General Background:	In adopting the original 2003 edition of the Rhode Island Life Safety Code, the Board maintained the unique Rhode Island requirement found at the time in RIGL 23-28.25-4(b)(2), of providing detection in spaces of twenty-four (24) inches or more above suspended ceilings.  Over the next ten (10) years, several requests were made to clarify this requirement and provide specific reasonable general exceptions. 

The Board more recently adopted sections 9.6.2.11(3) and (5) as part of the 2012 edition of the Rhode Island Life Safety Code in an effort to provide clarification and reasonable exceptions to the above rule.  These sections state:
					
9.6.2.11(3)	Combination rate of rise and one hundred thirty-five degrees (1350) F to one hundred forty degrees (1400) F fixed temperature heat detectors installed in accordance with NFPA 72, National Fire Alarm and Signaling Code, shall be provided in spaces of twenty four inches (0.61 m) or more above suspended ceilings.     
					
9.6.2.11(5)	Spaces twenty-four inches (061m) or more above suspended ceilings shall be exempt from the requirements of 9.6.2.11 (3) if the space is built of non-combustible construction and the space contains only wiring, ductwork and fixtures, properly installed under this code or the State Building Code.
					
	While several AHJs immediately applied the above provisions to provide the intended relief, others advised the Board that they did not enforce the Building Code and therefore did not feel comfortable making the proper assessment as to whether the installation of wiring, ductwork and fixtures complied with the Building Code.  One solution, proposed to address this situation, was to have the building owner secure an engineers report confirming the proper installation of the wiring, ductwork and fixtures.  However, in discussing this issue with members of the engineering community, it was determined that such an engineering assessment would be prohibitively expensive  greatly exceeding the cost of compliance and undermining the original intent of the code. 
	
Conclusions and Blanket Variance:	In light of the valid concerns raised above, and the need to ensure that legitimate general exceptions to the fire code are always available to building owners, the Board hereby grants a blanket variance to the provisions of section 9.6.2.11(5).  Now, an AHJ and/or building owner may utilize the following clarified standard in determining whether a building is required to be provided with the above ceiling heat detection:
						
9.6.2.11(5) (Clarified)  Spaces twenty-four inches (0.61m) or more above suspended ceilings shall be exempt from the requirements of 9.6.2.11(3) if the building is of Type I or Type II construction and all interior surfaces of the above ceiling space have a Class A or B interior finish rating and the space is not utilized for storage.
					
The Board notes that the above building classifications and interior finishes are readily defined in the fire code thereby eliminating the above-cited concerns.

Approved by the Fire Safety Code Board of Appeal & Review on July 30, 2013.