3003 W CASINO RD BLDG 45-11 2018-09-20

r, 1. Introduction The NFPA Standard on Airport Terminal Buildings, Fueling Ramp Drainage and Loading Walkways (415) is not listed as a referenced standard in Chapter 45 of the 2006 edition of the International Fire Code (IFC). Additionally, the topic of loading walkways is not specifically covered in the IFC or the IBC. However, Section 102.7 in the IFC indicates that in the absence of requirements within the IFC, NFPA or other national standards shall be considered applicable as approved by the local Fire Official. The issue herein lies within NFPA 415 regarding Section 6.2.4 which contains a prohibition of transparent or translucent walls, windows, or surfaces other than those windows located in the ramp access service door and in the cab area for the purpose of operating the aircraft loading walkway. 2. Discussion The Boeing Company is in the construction phase of an aircraft Delivery Center at the Boeing Everett site which will be solely used for the transfer of ownership of a purchased aircraft to its new owner or owner's representative. It is the intent of the Boeing Company to purchase, install and employ the use of loading walkways that are constructed of steel and glass components as manufactured by ThyssenKrupp or equivalent. The Boeing Company is requesting approval for this product per Section 104.9 of the IFC"Alternate Methods and Materials". Pursuant to this request, we offer the following: 1. Of primary importance is the Scope of NFPA 415 which states that it specifies the minimum fire protection requirements for the design, construction, and fire protection of aircraft loading walkways between the terminal building and aircraft. The purpose of which is to provide a reasonable degree of protection for life and property from fire at airport terminal complexes. It is the contention, then, of The Boeing Company that based on the specific application of this standard in reference to "Terminal Buildings" and "Terminal Complexes" in the Scope and Purpose of the document that this standard was not intended to be applied to private aircraft delivery centers and their appurtenances, such as aircraft loading walkways. 2. It is understood, that the primary objection to the use of transparent or translucent glazing material in the construction of aircraft loading walkways involves the potential for egress from an aircraft to a terminal building to be interrupted. This interruption is believed to be caused by the psychological affect that a person may have if they are expected to egress through a transparent egress path that may be exposed to fire from a spilled aircraft fuel fire on an aircraft ramp. The fear this person may feel could prevent them from evacuating the aircraft through the glass loading walkway and interfering with the flow of persons behind them that also need to exit the aircraft. ZI�+