A notice of intent to file an appeal of the recent June 14 decision of the National Fire Protection Association (NFPA) Technical Committee to amend its 150 Standard for Fire and Life Safety in Animal Housing Facilities requiring that sprinkler systems be installed in all animal housing facilities was submitted on July 4 to NFPA. The National Pork Producers Council prepared and submitted the notice on behalf of 15 agricultural trade groups that produce livestock and poultry, including the National Chicken Council. The actual appeal will be submitted by the July 9 deadline.
The NFPA’s 150 amendment will require the installation of sprinkler and smoke control systems in animal housing facilities for Category B animals. NFPA 150 divides animals into Category A animals, which are wild animals that pose a potential risk to the health and/or safety of handlers, rescuers, or the general public or animals that cannot be removed without potential risk to the health and welfare of the animal or other animals. Category B animals, according to NFPA, are all other domesticated animals not identified in Category A.
NFPA stated mission is “to reduce the burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training, and education.” NFPA standards are consensus based codes written by volunteers who form the “technical committees” responsible for these standards. The Technical Committee on Animal Housing Facilites has the responsibility of developing and updated NPFA 150. The members of the Technical Committee represent varioius interest groups such as consultants, government officials, manufacturers, zoos, insurance companies, animal welfare organizations, and authorities having jurisdiction. .
The written appeal will focus on several concerns including:
- The overall lack of due process in developing the standard and failure to provide a reasonable form of effective notice or opportunity for input or comments from the impacted stakeholders;
- The over-broad nature of the NPFA 150 amendment, which will impact all production livestock and poultry facilities without any evidence of any issues with fire in animal housing facilities;
- The economic impact the NFPA 150 amendment will have on U.S. livestock and poultry productions without any corresponding benefits to livestock and poultry production;
- The physical impracticability for significant majorities of livestock and poultry producers to find sufficient sources of water to achieve the amended NPFA 150 standard; and
- The risk of real harm to animal health and biosecurity of livestock and poultry production facilities that the amended NPFA 150 and corresponding NPFA 25 inspections standards require.
The notice of intent to file an appeal also requested the opportunity to present the appeal in person before NFPA during its scheduled meeting over August 7-9 when the appeal will be heard.
The other organizations besides the National Pork Producers Council and the National Chicken Council include the U.S. Poultry and Egg Association, National Turkey Federation, American Farm Bureau, National Cattlemen’s Beef Association, Dairy Farmers of America, Agri-Mark Inc., Northeast Dairy Farmers Cooperatives, United Egg Producers, National Council of Farmer Cooperatives, National Milk Producers Federation, Dairylea Cooperative, Select Milk Producers, and St. Albans Cooperative Creamery.
