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Seattle Fire Marshal and multiple testifiers flag editorial errors and mismatched standard editions in CR102; staff to post written comments and correct
Summary
Numerous speakers, led by the Seattle Fire Marshal, identified editorial omissions, inconsistent edition references (NFPA, ASHRAE, IEC/60335) and missing footnotes across CR102/CR103; staff acknowledged an editorial correlation process and will post and reconcile written testimony before workshops.
Multiple registered testifiers and the City of Seattle Fire Marshal's office submitted detailed, technical comments identifying editorial errors and inconsistent reference‑standard editions in the draft CR102/CR103 documents that accompany the 2024 code proposals.
Ken Burlette (Seattle Fire Marshal's office) repeatedly identified mismatches between the building and fire code CR102 documents — for example, differing NFPA editions referenced in WAC 51‑50 and WAC 51‑54a and missing or misnumbered table footnotes and appendix notes. He urged the SBCC and staff to correct the CR102 before final adoption to maintain correlation between model codes and Washington amendments.
Other witnesses (Daikin, Robert Glass; Eric Vandermee; and others) also pointed to omissions such as missing reference standards for chapter 15, editorial omissions of ASHRAE 15/34 2024 references, and discrepancies in table 11‑03‑1 refrigerant data that could create confusion for jurisdictions and enforcement officers.
Council staff said they are still correlating written testimony with oral testimony and expect to post written comments for public review next week; they committed to including those corrections and summaries in workshop materials prior to council deliberation. No formal change or vote was made at the June 12 hearing.
