The Home Builders Association of Virginia has made a considerable effort to stop the Virginia
Board of Housing & Community Development from adopting the 2009 International Residential
Code as approved by the membership of the International Code Council. We feel that this is
regrettable and feel obligated to respond to their objections point for point.
This is the Virginia Fire Prevention Association's response to The Home Builders Association of
Virginia's 10 Reasons Why Mandating Fire Sprinklers Makes No Sense For Virginia, available
at their website www.hbav.com.
HBAV Assertion #1
Statistics show today's better built homes are saving lives. From 1979-2003 the
death rate per million persons from house fires dropped 58 percent, according to
the U.S. Centers for Disease Control. That trend will continue as more new
housing stock is built, stronger building codes are enacted and especially as
smoke alarm maintenance by homeowners improves.
VFPA Reply
The reduction of fire fatalities has little to do with "better built homes." To the contrary, modern
residential construction has shifted from tradition dimension lumber framing to lightweight
engineered structural components. The performance of these structures in fire conditions
demonstrates a significant reduction in fire safety.
- A recent Underwriters Laboratory study funded by the Department of Homeland
Security, Report on Structural Stability of Engineered Lumber in Fire Conditions
documented the striking differences between traditional and engineered systems. For
example, a traditionally constructed floor system, without a drywall ceiling to protect its
underside, withstood the test fire for 18 minutes. By comparison, a similar system using
modern engineered wooden I-beams survived for about six minutes.
- Another study conducted by the National Research Council of Canada, concluded: "With
the relatively severe fire scenarios used in the experiments, the times to reach structural
failure for the wood I-joist, steel C-joist, metal plate, and metal web wood truss
assemblies were 35 to 60 percent shorter than that for the [traditional] solid wood joist
assembly."
The performance of lightweight components underscore the need for residential sprinklers in
modern residential construction.
HBAV Assertion #2
Sprinklers are rarely needed for house fires. Sprinkler proponents claim that a
residential system is reliable in 96-99 percent of all reported structure fires where
the fire was large enough to activate the system. But reports from the National
Fire Prevention Association (NFPA) show that the number of fires that occur in
one- and two-family dwellings equipped with sprinklers are so few that they are
not shown in studies done by the organization.
VFPA Reply
The effectiveness of residential sprinklers cannot be better demonstrated than by HBAV's
assertion. Residential sprinklers are so successful, that fire incidents often go unreported.
HBAV Assertion #3
Sprinklers cause unintended damage. Statistics from the Virginia Fire Incident
Reporting System show that 76.8 percent of all fires in Virginia from 2000
through 2008 either did not spread or were confined to an object or a room and
contained. But when sprinklers detect smoke they set off every sprinkler in the
house, not just in the room where the fire is occurring. In many homes that suffer
a fire where working sprinklers exist there is more water damage to the home than
fire damage.
VFPA Reply
HBAV's assertion is blatantly false and demonstrates a lack of understanding of residential
sprinkler systems. They state "When sprinklers detect smoke, they set off every sprinkler in the
house.¨
- Sprinkler heads are activate by heat, NOT smoke.
- Only one head is activated.
- They are designed to operate quickly enough that only one head is activated.
HBAV Assertion #4
Home insurance rates do not decrease with their use. Sprinkler proponents claim
the cost of home insurance decreases when you install fire sprinklers. It¡¦s true that
some states offer insurance credits for having fire sprinklers in the home. Using a
conservative sprinkler cost estimate of $1.50 per square foot in a 2,300-squarefoot
home with an annual property insurance rate of $1,000, it would take
approximately 35 years for a 10 percent credit to pay for the system. Insurance
agents in the Richmond area say credits rarely are given above 3.5 percent. Throw
in maintenance costs and it would take even longer for the credit to pay its due for
the system. However, that does not offset the increased costs charged for potential
water damage and flooding. In most cases sprinklers go off in areas of the home
where fire is not occurring, causing more claims for water damage than fire
damage. Virginia insurance agents say this drives the cost of insurance higher for
people who have sprinkler systems.
VFPA Reply
This is the first instance in which we have heard the validity of a construction code safety
requirement questioned based on the availability of an insurance discount. When code
requirements for arc fault and ground fault protection were adopted, was the question of an
insurance discount raised?
Again the assertion that sprinkler heads "go off" in areas of the home that are not
involved in fire either indicates a lack of technical knowledge, or a deliberate attempt at
obfuscation. Regardless of HBAV's assertion, a 2008 study by Newport Partners for the National
Fire Protection Research Foundation using data from ten states identified insurance savings from
0-10%, with the average discount of 7%.
HBAV Assertion #5
Smoke alarms potentially save more lives than sprinklers. A 2006 study by the
U.S. Fire Association (USFA) on the presence of working smoke alarms in
residential fires from 2001-2004 showed that 88 percent of the fatal fires in
single-family homes occurred where there were no working smoke alarms. USFA
and NFPA data continue to show that the vast majority of home fire fatalities
occur when there are no operational smoke alarms. The most recent NFPA report
on smoke alarms estimates that more than 890 lives could be saved annually if
every home had a working smoke alarm. From 2000-2004, 65 percent of the fire
fatalities reported occurred in homes where smoke alarms were not present or
were present and did not operate.
VFPA Reply
This fact has nothing to do with sprinklers, as the two are complimentary parts of a residential
fire protection system. Additionally, HBAV's analysis was taken from the National Association
of Home Builder's NAHB Recommended State & Local Amendments to the 2009 International
Residential Code. Dr. John Hall whose work was cited by NAHB refuted their conclusions in
Commentary on the NAHB Recommended State & Local Amendments to the 2009 International
Residential Code (IRC) Hall, Jr. J. (May 6, 2009). Dr Hall's comments are attached to this document.
We hope that HBAV's recognition that providing residential smoke alarms to the needy
who cannot afford them would save lives, will cause HBAV to adopt such a program as part of a
public outreach campaign. The money spent on HBAV's campaign to block the adoption of the
2009 IRC as approved by the ICC membership would have been a great start for the program.
HBAV Assertion #6
Sprinklers will harm efforts at providing affordable housing statewide. According
to an August 2006 survey of home builders done by the National Association of
Home Builders' Research Center, the average sprinkler system costs $2.66 per
square foot to install in a new home. For the average home size considered to be
affordable housing in Virginia 1,800 to 2,200 square feet the maximum cost
would be approximately $5,850. In the Richmond area, about 710 families lose
the ability to qualify for a new home mortgage with each $1,000 increase in the
price of a new home. Mandating fire sprinklers would keep more than 4,100
families from being able to buy affordable housing in the Richmond area. A hardwired,
interconnected smoke alarm system installed through the whole house
costs about $50 per alarm. You may have heard of the "Scottsdale study," which
sprinkler proponents are using to claim sprinklers do not harm affordable housing.
They claim sprinklers can be installed for as little as $1 per square foot. In
Scottsdale, AZ, where the Scottsdale study was done, these units can be installed
for $1 per square foot. But Scottsdale has some of the least expensive building
costs in America. Therefore, the Scottsdale study is not reflective of the average
cost for installation nationwide.
VFPA Reply
The United States Fire Administration estimates the true cost of sprinkler installation during
construction at $1- $1.50 per square foot, significantly lower than HBAV's assertion and on
average require only 8 additional man hours of labor. USFA's website
http://www.usfa.dhs.gov/citizens/all_citizens/home_fire_prev/sprinklers also refutes most of
HBAV's assertions.
HBAV Assertion #7
Sprinklers are much more difficult and time consuming to maintain than smoke
alarms. Homeowners have a difficult time remembering to change the batteries in
their smoke alarms once every six months. A sprinkler system requires much
more maintenance than simply replacing batteries. Based on the problems with
maintaining smoke detectors, it is easy to deduce that homeowners will not
maintain sprinkler systems at the level required for them to be at maximum
efficiency. More lives can be saved by educating the public to the importance of
maintaining hard-wired, interconnected smoke alarms in proper operating
condition than through mandating fire sprinklers.
VFPA Reply
Residential fire sprinkler systems are essentially maintenance free. Multipurpose
systems have no maintenance requirements at all, and stand-alone systems only require
an occasional test of the water flow alarm, if provided.
HBAV Assertion #8
Sprinklers can be damaged by extreme cold, causing water damage. Should a
home lose power for several days, as occurred in some parts of the Richmond area
during the early March snowstorm, the basins that hold water for sprinkler use can
freeze and burst. Homeowners most likely would have to take measures to keep
heat in the water basins, further increasing the cost that many rural Virginians
can't afford.
VFPA Reply
Fire sprinkler systems pose no greater risk of freezing than domestic plumbing if the system is
properly designed and installed. Residential sprinklers systems are no different than residential
plumbing. If quality products are used and the system is properly installed, it won't leak. If
substandard products are used or workmanship is faulty, leaks can occur. Sprinklers, piping and
fittings are held to a far higher level of quality than are domestic water components and
sprinklers must be rigorously tested. Listing tests for sprinklers include 700-PSI hydrostatic
strength, 500-PSI leakage resistance, 100,000 cycles water hammer resistance, 35-125 degree F
temperature cycling and freeze performance to -20 degree F for 24 hours. Sprinkler piping and
components are rated for a pressure of 175 PSI, while plumbing water supply systems are rated
for only 80 PSI.
HBAV Assertion #9
Sprinklers in homes on well water have additional problems. Owners will have to
calculate how the system will work if power goes out, or if the well's water level
is low enough to cause pressure problems. Extra water tanks, pumps and
generators could be purchased to help with pressure, but that adds more cost to
the system, cost many owners in rural Virginia could not afford.
VFPA Reply
Residential sprinklers supplied via wells indeed have additional costs, just as the basic
water supply for those homes does. Systems are designed for a maximum of 2 heads
flowing. Some homeowners have installed larger pressure tanks to supply their sprinkler
systems. This provides the added advantage of requiring their well pump to run less,
prolonging the life of the pump, and helping to offset the cost of the larger tank. Back-up
generators or emergency power are not required. Additionally, tanks and pumps are not
required to be listed for sprinkler service, saving the homeowner additional expense.
HBAV Assertion #10
Annual sprinkler installation costs will greatly exceed property losses nationwide
and in any jurisdiction where they are mandated. For example, had this mandate
been in place in 2005 the installation cost to builders would have been almost
$10.2 billion based on an average square-foot home with a cost of $2.66 per
square foot. The NFPA reported that the total home property loss, new and
existing homes, due to fire in 2005 was less than $5.8 billion. The installation
cost would have been nearly double the loss. As new homes continue to be better
built, the difference between installation cost and property loss will continue to
increase, and statistics show most people forced to have these installed will never
use them in their home.
VFPA Reply
Residential sprinklers, like smoke alarms are primarily installed to give occupants timely
notification and the opportunity to escape. Comparing the cost of these systems to the value of
structural fire loss is akin to comparing the cost to install airbags in vehicles with the vehicular
damage from auto accidents. The two don't compare. Responding to HBAV's assertion that
"People who are forced to install these systems will never use them," we can only say we
certainly hope not.
The Virginia Fire Prevention Association is dedicated to the prevention of fires and the
protection of lives and property though the Three E's of Fire Prevention, EDUCATION,
ENGINEERING and ENFORCEMENT. Our organization is composed of fire and building code
officials, fire inspectors, fire investigators and individuals and companies dedicated to the
reduction of fire waste within the Commonwealth of Virginia.