Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 2
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63104 Conventions
Proposed section 104.1.1, Construction and Manufacturing Tolerances, provides that all
dimensions are subject to conventional industry tolerances except where the requirement
is stated as a range with specific minimum and maximum end points. Section 104.1
notes that all dimensions not stated as a "maximum" or "minimum" are absolute and that
all dimensions are "subject to conventional industry tolerances."
Commenters requested that specific new construction allowances and tolerances be made
for a variety of materials and designs required by the proposed standards. The
Department believes that it is inappropriate for this agency to attempt to establish
construction and manufacturing tolerances for every material, element, or design that
may be used in new construction. Construction and manufacturing tolerances are best
addressed by industry standards, where available, and are built into the specifications in
the attached rules.
Section 104.2 provides that where the required number of elements or facilities to be
provided is determined by calculations of ratios or percentages and remainders or
fractions result, the next greater whole number of such elements or facilities shall be
provided. Where the determination of the required size or dimension of an element or
facility involves ratios or percentages, rounding down for values less than one-half is
permissible.
A commenter stated that it is customary in the building code industry to round up rather
than down for values less than one-half. As noted here, where the proposed standards
provide for scoping, fractional calculations will be rounded to the next whole number.
The Department is retaining the portion of section 104.2, Calculation of Percentages, that
permits rounding down for values less than one-half where the determination of the
required size or dimension of an element or facility involves ratios or percentages. Such
practice is standard with the industry, and is in keeping with model building codes.
105 Referenced Standards
Section 105 lists the industry requirements that will be referenced in the proposed
standards. This section also clarifies that where there is a difference between a provision
of the proposed standards and the referenced requirements, the provision of the proposed
standards applies.
Commenters noted that the National Fire Protection Association’s (NFPA) referenced
standard for fire alarms at section 105.2.5 is based on the NFPA 72 1999 or 2002 edition.
The commenters recommended editing the final standards to require compliance with the
edition of NFPA that is most recent because it is likely that the NFPA will amend its
standards prior to the issuance of final ADA Standards.
The rules that govern the publication of regulations that incorporate private standards by
reference require federal agencies to adopt specific editions of the referenced code that
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