RESIDENTIAL FIRE EXTINGUISHERS

As per what's been discussed and experienced in the past, one or two letters from each association does not produce results.  So here is your opportunity to add your comments, edit, or change to your liking and send it  on personal, business or town letterhead so we can be heard as a uniform group in numbers.


September 13, 2005

 

Mr. Michael L. Ticktin, Esq.

Chief, Legislative Analysis

Department of Community Affairs

PO Box 802

Trenton, NJ 08625-0802

 

RE:            Proposed Amendments:  N.J.A.C. 5:70-2.3, 2.9 and 4.19 for One- and Two-Family
      Dwelling Fire Extinguishers

      Proposal Number:  PRN 2005-293

 

Dear Mr. Ticktin:

The members of the Morris County Fire Prevention Association respectfully submit the following comments on the proposed regulations referenced above.

While the intentions of these regulations are admirable, they create a false sense of security and the potential for serious injury to the homeowners they were designed to protect.  This is evident by the disjunction between the social impact statements and the actual regulations proposed.  Specifically, all of the social impact benefits are predicated on the logic that “if” the occupants are properly trained and knowledgeable with regard to the use of portable fire extinguishers, and use them only after evacuating all personnel and calling the fire department, said extinguishers could represent an important segment of a residential fire protection program.  Unfortunately, the proposed regulations do not mandate any minimum training requirements.  They only require a passive exchange of information by stipulating the extinguisher must be accompanied by an owner’s manual or written instructions, which the homeowner may or may not elect to read.  This could prove to be very devastating to homeowners who have not read the instructions and splash their first kitchen grease fire across the room or onto themselves because they deployed the extinguisher from too close a distance.  This scenario can be further compounded if their inexperience, coupled with panic and the immediate availability of an extinguisher, prompts them to attack the fire without calling the fire department first.

Similarly, the economic impact statements reference a less-than-$10.00 fee for annual servicing, yet there is an obvious absence of any maintenance requirements for these extinguishers unless the homeowners read the instructions and elect to have them serviced as recommended.  Not only does this jeopardize the reliability of these extinguishers, it creates a double set of standards with the requirements for commercial business owners who must use certified fire protection equipment contractors to service their extinguishers on an annual basis. 

 The requirement for mounting an extinguisher in a visible spot, free from obstructions, is a moot point since there is no control over how the new homeowners will arrange the furniture and storage after the change of occupancy.

The requirements for an owner’s manual or written information listed in N.J.A.C. 5:70-4.19(e) 9 should clearly state that this is only required when it is not included on the extinguisher.  Most extinguishers manufactured today include this information on their labels. 

The exception granted to seasonal summer units in N.J.A.C. 5:70-4.19(f) is not warranted since there is equal, if not greater potential for a fire in these dwellings.  This is especially true if the renters are not accustomed to the different types of cooking or heating appliances that may be provided in these units.  The only justification for granting an exception to seasonal summer units would be if they did not contain any sources of ignition.

 In summary, we ask that you reconsider the implementation of these proposed regulations.  Forcing someone to install a fire extinguisher to fight fire in the name of safety is analogous to mandating the purchase of firearms for self protection and reducing crime.  Your consideration of these comments would be greatly appreciated.   

Sincerely,

Richard Heimbach

President