TRD’s code consultant discusses the code revision process and developing a relationship with code officials.
Paul Armstrong, P.E., C.B.O., has worked as an independent consultant, technical trainer and expert witness, providing expertise on both California and international building codes for more than a decade. Previously, he served 14 years on the code development staff of the International Code Council/International Conference of Building Officials. Tent Rental Division (TRD) of IFAI hired Armstrong as a consultant for the current code revision cycle. Here, Armstrong answers a few questions from InTents about the code revision process and how tent professionals can best work with code officials.
Why are tent codes under scrutiny?
Armstrong: There have been a number of failures. When those failures occur, the city, county or whatever the authority having jurisdiction is has a tendency to look right at the fire official or building official or both and ask difficult questions as to how this could happen. The follow-up question is, How can we make sure this doesn’t happen again?
How would you characterize the April Committee Action Hearing?
[Editor’s note: See the June–July 2018 issue of InTents for a review of specific proposals, or visit www.InTents.com and search “codes.”]
Armstrong: I thought it went very well. There are usually a couple of different activities that go on at the code hearings. One, there is the support of and opposition to various code changes. Then there is the networking that goes on—to some extent, team building or isolating your opposition. We [Armstrong and TRD Code Committee chair Tom Markel] made a lot of great contacts; in fact, there were people who supported our code changes that we didn’t even know were going to support them. And they did that because Tom and I talked to those fire officials and gained their support.
TRD submitted two code change proposals, and there were others we were reviewing, keeping track of or actively opposing. We weren’t counting on the TRD proposal related to flame propagation and labeling to pass on its first hearing, but it did. The bigger TRD proposal, wind and anchoring requirements, was disapproved by the committee. But we heard input from other code officials who said they didn’t care for the way something was currently worded, but they gave us ideas on how to approach that either in a public comment or a future code change.
Why is it important for TRD to have representatives at the code hearings —both a paid consultant such as yourself as well as TRD members?
Armstrong: It is important to have your voice there; otherwise you have people who may purport to represent the industry or a part of the industry submitting code changes, working with people who may or may not agree with the position of the Tent Rental Division. When you attend the meetings, you start to build a network of contacts across the country who can help you.
The contacts you make can take your code change and work on it too. It’s better to have a team of people looking at those things rather than just one person. I’ve personally developed code change proposals over the years by myself, and I’ve thought many times that what I’ve done is the greatest thing since sliced bread, and then you put it in front of a committee—especially a committee of highly opinionated code officials—and they point out the flaws in what you crafted. So it doesn’t surprise me when big code change proposals go down. Usually it takes a while for those thoughts to gain acceptance.
What can tent rental company owners or managers do to develop positive relationships with local officials?
Armstrong: First of all, get to know them. They are real people. Most of them are just looking for information by which they can approve your installation. It really is a rare thing to find someone who wants to shut everything down. Most cities and counties are really interested in having construction projects occur in their area, including tent installations and the events that go along with them. Nobody wants to be the bad guy.
Another thing is doing a presentation on the tent rental industry for local building and fire code officials—getting the information out there that the industry is there to work with them. I think that would be huge.
What do industry members risk by not getting involved in the code development process?
Armstrong: It’s always better to have a number of people and more resources that you can pull from to work on code changes. When you have just a few people, you don’t always hear of all of the problems. When you have a greater number and a variety of people from across the country participating, then you get various opinions and the culture of the industry from all those areas. You get a better feel for how the industry can really improve.
If you put your head down and don’t see what’s coming, then you’ll get run over by whatever code change or state regulation or local amendment is developed—perhaps in a knee-jerk reaction to a problem that occurred. Participation is the best way to go.
My advice is to encourage InTents readers to get involved, get to know their local code officials to understand their concerns, and step up and do some education to help the industry as a whole develop a great reputation.
The International Code Council (ICC) uses a three-year cycle to develop model codes. Tents and temporary structures fall under the International Fire Code (IFC). For the current code cycle, the IFC is in Group A.
Code proposals approved at the Committee Action Hearing (CAH) in April that did not receive a public comment will go into a consensus document that will be approved following the Public Comment Hearing (PCH) in October. Code proposals that received public comments can be modified at the PCH prior to the vote. Code proposals that were disapproved at the CAH can also be brought back via public comments.