,

UTENSILS, laundered LINENS, and SINGLE-SERVICE and SINGLE-USE ARTICLES may

not be stored:

(1) In locker rooms;

(2) In toilet rooms;

(3) In garbage rooms;

(4) In mechanical rooms;

(5) Under sewer lines that are not shielded to intercept potential drips;

(6) Under leaking water lines including leaking automatic fire sprinkler

heads or under lines on which water has condensed;

(7) Under open stairwells; or

(8) Under other sources of contamination.