| Date |
Text |
| 2016-05-21 16:35:05 | ****CORRECTIONS**** |
| | |
| | SAMANTHA HILL |
| | BUILDING PLANS EXAMINER |
| | [email protected] |
| | 561-805-6724 |
| | |
| | 2014 FLORIDA BUILDING CODE W 2014 WEST PALM BEACH |
| | AMENDMENTS TO THE FLORIDA BUILDING CODE, CHAPTER 1, |
| | ADMINISTRATION |
| | 2014 EXISTING BUILDING CODE LEVEL II 701.3 COMPLIANCE. |
| | ALL NEW CONSTRUCTION ELEMENTS, COMPONENTS, SYSTEMS, AND |
| | SPACES SHALL COMPLY WITH THE REQUIREMENTS OF THE |
| | FLORIDA BUILDING CODE, BUILDING. |
| | |
| | COMMENTS 1, 1A, 1B, 2A, 2B FROM THE PREVIOUS REVIEW |
| | WERE EITHER NOT ADDRESSED OR NOT ADDRESSED ADEQUATELY. |
| | RATHER THAN INCLUDE THESE ITEMS, CONSIDER THE FOLLOWING |
| | LIST IN ADDITION TO THE PREVIOUS LIST. |
| | |
| | REVIEW 2 COMMENT #1.) REFER TO PREVIOUS LIST; MANY |
| | QUESTIONS WERE RAISED IN THAT COMMENT LIST AND NOT |
| | ANSWERED. A CD WITH HUNDREDS PAGES OF MSDS SHEETS WAS |
| | PROVIDED. ONE PAGE, NOT SIGNED AND SEALED, NO |
| | INDICATION OF WHO PREPARED THE INFORMATION, PROVIDED |
| | THE FOLLOWING ?CHEMICAL DATA?: |
| | |
| | IF CHEMICAL IS ACID <250ML |
| | IF CHEMICAL IS ACETONE <1 LITER |
| | IF CHEMICAL IS PROPANOL <4 LITER |
| | IF CHEMICAL IS METHANOL <10 LITER |
| | IF CHEMICAL IS ACETONITRILE <4 LITER |
| | |
| | THIS "CHEMICAL DATA" DOES NOT ADDRESS THE COMMENTS FROM |
| | PREVIOUS REVIEW. OCCUPANCY CLASSIFICATION OF BUSINESS |
| | HAS NOT BEEN DEMONSTRATED. THE HAZARD, OR LACK OF |
| | HAZARD, HAS NOT BEEN DEMONSTRATED WITH THE DOCUMENTS |
| | PROVIDED. SINCE THE QUANTITIES OF HAZARDOUS MATERIALS |
| | IS UNCLEAR, COMPLIANCE WITH BUSINESS OCCUPANCY CANNOT |
| | BE DETERMINED. PREVIOUS REVIEW (ITEM 1B) REQUESTED |
| | INFORMATION CONSISTENT WITH THE FORMAT OF FBC TABLE |
| | 307.1(1) AND (2). THE QUESTIONS REGARDING THE AMOUNTS |
| | OF CHEMICALS USED IN EACH CATEGORY, FORM (SOLID, |
| | LIQUID, GAS), STORAGE, CLOSED OR OPEN SYSTEM, ETC. HAVE |
| | NOT BEEN ADDRESSED. OCCUPANCY CLASSIFICATION CANNOT BE |
| | CONFIRMED AS BUSINESS AS HAZARDOUS MATERIALS ARE |
| | ACKNOWLEDGED TO BE IN STORAGE AND IN USE (VIA THE MSDS |
| | SHEETS) BUT AMOUNTS OF EACH HAZARD HAS NOT BEEN |
| | PROVIDED BY THE DESIGN PROFESSIONAL. |
| | |
| | EXAMPLES OF HOW THE FORMAT OF THE "CHEMICAL DATA" IS |
| | GROSSLY INSUFFICIENT AS A RESPONSE TO THE PREVIOUS |
| | COMMENT LIST: |
| | |
| | A. WHAT DOES "IF CHEMICAL IS ACID <250ML" MEAN? AMOUNT |
| | IN USE, OPEN OR CLOSED, STORED, ALL THREE? 250ML OPEN |
| | AND CLOSED USE, 250ML STORED, TO EQUAL 750ML? 250ML |
| | STORED, AND THE CHEMICAL IS NEVER IN USE? |
| | B. IS THERE MORE THAN ONE ACID USED? 250 ML EACH ACID, |
| | OR TOTAL OF ALL ACIDS? OF THE 350 PAGES OF DATA |
| | PROVIDED, HOW MANY ARE ACIDS? ARE ALL OF THESE ACIDS |
| | CONSIDERED "CORROSIVE" PER THE TABLE, OR ARE ANY ALSO |
| | "TOXIC" OR "HIGHLY TOXIC"? |
| | C. HOW HAS ARCHITECT MADE A DETERMINATION OF BUSINESS |
| | OCCUPANCY WITHOUT THE SPECIFIC INFORMATION REQUESTED |
| | (QUANTITIES OF HAZARDOUS MATERIALS PER FBC B TABLES |
| | 307.1(1) AND (2)? |
| | D. IF ARCHITECT HAS THIS INFORMATION, WHY WASN'T IT |
| | PROVIDED AS REQUESTED? |
| | |
| | ONLY A DESIGN PROFESSIONAL (ARCHITECT, ENGINEER) CAN |
| | DESIGN A COMMERCIAL BUILDING PER FS 471, 481. THE |
| | BUILDING CLASSIFICATION IS PROVIDED BY THE ARCHITECT, |
| | BUT THE INFORMATION TO SUPPORT THAT CLASSIFICATION IS |
| | NOT SIGNED AND SEALED, DOES NOT INCLUDE A TITLE BLOCK |
| | OR ANY OTHER INFORMATION REGARDING WHO IS PROVIDING THE |
| | INFORMATION. |
| | |
| | REVIEW 2 COMMENT #2.) SEE FBC BUILDING 414.1.3 |
| | INFORMATION REQUIRED. A REPORT SHALL BE SUBMITTED TO |
| | THE BUILDING OFFICIAL IDENTIFYING THE MAXIMUM EXPECTED |
| | QUANTITIES OF HAZARDOUS MATERIALS TO BE STORED, USED IN |
| | A CLOSED SYSTEM AND USED IN AN OPEN SYSTEM, AND |
| | SUBDIVIDED TO SEPARATELY ADDRESS HAZARDOUS MATERIAL |
| | CLASSIFICATION CATEGORIES BASED ON TABLES 307.1(1) AND |
| | 307.1(2). THE METHODS OF PROTECTION FROM SUCH HAZARDS, |
| | INCLUDING BUT NOT LIMITED TO CONTROL AREAS, FIRE |
| | PROTECTION SYSTEMS AND GROUP H OCCUPANCIES SHALL BE |
| | INDICATED IN THE REPORT AND ON THE CONSTRUCTION |
| | DOCUMENTS. THE OPINION AND REPORT SHALL BE PREPARED BY |
| | A QUALIFIED PERSON, FIRM OR CORPORATION APPROVED BY THE |
| | BUILDING OFFICIAL AND PROVIDED WITHOUT CHARGE TO THE |
| | ENFORCING AGENCY. |
| | |
| | PRIOR TO RESUBMITTAL, PROVIDE A RESUME OF PERTINENT |
| | EDUCATION AND EXPERIENCE OF THE PERSON, FIRM OR |
| | CORPORATION PROPOSED TO PROVIDE THE REPORT FOR BUILDING |
| | OFFICIAL APPROVAL. THE RESUME SHOULD BE SUBMITTED VIA |
| | EMAIL FOR APPROVAL PRIOR TO RESUBMITTAL. |
| | |
| | REVIEW 2 COMMENT #3.) SEE ALSO FBC BUILDING 414.1.2, |
| | WHICH STATES THAT THE SAFE DESIGN OF HAZARDOUS MATERIAL |
| | OCCUPANCIES IS MATERIAL DEPENDENT. THE HAZARD, OR LACK |
| | OF HAZARD, IS STILL NOT CLEAR AS THE REQUESTED (AND |
| | REQUIRED) INFORMATION WAS NOT PROVIDED. IT IS CLEAR |
| | THAT HAZARDOUS MATERIALS WILL BE IN USE AND WILL BE |
| | STORED AT THIS LABORATORY, BUT QUANTITIES AND |
| | COMPLIANCE WITH ALL REQUIREMENTS OF FBC BUILDING 307 |
| | AND 414 ARE NOT CLEAR. THIS SHOULD BE ADDRESSED BY THE |
| | REPORT. |
| | |
| | REVIEW 2 COMMENT #4.) ARCHITECT'S RESPONSE REGARDING |
| | THE NITROGEN GENERATOR (1B) INSTRUCTS THE PLAN REVIEWER |
| | TO NOTE THAT NITROGEN IS AN INERT GAS, NA PER FBC TABLE |
| | 307.1(1) AND ALSO REFERS TO ATTACHED EQUIPMENT |
| | SPECIFICATIONS. THERE ARE A FEW ISSUES WITH THIS |
| | STATEMENT: |
| | |
| | A. WHERE ARE THE EQUIPMENT SPECS LOCATED? NONE OF THE |
| | 15 PDFS PROVIDED ON CD (TOTALING ALMOST 350 PAGES) WAS |
| | TITLED IN A MANNER WHICH WOULD INDICATE IT INCLUDED |
| | GENERATOR SPECS. IF INFORMATION REQUESTED IN PLAN |
| | REVIEW IS CONTAINED SOMEWHERE WITHIN HUNDREDS OF PAGES |
| | ON A CD, PLEASE PROVIDE FILE NAME AND PAGE. NONE OF THE |
| | HAZARDOUS MATERIALS ARE REFERENCED ON THE ARCHITECT'S |
| | PLANS. |
| | |
| | B. RESPONSE TO CONCERNS REGARDING THE NITROGEN |
| | GENERATOR WAS TO ADVISE THE REVIEWER TO NOTE THAT |
| | NITROGEN IS AN INERT GAS, AND THE AMOUNT ALLOWED BY THE |
| | TABLE IS NA AND THERE IS NO MAXIMUM CONCENTRATION |
| | LISTED. THE RELEVANCE OF THE RESPONSE THAT NITROGEN IS |
| | AN INERT GAS IS NOT CLEAR. ALTHOUGH THE AMOUNT ALLOWED |
| | PER CONTROL AREA IS NOT LIMITED, IT IS CONSIDERED A |
| | HAZARDOUS MATERIAL, AND ANY AMOUNT IS A RISK TO BE |
| | CONSIDERED. |
| | |
| | C. SINCE NITROGEN IS AN INERT GAS AS STATED, DOES THIS |
| | MEAN THAT INERT GASES DO NOT PRESENT A HAZARD? EVEN |
| | WHEN IN COMPRESSED FORM? (SEE FFPC PER FBC B 414.1.2). |
| | ISN'T NITROGEN A POSSIBLE HEALTH HAZARD? EVEN IF THE |
| | TABLE STATES "NA" AND THE QUANTITY PER CONTROL AREA IS |
| | NOT LIMITED, AM I MISINTREPRETING THE CODE TO THINK |
| | THAT ALL OF THE HAZARDOUS CHEMICALS, INCLUDING INERT |
| | GASES, INERT PRESSURIZED GASES, OR INERT LIQUIDS BE |
| | CONSIDERED WHEN PERFORMING A HAZARD ANALYSIS OF A |
| | FACILITY? ALTHOUGH I AM NOT KNOWLEDGEABLE ABOUT |
| | HAZARDOUS CHEMICALS, IT WOULD APPEAR THAT THE FACT THAT |
| | IT IS INERT DOES NOT ELIMINATE RISKS ASSOCIATED WITH |
| | THE HAZARD, WHICH IS WHY IT IS INCLUDED ON A TABLE OF |
| | "HAZARDOUS MATERIALS POSING A PHYSICAL HAZARD". THE |
| | PREVIOUS LIST QUESTIONED THE HAZARD OF NITROGEN AS |
| | RELATED TO OXYGEN DEPLETION. IS THIS FACT NOT STILL |
| | APPLICABLE, EVEN THOUGH IT IS "INERT"? AS MOST PLAN |
| | REVIEWERS, INCLUDING MYSELF, DO NOT HAVE EXTENSIVE |
| | EDUCATION IN CHEMISTRY, AND THE FBC CANNOT POSSIBLY |
| | ADDRESS EVERY CHEMICAL AND HAZARD WHICH EXISTS AT THE |
| | TIME OF THE WRITING OF THE CODE AND ALL CHEMICALS |
| | INTRODUCED TO THE MARKET AFTER ADOPTION OF THE CODE, |
| | THE FBC REQUIRES THAT A HAZARD ANALYSIS BE PERFORMED BY |
| | AN EXPERT (FBC B 414.1.3). IT IS NOT CLEAR WHO HAS |
| | PROVIDED THE HAZARD RELATED INFORMATION AND WHO HAS |
| | PERFORMED THE REQUIRED HAZARD ANALYSIS. UPON WHAT |
| | INFORMATION HAS THE BUSINESS OCCUPANCY BEEN DETERMINED? |
| | IT IS NOT CLEAR HOW THIS COULD BE CLASSIFIED AS |
| | BUSINESS WITHOUT THE INFORMATION REQUIRED BY THE |
| | PREVIOUS LIST AND BY FBC B 414.1.3. |
| | |
| | D. THE ARCHITECT'S RESPONSE TO QUESTIONS REGARDING THE |
| | NITROGEN GENERATOR REFERRED TO THE EQUIPMENT |
| | SPECIFICATIONS "ATTACHED". THESE QUESTIONS SHOULD BE |
| | ANSWERED BY THE HAZARD ANALYSIS REPORT OR BY THE DESIGN |
| | PROFESSIONAL BY INCORPORATING INFORMATION INTO THE |
| | PLAN. I HAVE SPENT HOURS SEARCHING THE "ATTACHED" FOR |
| | ANSWERS TO THE CODE RELATED QUESTIONS FROM THE PREVIOUS |
| | REVIEW, AND IT APPEARS THAT THE ANSWERS ARE NOT |
| | "ATTACHED"; EITHER NOT INCLUDED (AS IN THE CASE OF THE |
| | NITROGEN GENERATOR) OR THE DATA NOT PRESENTED IN THE |
| | CORRECT FORMAT (OVER 300 PAGES OF MSDS SHEETS). ALL |
| | ISSUES REGARDING THE HAZARDS OF THE FACILITY SHOULD BE |
| | ADDRESSED IN THE REPORT OR INCORPORATED INTO THE PLAN |
| | BY THE DESIGN PROFESSIONAL. IT IS NOT REASONABLE TO |
| | EXPECT FOR A NON EXPERT TO LOCATE ANSWERS IN A LENGTHY |
| | MANUFACTURER SPECIFICATION BOOK OR ATTEMPT TO CLASSIFY |
| | EACH CHEMICAL AND ADD THE AMOUNTS, ESPECIALLY WHEN THE |
| | AMOUNTS ARE NOT CLEAR. THESE QUESTIONS WERE RAISED BOTH |
| | TO ASSIST THE DESIGN PROFESSIONAL IN PROVIDING ADEQUATE |
| | INFORMATION TO DEMONSTRATE THAT HAZARDS WERE ADDRESSED |
| | AS WELL AS TO CONFIRM THE BUSINESS OCCUPANCY |
| | CLASSIFICATION. |
| | |
| | REVIEW 2 COMMENT #5.) THE ISSUES RAISED IN THIS REVIEW |
| | FOCUS ON ONLY ONE OF THE HAZARDOUS CHEMICALS IN THIS |
| | LABORATORY. THIS IS AN EXAMPLE OF HOW THE RESPONSE TO |
| | THE REQUEST FOR ADDITIONAL INFORMATION WAS INSUFFICIENT |
| | AND GIVES SOME OF THE ITEMS WHICH SHOULD BE CONSIDERED |
| | WHEN THE EXPERT PREPARES THE HAZARD ANALYSIS. IT IS |
| | ANTICIPATED THAT THE HAZARD ANALYSIS SHOULD ADDRESS |
| | MANY THINGS OF WHICH I AM ENTIRELY UNAWARE AS A HAZARD. |
| | THE PLAN SUBMITTED DOES NOT ACKNOWLEDGE THE EXISTENCE |
| | OF ANY HAZARDOUS CHEMICALS, YET IT APPEARS THAT AN |
| | ANALYSIS OF THE CHEMICALS PROPOSED FOR USE SHOULD HAVE |
| | A SIGNIFICANT IMPACT ON THE DESIGN OF THE SITE |
| | (STARTING WITH OCCUPANCY CLASSIFICATION), AS WELL AS |
| | DOCUMENTING THE ARCHITECT?S AND ENGINEER?S FAMILIARITY |
| | AND KNOWLEDGE OF THE HAZARDS. THE INFORMATION REQUESTED |
| | IN FIRST REVIEW REGARDING QUANTITIES TO DEMONSTRATE |
| | THAT THIS IS BUSINESS AND NOT HAZARDOUS OCCUPANCY |
| | SHOULD HAVE BEEN INCORPORATED INTO THE PLAN, OR A |
| | REFERENCE THAT THE REQUIRED HAZARD ANALYSIS REPORT HAS |
| | BEEN REVIEWED BY DORS IF THE ANALYSIS WAS DELEGATED |
| | (AND THE HAZARD REPORT PROVIDED FOR REVIEW). |
| | |
| | REVIEW 2 COMMENT #6.) WHEN RESUBMITTING, REVIEW THE |
| | PREVIOUS LIST, ITEMS 1 AND 2, AND ADDRESS ALL ITEMS AS |
| | WELL AS THE ITEMS ON THIS LIST VIA THE HAZARD ANALYSIS |
| | REPORT, INCORPORATING RESPONSES INTO THE PLAN AS |
| | APPROPRIATE, AND ADDITIONAL DATA OR SPEC SHEETS AS |
| | NEEDED. ALL INFORMATION SHOULD BE EASILY LOCATED AND IF |
| | IT IS NOT, ESPECIALLY AS THE DOR SHOULD BE FAMILIAR |
| | WITH THESE SPECS ALREADY, PLEASE ADVISE AS TO THE |
| | LOCATION, IN PARTICULAR IF THE INFORMATION IS CONTAINED |
| | WITHIN A LARGE DOCUMENT. THE ISSUES AND QUESTIONS |
| | PRESENTED IN THIS REVIEW AND PREVIOUS REVIEW SHOULD BE |
| | ADDRESSED IN THE REPORT REQUIRED BY FBC B 414.1.3. THIS |
| | LIST IS NOT COMPREHENSIVE. THE REPORT SHOULD BE |
| | COMPREHENSIVE AS AN EXPERT IN THE FIELD SHOULD BE AWARE |
| | OF ALL POTENTIAL RISKS AND SHOULD KNOW HOW TO PROVIDE |
| | EVIDENCE OF WHICH HAZARDOUS CHEMICALS (IN PARTICULAR, |
| | THE CHEMICALS INCLUDED IN THE TABLES) DO NOT PRESENT A |
| | HAZARD IN THIS APPLICATION, OR HOW THE HAZARD HAS BEEN |
| | MITIGATED, AND SHOULD PROVIDE THE QUANTITIES AS |
| | REQUIRED. IT WOULD BE HELPFUL IF AN EXCEL SPREADSHEET |
| | IS PROVIDED SO THAT MATHEMATICAL FORMULAS CAN BE |
| | CONFIRMED IF THE LIST OF CHEMICALS IS EXTENSIVE. |
| | |
| | IT IS NOT NECESSARY TO PROVIDE A RESPONSE LETTER WITH |
| | ANSWERS TO THE NUMEROUS ISSUES RAISED IN THE PREVIOUS |
| | AND THIS REVIEW AS THE REPORT SHOULD CLARIFY ALL ISSUES |
| | REGARDING ALL HAZARDS, HAZARDOUS MATERIALS (EACH |
| | CHEMICAL INDIVIDUALLY, POSSIBLE INTERACTIONS, ALL OTHER |
| | POTENTIAL HAZARDS), ETC. ALL REQUIREMENTS OF FBC B 414, |
| | 307, AND FFPC ARE TO BE CLEARLY ADDRESSED IN THE |
| | REPORT. |
| | |
| | REVIEW 2 COMMENT #7.) SEE FLORIDA STATUTE 553.80(2)(B). |
| | A FOUR TIMES PLAN REVIEW FEE WILL BE ASSESSED IF THIS |
| | COMMENT IS NOT ADDRESSED CORRECTLY A THIRD TIME, AS |
| | REQUIRED BY THE FLORIDA STATUTE. |
| | |
| | A SET HAS BEEN RETAINED. |
| | |
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