ES&H Manual

Fire Protection Supplement

Chapter 8:

Equivalencies and Exemptions


1.0             Purpose

This document provides guidance for the request and approval of alternative materials and methods to satisfy prescriptive fire and life safety code requirements and the method to request exemption from DOE fire protection requirements.

2.0             Scope

This document describes the procedure used to determine prescriptive fire code equivalencies and to justify exemptions from DOE requirements. Section 6.0 of this chapter details a complete list of current, approved equivalencies and exemptions.

Documented requests and approvals of exemptions and equivalencies at Jefferson Lab are also available in Docushare.

3.0             Responsibilities

3.1              Fire Marshal

·         Determine if an equivalency to or exemption from a fire protection code or standard requirement is necessary and prepare a request.

4.0             Process Steps

4.1              Equivalencies

4.1.1        Equivalency requests are prepared for approval for configurations of fire protection and life safety conditions that are determined to provide an acceptable level of protection, safety, and/or an equivalent level of performance of required systems, methods, or devices.


4.2              Exemptions

4.2.1        Exemption requests are prepared for configurations related to noncompliant fire protection and life safety related conditions that are determined to be in direct violation of a national standard, code, or DOE requirements. Document the conditions, costs and benefits, usually in the context of a Fire Hazard Analysis (FHA), and present the rationale for a proposed exemption.


4.3              Exemption or Equivalency Request Documentation


4.3.1        The level of documentation necessary to support an exemption or equivalency will vary, depending on the issue. As a minimum, each analysis identifies:

·         Specific site location or condition at issue.

·         Paragraph/section of the code or standard which addresses the issue.

·         Discussion as to why the literal requirements of the code or standard cannot be met.

·         Discussion which justifies the conclusion that the alternate configuration is acceptable or equivalent from a safety perspective to what is stipulated in the code or standard.

4.3.2        Exemptions and equivalencies that are programmatic in nature (affect more than an individual component or design feature) are supported through the facility FHA, if applicable. Where more than one exemption/equivalency request exists for a single facility/system, the request, evaluation, and discussion must demonstrate that the cumulative effect of such conditions will not increase the level of risk beyond an acceptable level.

4.4              Approval


4.4.1        The Fire Marshal submits the proposed equivalency or exemption to the Jefferson Lab Director’s Safety Council for institutional approval.

4.4.2        The Chief Operating Officer submits the request to the Thomas Jefferson Site Office (TJSO) for review and transmittal to the cognizant DOE authority for final review and approval.

4.4.3        Upon receipt of approval of the submitted exemption or equivalency request the Fire Marshal implements any compensatory measures that may accompany the approval.


4.5              Review


DOE approved fire protection exemptions and equivalencies are reviewed every three years in accordance with guidelines set forth in the Authority Having Jurisdiction (AHJ) delegation letter. These reviews evaluate ongoing need, continued validity of stated assumptions and compliance with applicable requirements.


5.0             References

·         International Fire Code-2006; paragraph 104.9 Alternative materials and methods


6.0             Approved Equivalencies and Exemptions


·         Fire Sprinkler Protection for Experimental Halls A, B & C – September 27, 2010

·         Manual Pull Stations, Beam Enclosure – April 21, 1995

·         National Fire Protection Association (NFPA) 101 Equivalency Approval – February 4, 2008

·         TJSO Approval of Very Early Smoke Detection Apparatus (VESDA) Isolation – September 24, 2012


7.0             Revision Summary


Revision 0.3 – 01/03/19 – Periodic Review; updated TPOC from E.Douberly to T.Minga

Revision 0.2 – 06/02/16 – Periodic Review; updated TPOC from D.Kausch to E.Douberly

Revision 0.1 – 09/17/13 – Periodic Review; updated links and references; added 6.0 Approved Equivalencies and Exemptions

Revision 0.0 – 09/28/09 – Initial content










Fire Protection Department

Tim Minga





This document is controlled as an on line file.  It may be printed but the print copy is not a controlled document.  It is the user’s responsibility to ensure that the document is the same revision as the current on line file.  This copy was printed on 1/10/2019.