Lack of response by CMP to comments

[sandsnow]

What or how is the CMP required to respond to or about when processing a comment?

I bring up points in my substantiation that they do not address in their response.

I don't expect all my proposals to be accepted (they weren't) but I did expect a response that was on point. I pointed out a conflict that if they didn't feel warranted a change that it should be passed on to the TCC. The conflict was not even mentioned in the commentary. If you want to look, do a search under my last name LeVoir in the .pdf document with the comments. Page 70-103 - 4-15

If you feel there is a conflict in the Code how can you point this out short of making a proposal for change?

A humbling experience to say the least. Out of four only one was accepted and that was in principle and that was because someone else had a better proposal and I just hitched a ride on that.

 

[infinity]

I don't know because I have yet to officially write a proposal but 1 out of 4 doesn't seem too bad.

 

[rbalex]

One out of four is very good, in fact.

Speaking to the core topic from the REGULATIONS GOVERNING COMMITTEE PROJECTS

Section 4.3.5.1 for Proposals:

The TC action on proposals "accepted in principle," "accepted in part," "accepted in principle in part" and "rejected" shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC?s rationale for its action so that rebuttal may, if desired, be submitted during the Comment period. A Proposal that does not include all of the information listed in 4.3.3(a) through 4.3.3(d) may be rejected by the Committee for that reason.

Section 4.4.6.3 for comments:

The TC action on Comments "accepted in principle," "accepted in part," "accepted in principle in part," "rejected," or "held" shall include a statement, preferably technical in nature, on the reason for the TC action. Such statement shall be sufficiently detailed so as to convey the TC?s rationale for its action.

I've been awed a few times at the outright BS some TCs have produced for their Panel Statements - but they are never called on it.
　
　

 

[sandsnow]

Thanks for the kind words on getting one accepted.

About my percieved conflict in the Code.....Can I submit something direct to the Technical Correlating Committee? Aren't they the ones who address conflicts within the Code

 

[George Stolz]

I bring up points in my substantiation that they do not address in their response.

Welcome to the Club.

Between "the existing text has been used successfully for years" and "the submitter did not adequately substantiate the change" you might begin to wonder if they had a hot date to get to.

A humbling experience to say the least.

Yes, indeed.

Out of four only one was accepted and that was in principle and that was because someone else had a better proposal and I just hitched a ride on that.

Not bad at all, I was 2/11 on the Proposals, and (shock shock surprise surprise) 0/1 on comments. Of course, my comment consisted mainly of asking them how the view was where their heads were, so I didn't hold out much hope for an answer on that.

 

[rbalex]

Thanks for the kind words on getting one accepted.

About my percieved conflict in the Code.....Can I submit something direct to the Technical Correlating Committee? Aren't they the ones who address conflicts within the Code

By the time the ROC is published the TCC has already reviewed and accepted the Panel Action (PA).

Your next step would be to file a NITMAM (Notice of Intent To Make a Motion) by May 7 to have the PA reviewed at the NFPA Annual Meeting June, 6-10. You do not need to be an NFPA member to make a motion - just to vote on it. You also have to be the originator or a commentor on the original Proposal. Before the Annual Meeting Technical Session, you can lobby any of the Member Sections, like Electrical or Architects, Engineers, and Building Officials(AEBO) for support.

Failing at the Annual Meeting, you can Appeal to the Standards Counsel (SC) and finally Petition the Board of Directors (BoD) - good luck with either one of them and it can be very expensive ($2500 for a Petition), although I did get the fee waived once.

Reversals have occurred at the Annual Meeting, but rarely and very rarely at the SC level. They may have happened at the BoD level, but I've never heard of one.

 

[sandsnow]

By the time the ROC is published the TCC has already reviewed and accepted the Panel Action (PA).

Your next step would be to file a NITMAM (Notice of Intent To Make a Motion) by May 7 to have the PA reviewed at the NFPA Annual Meeting June, 6-10. You do not need to be an NFPA member to make a motion - just to vote on it. You also have to be the originator or a commentor on the original Proposal. Before the Annual Meeting Technical Session, you can lobby any of the Member Sections, like Electrical or Architects, Engineers, and Building Officials(AEBO) for support.

Failing at the Annual Meeting, you can Appeal to the Standards Counsel (SC) and finally Petition the Board of Directors (BoD) - good luck with either one of them and it can be very expensive ($2500 for a Petition), although I did get the fee waived once.

Reversals have occurred at the Annual Meeting, but rarely and very rarely at the SC level. They may have happened at the BoD level, but I've never heard of one.

So it sounds as though I have to be there. Can't do it.

I was thinking more on the lines of next cycle. I would like them to address the conflict and make the different sections consistent.

 

[sandsnow]

Welcome to the Club.

Between "the existing text has been used successfully for years" and "the submitter did not adequately substantiate the change" you might begin to wonder if they had a hot date to get to.


Yes, indeed.


Not bad at all, I was 2/11 on the Proposals, and (shock shock surprise surprise) 0/1 on comments. Of course, my comment consisted mainly of asking them how the view was where their heads were, so I didn't hold out much hope for an answer on that.

Thanks, finally got around to doing it.

I like the hot date part. Pretty much what I was thinking