The PSME strongly objects to the inclusion of Fire Protection in House Bill 3565
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Objection to the inclusion of “Fire Protection”
On behalf of the 115,000 Professional Mechanical Engineers, Mechanical Engineers and Certified Plant Mechanics in the roll of members of the PSME and the one hundred fifteen (115) PSME Chapters scattered all over the country, middle east and Singapore, we hereby post objection to provision Section 5, Scope of Practice, under the function of Environmental Engineer article (b) of the proposed House Bill 3565, which states –
“(b) Plan, design, approve, investigate, evaluate, supervise, and monitor environmental engineering process, facilities including fire protection and sanitary utilities in buildings, and other related projects;”
PSME strongly object to this particular provision for the following reasons:
1. House Bill 3565 encroaches on the practice of Mechanical Engineering on "Fire Protection." Fifty percent (50%) of all Mechanical Engineers is on the practice of the design, consultancy, installation, maintenance or operation of fire protection system where twenty-five percent (25%) is in design, consultancy and installation.
2. Fire Protection, as the name suggests, is about safety. It is about preventing the occurrence and management of fire incidents. The Mechanical Engineers are the recognized profession in the Philippines by the following codes and laws:
a. National Building Code of the Philippines (PD 1096),
b. Mechanical Engineering Law (R.A. 8495),
c. Fire Code of the Philippines and
d. the Philippine Mechanical Engineering Code.
3. Fire protection is about preventing and managing the occurrence of fire incidents. It is about saving lives and properties, first and foremost. Fire Protection system and its components design, installation, operation and maintenance are in the scope of practice of mechanical engineering. The principles, engineering and science of fire protection is tightly woven in the education of a Mechanical Engineer. It is for this reason that the fire protection code are written by Mechanical Engineers with PSME front and center in the maintenance and update of the fire code.
4. Controlling and monitoring materials and effluents in a fire protection system are implemented through codes, laws and standards set by various government agencies.
5. HB 3565, insofar as its provisions related to fire protection are concerned, will cause confusion as to the proper professional legally designated to perform fire protection design, installation and construction. The HB 3565 may in fact worsen fire safety in the Philippines, not enhance it. This, with all due respect, is dangerous.
6. Sanitary and environmental engineering is about hygiene and saving the environment and not about preventing and managing the occurrence of fire incidents. In the National Building Code, the Sanitary Engineers do not have scope about fire protection.
HB 3565 Versus R.A. 8495, The Mechanical Engineering Act of 1998
Section 35 of Republic Act 8495, also known as "An Act Regulating the Practice of Mechanical Engineering in the Philippines" states that:
Section 35. Preparation of Plans and Supervision of Construction by Licensed Engineers Required. It shall be unlawful for any person to order or otherwise cause the fabrication, construction, erection, installation or alteration of any mechanical equipment, machinery or process for any mechanical works, projects, or plants, unless the designs, plans, layouts or specifications have been prepared by or under the responsible charge of, and duly signed and sealed by a Professional Mechanical Engineer. Likewise, proposals and quotations for the supply and fabrication of mechanical equipment, works, projects, plants, mechanical pollution abatement systems, mechanical fire protection systems, pressurized pipes with a working pressure of not less than 70 kPa, shall be duly signed and sealed by a Professional Mechanical Engineer. (See attached Annex-2)
This section explicitly mentioned the mechanical fire protection systems and pressurized pipes with a working pressure of not less than 70 kPa, which defines the fire protection system that the scope of sanitary engineering as defined in HB 3565 has encroached.
Sprinkler systems, hydrants, standpipes and other extinguishing system are categorized as mechanical fire protection system and under pipes of working pressure above 70 kPa.
HB 3565 Versus the National Building Code of the Philippines (PD1096)
The “Mechanical Documents” section in the National Building Code, particularly Section 302.7.k, provide that:
"Detailed plans of fire suppression systems, location of automatic and smoke detectors and alarm and initiating devices use to monitor the conditions that are essential for the proper operation including switches for the position of gate valves as well as alert and evacuation signals; the detailed layout of the entire safe area to be protected and the heat/smoke ventilation system." (See attached Annex-1)
Said “Mechanical Documents” are signed by a Professional Engineer.
Under the National Building Code, the Sanitary Documents have no stated scope about fire protection systems (see Section 302.8).
In addition to Section 302 of the National Building Code of the Philippines, the Schedule of Fees and other charges for Mechanical Fees includes:
g. Automatic fire sprinkler system, per sprinkler head………………….. 4.00 (See Annex-1A)
HB 3565 Versus the Fire Code of the Philippines & the Philippine Mechanical Engineering Code
Fire Protection in the Philippines is governed by the Bureau of Fire Protection (BFP). Hence under the issuance of Fire Safety Clearance for Installation of Automatic Fire Suppression System (AFSS), the recognized engineer to undertake the installation and construction is aProfessional Mechanical Engineer. (See attached Annex-3)
BFP issued Bureau of Fire Protection Operational Procedures Manual 2015, states and define under Sections;
1.1 BUILDING PLAN REVIEW
1.2 FIRE SAFETY INSPECTION (PRE-CONSTRUCTION PHASE)
1.3 FIRE SAFETY INSPECTION (CONSTRUCTION PHASE)
1.4 FIRE SAFETY INSPECTION AND ISSUANCE OF FSIC FOR OCCUPANCY
1.5 ISSUANCE OF FSIC FOR BUSINESS PERMIT
1.6. ISSUANCE OF FSIC FOR RENEWAL OF BUSINESS PERMIT
1.20 APPLICATION FOR THE APPROVAL OF THE ADEQUACY OF ALTERNATIVE AND/OR REMEDIAL FIRE SAFETY MEASURES
1.21 ISSUANCE OF CERTIFICATE OF EXEMPTION
These sections are adopted by Philippine Society of Mechanical Engineering Code. (See Annex 3-A)
Fire Protection is one of the primary tasks of Mechanical Engineers. It is in fact written and integrated into the PSME Code since 1980.
HB 3565 Versus International Mechanical Code
Aside from existing domestic laws governing fire protection, there is also a fire protection scope of Mechanical Engineers under International Mechanical Code Section 509 (See attached Annex 4)
PSME strongly objects to the inclusion of the term “fire protection” and request the august body to delete this in that particular provision so that the proposed amended provision will now read –
“(b) Plan, design, approve, investigate, evaluate, supervise, and monitor environmental engineering process, facilities including sanitary utilities in buildings, and other related projects;”
And because it is the only provision with the term “fire protection” throughout the proposed Bill excluding the Definition of terms, we respectfully request the august body to delete the following provisions under Section 4, Definition of Terms:
(l) Fire protection refers to the part of the water supply…
(m) Fire Protection System pertains to the engineered fire protection for…
In essence, and based on all the above, we strongly feel that with regards to Fire Protection, the definitions of tasks and functions relating to sanitary and environmental engineers contradict existing laws and codes as well as rules and regulations. We also believe that the engineering education of the Mechanical Engineers ensure sound judgement towards a reliable and effective fire protection systems.
There is a need to enhance and update the Fire Code of the Philippines and the Philippine Society of Mechanical Engineers and the Bureau of Fire Protection has initiated move to update it. However, HB3565 will only cause confusion and will not help in the effort to have an effective and reliable fire protection systems in the Philippines.
We commend the authors and the House of Representative in coming up with this HB 3565 to improve protection of our Citizen and the Environment and to help better define and improve the practice of Sanitation and Environmental Engineering.
We pray, however, to get your full support to our request for amending this proposed bill to exclude Fire Protection.
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