In a letter dated October 19, 2006, the Committee on Standards and Tests approved an installation of listed hoods at the University of Chicago, 61st & Ellis Avenue. On that same day, Ray Schmidt of the Halton Company was required to present to the committee their fully listed Capture-Jet hoods for review and approval.

The same day, Robert Fahlstrom, Manager of Regulatory Review issued the following approval:

Dear Mr. Schmidt:

In response to your team’s October 19, 2006, presentation to the Committee on Building Standards and Tests, the Committee has voted to: Approve the installation of Halton Capture-Jet kitchen exhaust hoods which are engineered to operate at ASTM 1704 and 2474 standards which are lower airflows than the Chicago Building Code requirements.

Approve the installation of Halton Capture-Jet kitchen exhaust hoods which are engineered to operate at ASTM 1704 and 2474 standards which are lower airflows than the Chicago Building Code requirements.

All other building code requirement shall be met. This approval is site specific and shall not be viewed as a precedent. A permit is required for this work. Please contact your project administrator for any further action.

Very truly yours,

Robert Fahlsrom
Manager of Regulatory Review
Chair of the Committee of Standards and Tests
For R. L. Rodriguez, Executive Director

UP YOUR STACK has repeatedly written about this issue. When revising their mechanical code in 2003 to comply with the ICC Mechanical Code, Chicago officials chose to leave out listed hoods. This of course, means any hood being planned for Chicago must use higher volumes of exhaust air in order to meet the antiquated square foot formula. Listed hoods use a lineal foot measurement to comply with certified testing procedures resulting in lesser amounts of air that need to be continually exhausted. That in turn, saves significant quantities of conditioned make-up air and expense at a time when most are looking for ways to conserve energy.

The larger issue here is why did the City of Chicago eliminate listed hoods in its 2003 code rewrite? The even larger issue than that may be why does this type of action seem to be spreading? Here are some other jurisdictions that are over-riding accepted national codes, standards and listings.

• State of Florida requiring a Type II hood over any device producing heat or steam.
• Massachusetts requiring tests to already listed equipment.
• San Francisco Bay Area (BAAQMD) planning to require high efficiency filters (see next article).

These are just a few examples of local and state jurisdictions that are going beyond nationally accepted codes, standards and listings by attempting to interpret data that has been diligently researched by national groups. These groups produce solidly researched evidence that is meant to standardize codes and eliminate the confusion and expense that comes with varying local and state codes.

Why does this trend seem to be accelerating? The reasons are varied. We believe that in most cases, local or state officials are acting in good faith, believing that they are going one better than the nationally accepted codes and standards.

But often we believe they fail to consider the effort put into developing the national codes in the first place. They overlook the years of research and testing that have led to the national codes being developed and passed.

In other instances, creating new rules that require additional testing and permitting can only be viewed as revenue producing sources. Period.

When viewed as a whole, the process of producing nationally accepted codes and standards, a process that normally takes years to develop, is now being undermined.

The many years of labor and work by hundreds and thousands of volunteer committee members is being overridden. We suggest that there are many opportunities for local officials to bring their concerns to these national committees.

We never stop learning and to be sure new ideas develop and need discussion. But acting unilaterally creates confusion and expense on the part of all elements of the industry.

There is never a good reason for a bad decision.