Proposed Rulemaking: California Code of Regulations: Title 19, Division 1, Chapter 5.5: Automatic Fire Extinguishing Systems Certification - Second 15-Day Notice: Comments
Dear Fire Marshal Richwine:
The California Association of Life Safety and Fire Equipment (CALSAFE) appreciates the opportunity to provide comments in response to the Second 15-Day Notice of Proposed Rulemaking: California Code of Regulations: Title 19, Division 1, Chapter 5.5: Automatic Fire Extinguishing Systems Certification, regarding a new fee-supported program for the installation of water-based Automatic Fire Extinguishing Systems, including a certification and registration program for individual fire sprinkler fitters or installers.
CALSAFE is an organization that represents fire equipment installation and service companies throughout the state of California. We are committed to bringing professionalism and quality to the service industry. Our members benefit from the training offered, the communication of code, and regulation updates and various interpretations as provided by CALSAFE. A number of our members currently serve on Office of State Fire Marshal Advisory Committees and Workgroups as unpaid volunteers, and have worked diligently with the agency to help update existing regulations for Title 19 of the California Health and Safety Code and the State Fire Code.
CALSAFE has always been in support of a Certification Program relating to testing and maintenance of Automatic Fire Extinguishing Systems. While CALSAFE did not agree there was a need for certification of installers, CALSAFE worked within the process in an attempt to keep the work of the Committee and Workgroup focused on the task of creating a reasonable and functional Certification program for installation of Water-Based Fire Protection Systems. This proposed regulation has now moved to an apprenticeship/journeyman program. The following comments are offered to help make the new, revised program outlined in the Second 15-Day Notice more cost effective and less burdensome on the regulated construction community and to prevent unnecessary job loss in California.