1990 Annual Meeting Technical Committee …...submitted to letter ballot of the Technical Committee on Aerosol Proucts, which consists of 20 voting members, in two segments. Segment

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Technical Committee Documentation A compilation of the documented action on comments received by the technical committees whose reports have been published prior to consideration at the NFPA Annual Meeting

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Please bring to the 1990 Annual Meeting San Antonio Convention Center San Antonio, TX May 21-24, 1990

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l [ ~ National Fire Protection Association N F P A ® 1 BATTERYMARCH PARK, P.O. Box 9101, QUINCY, MA 02269-9101

R Copyright ~-', 1990 All Rights Reserved

SUPPLEMENTARY

Report of Committee on Flammable Liquids

Correlat ing Committee

Leon C. Schal ler, Chairman E. I. Dupont de Nemours & Co.

G. E. Cain, G. E. Cain & Co. John J. Hawley, Underwriters Laboratories Donald M. Johnson, San Bruno, CA

Rep WSPA C. L. Kingsbaker J r . , At lanta, GA F. Owen Kubtas, The Glidden Co. Steven Landon, Trophy Club

Rep. TCATA Eugene S. Schmitt, Fire Marshal Divis ion Orv i l l e M. Slye J r . , Loss Control Associates Inc. W. 3. Smith, Underwriters Laboratories Inc.

Paul C. Lamb, Englewood, N3 (Member Emeritus)

Technical Committee on

Aerosol Products

Orv i l l e M. Slye J r . , Chairman Loss Control Associates Inc.

Charles B. Barnett, ASCOA Fire Systems Rep. NFSA

Byron L. Briese, Professional Loss Control, Inc. Steve Ermert, Malone & Hyde Inc. David L. Fredrickson, S. C. Johnson & Son Inc.

Rep. CSMA WilliamA. Gregg IV, Precision Valve Corp.

Rep. CSHA Richard 3. Hi ld, Verlan Limited James Koskan, Super Valu Stores, Inc. Thomas J. Kramer, Schlrmer Engineering Corp. Michael J. Madden, Phoenix Fire Department, AZ Edward Reardon, Fenwal Inc. Donald E. Rowson, Indust r ia l Hydrocarbons, Inc. Henry C. Scuoteguazza, Factory Mutual Research Corp. Larry O. Shackelford, Fluor Daniel Thomas Siciliano Jr. , Lehn & Fink Products Group Rodney P. Smith, The Kartridg Pak Co. David C. Tabar, The Sherwin-Wflliams Co. W. P. Thomas Jr. , Kemper Group

Rep. AAI Peter O. Gore Willse, Industrial Risk Insurers Gene Wolfe, Los Angeles County Fire Department, CA

Alternates

William 3. Beasland, Schirmer Engineering Corp. (Al ternate to T. 3. Kramer)

John A. Davenport, Indust r ia l Risk Insurers (Al ternate to P. 3. G. Wil lse)

D. Douglas Fratz, Chemical Special t ies Mfgs. Assn. Rep. CSMA (Al ternate to W Gregg)

Montfort A. Johnson, Montfort A. 3ohnsen & Assoc. Ltd (Al ternate to D. L. Fredrickson)

Jerome S. Pepi, Grinnel l Corporation Rep. NFSA (Al ternate to C. Barnett)

Kevin F. Sykora, The Sherwin-Williams Co. (Al ternate to D. C. Tabar)

Thomas K. Terrebonne, Kemper Group Rep. /b~I (Al ternate to W. P. Thomas J r . )

Technical Committee on

Automotive and Marine Service Stations

Eugene S. Schmltt, Chaiman Fire Marshal Divis ion

E. Joseph Bocci, Nat1 Capital Region Arthur C. Fink J r . , Husky Corp. Salvatore Gi lard i 3 r . , Am Insurance Services Group Daniel T. Grace, Ansul Fire Protection

Rep. FEtt¢ Fred Gre i l , City of New Car l l s le

Rep. NFPA/FSS Donald Mausz, Al l Out Fire Equipment Co., Inc.

Rep. FAFED John P. Hig~ins, Mutual Service Off ice Donald R. Hltchcock, Texaco, Refining and Marketing, Inc. Donald M. Johnson, San Bruno, CA

Rep. WSPA Marshall A. Klein, Marshall A. Klein & Assoc. Inc.

Rep. JLI Martin E. Magera, Underwriters Laboratories Inc. A. E. Mtttermaler, Tokhelm Corp.

Rep. GPMA Richard F. Murphy, Exxon Research & Engr. Co. R. L. Murray, Dover Corporation Wil l iam E. Rehr, City of Wheaton, IL

Rep. FHANA Robert N. Renkes, Petroleum Equipment I ns t i t u te 3ohn S. Robison, AL Fire Marshal's Off ice Wtlltam M. Shaughness[, Comm of MA Dept. of Pub Safety E. A. Talbot t , Salt River Project

Alternates

Fred B. Goodnlght, Amerex Corp. Rep. FEHA (Al ternate to D. T. Grace)

Wil l iam L. Har tze] l , Har leysv i l le Mutual Insurance Co. Rep. AISG (Al ternate to L. Gi lardi J r . )

3ohn R. McPherson, Exxon Co., USA

Technical Co~aittee on

Flammable and Combustible Liquids

Donald M. Johnson, Chairman San Bruno, CA

(Rep. WSPA)

Wi11iam S. Anderson, 3M Company Henry M. Bel l , Dow Chemical USA David L. Blomqulst, Chevron Corp.

Rep. API Weldon L. Brundrett, M&M Protection Consultants Michael T. Castellano, Joseph E. Seagram & Sons Inc.

Rep. DSC James I . Gallup, Mat1 Loss Control Service Corp. Wayne Geyer, Steel Tank I ns t i t u te John J. Hawley, Underwriters Laboratories Inc. Donald L. Hierman, Rhone-Poulenc, Inc.

Rep. CMA Michael S. Hildebrand, American Petroleum Inst . Edward Hildebrandt, V i l lage of Morton Grove Fire

Dept., IL Rep. IFIA

3oshy Paul Kal lungal, Ontario Fire Marshals Off ice James D. K ie f fe r , Hiram Walker & Sons Ltd Wallace D. Malmstedt, American Ins. Services Group Inc. John G. Manganaro I I , US Coast Guard Mavin O. Mehta, Defense Logist ics Agency - WIR Joseph R. Natale, Mobil Research & Development

Rep. NPRA Wi11iam E. Rehr, City of Wheaton

Rep. FMANA

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Robert N. Renkes, Petroleum Equipment Institute Gerald O. Rosicky, General Motors Corp.

Rep. NFPA IFPS Leon C. Schaller, E. I. Dupont de Nemours & Co.

Rep. NPCA Eugene S. Schmitt, Dept. of State Police

Rep. FMANA Henry C. Scuoteguazza, Factory Mutual Research Corp. Roger R. Singh, Insurers Advisory Organization Brooke B. Smith Or., Aspen Engineering Inc. Damon W. Snow, Monsanto Co.

Rep. SPI R. I. Spencer, Industrial Risk Insurers Thomas K. Terrebonne, Kemper Group

Rep. AAI Harold S. Wass Jr., IRM Insurance

Alternates

Brian H. Bender, ICI Americas Rep. NFPA IFPS (Alternate to G. O. Rosicky)

Robert H. Christopher, E. I. du Pont de Nemours (Alternate to L. C. Schaller)

J. W. Cragun, Phill ips Petroleum Co. John A. Davenport, Industrial Risk Insurers

(Alternate to R. I. Spencer) Robert D. Grausam, Kemper Group

Rep. AAI (Alternate to T. Terrebonne)

William R. Heitzig, Dow Chemical Co. Randolph C. Helland, US Coast Guard

(Alternate to 0. G. Manganaro I I) David L. Hodgden, Owens-Illinois Inc.

(Alternate to D. W. Snow) Richard Kraus, Mobil Oil Co. Martin E. Magera, Underwriters Laboratories Inc.

(Alternate to J. O. Hawley) David G. Mahoney, M&M Protection Consultants

(Alternate to W. Brundrett) Lee Paige, IRM Insurance

(Alternate to H. Wass) Douglas Rivers, 3M Co.

(Alternate to W. H. Anderson)

Nonvoting

Michael B. Moore, US Occupational Safety & Health Admin.

Richard F. Murphy, Exxon Research & Engr. Co. Rep T/C on Foam

Orville M. Slye Or., Loss Control Associates Inc. Terence P. Smith, US Occupational Safety & Health Admin.

(Alternate to M. B. Moore)

Staff Liaison: Robert P. Benedetti

This l i s t represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred.

The Supplementary Report of the Committee on Flammable Liquids is presented for adoption in 3 parts.

Part I of this Supplementary Report was prepared by the Technical Committee on Aerosol Products and proposes for adoption a Supplementary Report which documents its action on the public comments received on i ts Report on NFPA 30B-1990, Code for the Manufacture and Storage of Aerosol Products, published in the Technical Committee Reports for the 19g0 Annual Meeting.

Part I of this Supplementary Report has been submitted to let ter ballot of the Technical Committee on Aerosol Proucts, which consists of 20 voting members, in two segments.

Segment No. l consists of only Comments 30B-269 (Log No. 69) and 30B-268 (Log No. 298).

On Segment No. l, of 20 voting members, 18 voted affirmatively, l negatively (Mr. Wolfe), and I ballot was not returned (Mr. R. Reardon).

The reason for Mr. Wolfe's negative vote is as follows:

"The proposed Appendix (contained in) Comment #298 provides so l i t t l e substantive information that i t would be useless for determining i f an alternative to

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the code was appropriate. The substantiat ion for ( th is) Appendix is an excel lent j u s t i f i c a t i o n for Appendix (contained in) Comment No. 69."

Segment No. 2 consists of the balance of the other publ ic comments.

Segment No. 2, of 20 vot ing members, ig voted a f f i rmat ive ly and 1 ba l lo t was not returned (Mr. Reardon).

Part I of th is Supplementary Report has also been submitted to l e t t e r ba l l o t of the Correlating Committee on Flammable Liquids which consists of 10 voting members; a l l of whom voted a f f i rmat ive ly .

Part I I of th is Supplementary Report was prepared by the Technical Committee on Automotive and Marine Service Stations, and proposes for adoption a Supplementary Report which documents i t s action on the public comments received on i t s Report on NFPA 30A-1987, Automotive and Marine Service Station Code, published in the Technical Committee Reports for the 1990 Annual Meeting.

Part I I of th is Supplementary Report has been submitted to l e t t e r ba l lo t of the Technlcal Committee on Automotive and Marine Service Stations, which consists of 2] vot ing members; of whom 20 voted a f f i rmat ive ly , and I abstained (Mr. Hitchcock).

The reason for Mr. Hitchcock~s abstaining vote is as fol lows:

"The American Petroleum Ins t i tu te doesn't t o t a l l y agree with the Committee Action on one item, namely Comment 30A-2 (Log #5), regarding emergency breakaway devices on dispensing hoses. However, we do not wish to cast a negative vote on the ent i re (documentation) package."

Part I I of th is Supplementary Report has also been submitted to l e t t e r ba l lo t of the Correlat ing Committee on Flammable Liquids which consists of 10 voting members; al l of whom voted affirmatively.

Part I I I of this Supplementary Report was prepared by the Technical Committee on Flammable and Combustible Liquids, and proposes for adoption a Supplementary Report which documents its action on the public comments received on i ts Report on NFPA 30-1987, Flammable and Combustible Liquids Code, published in the Technical Committee Reports for the 1990 Annual Meeting.

Part I I I of this Supplementary Report has been submitted to le t ter ballot of the Technical Committee on Flammable and Combustible Liquids which consists of 30 voting members; of whom 28 voted affirmatively, l negatively (Mr. Smith), and I ballot was not returned (Mr. Singh).

The reason for Mr. Smith's negative vote is as follows:

"( I am) opposed to the Committee' Action on the Comments to (TCR Proposal No.) 30-43 to extend the effective date in 4-5.6.4 from September I, 1990 to September l , 1992. Reasons follow:

l) Effective dates and extensions thereto complicate code use, especially for the authority having jurisdict ion.

2) The hazards of liquids in plastic containers in general purpose warehouses are known by test and f i re experience. I t is inconsistent for the Code to permit such hazards to continue.

3) A substantial majority of the public comments to Proposal 30-43 were opposed to the extension of the effective date. The reasons given for each opposing comment were well substantiated.

With the above exception, the proposed amendments to (the Report on) NFPA 30 are acceptable and basically improve the Code. The decision to vote against the Committee Action because of this one issue was a d i f f i cu l t one."

Part I l l of this Supplementary Report has also been submitted to le t ter ballot of the Correlating Committee on Flammable Liquids which consists of lO voting members; al l of whom voted affirmatively.

PART I

(Log #305) 30B- l - (Entire Document): Reject ~UBMITTER: Rodney A. McPhee, Canadian Wood Council COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Consideration should be given to indicating that storage on plastic pallets is beyond the scope of this new standard. ~JBSTANTIATION: To my knowledge all testing and/or f i re protection engineering studies carried out to develop the guidelines as proposed did not consider the use of plastic pallets as storage aids. I t is well known that plastic pallets have a different heat release history than wood pallets. Also, the stabi l i ty of the plastic pallet under f i re conditons is fe l t to be not as good as wood pallets. Pile s tab i l i ty during f ire conditions in solid pile storage is cr i t ical to the suppressibility of the f i re due to collapsing stock shielding the f i re from water sprays. In rack storage, premature or early failure of the pallet could cause storage to fa l l out of the racks spreading f i re to adjacent rows of storage as well as shielding the seat of the f i re from the water sprays.

Until actual f i re test data is developed, the application of the design cr i ter ia in the standard should be limited as proposed. ~OMMI_~_IEE~QN: Reject. COMMITTEE STATEMENT: The submitter has offered no specific changes to the text. Also, the Committee feels that the subject of this comment is beyond the scope of NFPA 30B.

(Log #308) 30B- 2 - (Entire Document): Reject ~ : Arnold Doleisi, Scrivner, Inc. COMMENT ON PROPOSAL NO.: 30B-I I~,_C_OliMF, I~)AT~O_I~: The proposed amendment 30B should not be submitted at this time due to insufficient and inadequate preparation of wording within the document. SUBSTANTIATION: Code 30B was prepared without due consideration for existing NFPA Code requirements. There are numerous noted inconsistencies with NFPA 30, NFPA 231, and NFPA 231C. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that adequate review and preparation have been accomplished. The submitter cites no specific inconsistencies to substantiate his claim.

(Log #146) 30B- 3 - (I-1.3 (New)): Reject ~ : James R. Quiter/Jerome E. Cunningham, Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: N/A REC~MEND&TION: Add I- I .3 as follows:

"This code shall not apply to storage of aerosol products by end-users." SUBSTANTIATION: The scope statement, section I- I .1, states that the code applies to storage of aerosol products but does l imi t the word "storage" to warehouse or mercantile fac i l i t ies . I f i t is the Committee's intent that the code not apply to storage of aerosol products by end-users, i t should be so stated in the scope sec t i on . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Certain end users are addressed in Section 4-3. I t is unclear what the Submitter means by an "end-user," however.

(Log #I) 30B- 4 - ( I - I .3 (New)): Accept in Part S__VBMITTER: Ronald R. Czischke, Underwriters Laboratories Inc. COMMENT ON PROPOSAL NO~: 30B-I RECOMMENDATIO~ New text:

I - I .3 This Code shall not apply to the storage and display of type DOT 2P and/or 2Q containers with the contents comprised entirely of LP-Gas products. (See NFPA 5B).

SUBSTANTIATION: Containers for the storage and display of LP-Gas products is covered in NFPA 58, Standard for the Storage and Handling of Liquefied Petroleum Gases. COMMITTEE ACTION: Accept in Part.

Use the wording proposed, but delete "Type DOT 2P and/or 2Q."

Also, revise to read: "whose contents are comprised entirely of." COMMITTEE STATEMENT: The changes made by the Committee reflect the fact that NFPA 30B doesn't apply to any LP-Gas container.

(Log #50) 3OB- 5 - (I-2): Accept in Principle SUBMITTER: Salvatore A. Gilardi, Jr., American Insurance Services Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add the following to the end of the definition to read:

" . . . display aerosol products and to provide f ire protection guidelines to these fac i l i t ies . " SUBSTANTIATION: To better define the purpose of this standard. COMMITTEE ACTION: Accept in Principle.

Retain the current I-2, but add the words "and control" after the word "prevention." COMMITTEE STATEMENT: The Committee's wording is more descriptive of NFPA 30B's stated purpose.

(Log #84) 30B- 6 - (I-4): Reject SUBMITTER: Gene Wolfe, Los Angeles County Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

I-4 Retroactivity. The provisions of this Code are considered necessary to provide a reasonable level of protection from loss of l i f e and property from f ire and explosion. They reflect situations and the state of the art at the time the Code was issued.

Existing plants, equipment, buildings, structures, and installations for the storage, handling, or use of aerosol products that are not in st r ic t compliance with the terms of this code may be continued in use at the discretion of the authority having jurisdiction provided they do not constitute a recognized hazard to l i f e or adjoining property." SUBSTANTIATION: This subsection as written would imply that existing occupancies with aerosol products could continue regardless of the hazard. This would not be consistent with other NFPA standards. The proposed change would substitute language from 30-A. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The wording of the Retroactivity statement is set by NFPA Standards Council Policy.

(Log #173) 30B- 7 - (I-4): Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin Williams COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

I-4 Retroactivity. The provisions of this Code are considered necessary to provide a reasonable level of protection from loss of l i f e and property from f ire and explosion. They reflect situations and the state of the art at the time the Code was issued. Unless otherwise noted, i t is not intended that the provisions of this Code be applied to fac i l i t ies , equipment, structures or installation prior to the effective date of the Code. SUBSTANTIATION: This is a new code and as such as all established building and equipment should not have to be in compliance with the code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The wording of the Retroactivity Statement is set by NFPA Standards Council Policy.

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(Log #51) 30B- 8 - (I-6, Aerosol): Reject ~TTER: Salvatore A. Gilardi, Jr . , American Insurance Services Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise the def in i t ion of an aerosol to read as follows:

"A product such as a mist, spray, foam, gel, or aerated powder that is dispensed by a propellant." SUBSTANTIATION: For c la r i t y and to eliminate the use of the word "aerosol" in i ts def in i t ion. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The concerns of the Submitter are covered by the Appendix item. The submltter's version is unnecessarily broad in that i t does not mention a container.

(Log #190) 30B- 9 - (1-6, Aerosol): Reject ~ : Robert Malanga/William Webb, Rolf Jensen and Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise def in i t ion of "Aerosol" to read:

Aerosols. Suspensions of various kinds may be formed by placing the components together with a compressed gas in a container (bomb). The pressure of the gas causes the mixture to be released as a fine spray (aerosol) or foam (aerogel) when a valve is opened. This technique is used on an industrial scale to spray paints and pesticides. I t is also used in consumer items such as perfumes, deodorants, shaving cream, whipped cream and the l lke. The propellant gas may be hydrocarbon (propane, isobutaine) or dimethyl ether. Admixture of 15 percent of methyl chloride with the hydrocarbons reduces their flammable risk, while water can be used with dimethyl ether. Carbon dioxide generated in situ is a more recently developed propellant, which does away with the flammability problem. SUBSTANTIATION: Definitions should correspond to those of a nationally recognized publication such as the Condensed Chemical Dictionary, Sax and Lewis, l l t h Edition. The present def in i t ion is redundant with that of an "Aerosol Container" and does not give any information as to what causes or contributes to the hazards of aerosols. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Submitter's discussion is much too l imi t ing in that only two forms of product are cited, as are only a few of many propellants. Also, the description is more of a hazard description, rather than a "code language" def in i t ion. The wording is also technically inaccurate in that methyl chloride is not used at al l and carbon dioxide does not to ta l l y eliminate the Flammability problem.

(Log #202) 30B- 10 - (I-6, Aerosol): Reject SUBMITTER: Stephen M. Stuart, Johnson & Higgins COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Define "Aerosol" as:

"A product that is dispensed from an aerosol container by a propellant under pressure greater than atmospheric." SUBSTANTIATION: The def in i t ion of "Aerosol" now being considered could be interpreted to include pump-spray products where the contents are not under pressure. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The current def in i t ion is adequate for the purposes of this standard. Also, since the def in i t ion specifies "propellant" the concerns of the submltter are addressed.

(Log #191) 30B- II - (I-6, Aerosol Container): Reject ~ : Robert Malanga/William Webb, Rolf Oensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise def in i t ion of aerosol container to read:

" ( I ) A cylinder that has no safety re l ie f device with a maximum length of 12 in., exclusive of the neck, and an outside diameter of less than 4-I/2 in. with an internal pressure of up to l,SO0 psi, or

(2) A glass or plast ic bott le that is designed and intended to dispense an aerosol." ~UBSTANT~ATIQN: The major f i re protection concern of aerosol containers is the absence of a safety device to relieve a potential build up of pressure due to excessive heating that can cause container fai lure. The Code of Federal Regulations recognizes that a safety re l ie f device is necessary to protect larger pressurized containers and has excluded aerosol containers from the requirements due to their small size. NFPA 308 should attempt to f i l l this gap by requiring alternative safeguards. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The proposed change would res t r ic t the def in i t ion to certain aerosol products and containers and yet would include products that are not intended to be covered by this code.

(Log #244) 30B- 12 - (I-6, Aerosol Container): Accept in Principle SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to the end of the def ini t ion of "Aerosol Container" the following statement:

"Containers of a capacity of less than I ounce net weight shall not be considered to be aerosol containers for the purpose of this Code." SUBSTANTIATION: Testing of butane cigarette l ighters has shown that small containers have signi f icant ly reduced f i re hazard as compared to larger containers. [See Factory Mutual Data Sheet 7-295.2 (Nov. 1986).] I t is therefore very l i ke ly that very small aerosols also do not present the same hazard as larger aerosol products. Until such time as testing is done on very small aerosols, they should be excluded from consideration in this standard. COMMITTEE ACTION: Accept in Principle.

Add new 4-I.5.1 to read: "Subject to the approval of the authority having

jur isd ic t ion, Level 2 aerosol products in containers whose net weight of flammable contents is less than 1 ounce may be stored as Group A plastics, as defined by NFPA 231, Standard for General Storage, and NFPA 231C, Standard for Rack Storage of Materials." COMMITTEE STATEMENT: This better accomplishes the intent of the submitter and provides guidance for proper protection.

(Log #145) 3OB- 13 - (1-6, Aerosol Conta iner ) : Accept in P r inc ip le SU~MITTER: Eileen J. Moyer, Airwick Industries COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

Aerosol Container. A metal can, up to a maximum size of 1000 ml (33.8 f lu id ounces) and a minimum size of not less than l f lu id ounce (29.5 ml) or a glass or plast ic bott le up to a maximum size of 4 f lu id ounces (I18 ml), that is designed and intended to dispense an aerosol. SUBSTANTIATION: Small size aerosols do not pose the same f i re hazard as larger size aerosols therefore restr ic t ion of stacking to one pal let high with conventional sprinkler systems is unnecessary. We are a manufacturer of Binaca aerosol breath sprays which are sold in 0.2 oz. containers and which would be classed as a level 2 aerosol. Insurance providers require manufacturers to not only meet but exceed written standards for storage of aerosol products. Factory Mutual Systems is regarded as the leading authority by the insurance industry for storage guidance and has established provisions for aerosols 5 f l oz. or less because their testing has shown that the small size of each container reduces f i re hazard. Attached is a copy of Factory Mutual's code 7-295.2 under which Binaca has been classif ied. Factory Mutual has advised our insurance carr ier that Binaca may be stored two pallets high allowing us to e f f ic ient ly use

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limited warehouse space. Factory Mutua1's assessment of our storage fac i l i t ies resulted in a determination by them that Binaca could be stored in our main warehouse areas and did not present a f i re hazard requiring storage in a separate flammability cutoff area.

NOTE: Supporting material is available for review at NFPA Headquarters.

COMMITTEE ACTION: Accept in Principle. By means of action on Comment 30B-12 (Log #244).

~OMMITTEE STATEMENT: See Comment 30B-12 (Log #244).

(Log #52) 30B- 14 - (I-6, Back Stock Area): Reject SUBMITTER: Salvatore A. Gilardi, Jr., American Insurance Services Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete the word "back" from the "Back Stock Area." SUBSTANTIATION: Clarif ication and to eliminate confusion for other stock areas not necessarily located in the back of a fac i l i t y . COMMITTEE ACTIOn: Reject. COMMITTEE STATEMENT: The term adequately and clearly conveys the intent of the Code. Also, "back stock area" is being used out of context by the submitter.

(Log #2080) 30B- 15 - (I-6, Bonding and Grounding): Accept SUBMITTER: David C. Tabor, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new definition for Bonding and Grounding, as follows:

Bonding. The process of connecting two or more conductive objects together by means of a conductor.

Grounding (Earthing). The process of connecting one or more conductive objects to the ground, and is a specific form of bonding. SUBSTANTIATION: None. COMMITTEE ACTION: Accept.

(Log #211) 30B- 16 - (I-6, ESFR): Accept in Principle SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON P R O P ~ : 30B-I RECOMMENDATION: Add a new definit ion to Section I-6:

I ESFR Sprinklers. Early Suppression Fast Response Sprinklrs. SUBSTANTIATION: A significant amount of time, testing and funding have been spent on the development of thls sprinkler system. I t as well is mentioned several times in the code. For identif ication purposes, the definition of ESFR must be provided. C O M M I ~ N : Accept in Principle.

I Add to the submitter's text: "A type of fast-response sprinkler l isted for its

capability to provide f i re suppression of specific high • challenge f i re hazards."

COMMITTEE STATEMENT The Committee's proposed wording correlates with NFPA 13.

(Log #11) 30B- 17 - (I-6, Flammable and Combustible Liquids): Accept SUBMITTER: Donald M. Johnson, WSPA

.COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Definitions of Combustible and • Flammable Liquids. Use definitions that are identical to those used in NFPA 30. SUBSTANTIATION: To avoid possible confusion in use of the two related codes. COMMITTEE ACTION: Accept.

(Log #122) 30B- 18 - (I-6, Flammable Liquids): Accept in Principle SUBMITTER: Orvil le M. Slye, Loss Control Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMM~NOATION: Change definition for flammable liquld by deleting the published definition and substitute the definition now contained in NFPA 30. SUBSTANTIATION: Presents conflict in terminology with NFPA 30. Change in definition wil l eliminate slight differences. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-17 (Log #11). COMMITTEE STATEMENT: Comment 30B-17 (Log #11) is more complete.

(Log #151) 30B- 19 - (I-6, Propellant): Accept SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

Propellant: The liquefied or compressed gas that expels the contents from an aerosol container when the valve is actuated. A propellant is considered flammable i f i t can form flammable mixturs with air or i f a flame is self propagating in a mixture of the propellant and air. SUBSTANTIATION: Earlier definition may exclude propellant mixtures with air in concentrations above UFL. COMMITTEE ACTION: Accept.

(Log #245) 30B- 20 - (I-6, Propellant): Reject SUBM~TT[R: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to the end of the definition of "Propellant" the following:

"For the purpose of classylng aerosols under I-7.3(b), I-7.4 and Table I-7, each individual component in a propellant blend must be individually subjected to the above cr i ter ia in determining the amount of flammable propellant." SUBSTANTIATION: This clari f icat ion is necessary to avoid potential overclassificatlon of aerosols containing blends of flammable and nonflammable propellants. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Submitter's proposed wording is not part of a definition.

(Log #46) 30B- 21 - (I-6): Reject SUBMITTER: Donald R. Strobach, Du Pont Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

After "A propellant is considered flammable i f i t forms flammable mixtures with air or i f a flame is self-propagating in a mixture of the propellant and air"

add: "For the purposes of Table I-7, Note 2, each

individual pure component of a propellant blend wil l be subjected to this cr i ter ion." SUBSTANTIATION: This revision is necessary to be consistent with the proposed method of calculating " percent flammable propellant" in Table I-7, Note 2. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Submitter's proposed wording is not part of a definition.

(Log #212) 30B- 22 - (1-7): Accept in Pr inciple SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMHENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph to read:

1-7 Class i f icat ion of Aerosol Products. Aerosol products shall be c lass i f ied as Level 1, Level 2, or Level 3 according to the fol lowing def in i t ions . An a l te rnat ive method for determining the aerosol

81

c lass i f i ca t ion is to conduct a fu l l scale array 12-pallet test. The results from the 12-pallet test w i l l prevail over the de f in i t i on c lass i f i ca t ion of aerosol products. (Se Table I-7. See also Appendix B for a discussion of the Aerosol Flammability Test.) SUBSTANTIATION: The de f in i t i on of the three Level c lass i f icat ions are a rb i t ra ry and are not based upon any s ign i f icant val id data or experience. These c lass i f icat ions should be reconsidered in l i gh t of the good history and experience enjoyed by aerosols in warehouses and re ta i l f a c i l i t i e s . Much more data is needed before any c lass i f i ca t ion should be f ina l ized. At the very least, the c lass i f i ca t ion of a product should be a11owed via the means by which the c lass i f i ca t ion def in i t ions were established o r ig ina l l y , i .e . by large scale f i r e test ing. COMMITTEE ACTION: Accept in Principle.

Revise current I-7 to read: I-7 ~ Class i f icat ion of Aerosol Products. Aerosol

products shall be c lass i f ied as Level I, Level 2, or Level 3 according to the def in i t ions given in l-7.1 through I-7.4. Such c lass i f i ca t ion shall be permitted to be based on data obtained from ei ther a properly-conducted, fu l l - sca le f i r e test u t i l i z i n g a 12 pal le t test array or from the Aerosol Flammability Test. (See Appendix B for information on the Aerosol Flammability Test) ." COMMITTEE STATEMENT: The Committee's version of the proposed wording more c lear ly achieves the intent of the submitter.

(Log #37) 30B- 23 - ( I -7 ) : Accept in Principle ~ : Donald R. Strobach, DuPont Company COMMENT ON PROPOSAL NO.: 30B-] RECOMMENDATION: Revised text :

I-7 Class i f icat ion of Aerosol Products. Aerosol products shall be c lass i f ied as Level I, Level 2, or Level 3 based on the results of a sprinklered, large-scale, f i r e test; e.g. 12-pallets or the results of the Aerosol Flammability Test (See Appendix C for a discussion of these tests) .

Where these test data are not avai lable, the fol lowing def in i t ions may be used to c lass i fy aerosol products. I f test results and the def in i t ions assign d i f fe ren t levels to the same product, the test results shall c lass i fy the product. SUBSTANTIATION: Although the formulaton c r i t e r i a in this code for the c lass i f i ca t ion of aerosols as Level l , Level 2 and Level 3 are based on numerous large, small- and intermediate-scale sprinklered f i r e tests, less than a dozen formulations were used to simulate the many thousands of diverse aerosol formulation systems currently on the market. In addit ion, new formulations are constantly being developed and marketed. The use of val id f i r e test data to reclassi fy aerosols must be allowed to assure the continued development of data on aerosol f lammability, as well as to encourage the development of less flammable aerosol products. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-22 (Log #212). COMMITTEE STATEMENT: See Committee Statement for Comment 30B-22 (Log #212).

(Log #147) 30B- 24 - ( I - 7 . I ) : Accept SUBMITTER: James R. Quiter/Jerome E. Cunningham, Ro]f Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise I-7.1 to read:

"Level l aerosol products are those whose base products contain up to 25 percent by weight of materials with f lashpoints of 500°F (260uc) or less." SUBSTANTIATION: The present de f in i t i on of Level l aerosols contains the phrase "water-miscible or water-immiscible." This phrase is i r re levant and should be deleted to improve c l a r i f y of the de f in i t ion . C_OMMITTEE ACTION: Accept.

(Log #53) 30B- 25 - ( I -7 .1) : Accept in Principle SUBMITTER: Salvatore A. Gi lard i , J r . , American Insurance Services Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add the word "combined" to the sentence as to read:

" . . . products are those whose combined base products . . ." SUBSTANTIATION: This would eliminate the poss ib i l i t y of having a product which contains 25 percent by weight of water-miscible and 25 percent water-immiscible matrlal being c lass i f ied as a Level I product. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-24 (Log #147). COMMITTEE STATEMENT: This comment is essent ia l ly the same as Comment 30B-24 (Log #147).

(Log #172) 30B- 26 - ( I -7 .3) : Reject SUBMITTER: James J. Albanese, Jr . , Chemsico COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text :

I-7.3 Level 3 Aerosol products are those: (a) whose base products contain more than 55~ by

weight of water immiscible materials with flash points of 500°F (260°C) or less; or contain chlorinated solvents such as methylene chloride, 1 - l . l - t r i ch lo re thane or perchlorethylene and a flammable propel lent; or . . . (Table I-7) Note 3: Products containing chlorinated solvents such as methylene chloride, 1 ,1, l - t r ich lorethane or perchlorethylene and a flammable propellent are to be considered Level I I I . SUBSTANTIATION: Factory Mutual's tests conducted for CSMA indicated that "methylene chloride may increase the severi ty of a Level I I I aerosol f i r e . " Though other chlorinated solvents were not tested, there is no reason to believe, since they have very simi lar chemical structures, that they would not also increase the severi ty of a f i r e . Flame projection tests on chlorothene-containing aerosols using hydrocarbon propellent exhib i t enhanced flames as well as moxious chlorinated odors (phosgene, hydrochloric acid, etc.) that would severely hinder f i r e f ight ing. The enhancement of the f i r e and the added d i f f i c u l t y of f igh t ing a f i r e of aerosols containing chlorinated solvents requires that they be restr ic ted as Level I l l aerosols.

NOTE: Supporting mater ia l is ava i l ab le fo r review at NFPA Headquarters.

~OMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The f i r e tests conducted by FMRC did not show the increased f i r e severity described by the submitter.

(Log #174) 30B- 27 - ( I -7.5 (New)): Accept in Principle ~ : Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new text :

I-7.5 Aerosol products shall be c lass i f ied according to sections I-7.1, I-7.2, and I-7.3 and Table I-7, i f val id data from properly conducted fu l l scale array 12-pallet test indicates a d i f fe ren t c lass i f ica t ion, the test data wi l l supersede the above sections. SUBSTANTIATION: The use of val id test data to rec lassi fy aerosols must be allowed to encourage the development of less flammable aerosol products. Also, the use of f i r e test data is the most accurate means of c lass i fy ing an aerosol product. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-22 (Log #2]2). COMMITTEE STATEMENT: This comment has the same ef fect as Comment 30B-22 (Log #212).

82

(Log #246) 30B- 28 - (1-7,5 (New)): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new paragraph I-7.5 to read as follows:

I-7.5 In any case, where the propellant is nonflammable, and less than 85 percent of the net weight of the base product is flammable and water miscible, the classification shall be Level 1. SUBSTANTIATION: Recent 12-pallet sprinklered f i re tests have demonstrated that products of this formulation represent a Level l challenge, and should not be classified as Level 2, as would occur using paragraph I-7.2. COMMITTEE ACTION: Accept.

(Log #213) 30B- 29 - (I-7.5 (New)): Accept in Principle SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: New paragraph is to read:

I-7.5 In any case where a propellant is nonflammable, and less than 85 percent of the net weight of the base product is flammable and water miscible, the classification shall be lowered to the next lower level. SUBSTANTIATION: Large scale f i re test data, demonstrate the reduction of flammable characteristics of aerosol products when the percent of flammable propellant is reduced and the percent of water miscible base product constituents ( i .e. alcohol) is increased.



COMMITTEE STATEMENT: This submittal is the same as that in Comment 30B-28 (Log #246).

(Log #214) 30B- 30 - (I-7.6 (New)): Reject ~UBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: New paragraph is to read:

I-7.6 When approved by the Chief, the classification level of an aerosol may be reduced based upon evidence supporting a different classification, Such evidence may include large scale f i re tests, engineering calculations or computer f i re modeling based upon accepted large scale f i re tests, or other information or data having i ts basis in science. SUBSTANTIATION: Large scale f i re tests are the most accurate means of determining the classification of an aerosol product. The classification system uti l ized in this code was in fact based on data generated by large scale tests. To insure a product is accurately classified, the running of large scale tests must be allowed to supersede those c l a s s i f i c a t i o n de f i n i t i ons l i s t ed in 1-7 through 1-7.3. As we l l , increasing reliable engineering calculations based upon accepted large-scale f i re test and computer modeling may be available.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is covered by the Equivalency Statement in I-3.

(Log #247) 3OB- 31 - (I-7.6 (New)): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufactuers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add a new paragraph I-7.6 to read as follows:

I-7.6 Subject to the approval of the authority having jurisdict ion, the classification of an aerosol may be changed based on evidence supporting a different classification. Such evidence may include sprinklered

f i re tests, the Aerosol Flammability Test, engineering calculations, computer modeling based on sprinklered f i re tests, or other scienti f ic data or information. SUBSTANTIATION: Although the formulation cr i ter ia in this code for the classification of aerosols as Level I, Level 2 and Level 3 are based on numerous large, small- and immediate-scale sprlnklered f i re tests, some formulation systems currently on the market, as well as those to be developed in the future, have not yet been subject to classification tests. For instance, few tests have been conducted on formulations with nonflammable propellants, and some formulations may prove to have mutual solubi l i ty between materials that lowers the pressure and delays rupture. In addition, new formulations are constantly being developed and marketed. The use of f i re test and other relevant data to reclassify aerosols must be allowed to assure the continued development of data on aerosol flammability, as well as to encourage the development of less flammable aerosol products. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is addressed by the Equivalency Statement, Section 1-3.

(Log #248) 30B- 32 - (Table 1-71: Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise Table I-7 to add a new line to read as follows:

I f Percentage of Flammable Material in Base Product is:

And Propellant is: Then Level is

<85% and water nonflammable I miscible

SUBSTANTIATION: Change needed to make Table 1-7 consistent with new paragraph I-7.5. This change is based on recently conducted large-scale sprinklered f i re tests. COMMITTEE ACTION: Accept.

(Log #219) 30B- 33 - (Table I-7): Accept SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise Table I-7 ( f i f th line) to read:

"<85% and water miscible nonflammable l" SUBSTANTIATION: This change comes as a result of large scale f i re tests showing that this formula variable is identified as level I. Attached are test data documenting the reduction in flammable characteristis of this product type.


COMMITTEE ACTION: Accept.

(Log #47) 30B- 34 - (Table I-7, Note 2): Accept SUBMITTER: Donald R. Strobach, DuPont Company COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise Note 2 to read:

The percentage of flammable propellant is i ts proportion of the total contents, by weight. Any nonflammable portion (See Propellant at l - 6) of a propellant blend is not included in the calculation. The percentage is calculated as follows:

% Flammable Propellant =

weight of flammable pro~ellant components x I00 weight of contents

SUBSTANTIATION: The percent of flammable propellant in an aerosol product is required to classify products using Table I-7. Nonflammable constituents are

83

excluded from the calculation to determine the percent of flammables in the Base Product. By analogy, nonflammable propellants should be excluded from the calculation to determine "% Flammable Propellant." As written, propellant blends that are only marginally flammable with very low energy release per unit weight would be treated as i f they were pure flammable propellants. The lat ter situation offers no incentive to marketers to reduce the flammables content of their products. COMMITTEE ACTION: Accept.

Also, revise the middle column of Table I-7 as follows:

"And Percentage of Flammable Propellant is;

0% <50% >50%, but <80%

0% <50% Z50% 0%

<50% ~50%

0% to 100% >_8O%

COMMITTEE STATEMENT: The changes to the table more completely achieve the objective of the submitter.

(Log #249) 30B- 35 - (Table I-7): Accept in Principle ~VBMITT~R: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON pROPOSAL NO.: 30B-I RECOMMENDATION: Add new third footnote to table to read as follows:

Note 3: I f a mixture of both flammable and nonflammable propellants are contained in a product, only the weight of the flammable propellant should be used in calculating the flammable propellant level. SVBSTANTIATION: Although uncommon today, future aerosols may contain mixtures of both flammable and nonflammable propellants, making this clari f icat ion useful. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-34 (Log #47). COMMITTEE STATEMENT: This submittal effects the same change as Comment 30B-34 (Log #47).

(Log #300) 30B- 36 - (2-I): Accept in Principle SUBMITTER: Byron L. Briese, Oak Ridge, TN COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete current paragraph 2-I and substitute the following:

"Site Requirements. Distances between buildings used for the manufacture or storage of aerosol products and adjacent buildings or property lines shall be based upon sound engineering principles. Specific distances shall be developed accounting for the potential for explosive release from the building(s} as well as building to building f i re propogation." SUBSTANTIATION: This change to the draft standard elimiantes the reference to unspecified codes or standards. COMMITTEE ACTION: Accept in Principle.

Revise 2-I to read as follows: "Site Requirements. Distances between buildings used

for the manufacture or storage of aerosol products and adjacent buildings or property lines that are or can be bui l t upon shall be based on sound engineering principles." COMMITTEE STATEMENT: The revised f i r s t sentence is now parallel with similar requirements in NFPA 30 for storage of flammable liquids. The second sentence is deleted because i t adds nothing to the intent of this Code.

(Log #119) 30B- 37 - (2-2.1): Accept SUBMITTER: Steve Ermert, Malone & Hyde COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete complete paragraph:

"Buildings or structures involved in manufacturing or storing of aerosol products shall not contain a basement or a space below the finish of the ground level." SUBSTANTIATION: Paragraph 3-4.1 - "Buildings or structures involved in the manufacturing of aerosol products shall have no basement . . ."

Paragraph 4-I.4 - "Storage of Level 2 and Level 3 aerosol products shall not be permitted in basement areas." This statement allows Level I storage in basement.

I. Paragraph 2-2.1 conflicts with 4-I.4 which allows Level l aerosol storage. COMMITTEE ACTION: Accept.

(Log #148) 30B- 38 - (2-2.1): Accept in Principle ~LLLB_M_ITTER: James R. Quiter/Jerome E. Cunningham, Roll Jensen & Associates, Inc. COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Revise 2-2.1 to read:

"Buildings or structures involved in manufacturing or warehousing of aerosol products shall not contain a basement or space below the finish f loor of the ground level."

Delete from 2-2.1: "Exception: Mercantile occupancies." SUBSTANTIATION: The present language in section 2-2.1 states that buildings or structures involved in manufacturing or storing aerosol products shall not contain a basement. This statement is too broad. I t could apply to office buildings and hotels which often have basements and are involed in storing aerosol products. By substituting the word "warehousing" for "storing," the ambiguities and potential misinterpretations are eliminated. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-37 (Log #119). COMMITTEE STATEMENT: The subject paragraph has been deleted to eliminate the confusion.

(Log #250) 30B- 39 - (2-2.1 Exception (New)): Accept in Principle SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to paragraph 2-2.1 an exception to read as follows:

Exception: As provided by Section 3-4.1. SUBSTANTIATION: This makes 2-2.1 consistent with CSMA's recommended addition to 3-a.l. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-37 (Log #I19). COMMITTEE STATEMENT: This new exception is not needed because the changes made per Comment 30B-37 (Log #119) accomplishes the same objective.

(Log #IZ3} 30B- aO - (2-2.1): Reject ~UBMITT~R: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

2-2.1 Building Construction. Buildings or structures involved in the manufacturing or storing of aerosol products shall not contain a basement, or a space below the finish f loor of the ground level unless this basement or space is protected by suitable gas sensing and ventilation systems to meet requirements of the authority having jurisdict ion. SVBSTANTIATION: Structures should not be precluded from use i f adequate protection is provided. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Provisions for basement areas wil l be addressed in Chapters 3, 4 and 5.

B4

(Log #192) 3OB- 41 - (2-2.1 Exception (New) and 3-4.1 Exception (New)): Reject SUBMITTER: Robert Nalanga/Will iam Webb, Rolf Jensen& Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-l RECOMMENDATION: Add the following paragraph:

Exception: Basements that are mechanically ventilated in accordance with NFPA 30 Section 5-3.3 and that are separated from al l areas above by 2 hr f i re res is tant construct ion. SUBSTANTIATION: The existing section is too restr ic t ive for in-place operations in buildings with basements. A proper ly designed and funct ional vent i lat ion system that prevents the build-up of stray vapors from other areas provides equivalent alternative protection. I t is not the intent of this proposed change to permit storage in basements.

The Z-hour f i re separation is consistent with NFPA 30, Section 5-3.2.2. COMMITTEE ACTION: Reject. COHHITTEE STATEMENT: Provisions for basement areas wi l l be addressed in Chapters 3, 4 and 5.

(Log #149) 30B- 42 - (2-2.2): Accept SUBMITTER: 3ames R. Qulter/3eromo E. Cunnlngham COMMENT ON PROPOSAL NO.: 30B-I

I RECOMMENDATION: Add to 2-2.2 as follows: "Fire dampers shall be installed in accordance with

manufacturer's instructions and NFPA gOA, Standard for the Instal lat ion of Air Conditioning and Ventilation Systems." SUBSTANTIATION: Add for completeness. COMMITTEE ACTION: Accept.

(Log #208A) 30B- 43 - (2-2.2): Accept in Principle SUBMITTER: David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

"Openings in f i r e wal ls shal l be kept to a minimum. All personnel doorways shall be protected with automatic or self-closing doors. All other openings ( i .e . ductwork, conveyor lines, etc.) shall be protected with automatic closing dampers where such openings are:

(a) exposed to a minimum combined net weight of l,OOO Ibs of Level 2 and Level 3 aerosol products located within 50 f t of the f i re wall, or

(b) exposed to a minimum combined net weight of 2,500 Ibs of Level 2 and Level 3 aerosol products located within 100 f t of the f i re wall or

(c) greater than 2 f t by 2 f t Alternative protection for small openings such as by

waterspray and shrouds may be considered, provided they are acceptable to the authority having Jurisdiction." SUBSTANTIATION: Not a l l " f i re walls" are true f i re wails. Large numbers of conveyor openings are often found in aerosol plants; only these walls which are designed as true f i re separations, with (a) large openings, or (b) potential exposure to flying/flaming aerosols exists, may t ru ly warrant dampers. Some discretion is advised where f i re exposure is negligible. COMMITTEE ACTION: Accept in Principle.

Add the words "or self closing" after the words "automatic closing" to existing 2-2.2. COMMITTEE STATEMENT: This more easily accomplishes the objectives of the submltter.

(Log #124) 30B- 44 - (2-2.3): Reject SUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised test:

" . . . The design and construction of conveyor l l i nes and.o}~r~physical obstacles, such as in the

flammable p~opellant charging and pump rooms, shall not allow entrapment of personnel and shall provide for direct access to exits. "Direct access" can be achieved with the use of crossovers in charging rooms constructed prior to January l , 1991."

SUBSTANTIATION: Space l imitat ions and conveyor designs used in the construction of older charging rooms may preclude direct access. A crossover should be considered as acceptable for these fac i l i t i es . COMMITTEE ACTION: Reject. CQHHITTEE STATEMENT: This proposed wording, in effect, makes certain interpretations of requirements in NFPA 101, Life Safety Code.

(Log #193) 30B- 45 - (2-3.2): Reject ~LU_B_M_I_T!F..~: Robert Malanga/William Webb, Roll 3ensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise the section to read:

"Aerosol product storage and display areas with less than l,O00 Ibs of aerosol containers shall be classified as Class I Division 2 locations." SUBSTANTIATION: The Standard differentiates between amounts of storage of greater/less than l,O00 Ibs for the level of the f i re hazard. In a large storage area, cartons of aerosols are constantly moved and shelved which creates puncture and rupture possibi l i t ies.

NFPA 70 Section 500-5 clearly states that an area where there is the l ikelihood of an accidental release of a vo la t i le , flammable material shall be considered as a Class I D i v . 2 hazardous location. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The likelihood of a release and the resulting volume of the material released do not warrant electr ical classif ication of a storage or display area. This is an incorrect interpretation of the def ini t ion of a Division 2 area.

(Log #230) 30B- 46 - (2-6.1.I (New)): Reject ~ : C. P. Clapp, Creative Products Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new paragraph:

2-6.1.1 C02 Automatic Fire Protection. May be a11owed where warehouses can be reasonably closed to vent i lat ion except through roof vents with appropriate engineering. Such total flooding system should employ predischarge alarms with time delays provided to permit evacuation of personnel before actual discharge and meet general requirements of NFPA No. 12. SUBSTANTIATION: Products containing high concentrations of certain materials such as high flash low vo la t i le oi ls f loat on water and are d i f f i cu l t to contain part icular ly with high volume water discharges. C02 is an effective extinguisher, wi l l work under most weather conditions, is cost effective and safe with the detection and control equipment available with bulk C02 systems. Floating ol l presents an environment contamination potential that in special cases could be more serious than the f i re. The Sherwin Williams warehouse f i re is an example. Water was stopped to prevent potential contamination of the underground aquafer. CQMtIITTEE ACTION: Reject. COMMITTEE STATEMENT: Fire protection requirements in this Code are based on ful l -scale f i re tests done with automatic sprinklers. Also, the Equivalency statement would allow other means of protection.

(Log #30t) 30B- 47 - (2-6.2) : Accept ~ : Byron L. Briese, Oak Ridge, TN COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Delete exception to paragraph 2-6.2 and move to Section 4-2. SUBSTANTIATION: Exceptions to protect ion requirements are more appropr ia te ly posi t ioned wi th in the standard at the section reserved fo r the occupancy appl lcable to the exception. COMMITTEE ACTION: Accept.

85

(Log #55) 30B- 48 - (2-6.2 Exception): Reject SUBMITTER: Salvatore A. Gilardi, Jr . , American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 3gB-I RECOMMENDATION: Delete the exception. SUBSTANTIATION: Hose stations should be provided in accordance with NFPA 231 in unsprlnklered buildings as well as sprinklered ones as required in this Standard (NFPA 30B, section 2-6.1). COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The subject of hose streams wi l l he covered in Chapters 3 and d.

(Log #54) 30B- 49 - (2-6.2.l (New)): Reject SUBMITTER: Salvatore A. Gi lardi , Jr . , American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add a new section 2-6.2.1 as follows:

2-6.2.1 Small Hose Systems. Small hose systems shall be instal led in accordance with the provisions of NFPA 231, General Storage. SUBSTANTIATION: NFPA 231, section 5-3.1 requires small hose systems be instal led throughout so as to reach al l portions of the storage area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is addressed by 4-2.3 of this Code.

(Log #208B) 3OB- 50 - (2-7.3): Accept SUBMITTER: David C. Tabar, The Sherwin-Willlams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

"Operation of an alarm system shall control the following:

(a) release of hold-open devices for f i re doors; (b) vent i lat ion systems, as determined necessary for

l i fe-safety or f i re safety. SUBSTANTIATION: The original intent of cal l ing for automatic f i re door closure (not self-closing personnel doors or wall opening dampers) was to require faster-acting closure mechanisms at aerosol storage rooms to avoid the delay time in activating fusible l ink-activated drop-down doors, which have large openings through which f lying/f laming aerosol can travel.

(b) I t may not be necessary to shut down al l vent i lat ion systems upon activation of an alarm in a single story occupancy provided with adequate egress fac i l i t i es . COMMITTEE ACTION: Accept.

(Log #251) 30B- 51 - (3-2): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise the def in i t ion of "Reject Container" as follows:

Reject Container Receptacle. A receptacle used to store scrap, p a r t i a l l y - f i l l e d or f u l l y - f i l l e d aerosol containers pr ior to disposal.

Note: Change wi l l require insertion of "receptacle' after al l references to "reject container" elsewhere in Chapter 3. SUBSTANTIATION: The change avoids confusion by reserving the term "container" for use only in referring to an aerosol container, i .e . an aerosol can. COMMITTEE ACTION: Accept.

(Log #208C) 30B- 52 - (3-3.4): Accept in Principle S__UBMITTER: David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise 3-3.4 to read:

"New flammable propellant charging and pump rooms shall be separated from other buildlngs or structures by a distance of at least 5 f t or from other areas by noncommunicating walls. Flammable propellant charging and pump rooms shall be separated from flammable propellant storage tanks and from flammable and combustible l iquid storage by a distance of at least 25 f t . " SUBSTANTIATION: I believe the recommended changes better c la r i fy the Committee's intent. COMMITTEE ACTION: Accept in Principle.

Revise the proposed new wording to read as follows: "Flammable propellant charging and pump rooms shall

be separated from adjacent buildings or structures by noncommunicating walls or by a distance of at least 5 f t and from inside areas by noncommunicating walls. Flammable propellant charging and pump rooms shall be separated from flammable propellant storage tanks and from flammable and combustible l iquids storage by a distance of at least 25 f t . " COMMITTEE STATEMENT: The Committee's wording better achieves the objectives of the submitter.

(Log #105) 30B- 53 - ( 3 -3 .4 ) : Hold f o r Fur ther Study SUBMITTER: Thomas G. Meier, The Gillette Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

3-3.4 Preferred instal lat ions have propellant charging and pump rooms separated from other buildings or structures by a distance of at least 5 f t (I.5 m) or by noncommunicating walls. Appropriately designed internal or attached gas rooms are acceptable provided they comply with the design c r i te r ia in table 3-4 t i t l ed "Design Cri ter ia - Internal Gas Room."

Table 3-4 Design Cri ter ia - Internal Flammable Propellant Charging and Pump Room

General: Structure must be able to hold and vent a hydrocarbon a i r mixture explosion. Room design wi l l depend on the size of room and vent stack size.

Steps: Determine: - Room size for operation - Max pressure of combustion - Vent areas required to relieve a

hydrocarbon a i r explosion - Wall strength needed to hold

explosion

Note: The use of experienced consultants for this type of design is necessary.

Safety Systems: - Exhaust fans (two level) 20%, 40% - Combustible gas detectors - Room strength - Back-Up: Independent battery or

diesel generator power for fa i l safe exhaust

- Explosion Suppression System with UV and pressure detection (manual actuation desirable)

- Automatic propellant supply shut-off triggered by excess gas flow valves and normally closed ball valves.

- Monitor at guard station or other manned work station

Operating Cr i ter ia: - Daily analyzer checks for accuracy plus records kept

- Preventive maintenance of analyzer monthly

- Written safety systems maintenance procedures with written records kept

- Periodic training of al l personnel with documentation

- Self-contained breathing apparatus available to enter gas room after Halon release

B6

SUBSTANTIATION: Internal gas rooms have been excluded from the proposed code. Careful design and proper gas room operatln~ procedures have been successfully employed at G111ette to safely produce over 1.5 b i l l ion aerosols in the past 12 years. The code, as written, would not permit additional lines in current fac i l i t ies . The code must allow reasonable alternatives to be effective, COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT; This COmment introduces new design concepts that have not had public review or extensive Committee review.

(Log #252) 30B- 54 - (3-3.4 Exception (New)): Hold for Further Study ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 3-3.4 to add an exception to read as follows:

Exception: Interal flammable propellant charging and pump rooms are acceptable, provided they meet the cri teria in Table 3-4, t i t led , "Internal Gas Room Protection." SUBSTANTIATION: At least one CSMA member company has interior gas houses are currently used by a significant number of aerosol manufacturers. In one instance, over 1.5 b i l l ion cans have been produced in a fac i l i t y of this type, without a significant problem. Some firms lack available outside area for a segregated gas house and would have to move the manufacturing operation elsewhere. With proper design, controls and procedures the safety of these internal gas houses may be equated with that of external or noncommunicating types. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-53 (Log #105).

(Log #152) 30B- 55 - (3-3.4): Reject ~ : Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised text of 3-3.4:

" . . . or by noncommunicating walls. Flammable propellant charging and pump rooms shall be separated from flammable propellant storage tanks and from flammable and combustible l iquid storage by a distance of at least 25 f t , except as provided in NFPA 58 and NFPA 30." SUBSTANTIATION: The separation distance requirement is only IO f t from general purpose buildings for single LPG containers up to 1200 gal. capacity and multiple containers of 500 gal capacity or less. Since propellant charging and pump rooms are required to be of exploson proof constructin, the separation requirements for LPG storage tanks from such buildings need not be any more stringent than mandated by NFPA 58 and NFPA 30. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: These fac i l i t ies require greater separation due to the inherent explosion hazards of the process.

(Log #175) 30B- 56 - (3-3.4): Reject SVBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwln-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph text:

3-3.4 Flammable propellant charging and pump rooms shall be separated from other buildings or structures by a distance of at least 5 f t (1.5 m) or by noncommunicating walls. Flammable propellant charging and pump rooms shall be separated from flammable propellant storage tanks and from flammable and combustible l iquid storage tanks by a distance of at least 25 f t (Bm). SUBSTANTIATION: Sprayon Products has produced one bi l l ion cans in interior gas houses without any significant problems. Also our plants do not have area

to provide the gas houses. With proper design, which is described in Section 3-4 of this code, i t should provide a safe condition to operate. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same reason as for Comment 30B-55 (Log #152).

(Log #231) 30B- 57 - (3-4.1): Reject SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"Buildings or structures involved in the manufacturing of aerosol products shall have no basement or any space below the finish floor of the ground level except in the manufacturing of aerosol food products where appropriate drainage wil l be allowed below floor level for cleaning and sanitation procedures necessary to maintain good manufacturing practices required under CFR 21. SUBSTANTIATION: In the manufacture of aerosol food and dairy products, drainage systems are essential to allow scrubbing and cleaning of equipment, floors, walls and ceilings of food establishments. Sanitation would be impossible under the code as written. CO HMITTEE ACTION: Reject. COMMITTEE STATEMENT: Drainage is addressed by Section 3-II of this Code.

(Log #253) 30B- 58 - (3-4.1 Exception (New)): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to paragraph 3-4,1 an exception to read as follows:

Exception: Subject to the approval of the authority having jurisdict ion, basements or below ground level areas are acceptable, provided they are ventilated at a minimum flow rate of one cfm per square f t of floor area and provided the nearest entrance or access point is located at least 50 f t (15.1 m) in any direction from the nearest point of the gas house. SUBSTANTIATION: Although the continuing use of such structure is protected by the retroactivity provision, s t i l l there are thousands of manufacturing fac i l i t ies and retail outlets with basements or below ground level areas. Some areas may be small or remote, such as furnace rooms or tank overflow basins. Proper protection should make other buildings or structures acceptable. I f necessary, ventilation or other essential elements of such protection could be incorporate, COMMITTEE ACTION: Accept.

(Log #106) 30B- 5g - (3-4.2): Reject SUBMITTER: Thomas G. Meier, The Gil lette Company COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Omit entire statement. Flammable propellant charging operations shall be limited to the ground floor. SVBSTANTIATION: The statement would prohibit internal gas rooms or upper floors of buildings where proper ventilation and gas room vent stack are best located. A gross leak outside of the room would be no more dangerous as a gross leak in a single story building. Over 12 years experience with internal upper floor rooms has been without incident, COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This proposal would constitute a direct violation of NFPA 58.

(Log #254) 3OB- 60 - (3-4.2): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMHENDATION: Omit paragraph 3-4.2.

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SUBSTANTIATION: At least one CSMA member company has had 12 years of experience with internal gas rooms with two of the rooms on the top floor of a three story building. They have safely produced about 1.5 b i l l ion cans during that period. Their careful design and proven record cannot be ignored in the code preparation. Gas room operation procedures are a very significant part of the total picture. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This proposal would constitute a direct violation of NFPA 58.

(Log #107) 30B- 61 - (3-4.4): Reject ~ : Thomas G. Meier, The Gil lette Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"The walls and roof of external flammable propellant charging and pump rooms shall be of damage-limiting construction, except for required deflagration vents. Internal room must contain and vent any explosion." SUBSTANTIATION: Internal gas rooms rely on room strength to contain and hold any explosion and vent the pressure vert ical ly through a properly sized vent stack. COMMITTEE ACTION: Reject.

STATEMENT: Current 3-4.4 does not prohibit an interior propellant charging room.

(Log #208D) 30B- 62 - (3-4.4): Reject ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Paragraph 3-4.4 - revise to read:

3-4.4 The walls and roof of newly constructed flammable propellant charging and pump rooms shall be of damage-limiting construction, except for required deflagration vents. (See also 3-4.5) SUBSTANTIATION: I believe the recommended changes better clarif ies the Committee's intent. Note also the Exception found within 3-4.5, which mandates explosion suppression systems in existing fac i l i t ies where deflagration venting cannot be installed. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is addressed by the retroactivity statement in Chapter ].

(Log #108) 30B- 63 - {3-4.4.1): Reject B~U~_H~_TTER: Thomas G. Meier, The Gil lette Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add reference as follows or substitute for existing statement:

" I t is is essential that any propellant charging room be specifically designed by qualified professionals." SUBSTANTIATION: The existing statement tries to state minimum requirements but seems specific and confusing. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee can see no way for this Code to establish qualifications for professionals.

(Log #153) 30B- 64 - (3-4.5(b)): Reject ~ : Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete 3-4.5(b). SUBSTANTIATION: Unlike propellant charging rooms, for the most part, pump rooms should not contain high gas concentrations. Gas levels build up in pump rooms only during periods of seal failure in pumps, failure of valve packings or flex f i t t ings, etc. Gas detection systems and automatic shut down of pumps under hazardous conditions are adequate safety precautions for pump rooms. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: There is a definite hazard involved with gas build-up in a pump room, with attendant explosion hazard.

(Log #110) 30B- 65 - (3-5.2(b)): Accept in Principle SUBMITTER: Thomas G. Meier, The Gil lette Company COHMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph 3-5.2(b) - Make up air shall be taken directly from the outside. ~UBSTANTIATION: In very cold climates, warmed air is needed for proper gasser operation. Intakes must be such that gas cannot flow out of the room except through the exhaust system. Rooms must have a negative pressure or be in a shut off mode. COMMITTEE ACTION: Accept in Principle.

Revise 3-5.2(b) to read: "Make-up air shall be taken either directly from

outside or from areas of the building where flammable vapors are not present." COMMITTEE STATEMENT: The Committee's wording provides the f l e x i b i l i t y desired by the submitter, yet s t i l l reinforces the philosophy that make-up air must be drawn from a "clean" source.

(Log #232) 3OB- 66 - (3-5.2(b)): Accept in Principle SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-] RECOMMENDATION: Deleted tex t :

"Make up a i r shall be taken from the outside." SUBSTANTIATION: Make-up a i r should be allowed from conveyor ports and other communicating openings to maintln air flow from all other areas into charging room with a negative charging room pressure. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-65 (Log #110). COMMITTEE STATEMENT: The changes made in Comment 30B-65 (Log #]lO) achieve the objective of this comment.

(Log #257) 30B- 67 - (3-5.2(b)): Accept in Principle ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph 3-5.2(b). SUBSTANTIATION: I t is not clear why make-up air shall be necessarily from the outside. Warm air in very cold climates is needed to allow proper gasser operation. Intakes must be such that gas cannot flow out of the room except through the exhaust systems. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-65 (Log #110). COMMITTEE STATEMENT: The changes made in Comment 30B-65 (Log #110) achieve the objective of this comment.

(Log #176) 30B- 68 - (3-5.2(b)): Accept in Principle SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph text "3-5.2(b) Make-up air shall be taken directly from the outside." SUBSTANTIATION: This would cause unnecessary expense due to heating of cold air in winter months to provide proper operation of the gasser. With proper exhaust, there is no reason not to use make-up air from the plant. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-65 (Log #llO). COMMITTEE STATEMENT: The changes made in Comment 30B-65 (Log #llO) achieve the objectives of this comment.

(Log #233) 30B- 69 - (3-5.2(c)): Reject ~ : C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Deleted text:

"Air inlets and outlets shall be located so that air flows uniformly across floor of room." SUBSTANTIATION: I. Make up air should be allowed from conveyor ports and entryways.

88

2. Our gas house has 4 compartments consisting of 3 f loor to conveyor-top cells to separate each charger from the total area at f loor level. Heavier than a i r gases are contained for ear l ier detection and automatic shut off on an individual l lne basis. The system is highly responsive and not dependent on easily disrupted a i r flows.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Uniform airf low across the f loor cannot be attained with high level inlets and outlets.

(Log #154) 30B- 70 - (3-5.2(d) and ( j ) (New)): Reject ~ : Bala Nathan, Divers i f ied CPC Internat ional COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised tex t :

(d) Ventilation for propellant charging room shall be determined according to the following . . .

New text: ( j ) For pump rooms, a i r flow rate for vent i lat ion

shall be at least I CFM per sq f t of f loor area. ~UBSTANTIATION: Pump rooms are generally unmanned and normally operate with gas concentrations well below those found in propellant charging rooms. Instal lat ion of gas detection systems and alarms provide the necessary backup during times of fugit ive releases. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: There is no proven indication that the l i f e safety exposure in a pump room is less than in a propellant charging room.

(Log #111) 30B- 71 - (3-5.2(e)): Accept in Principle ~_l)_B_~J~: Thomas G. Meier, The Gi l le t te Company COMMENT ON PROPOSAL NO.: 3DB-I RECOMMENDATION: Change from three to two a i r changes per minute.

Propose: (e) Emergency vent i lat ion shall be automatically

activated at not more than 20 percent of the lower explosive l im i t . I t shall be designed to provide at least two a i r changes per minute. SUBSTANTIATION: Two a i r changes/mln, has proven over 12 years to be adequate and practical. To change to or provide the higher flow of three a i r changes would be very costly and appears excessive. I f the gas level is high enough to require three changes there are problems that need correction. COMMITTEE ACTION: Accept in Principle.

Revise 3-5.2(e) to read: "Emergency ventilatlon shall be automatically

activated at not more than 20 percent of the lower flammable l im i t . I t shall be designed to provide 150 percent of the a i r flow rate determined in 3-5.2(d) or two a i r changes per minute, whichever is greater." COMMITTEE STATEMENT: The Committee's wording ensures an adequate factor of safety between normal vent i lat ion flow rate and emergency vent i lat ion flow rate.

(Log #258) 3OB- 72 - (3-5.2(e)): Accept in Principle ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 3-5.2(e) to read:

Emergency vent i lat ion shall be automatically activated at not more than 20 percent of the lower explosive l im i t . I t shall be designed to provide at least two a i r changes per minute. SUBSTANTIATION: Two ai r exchanges per minute is considered practical by a number of experts, thus avoiding a transit ion from laminar to turbulent flow, and recognizing the safety aspects of automatic propellant shut off valves and back-up valves. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 3OB-71 (Log #111). COMMITTEE STATEMENT: This is the same as Comment 30B-71 (Log # I l l ) .

(Log #125) 3OB- 73 - (3-5.2(e)): Accept in Principle SUBMITTER: Dale Cook, Peterson/Puritan Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

Emergency vent i lat ion shall be automatically activated at not more than ZO percent of the lower explosive l im i t . I t shall be designed to provide at least three a i r changes per minute.

Recommend: At least two a i r changes per minute. SUBSTANTIATION: Two a i r changes per minute is generally regarded by experts as acceptable. Higher exchange rates can result in turbulence and mixing of gas with a i r in the room. Fail safe operations (automatic propellant shut off) impact this requirement as wel l . COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-71 (Log #111). COMMITTEE STATEMENT: This is the same as Comment 30B-71 (Log #111).

(Log #155) 30B- 74 - (3-5.2(e)): Accept in Principle SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised text:

"Emergency vent i lat ion shall be automatically activated at not more than 20 percent of the lower explosive l im i t . I t shall be designed to provide at least two a i r changes per minute or twice the normal flow rate, whichever is greater. I f emergency vent i lat ion conditions persist for longer than 10 minutes (the duration to be debated by panel members), then the gassing room operation shall be automatically shut down." SUBSTANTIATION: Higher a i r flow rates in the gassing room can lead to a false sense of security during emergency vent i lat ion. For instance, i f emergency conditions are induced by defect ive gassing heads or leaking lines and the vent i lat ion were to fa i l at the same time, the gas concentration in the room can reach dangerous level rapidly. Limiting the a i r changes to two per minute is l i ke ly to help in catching the fugit ive emissions while they are s t i l l manageable. The provision of automatic shutdowns after a period would force f i l l e r s to investigate problems at an early stage and at the same time mlnlmize the risk of vent i lat ion fai lure during emergency conditions. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATEMENT: The changes made per Comment 30B-71 (Log #111) achieve the object ives of th is comment.

(Log #I12) 3OB- 75 - (3-5.2(f)): RejeCt SUBMITTER: Thomas G. Meier, The Gi l le t te Company COMMENT ON-PROPOSAL NO.: 30B-I RECOMMENDATION: Change "height of exhaust stack above roof to at least 4 f t . "

Exhaust discharge stacks shall be separated horizontally by at least lO f t (3 m) from make-up a i r intakes and shall terminate at least 10 f t (3 m) above the roof and at least 3 f t ( l m) above any other building within 25 f t (7.6 m). (See NFPA 91, Standard for the Instal lat ion of Blower and Exhaust Systems for Dust, Stock, and Vapor Removal or Conveying, for further information.) SUBSTANTIATION: The need for discharge stacks higher than 4 f t above the roof is questionable. The exhaust is being forced up and dissipates very well at 4 f t . COMHITTEE ACTION: Reject. COMMITTEE STATEMENT: This wording would be inconsistent with other NFPA standards. Also, the additional height is fe l t necessary due to anticipated l iquid carryover in the exhaust stack from the charging room.

(Log #259) 30B- 76 - (3 -5 .2 ( f ) ) : Reject SUBMITTER: D. Douglas Fratz, Chemical Specialt ies Manufacturers Association COHHENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph 3-5.2(f) to read:

8g

"Exhaust discharge stacks shall be separated horizontally by at least lO f t (3 m) from make-up a i r intakes and shall terminate at least 3 f t (1 m) above the roof and at least 3 f t ( l m) above any other building within 25 f t (7.6 m). (See NFPA 91, Standard for the Instal lat ion of Blower and Exhaust Systems for Dust, Stock, and Vapor Removal of Conveying, further information.)" SUBSTANTIATION: Requiring a i r intakes to be 10 f t above the roof is excessive and unnecessary. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-75 (Log #112).

(Log #234) 30B- 77 - (3-5.2(f)) : Reject SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Revised text:

(f) Exhaust discharge stacks shall be separated horizooLally by at least IO f t (3 m) from make-up a i r intakes and shall terminate at least 3 f t (I m) above the roof . . . SUBSTANTIATION: Our roof section is 3 stories high and very windy. 3 feet above roof is adequate and rel iable while 10 f t would be d i f f i c u l t to support and would be more subject to wind and storm damage. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-75 (Log #112).

(Log #194) 30B- 78 - (3-5.2(h)): Reject SUBMITTER: Robert Malanga/William Webb, Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add the following clause to the paragraph:

"and al l e lectr ic motors shall be of the Total ly Enclosed Fan Cooled (TEFC) type or otherwise approved for Class I D i v . I locations.

Exception: Electr ic motors that are located remote to the ductwork." SUBSTANTIATION: Since the vent i lat ion equipment is required for emergency vapor removal, as outlined in Section 3-5.2(e), the e lectr ic motors powering such equipment should not provide a source of igni t ion. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This is adequately addressed by 3-6.2 and by Section 2-3.

(Log #156) 30B- 79 - (3-5.2( i ) ) : Reject SUBMITTER: Bala Nathan, Diversif ied CPC International COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised text:

"The propellant charging room shall be maintained at a negative pressure of at least l in. water column in relation to ambient a i r . " SUBSTANTIATION: A minimum acceptable pressure d i f ferent ia l should be stipulated. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: There is no technical jus t i f i ca t ion for the minimum di f ferent ia l specified. The Committee does not see an advantage to specifying a d i f ferent ia l .

(Log #208E) 30B- 80 - (3-5.3): Accept SUBMITTER: David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL flO.: 3OB-I RECOMMENDATIg_N: Revise to read:

"Mechanical exhaust vent i lat ion shall be provided for flammable base product f i l l i n g areas. For areas that contain production operations l i ke ly to emit hazardous concentrations of flammable vapors, general area mechanical vent i lat ion shall be provided at a minimum flow rate of one cfm per sq f t of f loor area. Venti lation shall be arranged to uniformly sweep the entire f loor area.

~UBSTANTIATION: The need for one cfm per sq f t of f loor area has not been substantiated for areas not l i ke ly to emit hazardous concentrations of flammable vapors. The recommended change allows for quantifiable determinations to be made in accordance with the provisions of NFPA 30. COMMITTEE ACTION: Accept.

Including the current exception.

(Log #157) 30B- 81 - (3-5.3): Reject SUBMITTER: Bala Nathan, Diversif ied CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

" . . . at a minimum flow rate of one CFM per square f t of f loor area. Wherever possible, vent i lat ion shall be arranged to uniformly sweep the entire f loor area." SUBSTANTIATION: Local exhaust systems wi l l have a tendency to breakup the flow pattern in the rest of the room.

Venti lat ion for comfort is usuallyd designed to exhaust from a higher elevation (near the cei l ing). Flow pattern obtained in such a system is not l i ke ly to uniformly sweep the entire f loor area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This text is a design cr i ter ia , not a performance goal. I t is recognized that the airf low pattern wi l l be disturbed by local exhaust and by personnel movement.

(Log #158) 30B- 82 - (3-5.4): Hold for Further Study SUBMITTER: Bala Nathan, Diversif ied CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

" . . . and shall be suff ic ient to maintain the atmosphere around the bath at below 10 percent LEL under normal operating conditions." SUBSTANTIATION: The atmosphere around the test bath excepting the immediate v i c in i t y of 5 f t is not required to be designed for explosion-proof construction. There is no reason why the requirement For gas concentrations in this area be less stringent than recommended for gassing room under normal operating conditions. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: This comment proposes a design concept that hasn't been addressed by the Committee.

(Log #177) 3OB- 83 - (3-5.4): Hold For Further Study SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete the words "enclosed and" from paragraph 3-5.4. The paragraph should read:

"Aerosol container test baths shall be provided with exhaust vent i lat ion. The vent i lat ion Flow rate shall be determined by the production rate of the test bath and shall be suff ic ient to maintain the atmosphere around the bath below lower explosive l imits under normal operating conditions." SUBSTANTIATION: The need for enclosed exhaust is unnecessary. I t would not only be costly and inhibi t proper maintenance, but could hinder f i re f ighting appartus access. With proper vent i lat ion, levels of gas from ruptured cans would be kept at below the lower explosive l imi ts . COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-82 (Log #158).

(Log #208F) 30B- 84 - (3-5.4): Hold for Further Study iUBMITTER: David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

"Aerosol container test baths shall be enclosed. When determined necessary by the frequency of can ruptures and the emission of hazardous concentrations

90

of flammable vapors or gases, the test bath shall be provided with exhaust ven t i l a t ion . In such case, the ven t i la t ion flow rate shall be determined by the l ike l ihood of can rupture and quanti ty of flammable vapor released from the test bath area and shall be suf f ic ien t to maintain the atmosphere around the bath below the lower explosive l imit under normal operating conditions. SUBSTANTIATI~: Substantiation has not been provided to the Committee to warrant local exhaust for al l test baths. The likelihood of a single can rupture is less than 1 in 1,000,000. Further, while local exhaust may be desirable for test baths operating at 160°F, i t may not be necessary for those operating at 130°F. Interestingly, there exists an equivalent likelihood for a single can rupture in test baths at 130°F as there is for a can rupture at the labeler, tipper, or case packer. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 308-82 (Log #158).

COMMITTEE ACTION: Reject. CQMMITT{E STATEMENT: This is already covered by 3-14.3.2.

(Log #113) 30B- 88 - (3-6.1.1): Reject SUBMITTER: Thomas G. Meier, The G i l l e t t e Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Replace 3-6.1.1 as fol lows:

"Vacuum pumps for propellant charging shall be located inside the gas room or in their own safe area with discharged piped direct ly outdoors." SUBSTANTIATION: Vacuum pumps have been a known safety concern and should be treated as a source of flammable gas. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as Comments 30B-86 (Log #260) and 30B-87 (Log #159).

(Log #235) 30B- 85 - (3-5.5): Accept in Principle ~Li/~_M_ITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"Local exhaust ventilation shall be provided for reject aerosol containers that are located outside the propellant charging room unless they are stored out of doors in an open area." SUBSTANTIATION: Reject containers must be removable from tlle charging room for ultimate disposition. I f rejects are punctured or crushed, operation should be outside of the charging area preferably out of doors away from other structures and operations. COMMITTEE ACTION: Accept in Principle.

Revise 3-5.5 to read: "Local exhaust ventilation shall be provided for

reject aerosol containers that are located within buildings." COMMITTEE STATEMENT: The Committee believes that i ts rewording achieves the intent of the submitter.

(Log #260) 30B- 86 - (3-6.1.I): Reject ~_~BMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 3-6.1.1 to read:

" I f vacuum pumps used in conjunction with propellant charging are remotely installed ( i .e. not in the charging room), the area within 5 f t (15 m) of the extremities of the pumps shall be classified as a Class I, Division 2 location.

Exception: This requirement is waived i f the vacuum pumps are locai.ed in their own safe and protected area and i f the total discharge is piped directly to the outside, per 3-14.2." SUBSTANTIATION: I f vacuum pumps become conduits for flammable propellant gas through a mechanical failure in the propellant charger, surrounding them with a small Class I, Division 2 safety area wi l l be of very limited benefit. The key safety measure is to exhaust all the flammable gas to the open air. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The concerns expressed are covered by 3-6.1.1, Section 2-3, and the vent stack requirements.

(Log #159) 30B- 87 - (3-6.1.I): Reject ~ : Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to present text:

"For remote installations, vacuum pumps shall discharge to the outside, keeping a minimum clearance of at least I0 f t from any air intakes and doorways." SUBSTANTIATION: This would prevent accumulation of flammable vapors either from base product or from flammable propellants in enclosed uncontrolled areas.

(Log #160) 30B- 89 - (3-9.1): Reject SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-1 R~COMMENDATION: None. SUBSTANTIATION: Definitions of wet-plpe and Deluge-type sprinklers or appropriate NFPA reference to same, would be helpful. COMMITTEE ACTION: ReJect. COMMITTEE STATEMENT: This is covered by 2-6.1.

(Log #85) 30B- go - (3-10.1): Accept in Pr inciple SUBMITTER: Gene Wolfe, Los Angeles County Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise the paragraph to read:

3-10.1 When required by the authority having jurisdict ion, production equipment such as mixers, solvent tanks, or fixed open containers, shall be protected by an automatic extinguishing system. Such systems shall be designed and installed in accordance with the following, as applicable:

NFPA 11, Standard for Low Expansion Foam and Combined Systems;

NFPA lIA, Medium and High Expansion Foam Systems NFPA t2, Standard on Carbon Dioxide Extinguishing

Systems NFPA 16, Standard on Deluxe Foam-Water Sprinkler and

Foam-Water Spray Systems NFPA 17, Standard for Dry Chemical Extinguishing

Systems SUBSTANTIATION: The paragraph as written makes no sense. I t requires the authority having Jurisdiction to except an automatic extinguishing system that complies with an NFPA standard. I t also requires the A.H.3. to except halon protection systems. Halon should only be used when no other alternative exists. COMMITTEE ACTION: Accept in Principle.

Revise 3-I0.I to read: "Where automatic f i re extinguishing systems are

provided to protect production equipment, such as mixers, solvent tanks, or f ixed open containers, such systems shall be designed and ins ta l led in accordance with the following, as applicable:

NFPA I I , Standard for Low Expansion Foam and Combined Agent Systems,

NFPA IIA, Standard for Medium and High Expansion Foam Systems

NFPA 12, Standard on Carbon Dioxide Extinguishing Systems

NFPA 12A, Standard on Halon 13Ol Fire Extinguishing Systems

NFPA 12B, Standard on Halon 1211 Fire Extinguishing Systems

NFPA 16, Standard on Deluge Foam-Water Sprinkler and Foam-Water Spray Systems

NFPA 16A, Recommended Practice for the Installation of Closed-Head Foam-Water Sprinkler Systems

NFPA 17, Standard for Dry Chemical Extinguishing Systems

91

COMMITTEE STATEMENT: The revised wording is clear and more easily interpreted. I t also is broader in that more types of systems are addressed.

(Log #114) 30B- 91 - (3-11.2): Reject ~BMITTER: Thomas G. Meier, The Gil lette Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Recommend adding to 3-11.2 as follows:

"Propellant f i l l i n g rooms shall have no floor drains " SUBSTANTIATION: Gas can flow down through a "dried trap" drain and collect in sewers or other connected locations. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Certain propellant charging rooms may require floor drains (e.g., food processors). Section 3-11 adequately handles this.

(Log #161) 3OB- 92 - (3-11.2): Reject ~VBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

" . . . or discharge into public waterways, the drainage system shall be equipped with traps, separators or other devices that wi l l divert flow of flammables to a safe location. SUBSTANTIATION: None. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The intent of this section is to prevent discharge of hazardous materials into public waterways. The submitter's suggestion would l imit application of 3-II.2 just to "flammables."

SUBSTANTIATION: Occasional entry of personnel in charging rooms should not mandate the installation of explosion suppression systems. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 3OB-g3 (Log #162).

(Log #236) 30B- 95 - (3-12.1.I (New)): Reject SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 3OB-I RECOMMENDATION: New text:

3-12.1.I An explosion prevention system ut i l iz ing C02 interlocked with a gas detection system may be uti l ized where warning of C02 discharge is init iated at 20 percent of the L.E.L. (lower explosive limits) to permit evacuation of personnel concurrent with automatic gas l ine shut off. C02 discharge to be init iated at the 40 percent L.E.L. detector level concurrent with appropriate time delayed exhaust shut off. System to comply with NFPA 12. SUBSTANTIATION: Our changing room has 3 conveyor-high cells with zone detectors plus main detectors at each end of the charging room outside of the cell areas. The main detectors would be uti l ized to warn and actuate the C02 system to eliminate the possibi l i ty of a charging house explosion. The system would be ozone safe, not subject to banning of the extinguishing material and safe for personnel and the environment. I t would meet paragraph #3 equivalency requirement for quality, f i re protection, effectiveness, durabil ity, and safety in comparison with the code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This comment would restrict protection schemes to only using carbon dioxide, the Committee does not feel this is just i f ied.

(Log #162) 30B- 93 - (3-12.1): Reject ~UBMITTER: Bala Nathan, Diversified CPC International ~OMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

" I f charging room and pump room operations require attention and/or monitoring by personnel stationed within the chargin 9 room, then an explosion suppression system meeting the requirements of NFPA 69, Standard for Explosion Prevention Sytems, shall be instal led." SUBSTANTIATION: Occasional entry of personnel in charging rooms should not mandate the installation of explosion suppression systems. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The requirement for an explosion suppression system has been v i r tua l ly unquestioned by this Committee. The Committee is well aware of the hazards and is s t i l l in favor of such protection for certain high risk areas.

The records show that the majority of suppressed deflagrations in aerosol f i l l i n g rooms and propellant pump rooms have occurred when personnel were present. No injuries resulted. The records also show that such systems have never failed to suppress the deflagration.

I t should be remembered that such systems are designed to stop the deflagration at i ts incipient stage, while a deflagration vent merely directs the f ireball and i ts pressure wave to a predetermined location. I t would appear that to stop the deflagration before i t reaches the point where the vent operates would result in increased safety for any personnel in the area.

(Log #261) 30B- 94 - (3-12.1): Reject SVBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Modify paragraph 3-12.1 to read as follows:

3-12.1 I f chargin~ room and pump operations require personnel to be statloned within the charging room, an explosion suppression system meeting the requirements of NFPA 69, Standard on Explosion Prevention Systems, shall be installed.

(Log #115) 30B- 96 - (3-12.2): Accept SUBMITTER: Thomas G. Meier, The Gil lette Company ~OMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete "only" and revise 3-12.2 to read:

"Where installed, an engineered explosion suppression shall meet the requirements of NFPA 69, Standard for Explosion Prevention Systems, and shall use detectors that respond to radiant energy. Pressure detectors may also be used to back up radiant energy detectors." SUBSTANTIATION: The language "shall only use" restricts the use of redundant but effective pressure detectors. COMMITTEE ACTION: Accept.

But make the following changes to the submitter's wording:

Add the word "system" after the word "suppression." Add "or ul traviolet l ight" after "radiant energy."

COMMITTEE STATEMENT: The f i r s t change is editorial. The second change reflects the fact that ultraviolet detectors are also available.

(Log #237) 30B- 97 - (Table 3-13): Reject SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

Condition Automatic Action Detection of 20% of Alarm activates. General the lower explosive ventilation flow rate l imi t , increases to a minimum of 3

air changes per minute. I f a C02 explosion prevention interlock is used, main propellant l ine shuts down and C02 warning alarm activates to warn personnel to vacate the area.

At detection of 40% After "shuts down" add; with of the lower explosive C02 explosion prevention l imit , system, C02 discharge is

init iated along with time delayed exhaust system shut down.

92

SUBSTANTIATION: To be consistent with proposed 3-12.1.I allowing C02 explosion prevention systems, automatic interlock paragraph must be amended. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-95 (Log #236). Also, this wording is restricted to only one extingiushing agent.

(Log #262) 30B- 98 - (Table 3-I.3): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO-: 30B-I RECOMMENDATION: Revise Table 3-13 to read as follows:

Table 3-13 Equipment Interlocks

Condit ion

Detection of 20% of the lower explosive l imit

Detection of 40% of the lower explosive l imit

Actuation of protective systems within the propellant charging room or product f i l l area.

Automatic Action

Alarm activates. General ventilation flow rate increases to a minimum of 2 air changes per minute.

Audible alarm activates. Main propellant line shuts down. All equipment in propellant charging room shuts down.

Automatic shut-down of entire propellant charging line.

SUBSTANTIATION: See 3-5.2(e). Two air changes per minute is a reasonable minimum. COMMITTEE ACTION: Accept.

But make the following change to the f i rs t entry under "automatic action":

"General ventilation flow rate increases to that required by 3-5.2(e)." COMMITTEE STATEMENT: The Committee's change is to provide correlation between the table and the text.

(Log #126) 30B- 99 - (Table 3-13): Accept in Principle ~ : Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Table 3-13 . . . General ventilation flow rate increases to a minimum of 3 air changes per m inu te . . .

Recommend . . . General ventilation flow rate increases to a minimum of 2 air changes per minute. SUBSTANTIATION: See 3-5.2(e). ~_QMMITTEE ACTI(~FF: Accept in Principle.

By means of action on Comment 30B-98 (Log #262). COMMITTEE ~TATEMENT: See Comment 30B-98 (Log #262).

(Log #195) 30B- 100 - (Table 3-13): Reject ~ : Robert Malanga/William Webb, Roll Jensen and Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add the following wording to the paragraph on the third category, second column:

"Automatic shut-down of entire propellant charging line and all electrical equipment in the room except for those required for f i re protection systems." SUBSTANTIATION: Shutting down the propellant charging line alone does not eliminate al l potential sources of ignition whereas ful l electrical shut-down wil l eliminate man)' more. COMMITTEE ACTIDj~: Reject. COMMITTEE STATEMENT: This is not necessary, since the area is already provided with explosion proof electrical equipment. Also, the ventilation system must be kept running.

(Log #163) 30B- I01 - (Table 3-13): Accept in Part SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION:

Condition

20% or more LEt condition persists for longer than 10 mins. Detection of 40% of the lower explosive l imi t

Automatic Action

Same actions as at 40% LEt condition

. . . . . charging room shuts down. Vacuum pump/s used in conjunction with aerosol can f i l l i ng shuts down.

SUBSTANTIATION: Require f i l l e rs not to ignore persistent emergency ventilation condition. Shutting down vacuum pumps would prevent flammable vapors being pumped into uncontrolled areas. COMMITTEE ACTIOFF: Accept in Part.

Accept only the requirement to shut-down the vacuum pump at detect ion level of 40 percent. COMMITTEE STATEMENT: The Committee fee ls that current act ions fo r the 20 percent detect ion level are adequate.

(Log #164) 30B- 102 - (3-14.3.2(a)): Accept ~UBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"The discharge vent shall terminate at a safe location outside and at least I0 f t away from any air intake." SUBSTANTIATION: None. COMMITTEE ACTION: Accept.

(Log #165) 30B- I03 - (3-14.3.2(b)): Reject SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: None. SUBSTANTIATION: 1. What, when vacuum pumps are located outs ide the gassing room but not enclosed in a separate bu i l d ing .

2. The amount of gas exhausted through a vacuum pump is so small , i t does not present any where near the hazard level as from charging room vent exhausts. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This requirement is considered necessary for safety.

(Log #166) 3OB- 104 - (3-14.3.2(c)): Reject SUBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"Vent manifolds shall not be allowed unless adequately protected for backflow by using devices such as backflow check valves." SUBSTANTIATION: This provision is necessary for ease of construction, operations and minimize complications from a number of vent stacks. COMMITTEE ACTION: Reject. ~_O~MMITTEE STATEMENT: Backflow check valves are not reliable enough for safety service, especially where deflagrations can occur.

(Log #178) 30B- 105 - (3 -14 .3 .2 (c ) ) : Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Willlams Co. COMMENT ON PROPOSAL NO.: 3OB-I R__ECOMHENDATION: Revise paragraph to read:

(c) Vent manifolds shall be permitted provided that proper automatic controlled valves to avoid cross-contamination provide high pressure rel ief is installed. SUBSTANTIATION: Properly valved vent manifolds with automatic controls to avoid cross-contamination and provide rel ief for high pressure would ensure a safe condition. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-I04 (Log #]66).

93

(Log #167) 30B- I06 - (3-14.4.2): Reject ~_(LBMITTER: Bala Nathan, Diversif ied CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

(a) The pump shall be located at least 25 f t from any intake opening of normally occupied buildings not designed for explosion-proof service.

(b) The pump shall be located at least lO f t from charging room intake opening.

(c) The pump shall be located at least 25 f t from any area subjected to vehicular t ra f f i c or from other sources of igni t ion. ~ : I. Under normal operating conditions, gas concentrations in the v i c in i t y of tile pump should be below I0% LEL. Separation of 25 f t from intake openings of unprotected buildings should provide adequate protection.

2. Charging rooms are already well protected for explosion proof service and are provided for large a i r movement. COMMITTEE ACTION: Reject. ~OMMITTEE STATEME_NT: This would reduce the level of safety below that which the Committee feels is desirable.

(Log #168) 30B- I07 - (3-14.4.2): Accept ~S_U_B_I~LU_T_F,~R: Bala Nathan, Diversif ied CPC International COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Revised text:

" I f located outside, the propellant charging pump shall be permitted to be located . . ." SUBSTANTIATION: Distinction should be made between the propellant pumps in the tank farm and unloading areas and those used for actually charging the propellant in an aerosol can and located in or around charging rooms. COMMITTEE ACTION: Accept.

Make this same change to paragraphs 3-14.3.1, 3-14.3.2. Also, in 3-14.4.2, change to read:

"The flammable propellant charging pump." COMMITTEE STATEMENT: This change is needed elsewhere. The change to 3-14.4.2 is for further c la r i ty .

(Log #302) 30B- 108 - (3-14.6): Hold for Further Study SUBMITTER: Byron L. Briese, Oak Ridge, TN COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add the following section to Chapter 3:

"Outside Charging Houses: Ignit ion sources shall be located with respect to exter ior aerosol charging operations based on an analysis of the release of the most l i ke ly quantity of propellant that would be released in an uncontrolled fashion." SUBSTANTIATION: Currently, the standard is s i lent regarding exter ior operations except for the location of propellant pumps. Current technology, available from many sources, can describe the movement of vapor clouds. ~MITTEE ACTL(~N~: Hold for Further Study. COMMITTEE STATEMENT: This concept has not had adequate Committee review.

(Log #266) 30B- 109 - (3-15): Accept in Principle SUBMITTER: O. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I ~ : Revise paragraph 3-15 to read as follows:

3-15 End of Production Line Storage. Storage of up to 4000 Ibs. of Level 2 or Level 3 aerosol products per production l ine or rework production l ine shall be permitted in production areas, such as in staging areas (e.g. awaiting transfer to a warehouse), provided they are stored no more than one palletload high. All other storages shall be protected in accordance with Tables 4-I through 4-6 as applicable. SUBSTANTIATION: The larger aerosol manufacturing plants often have from 4 to IO production lines. Limiting end-of-line storage of a high-speed l ine to:

2500 Ibs Number of Lines

would mean that part ial palletloads of f i l l ed stock would usually have to be removed to the warehouse before stacking and wrapping could be completed. No f i res are known to have originated in these temporary storage areas. COMMITTEE ACTION: Accept in Principle.

Delete current 3-15. Add the following as an exception to 3-9.2: "Storage of up to 2500 Ibs of Level 2 or Level 3

aerosol products per production l ine or rework production l ine shall be permitted in production areas, such as in staging areas (e.g. awaiting transfer to a warehouse), provided they are stacked no more than one palletload high and there is no warehouse storage of aserosol products within 25 f t of the production line. All other storage shall be protected in accordance with Tables 4-I through 4-6, as applicable." COMMITTEE STATEMENT: The Committee feels that this can best be handled as an Exception to 3-9.2. Further, the Committee's version is more clear.

(Log #73) 30B- 110 - (3-15): Accept in Principle B$_U_~.~bUJ_I~R: Ronald W. Vath, The Mennen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text :

3-15 End-of-Production-Line Storage. Storage of more than 10,000 Ibs (4540 kg) of level 2 and 3 aerosol products in active production areas, such as staging areas (e.g., awaiting transfer to a warehouse), shall be protected in accordance with Tables 4-I through 4-6, as applicable. SUBSTANTIATION: The levels as shown are to allow for practical holding capabil i ty for mult i l ine operations. The suggested quantities are thought to be f i re safe as protection in Tables 4-1 through 4-6 are predicated upon unattended storage areas where incipient f ires may get an appreciable start before manual and automatic sprinkler mitigation would being. In an active production area, attending employees who can immediately address an incipient f i re wi l l be present. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-I09 (Log #266). COMMITTEE STATEMENT: See Comment 30B-I09 (Log #266).

(Log #127) 30B- I l l - (3-15): Accept in Principle ~ : Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"End of Production Line Storage. Storage of more than 2500 Ibs of Level 2 and 3 aerosol products in production areas, such as in staging areas (e.g. awaiting transfer to a warehouse), shall be protected in accordance with Tables 4-I through 4-6 a@ applicable."

Recommend" "End of Production Line Storage. Storage of up to 4000 Ibs of Level 2 or Level 3 aerosol products per production l ine or rework production l ine shall he permitted in production areas, such as in staging areas (e.g. awaiting transfer to a warehouse), provided they are stored no more than one palletload high. All other storages shall be protected in accordance with Tables 4-I through 4-6 as applicable." $VBSTANTIATION: The larger aerosol manufacturing plants often have from 4 to lO production lines. Limiting end-of-line storage of a high speed l ine to:

2~00 Ib~ Number of Lines

would mean that part ial palletloads of f i l l ed stock would have to be removed to the warehouse before stacking and wrapping could be completed. No fires are known to have originated in these temporary storage areas. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-I09 (Log #266). COMMITTEE STATEMENT: See Comment 30B-I09 (Log #266).

94

(Log #171) 30B- 112 - (3-15): Accept in Principle ~VBM~TTER: Gary T. Mi l ler , S. C. Johnson & Son, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

3-15 End-of-Production Line Storage. Storage of more than I0,000 Ibs (4540 kg) of Level 2 and 3 aerosol products in production areas, such as storage areas (e.g., awaiting transfer to a warehouse) shall be protected in accordance with Tables 4-I through 4-6 as applicable i f the residency time in the temporary storage area exceeds 4 hours. SUBSTANTIATION: The restr ic t ion to end-of-productlon-line storage of 2,500 Ibs. is far too rest r ic t ive for the operation of high speed production lines, especia111y i f the output of several production lines is pal let ized in one central location. Pal let iz ing areas and areas for staging finished goods for transportation to warehouses generally have good size open space with noncombustibles in the area. No f i res are known to have originated in these temporary storage areas. In high speed multiple aerosol l ine production operations, the residency time in the temporary storage area averages two hours. A time l imi t of 4 hours would accommodate variables associated with production l ine downtime. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-lOg (Log #266). COMMITTEE STATEMENT: See Comment 30B-109 (Log #266).

(Log #179) 30B- l l3 - (3-15): Accept in Principle ~UBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

3-15 End-of-Production-line Storage. Storage of more than 2,500 Ibs (1135) per production l ine of Level 2 and 3 aerosol products in production areas, such as in staging areas (e.g. awaiting transfer to warehouse) shall be protected in accordance with Tables 4-I through 4-6 as applicable. SUBSTANTIATION: The restr ic t ion of 2,500 Ibs per plant is unrealist ic due to the fact that larger plants that have over two lines of production could not even store one pal let per l ine. The l im i t of 2,500 Ibs. per l ine is more rea l is t ic . This provides for one pal let at the end of the l ine while one pal let is being wrapped and transferred to the warehouse. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-lOg (Log #266). COMMITTEE STATEMENT: See Comment 30B-109 (Log #266).

(Log #208H) 30B- )14 - (3-16.3(e)): Accept ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

(e) When more than f ive containers are to be evacuated at any one time, the operation shall be conducted in the propellant room, outdoors, or within equipment or f a c i l i t i e s speci f ical ly designed for this purpose. SUBSTANTIATION: F lex ib i l i t y . COMMITTEE ACTION: Accept,

I But change "propellant room" to "propellant charging room." COMMITTEE STAI~ME~: Changes are for c la r i ty .

SUBSTANTIATION: Some guidance should be given regarding an acceptable outdoor location for evacuating containers. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-If4 (Log #208H). COMMITTEE STATEMENT: See Comment on 30B-I14 (Log #208H).

(Log #128) 30B- I16 - (3-16.3(e)): Reject ;~_U_~_~I~_TjT_E_~: Dale Cook, Peterson/Puritan Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"When more than f ive containers are to be evacuated at any one time, the operation shall be conducted in the propellant charging room or outdoors. In either case, the containers shall be grounded."

Recommend: When more than f ive containers of Level 2 or Level 3 products are to be evacuated . . . ~UBSTANTIATION: Level 1 aerosols do not pose a threat that jus t i f i es this level of precuation. COMMITTEE ACTION: Reject. COMMITTEE S T y : Even a Level I aerosol product can hold a substantial amount of flammable propellant. The protection required is considered necessary.

(Log #180) 30B- 117 - (3-16.3(e)): Reject ~ : Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

(e) When more than f ive containers of Level 2 or 3 products are to be evacuated at any one time, the operation shall be conducted with proper vent i lat ion to ensure the lower explosive l im i t is not exceeded or outdoors. In either case, the containers shall be grounded. SUBSTANTIATION: There is no need to perform this function in a charging room. The most important feature is adequate vent i lat ion such as a hood or other exhaust vent i lat ion. I f the LEL is not exceeded, there should not be a signi f icant problem. COMMITTEE ACTION: Reject. COMMITTEE ~TATEMENT: Same reason as for Comment 30B-I16 (Log #128).

(Log #23B) 30B- I18 - (3-16.3(e)): Reject ~ : C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete (e). Substitute:

(e) When more than l container is punctured at any one time, the vent i lat ion rate of hood shall provide 3 a i r charges a minute and hood shall be equipped with a gas detector to warn operators of a hazardous condition. SUBSTANTIATION: The problem of a i r movement from the hood is not addressed nor is the size of the container bein 9 exhausted. Five 22 oz cans may pose a bigger problem than several very small cans. Hole size cannot be guaranteed. A detector is advisable which wi l l appropriately warn operators of the hazard. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This proposed requirement is too rest r ic t ive, with no apparent increase in the level of safety.

(Log #89) 30B- 115 - (3--17.3(e)): Accept in Principle ~ : Michael 3. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read as follows:

(e) When more than f ive containers are to be evacuated at any one time, the operation shall be conducted in the propellant charging room or outdoors, in a safe location away from sources of igni t ion. In either case, the containers shall be grounded.

(Log #2081) 30B- 119 - (3-16.4): Accept SUBMITTER: David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

"When mechanical propellant f i l l i n g equipment is similar to that u t i l i zed within production operations, the laboratory shall be considered to be a p i lo t plant and shall meet the construction and vent i lat ion requirements of Chapter 3 of this Code."

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SUBSTANTIATION: This better clar i f ies the intent, as small-scale manual propellant f i l l i n g can safely he performed within a laboratory hood. COMMITTEE ACTION: Accept.

But delete the word "mechanical" and retain 3-16.4.1. COMMITTEE STATEMENT: The f i r s t change is considered editorial. The Committee feels that the requirements for cold f i l l i ng is s t i l l needed.

(Log #267) 3OB- 120 - (3-16.4): Accept in Principle ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDS: Revise paragraph 3-16.4 to read as follows:

3-16.4 When automated mechanical propellant f i l l i n g equipment is located in an aerosol laboratory, the laboratory shall be considered to be a p i lot plant and shall meet the construction and ventilation requirements of Chapter 3 of this Code. SUBSTANTIATION: This requirement is excessive for the nonautomated hand f i l l i n g equipment commonly used in aerosol laboratories: See proposed new paragraph 3-16.4.2 for more reasonable requirements for nonautomated f i l l i n g operations. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-I19 (2081). COMMITTEE STATEMENT: See Comment 30B-I19 (208I).

(Log #239) 30B- 121 - (3-16.4): Accept in Principle ~L~_t~_TJ_~_~: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"When mechanical propellant f i l l i n g equipment (not to include transfer cans or manually operated burette gasers) is located in an aerosol laboratory . . . etc. SUBSTANTIATION: "Mechanical propellant f i l l i n g

notequi~;~;ei~ r : ~ f ~ f ~ e ; ~ l ~uud~;~b:~d thisIt shoutdneeds to be spelled out clearly. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-119 (208I). COMMITTEE STATEMENT: See Comment 30B-I19 (208I).

(Log #169) 30B- 122 - (3-16.4): Accept in Principle S ~ M ~ : Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATI_O_~: Revised text:

"When automatic propellant f i l l i n g equipment is located in an aerosol laboratory, the laboratory shall be considered to be a p i lot plant and shall meet the construction and ventilation requirements of Chapter 3 of this code. Nonautomatic propellant f i l l i n g in an aerosol laboratory shall only be conducted inside a well-ventilated fume hood. SUBSTANTIATION: Fi l l ing of propellant in an aerosol laboratory for research or can testing purposes would be affected with the previous wording. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-119 (Log #208I). COMMITTEE STATEMENT: See Comment 30B-119 (Log #208I).

(Log #38) 30B- 123 - (3-16.4.1): Accept ~ : Donald R. Strobach, DuPont Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: After " . . . shall be prohibited." Add:

" to prepare aerosol samples for standard or routine evaluation. Cold f i l l i n g of flammable propellant may be used to prepare small numbers of samples for special testing where alternative f i l l i n g methods are impractical or cannot be used."

SUBSTANTIATION: DuPont developed an accelerated corrosion test apparatus for aerosol formulations, especially those using diemethyl ether propellant. One of the cell electrodes is prepared by dr i l l ing a hole through an aerosol valve (perpendicular to the plane of the mounting cup) and inserting a steel rod into i t . The second electrode is the aerosol can i tse l f . By necessity, the propellant must be cold f i l led when carrying out the test. I f the cold f i l l i ng of flammable propellants is prohibited, as in 3-16.4.1, this very valuable test cannot be conducted. COMMITTEE ACTION: Accept.

(Log #240) 30B- 124 - (3-16.4.1): Accept in Principle SUBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"Cold f i l l i n g of flammable propellant shall be prohibited unless operation is total ly contained in a charging room with detectors and automatic suppression systems employed." SUBSTANTIATION: Prohibition of operation does not allow for future developments nor does i t adequately consider existin~ available equipment. In years past, we safely cold f111ed isobutane fu l ly cognizant of the hazard. We monitored the operation carefully and never had a problem. Cold f i l l i n g of flammable propellants can be done safely. COMMITTEE ACTION: Accept in Principle.

No change required. COMMITTEE STATEMENT: Cold f i l l i n g is already allowed.

(Log #268) 30B- 125 - (3-16.4.2 (New)): Accept in Principle SUBMITTER: D. Douglas Pratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add a new paragraph 3-16.4.2 to read as follows:

3-16.4.2 Nonautomated mechanical f i l l i n g of propellant in an aerosol laboratory, shall only be conducted inside a well ventilated fume hood. The maximum aount of flammable propellant permitted inside the laboratory is 20 pounds. SUBSTANTIATION: This provides more reasonable requirements for the safe small-volume f i l l i n g of aerosols using nonautomated equipment. COMMITTEE ACTION: Accept in Principle.

Revise the submitter's wording as follows; "Manual f i l l i n g of flammable propellant in an aerosol

laboratory shall be conducted inside a well-ventilated laboratory hood." COMMITTEE STATEMENT: The Committee's version is more concise and achieves the objectives of the submitter.

(Log #181) 30B- 126 - (4-1.1): Accept ~ : Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

4-1.I All cartons of aerosol products produced after 3anuary l , 1992 shall be labeled with the classification of the aerosol products contained, in accordance with Section I-7. Cartons shall be clearly labeled as follows:

"Level Aersols" SUBSTANTIATION: The date for compliance should be a production date. Otherwise, cartons would have to be recalled for labeling. Also this would be in agreement with the "Channels in Trade" policies adopted by federal agencies.

Cartons need to be clearly marked but not necessarily on two sides. COMMITTEE ACTION: Accept.

But change the word "labeled" to "identified on at least one side." COMMITTEE STATEMENT: The Committee's changes allow for more f l ex i b i l i t y .

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(Log #129) 30B- 127 - (4-1.1): Accept in Principle B~_U~J_!_~: Dale Cook, Peterson/Puritan Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

Effective January I, 1992, a l l cartons of aerosol products shall be labeled with the classif ication of the aerosol product contained, in accordance with Section I-7. Cartons shall be labeled on two sides as follows:

"LEVEL - AEROSOL" Recommend: All cartons of aerosol products produced

a f t e r January 1, 1992, shal l be labeled with the c l ass i f i ca t i on of the zero . . . SUBSTANTIATION: Small quantities of aerosols remain in the trade for periods up to three years. The requirement to locate and label these mater ia ls is not resonable. A period of time w i l l be required to incorporate the label in to shipper design. COMMITTEE ACTION: Accept in Pr inc ip le .

By means of act ion on Comment 308-126 (Log #181). COMMITTEE STATEMENT: See Comment 30B,126 (Log #181).

(Log #215) 30B- 128 - (4-1.1): Accept in Principle SUBHITTER: Joseph Sessa, tehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph to read:

4-1.1 A l l cartons of aerosol products produced a f t e r January 1, 1992 shal l be labeled with the c l ass i f i ca t i on of the aerosol products contained, in accordance with Section 1-7. Cartons shal l be labeled on two sides as fo l lows: "Level Aerosol . " SUBSTANTIATION: The arbitrary assignment of a date by which al l cartons in the distr ibut ion chain must be carton marked is ent i re ly inappropriate. To allow for timely compliance, a date after which al l products produced wi l l be labeled, is in agreement with common industry practice as well as "Channels in Trade" policies being adopted by federal agencies at this time. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 308-126 (Log #181). COMMITTEE STATEMENT: See Comment 30B-126 (Log #181).

(Log #2083) 3OB- 129 - (4-1.1): Accept in Principle ~ : David C. Tabar, The Sherwin-Williems Company COMMENT ON PROPOSAL NO.: 30B-I ~MM~NOATION: Revise to read:

4-I.1 All cartons of aerosol products produced after 3anuary I, 1992 shall be labeled with the classif ication of the aerosol products contained, in accordance with Section I-7. Cartons shall be labeled on two sides as fo l lows:

LEVEL AEROSOL

SUBSTANTIATION: This provision wi l l provide more real is t ic and timely compliance throughout the entire distr ibut ion chain. COMMITTEE ACTION: Accept in Principle,


(Log #241) 3OB- 130 - (4-1.1): Accept in Principle ~ : C. P. C1app, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Second sentence:

"Cartons shall be printed or labeled on two sides or one side and one end as follows: Level - aerosol." SUBSTANTIATION: Cartons may be printed or labeled in the f la t where one side and one end is exposed for easy marking. I f 2 sides are marked, cartons must be turned over to do th i s . Also, p r i n t i ng is as su i tab le as labe l ing . This would in no way diminish the intended resu l t of marking and would a l low more e f f i c i e n t product ion. ~OMMITTEE ACTION: Accept in Pr inc ip le .

By means of act ion on Comment 308-126 (Log #181). COMMITTEE STATEMENT: See Comment 308-126 (Log #181).

(Log #220) 30B- 131 - (4 -1 .2) : Reject SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph to read:

4-1.2 Cartons of aerosol products tha are not marked wi th the c l ass i f i ca t i on l eve l , and i f the product c l ass i f i ca t i on is not otherwise i d e n t i f i a b l e , shal l be considered to be leve l 3 aerosol products. SUBSTANTIATION: This language is added to avoid misc lass l fy lng products to the highest level when informat ion Jus t i f y i ng a proper c l ass i f i ca t i on is readily ava i l ab le . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that 4-1.2 is necessary for the reinforcement of 4-1.1.

(Log #270) 30B- 132 - (4-1.1 and 4-1.2) : Reject SUBHITTER: D. Douglas Fratz, Chemical Specia l t ies Manufacturers Associat ion COMMENT ON PROPOSAL NO.: 30B-1 RECOHMENOATION: Delete paragraph 4-1,1 and revise 4-1.2 as fo l lows:

4-1.2 Aerosol products that cannot be read i l y i den t i f i ed regarding t h e i r proper c l ass i f i ca t i on level shal l be considered to be Level 3 aerosol products. SUBSTANTIATION: A requirement fo r the labe l ing of aerosol cartons is ne i ther necessary nor appropr iate for the fo l lowing reasons:

1) Labeling fo r var ious types of aerosol products are c lea r l y speci f ied by various federal statutes and regulat ions which preempt state and local labe l ing requirements. Federal agencies wi th Ju r i sd ic t ion over aerosol product labe l ln~ include the Environmental Protect ion Agency (pest ic ides, inc luding d is in fec tan ts ) , the Food & Drug Administ rat ion (foods, drugs and cosmetics), the Consumer Product Safety Commission (other consumer-use products), the Occupational Safety and Health Administ rat ion ( i ndus t r i a l and i n s t i t u t i o n a l products fo r workplace-use), and the Department of Transportat ion (a l l aerosols shipped i n t e r s t a t e ) .

2) Although NFPA 30B is a "National Fire Code," f i r e codes are enforced as state and local laws by state and local o f f i c i a l s . At any given time in the fu ture, these state and local codes may d i f f e r regarding the spec i f ic requirements fo r carton labe l lng , or even contain d i f f e r i n g c r i t e r i a for the c l ass i f i ca t i on of aerosols, since such c r i t e r i a are l i k e l y to evolve and be fu r ther ref ined as more data are generated on ex is t ing and newly developed aerosol formulat ions. Local o f f i c i a l s seeking to enforce d i f f e r i n g labe l ing requirements across the county would present an unreasonable burden on i n te r s ta te commerce.

3) A requirement fo r carton labe l ing on two sides as the only means to communicate aerosol c l ass i f i ca t i on unduly r es t r i c t s equal ly e f f icac ious means, such as p a l l e t labe l ing . The reasonable goal of th is section - - to assure that aerosols are read i l y i d e n t i f i a b l e in regards to c l ass i f i ca t i on during storage - - can best be at ta ined by a f l e x l b l e , performance-oriented approach.

4) The CSHA has developed and approved the "CSHA Commercial Practices Standard on Class i fy ing and Communicating Fire Protect ion Informat ion for Aerosol Products." This vo luntary industry standard establ ishes as standard aerosol industry pract ice thec lass l f i ca t i on of products according to the c r i t e r i a in NFPA Code 30B, and the communication of that informat ion throughout the d i s t r i b u t i o n chain through carton marking and Hater ia l Safety Data Sheets. There is therefore no need to include requirements in NFPA Code 30B (or in state and local f i r e codes) for aerosol carton labe l ing . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comments 30B-130 (Log #241) and 30B-131 (Log #220).

(Log #216) 3OB- 133 - (4-1.3) : Hold for Further Study SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COHH~NT ON PROPOSAL NO.: 3013-1 RECOHHENOATION: Delete paragraph 4-1.3.

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SUBSTANTIATION: This paragraph was inserted original ly as a result of some testing that was done with fire-retardant cartons. I t is entirely possible in the future to develop a can and valve system that indeed wil l change the level of the product. Section 4-1.3 as written would preempt any packaging solution. As well, advances in corrugated technologies would be nul l i f ied by this section. ~OMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: The Committee needs more information on tests conducted, and on potential alternate systems, before i t can consider deleting 4-1.3.

{Log #208K) 30B- 134 - (4-1.3): Hold for Further Study SUBMITTER: David C. Tabar, The Sherwln-Willlams Company COMMENT ON PROPOSAL NO.: 30B-I RE~OMMENDATION: Delete paragraph 4-I.3. )UBSTANTIATION: This paragraph would eliminate incentives to improve the packaging system, and ultimately fire-safety. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-133 (Log #216).

{Log #271) 30B- 135 - (4-1.3): Accept ~UBMITT~R: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 4-1.3 to read:

4-1.3 Fire retardant cartons shall not be considered an acceptable alternative to the protection requirements of this chapter. S_U_BSTANTI~: CSMA sponsored a small-scale f i re test with aerosols in fire-retardant outer cartons which demonstrated only limited benefits. Other types of fire-retardant or fire-proof packaging should not be automatically precluded by this standard. COMMITTEE ACTION: Accept.

(Log #130) 30B- 136 - (4-1.4): Accept in Part SUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Storage of Level 2 and Level 3 aerosol products shall not be permitted in basement areas.

Recommend; "Storage of Level 2 and Level 3 aerosol products shall not be permitted in basement areas of warehouses. For storage in mercantile occupancies ( i .e. backstock storage areas) see Chapter 5." SUBSTANTIATION: See paragraphs 5-1.3 and 5-2. COMMITTEE ACTION: Accept in Part.

Delete second sentence. Add exception to read: "As provided for in Section 4-3."

COMMITTEE STATEMENT: The Committee does not agree with the exception for mercantile occupancies. Also, Chapter 5 controls storage in mercantile occupancies, not Chapter 4.

(Log #63) 30B- 137 - (4-1.6): Accept SUBMITTER: David R. Church/David J. Cox, Amway Corp. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

"Encapsulated storage of Level 2 and Level 3 aerosol products shall not be permitted. Stretch-wrap of aerosol containers in lieu of cartons shall not be permitted. However, stretch-wrapping of pallet loads of aerosol products is permitted." SUBSTANTIATI_OJ~: Rewrite 4-I.6 to exempt Level I aerosols from encapsulation restriction. Encapsulation of Class I I I commodities is permitted in NFPA 231C. Clarification as to pallet load stretch wrapping is needed.

COMMITTEE ACTION: Accept. But change "pal let loads" to "cartons."

COMMITTEE STATEMENT: The change is editor ial .

(Log #131) 30B- 138 - (4-1.6): Accept in Principle ~U_~J!I~[!_E_~: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

Encapsulated storage of cartons of aerosol products shall not be permitted. Stretch-wrap of aerosol products in lieu of cartons shall not be permitted.

Recommend: "Encapsulated storage of cartons (plastic wrap on sides and top of pallet loads) of aerosol products shall not be permitted. Plastic wrap on sides only is permitted. Stretch wrapping of trays of Level 2 and Level 3 aerosol is not permitted." SUBSTANTIATION: Proposed language is too ambiguous. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-137 (Log #63). COMMITTEE STATEMENT: See Comment 30B-137 (Log #63).

(Log #204) 30B- 139 - (4-I.6): Accept in Principle ~ : Stephen M. Stuart, Johnson & Higgins COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Reword this paragraph to read:

"Encapsulated storage of cartons of Level 2 and 3 aerosol products shall not be permitted. Stretch-wrap of Level 2 and 3 aerosol products in lleu of cartons shall not be permitted. I t is permissible to encapsulate cartons of Level I aerosols and to stretch-wrap Level I aerosols in lleu of cartons. I t is also permissible to stretch wrap cartons of any aerosol product so long as the top of the pallet load is not covered by the wrap." SUBSTANTIATION: Level I aerosols in cartons are equivalent to Class I I I commodities. These can be encapsulated or stretch-wrapped as long as sprinkler densities are adjusted upwards per NFPA 231C. Since stretch-wrapping does not have the same hazard as encapsulation, this should he allowed for cartons of Level Z and 3 aerosols. COMMITTEE ACTION: Accept in Principle.


(Log #217) 30B- 140 - (4-1.6): Accept in Principle ~U_~J~LT.IF, J~: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

4-I.6 Encapsulted storage of cartons of aerosol products shall not be permtted. Stretch-wrap of aerosol products in lieu of cartons shall not be permitted. Cartons to be used for display purposes are exempt from this code. SUBSTANTIATION: The wording in this section originally would have denied the use of plastic wrapping of aerosol units for display purposes. This does not pose the same threat for f i re suppression that encapsulation does in the warehouse setting. Thus the provision for exemption under retail conditions is necessary. COMMITTEE ACTIOn: Accept in Principle.


(Log #272) 30B- 141 - (4-1.6): Accept in Principle ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 4-I.6 to read:

"Encapsulated storage of cartons (plastic wrap on sides and top of pallet loads) of Level 2 and 3 aerosol products shall not be permitted. In harmony with U.S. Department of Transportation regulations, the plastic stretch-wrap of trays of aerosol products, in lieu of outer shipping cartons, shall not be permitted. However, stretch-wrapping of pallet loads of aerosol products around four sides is permitted."

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SUBSTANTIATION: Clarif ication of current requirement, and exemption of Level 1 aerosols from the encapsulation restrictions. COMMITTEE ACTION: Accept in Principle.


(Log #273) 308- 142 - (4-1.7): Accept in Principle ~UBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 308-1 RECOMMENDATION: Modify paragraph to read:

4-I.7 Level 2 and 3 aerosol proucts in containers designed to vent at pressures signif icantly below the pressure at which a standard aerosol container would rupture shall not be stored. SUBSTANTIATION: The current language unfairly and unreasonably affects only a single type of pressure rel ief system that happened to be the subject of a small-scale f i re test. What was learned in that test and other aerosol f i re tests sponsored by CSMA was not that rim venting presents an adverse condition, but that sufficiently earl ier venting of flammable aerosol contents into the f i re can result in more rapid f i re growth, and a f i re that may be more d i f f i cu l t to control The key factor is early and nonreversible venting of contents. Logically, this adverse effect would be expected to occur with other types of venting systems as well, i f they resulted in flammable contents being added to the f i re signif icantly earlier. On the othr hand, a rim-vent-release system installed on a stronger aerosol container (2P or 2Q) which is designed to vent at a pressure equal to or greater than the rupture pressure of a standard can would not logically be expected to present a higher f i re challenge than a non-rim-vent-release standard can, and indeed would most l ikely provide some benefit. The key factor here is the lowering of the pressure at which the contents begin to add fuel to the f i re, not any particular technology which may achieve this effect. COMMITTEE ACTION: Accept in Principle.

Revise 4-1.7 to read: "Level 2 and Level 3 aerosol products whose

containers are designed to vent at pressures less than 210 psig shall not be stored." COMMITTEE STATEMENT: The current language unfairly and unreasonably affects only a single type of pressure-relief system that happened to be the subject of a small-scale f i re test. What was learned in this and certain subsequent f i re tests is that sufficiently earlier than normal venting of Flammable aerosol contents into a f i re wi l l result in more rapid f i re growth, and a f i re that is more d i f f i cu l t to control. Nonrupturing venting of the contents is incidental. All forms of devices used to cause premature venting of flammable contents wi l l cause similar results and therefore must be considered.

By the use of various venting systems installed in cans having the construction features ut i l ized in "DOT Specification 2Q aerosol cans, designs can be used that prevent the venting of contents at pressures below 210 psig, while s t i l l permitting the device to reliably prevent rupture of the aerosol dispenser. The minimum venting pressure of 210 psig is equivalent to the regulatory minimum burst pressure of "nonspecification" aerosol cans, and wi l l thus prevent premature venting of such pressure-relieving dispensers compared to the "nonspeclfication" aerosol can without such venting device.

NOTES: The DOT "nonspecification" (nonventing) aerosol can accounts for about 85 + % of all aerosol cans sold in the USA.

The "DOT Specification 20" can (nonventing) is regulated not to burst below 270 psig.

(Log #ll8) 30B- 143 - (4-1.7): Reject ~VBMITTER: C. W. Schild, American National Can Company ~MENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: We suggest and urge that section 4-I.7 be deleted from the proposed NFPA 30B regulation.

SUBSTANTIATION: This section singles out one container style from the various pressure vent style containers available and prevents any storage of levels 2 and 3 aerosol products in the rim vent release (RVR) container. We suspect that these other container styles were not included in the proposed code revision simply because they were not included in earlier f ire safety testing. Further no data is available with RVR cans with levels 2 or 3 aerosol products when f i re tested under adequate sprinkler protection. The RVR feature was designed for general consumer safety. I t is recognized by Assn. of American Railroads, Bureau of Explosives as an acceptable safety rel ief device for l lqui f led petroleum gas.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Action on Comment 30B-142 (Log #273).

(Log #]20) 308- 144 - (4-1.8): Reject SUBMITTER: Steve Emert, Malone & Hyde COMMENT ON PROPOSAL NO.: 308-1 RECOMMENDATION: Delete complete paragraph:

4 - ] , 8 Noncombustible d ra f t curtains shal l be installed as follows:

(a) At the interface between the ESFR sprinkler design area and the standard spray sprinkler design area; and

(b) At the interface between the design areas ut i l iz ing ordinary sprinklers and high-temperature sprinklers.

The draft curtains shall extend for a depth of 6 f t (1.8 m) or 20 percent of the building height, whichever is greater. SUBSTANTIATION: Curtain boards are only discussed in NFPA 204M (Smoke and Heat Venting). The standard was

~ ublished as a guide for the instal lat in of smoke and eat venting systems. Much of the material is

cont rovers ia l . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that the need for draft curtains is just i f ied. They constitute the interface between the two different sprinkler system designs.

(Log #170) 30B- 145 - (4-1.8): Accept in Principle ~UBMITTER: Bala Nathan, Diversified CPC International COMMENT ON PROPOSAL NO.: 30B-1 RECOMHENDATION: Revised text:

I "The draft curtains shall extend for a depth of 6 f t or 25 percent of the ceiling height whichever is smaller." SUBSTANTIATION: This would avoid having long draft curtains in warehouses and storage areas with low ceiling. COMMITTEE ACTION: Accept in Principle.

I Use the submitter's wording, but change "25 percent" to "20 percent." COHMITTEE STATEMEN!: The Committee feels that 20 percent is a more reasonable figure.

(Log #132) 30B- 146 - ( 4 - ] . 8 ) : Accept in Principle SVBMITTER: Dale Cook, Peterson/Puri tan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMHENDATION: Last paragraph - The draft curtains shall extend for a depth of six f t (1.8 m) or 20 percent of the building height, whichever is greater.

Recommend: The draft curtains shall extend for a depth of 20 percent of the building height. ~UBSTANTIATION: In low-ceiling warehouses, draft curtains extending for a depth of six f t (1.8 m) would" hang relatively close to the floor level and interfere with stock transfer operations. There is no safety purpose to be served by long draft curtains in such warehouses.

99


COMMITTEE STATEMENT: See Comment 30B-145 (Log #170).

(Log #274) 30B- 147 - (4-1.8): Accept in Principle ~MITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDAT~: Modify the final sentence of paragraph 4-I.8 to read:

"The draft curtains shall extend for a depth of at ]east 3 f t (0.9 m)." SUBSTANTIATION: In low-ceiling warehouses, draft curtains extendin~ for a depth of six f t (I.8 m) would hang relatively close to the floor level and interfere with stock transfer operations. There is no safety purpose to be served by draft curtains longer than 3 f t in such warehouses. Three f t would be deep enough to prevent a f i re in one area from activating a lower-temperature-rated or quicker-response sprinkler in the adjoining area. COMMITTEE ACTION: Accept in Principle.


(Log #I01) 30B- 148 - (4-I.8(b)): Reject ~BMITTER: Greg Heying, Super Valu Stores, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised draft:

"The draft curtains should extend for a depth of 6 f t or 20 percent of the building height, whichever is greater." S U ~ I O Q ~ : This wording gives the jurisdiction having authority freedom to modify the requirement to meet i ts intent: - - - concern for premature activation of neighboring sprinkler systems with lower link temperatures or different R.T,I. The code as written goes beyond what is necessary to contain heat while significantly l imit ing operational freedom in a warehousing/distribution fac i l i t y . A change in wording from shall to should provides some degree of f l e x i b i l i t y in code application for these situations. COMMITTEE ACTION: Reject. ~OMMITTEE STATEMENT: Advisory statements cannot be in the body of a code. Also, the Committee feels that this should be mandatory.

(Log #133) 30B- 149 - (4-2.5): Mold for Further Study ~LUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised text.

Solid shelving that is installed in racks that contain Level 3 aerosol products shall be protected in accordance with Table 4-6. Solid shelving that is installed in racks that contain Level 2 aerosol products and that are protected by standard sprinklers shall also be protected in accordance with Table 4-6. Solid shelving shall not be installed in racks that are protected by a sprinkler system that used ESFR heads.

Recommend: In the second sentence, change from" "in accordance with Table 4-6." to: " . . . in accordance with Table 4-5."

SUBSTANTIATION: The standard does not adequately recognize the reduced hazard of Level 2 aerosols. I f flues are maintained, additional face sprinklers or higher ceiling density are of questionable value. COMMITTEE ACTION: Hold for Further Study. CQMMITTEE~!A_TEME~: The Committee feels that this change can only be just i f ied based on test results.

(Log #I02) 30B- 150 - (4-2.5): Hold for Further Study ~ : Greg Meying, Super Valu Stores, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-2.5 Solid shelving installed in racks containing Level I I and I I I aerosols does not affect the recommended protection cr i ter ia included in this standard except as specifically identified for ceiling only protection systems. SUBSTANTIATION: Solid shelving in a rack storage arrangement actually increases response time of the in-rack sprinklers and in so doing increases the effectiveness of the system. As such, a requirement for additional lines of sprinklers is excessive. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-149 (Log #133).

(Log #205) 30B- I51 - (4-2.5): Hold for Further Study SUBMITTER: Stephen M. Stuart, Johnson & Higgins COMMENT ON PROPOSAL NO.: 30B-I RECOMMENpATION: Modify this paragraph to read:

"Solid shelving shall not be installed in racks that are protected by a ceiling sprinkler system that ut i l izes ESFR sprinklers. Racks provided with solid shelving that contain Level 2 and 3 aerosols shall be protected by standard spray sprinklers in accordance with Tables 4-5 and 4-6 respectively."

Add qualifying notes to the tables for exact details. ~UBSTANTIATION: The standard does not offer protection for solid shelves, but for aerosols. Tables 4-5 and 4-6 ask for sprinkers of some sort in every t ier of the racks. Specific recommendations for solid shelving can easily be included in the tables. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-149 (Log #133).

(Log #276) 30B- 152 - (4-2.5): Hold for Further Study SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 4-2.5 to read:

"Solid shelving that is installed in racks that contain Level 3 aerosol products shall be protected in accordance with Table 4-6. Solid shelving that is installed in racks that contain Lvel 2 aerosol products and that are protected by standard sprinklers shall also be protected in accordance with Table 4-5. Solid shelving shall not be installed in racks that are protected by a sprinkler system that uses ESFR heads unless in-rack sprinklers are also provided." SUBSTANTIATION: Where solid shelves are used for Level 2 aerosols, the standard now requires the same protection as for Level 3 aerosols. Where flues are maintained, i t is very questionable i f the additional face sprinklers or increased ceiling density is necessary. Also, i t is the potential lack of in-rack sprinklers that is of concern regarding solid shelving in racks, not the use of ESFR sprinklers per se. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-149 (Log #]33).

(Log #2) 30B- 153 - (4-3): Accept SUBMITTER: Gerald M. Brown, General Motors Corp. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Section 4-3 should reference 4-I.5 regarding level 1 storage. Also, is i t the Committee's intent to allow the limited level 2 and level 3 storage in unsprinklered areas? SUBSTANTIATION: The comment is intended to clari fy the section, which currently does not address Level 1 storage. In the absence of any description, unlimited storage could be assumed. The section also does not specify any f i re protection requirements, again leading to the assumption none is required.

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COMMITTEE ACTION: Accept. Add the words "Level 2 and Level 3" before the words

"aerosol products in the following paragraphs: 4-1.6, 4-3.1, 4-3.2, 4-4.1, 4-4.2, 4-4.3, 4-4.3(a), 4-5.1, 4-5.2.1, 4-5.2.~I.I(a) and (b), 4-5.2.1.2(a), 4-5.2.4, 4-5.2.5, 4-6.1, 4-8.3, 4-8.3.1(a) and (b), 4-8.3.2(a), 4-9.1 and 4-9.2

(Log #242) 30B- 154 - (4-3.1): Reject ~UBMITTER: C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-1 ~ : Revised text:

"Storage of aerosol products in a single f i re area in occupancies other than warehouses, such as assembly, business, educational, industrial and inst i tut ional occupancies, excepting work in process in aerosol manufacturing factories, shall be permitted up to the following quantit ies:" SUBSTANTIATION: Aerosol manufacturing factories of necessity must complete the pal let iz ing of finished goods from their production lines prior to committing them to storage. Aerosol manufacturing fac i l i t i es have special expertise to handle such work in process operations. I personally have been involved with them since 1949 and nave never had a problem with work in process at the end of the l ine. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This was addressed by the action taken on Comment 30B-109 (Log #266).

(Log #304) 30B- 155 - (4-3.1): Accept SUBMITTER: Byron L. Briese, Oak Ridge, TN COMMENT ON PROPOSAL NO.: 30B-1

J RECOMMENDATION After " . . . other than warehouses" in the section add "or mercantile occupancies." ~UBSTANTIATION: Chapter 5 contains storage requirements for mercantile occupancies. COMMITTE{ ACTIOn: Accept.

(Log #196) 30B- 156 - (4-3.1(a) and (b)): Reject SUBMITTER: Robert Malanga/William Webb, Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete subparts (a) and (b) and reword the f i r s t sentence to end with the following wording:

" . . . shall be permitted up to a one-day's supply." S_Bt~B~STANTIATI__OJ~:: The storage of aerosol containers in nenstorage, nonmercantile occupancies is not just i f ied other than that required for normal operations. A 500 - lO00 ]b supply in such areas that are not protected or monitored as an aerosol storage area can overtax the capability of existing f i re protection systems, i f any. ~ I T T E E ACTION: Reject. COMMITTEE STATEMENT: The submitter appears to be confusing storage of aerosol products with usage.

(Log #98) 30B- 157 - (4-,~.I): Reject ~ : William P. Thomas, Kemper National P & C Companies COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Eliminate paragraph 4-4.1 and renumber subsequent paragraphs appropriately. SUBSTANTIATION: Paragraph 4-4.1 allows 2 I/2 pal let loads of level 2 aerosols in a warehouse that could be well protected without the aerosols. One pal let load of level 3 in one test opened 36-286°F rated sprinklers with a constant 0.30 density. I f the present wording is allowed, many warehouses wi l l no longer be properly protected. How could we allow this knowing i t could circumvent the protection? COMMITTEE AqTIO__N: Reject. COMMITTEE STATEMENT: The Committee feels that i t must recognize the rea l i ty of small quantity storage of aerosols in fac i l i t i es that are unprotected.

(Log #74) 30B- 158 - (4-4.1(a) and (b)): Reject ~ : Ronald W. Vath, The Mermen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: a) A maximum of 7500 Ibs (3405kg) net weight of Level 2 aerosol products or

b) A maximum of 3000 lbs (1362 kg) net weight of Level 3 aerosol products.

In no case shall the combined net weight of Level 2 and Level 3 aerosol products exceed 7500 lbs (3405 kg). SUBSTANTIATION: In l ight of today's high tech f i re fighting apparatus and immensely improved training cr i te r ia and state mandated training programs, the response capabil ity is thought to be adequate to protect and mitigate f i re situations for larger amounts than currently appear in the proposal. COMMITTEE ACTION: Rej'ect. COMMITTEE STATEMENT: The Committee feels that the quantities proposed are too great for an unprotected fac i l i t y . See also Comment 30B-157 (Log #98).

(Log #277) 30B- 159 - (4-4.1): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association ~OMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 4-4.1 to read:

4-4.1 Solid pi le, palletized, or rack storage of aerosol products shall be permitted in a general purpose warehouse that is unsprinklered or signif icant ly underprotected for Level 2 and 3 aerosol storage, as seen in Tables 4-I and 4-2, up to the following quantities:

(a) A maximum of 2500 lbs (1135 kg) net weight of Level 2 aerosol product in any 5,000 square f t area.

(b) A maximum of lO00 Ibs (454 kg) net weight of LeveI 3 aerosol products in any 5,000 square f t area.

In no case shall the combined net weight of Level 2 and Level 3 aerosol products exceed 2500 Ibs (1135 kg) in any 5,000 square f t area. SUBSTANTIATION: This modification presents a more reasonable l imi tat ion aimed at severely restr ict ing the amount of aerosols allowable in essentially underprotected areas of a general purpose warehouse. Warehouses with significant levels of automatic sprinkler protection should be addressed separately (see 4-4.2). COMMITTEE ACTION: Reject. ~OMM!TTEE STATEMENT: Same reason as for Comment 30B-158 (Log #74).

(Log #182) 30B- 160 - (4-4.2): Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph to read:

4-4.2 Subject to the approval of jur isdict ion, solid pi le, palletized storage or rack storage of Level 2 and Level 3 aerosol products shall be permitted in general purpose warehouses that are protected throughout by an automatic sprinkler system up to maximum of 50,000 lbs per any lO,O00 square foot area. ~UBSTANTIATION: This is a more reasonable approach to l imit ing concentrations of Level 2 and Level 3 aerosols in general purposes warehouse which are protected by automatic sprinkler systems. Also, this provides for the movement of truckloads of aerosols which is the common quantity shipped. The results of a small survey of Sprayon Products customers is attached. This survey shows that the majority of customers used general warehouses and that 20,000 plus pounds of aerosols are stored in each. To l im i t the quantity of aerosol products to 12,000 would cause mass shipping confusion and economic loss.


COMMITTEE ACTION: Reject. COMMITTEE ~TATEMENT: This would substantially increase the quantity of aerosols beyond what the Committee intended.

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(Log #208L) 30B- 161 - (4-4.2): Reject SQBMITTER: David C. Tabar, The Sberwln-Williams Company COMMENT ON PROPOSAL NO-: 3DB-I RECOMMENDATION: Revise to read:

4-4.2 Subject to the approval of the authority having jur isd ic t ion, solid p i le, pal let ized storage or rack storage of Level 2 and 3 aerosol products shall be permitted in general purpose warehouses that are protected throughout by an automatic sprinkler system as provided for in Tables 4-I through 4-6, subject to the following:

(a) The sprinkler system over the aerosol storage area and for a distance of 20 f t (6 m) beyond shall be designed in accordance with Tables 4-I and 4-2, or (b) storage of flammable and combustible l iquids in containers other than metal or in containers of one gallon capacity or greater shall be separated from the aerosol product storage area by at least 25 f t (8 m). ~UBSTANTIATION: This better represents the results of f i re research on aerosol products. ~OMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The proposed changes would require a complete revision of the rest of the chapter. This is not jus t i f i ed at this time.

(Log #218) 30B- 162 - (4-4.2): Reject ~ I T T E R : Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 3DB-I RECOMMENDATION: Revise paragraph to read:

4-4.2 Subject to the approval of the authority having jur isd ic t ion, solid p i le , pal let lzed storage or rack storage of level 2 and 3 aerosol products shall be permitted in general purpose warehouses that are protected throughout by an automatic sprinkler system up to a maximum height allowed for that sprinkler system. SUBSTANTIATION: This change acknowledges the protection of sprinkler systems proven by large scale testing. The attached compilation of tests are provided in support of this statement. This testing has shown that storage of level 2 and 3 aerosol products in accordance with Tables 4-I through 4-6 can be protected.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same reason as for Comment 30B-161 (Log #208L).

(Log #278) 30B- 163 - (4-4.2): Hold for Further Study SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 4-4.2 to read as follows:

4-4.2 Solid p i le or pal let ized storage of aerosol products shall be permitted in a general purpose warehouse that is protected throughout by an automatic sprinkler system that substantially approaches or is equivalent to the protection in Tables 4-I and 4-2 up to a maximum total quantity of 12,000 Ibs (5450 kg) combined net weight of Level 2 and Level 3 aerosol products in any 5,000 sg f t area subject to the following:

(a) Storage of flammable and combustible l iquids in containers other than metal or in containers of greater than gallon capacity shall be separated from any aerosol product storage area by at least 25 f t (8 m). Such storage shall also meet the requirements of 4-5.6 of NFPA 30, Flammable and Combustible Liquids Code. S UBSTANTIATIJ~N: This modification takes a more reasonable approach to l imi t ing the concentrations of Level 2 and 3 aerosols in general purpose warehouses which have substantive automatic sprinkler systems wKich nevertheless fa l l s l igh t ly short of those shown to be effective for highly concentrated aerosol storgs, or otherwise varies from the exact protection requirements in the Tables 4-I and 4-2.

COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: This proposes a new concept that has not had public review.

(Log #221) 308- 164 - (4-4.2(a)): Hold for Further Study SUBMITTER: Joseph Sessa, Lehn & Fink Products Group ~MMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: Revise paragraph to read:

(a) the sprinkler system over the aerosol storage area and for a distance of 20 f t (6 m) beyond shall be designed in accordance with Tables 4-I through 4-6. SUBSTANTIATION: This change is made to reference protection of rack storage along with l is t ings of protection for pal let and solid pi le storage. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 308-163 (Log #278).

(Log #6) 308- 165 - (4-4.2(b)): Accept SUBMITTER: Edward Hildebrandt, Vil lage of Morton Grove ~OMMENT ON PROPOSAL NO.: 3OB-I RECOMMENDATION: Revised text:

(b) Storage of flammable and combustible l iquids shall be separated from the aerosol products storage area by at least 25 f t (8 m). $VB~TANTIATION: In my opinion, i t is beyond the scope of proposed 30B to specify the storage configuration for flammable and combustible l iquid containers. I t is assumed that flammable l iquids wi l l be stored in compliance with provisions of NFPA 30. The revised paragraph reflects the needed separation of products. COMMITTEE ACTION: Accept.

(Log #12) 308- 166 - (4-4.2(b)): Accept in Principle ~ : Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 3OB-I RECOMMENDATION: Reword to:

"The aerosol product storage area shall be separated from storage of flammable and combustible l iquids in containers other than metal, or in containers of one gallon capacity or greater, by at least 25 f t (8 m)." SUBSTANTIATION: I t is outside the scope of this code to regulate storage of flammable and combustible l iquids. COMMITTEE ACTION: Accept in Principle.

By means of Action on Comment 308-165 (Log #6). COMMITTEE STATEMENT: See Comment 30B-165 (Log #6).

(Log #134) 30B- 167 - (4-4.2(b) and 4-4.3(b)): Accept in Principle SUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: 4-4.2(b) and 4-4.3(b). Storage of flammable and combustible l iquids in containers other than metal or in containers of one gallon capacity or greater shall be separated from the aerosol product storage area by at least 25 f t (7.6 m). Such storage shall also meet the requirements of 4-5.6 of NFPA 30, Flammable and Combustible Liquids Code.

Recommend: Storage of flammable and combustible l iquids in containers other than metal or in containers of over one gallon capacity shall be separated. SUBSTANTIATION: The one gallon container is a standard size. The proposed code would result in the creation of a new container size to defeat the restr ict ion.

NOTE: I t may be appropriate to state "U.S. Gallon" instead of "gal lon," to prevent confusion with the English and Canadian Imperial Gallon, since the code wi l l be u t i l i zed in other countries. COMMITTEE ACTION: Accept in Principle.


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(Log #222) 30B- 168 - (4-4.2.1 (New)): Hold for Further Study S~B_MITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new paragraph to read:

4-4.2.1 In ter ior walls shall have a f i re resistance rating of one or two hours and shall be continuous from f loor to the underside of the roof deck. SUBSTANTIATION: This paragraph is added to include appropriate in ter ior wall protection for warehouses storing level 2 and 3 aerosols. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-163 (Log #278).

(Log #223) 30B- 169 - (4-4.2.1(a) (New)): Hold for Further Study SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new paragraph to read:

(a) For in ter ior walls having a f i re resistance rating of two hours, the aggregate f loor area ut i l ized for aerosol product storage shall not exceed 20 percent of the total f loor area of the warehouse, up to a maximum of 40,000 sq f t (3700 sq m). SUBSTANTIATION: This paragraph specifies allowable l imits when 2 hour in ter ior f i rewalls are in place. This is consistent with paragraph 4-5.2.1.I(a) cal l ing for 2-hour f i re walls i f 20% of the f loor space is ut i l ized for aerosol storage.


COMMITTEE ACTION: Hold for Further Study. COMMITTEE_STATEMEN!: Same as for Comment 30B-163 (Log #278).

(Log #224) 30B- 170 - (4-4.2.I(b)) : Hold for Further Study SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add new paragraph to read:

(b) For in ter ior walls having a f i re resistance rating of one hour, the aggregate f loor area ut i l ized for aerosol product storage shall not exceed lO percent of the total f loor area of the warehouse, up to a maximum of 20,000 sq f t (1850 sq m). SUBSTANTIATION: This paragraph specifies allowable l imits when l hour in ter ior f i rewalls are in place. This is consistent with paragraph 4-5.2.1.I(b) cal l ing for l-hour f i rewalls i f lO percent of the f loor space is u t i lz ied for' aerosol storage.


COMMITTEE AC~N: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-163 (Log #278).

adequately protected with the fixed sprinkler systems currently required in the 30B proposal. In requiring containment as an addition to fixed f i re protection systems, the standard is responding to a perceived hazard and the well published consequences of improperly protected aerosols, rather than documented testing and research. Containment places an increased cost on our f i re protection systems, impacts on our operational eff iciency, and adds no value. I f in fact, the purpose of the NFPA 30B standard is to provide minimum requirements (Section I-2), requiring containment in the standard goes well beyond the standard's stated purpose. We strongly urge the Committee to reevaluate i ts position on containment and modify the standard accordingly. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-180 (Log #280). COMFfITTEE STATEMENT: See Comment 30B-180 (Log #280).

(Log #183) 30B- 172 - (4-4.3): Hold for Further Study SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwi n-Will Jams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph text:

4-4.3 Subject to the approval of the authority having jur isd ic t ion, rack storage of aerosol products shall be permitted in a general purpose warehouse that is protected throughout by an automatic sprinkler system up to a maximum total quantity of 24,000 Ibs (I0,900 kg) combined net weight of Level 2 and Level 3 aerosol products, subject to the following:

(a) The sprinkler system in the aerosol products storage area shall be designed in accordance with Tables 4-3 through 4-6. The cei l ing sprinkler system design shall extend for 20 f t (6 m) beyond the aerosol products storage.

(b) Storage of flammable and combustible l iquids in containersother than metal or in containers of one-gallon capacity or greater, shall be separated from the aerosol product storage area by at least 25 f t (8 m) .ll SUBSTANTIATION: This subject covered in revised comments for 4-4.2.

4-4.2 Subject to the approval of the authority having jur isd ic t ion, solid, p i le , palletized storage of rack storage of level 2 and 3 aerosol products shall be permitted in general purpose warehouses that are protected throughout by an automatic sprinker system up to a maximum height allowed for that sprinkler system.

4-4.2(a) The sprinkler system over the aerosol storage area and for a distance of 20 f t (6 m) beyond shall be designed in accordance with Tables 4-I through 4-6. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-163 (Log #278).

(Log #103) 30B- 171 - (4-4.2, 4-4.3, 4-5.2.1, 4-5.2.1.1, 4-5.2.1.2): Accept in Principle SUBMITTER: Greg Heying, Super Value Stores, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: 4-4.2 (a) and (b) delete.

4-4.3 (a) and (b) delete. 4-5.2.1 (Revised): "Storage of aerosol products shall be in a segregated

area that is separated from the rest of the warehouse by a two hour rated f i re wall when the total aggregate storage in the warehouse exceeds 20 percent of the available storage space."

4-5.2.1.I(a) and (b) delete. 4-5.2.1.2 (a) through (f) delete.

SUBSTANTIATION: These comments are based on our review of the relevant f i re tests completed by FM and CSMA over the last 8-9 yars in addition to actual f i re experience at one of our d istr ibut ion f ac i l i t i e s . None of the data From the previously mentioned f i re tests or from our own f i re experience substantiate the need for fenced or walled containment where aerosols have been

(Log #279) 30B- 173 - (4-4.3): Hold for Further Study SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 4-4.3 to read as follows:

4-4.3 Rack storage of aerosol products shall be permitted in a general purpose warehouse that is protected throughout by an automatic sprinker system that substantially approaches or is equivalent to the protection in tables up to a maximum total quantity of 24,000 Ibs (10,900 kg) combined net weight of Level 2 and Level 3 aerosol products in any IO,O00 sq f t area. Subject to the following:

(a) Storage of flammable and combustible l iquids in containers other than metal or in containers of greater than one gallon capacity shall be separated from the aerosol product storage area by at least 25 f t (8 m). Such storage shall also meet the requirements of 4-5.6 of NFPA 30, Flammable and Combustible Liquids Code. SUBSTANTIATION: This modification takes a more reasonable approach to l imi t ing the concentrations of Level 2 and 3 aerosols in general purpose warehouses

103

which have substantive automatic sprinkler systems which nonetheless fa l l s l ight ly short of those shown to be effective for highly concentrated aerosol storages, or otherwise varies from the exact protection requirements of Tables 4-3, 4-4, 4-5 and 4-6. COMMITTEE ACTION: Hold for Further Study. COMMITTEE ..... STATEMENT: Same as for Comment 30B-163 (Log #278).

(Log #225) 30B- 174 - (4-4.3 through 4-4.3(b)): Hold for Further Study SUBMITTER: 3oseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraphs 4-4.3 through 4-4.3(b). SUBSTANTIATe: These paragraphs are deleted because of references made in revised paragraphs 4-4.2 and 4-4.2(a). Limitations are more appropriately set via test data. COMMITTEE ACTION: Hold For Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-163 (Log #27B).

COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-163 (Log #278).

(Log #14) 30B- 178 - (4-5.11: Accept in Principle ~ : Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete this paragraph, SUBSTANTIATION: I t is outside the scope of this code to specify requirements for those areas of a General Purpose Warehouse not used for storage of aerosol products, and that are inconsistent with the provisions of NFPA 231 and 231C, which are referenced. COMMITTEE ACTION: Accept in Principle.

Revise 4-5.1 to read: "Segregated storage of aerosol products in a general

purpose warehouse shall only be permitted in a warehouse that is protected throughout by an automatic sprinkler system that is designed in accordance with NFPA 231, Standard for General Storage, or NFPA 231C, Standard for Rack Storage of Materials, whichever is applicable." ~_OMMITTEE STATEMENT: This revision should eliminate the correlation problem.

(Log #99) 30B- 175 - (4-4.3(b)): Accept in Principle SUBHITTER: William P. Thomas, Kemper National P & C Companies COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph 4-4.3(b) to read:

"Storage of flammable and combustible liquids shall be separated from the aerosol product storage by at least 25 f t . " SUBSTANTIATION: We should use extreme caution when storing flammable liquids and aerosols in the same area. The present wording allows metal containers less than l gallon in size to be stored intermixed with aerosols. No tests with aerosols started by flammable liquids have been conducted that I know about. A Sherwin Williams loss had a mixture of aerosols and flammable liquids. Ignition by flammable liquids in other tests resulted in normally acceptable protection to be inadequate. COMMITTEE ACTION: Accept in Principle.

Revise 4-4.3(b1 to read: "Storage of aerosol products shall be separated from

storage of flammable and combustible liquids by at least 25 f t . " COMMITTEE STATEMENT: The revised wording is for editorial purposes.

(Log #13) 30B- 176 - (4-4.3(b)): Accept in Principle SUBMITTER: Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Same text as proposed for Comment 30B-166 (Log #121. SUBSTANTIATION: Same reason as for Comment 30B-166 (Log #12). COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B- 175 (Log #991. COMMITTEE STATEMENT: See Comment 30B-175 (Log #99).

(Log #226) 30B- 177 - (4-5 through 4-5.2.6(b1): Hold for Further Study SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete al l paragraphs 4-5 through 4-5.2.6(b). SUBSTANTIATION: These paragraphs have been deleted because of extensive large scale testing proving that storage of level 2 and 3 aerosols under protection and storage restrictions set forth in Tables 4-I through 4-6 can be protected without segregation. The documents attached represent over ten years of f i re testing and 2 mill ion dollars spent, to document this point and cannot be ignored.


(Log #1351 30B- 179 - (4-5.2): None Required ~ : Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO. : 30B-1 RECOMMENDATION: Revised text:

Solid pile, palletlzed, or rack storage of Level 2 and Level 3 aerosol products in excess of the maximum quantities given in subsection 4-4.2 shall be permitted in general purpose warehouses, subject to the requirements in 4-5.2.1 through 4-5.2.6.

Recommend: "Solid pile, palletized, or rack storage of Level 2 and Level 3 aerosol products in excess of the maximum quantities given in subsections 4-4.2 and 4-4.3 shall be p e r m i t t e d . . . " SUBSTANTIATION: Subsection 4-4.2 discusses only pile and palletized storages. Rack storages are covered in 4-4.3. COMMITTEE ACTION: None Required. COMMITTEE STATEMENT: The TCR version of NFPA 30B already states what the submitter recommends.

(Log #280) 30B- ]80 - (4 -5 .2 . i thru 4 - 5 . 2 . ] . 3 ) : Accept in Pr inc ip le ~ : O. Douglas Fratz, Chemical Specla l t ies Manufacturers Associat ion COMMENT ON PRQpOSAL NO.: 30B-1 R[COMMENDATION: Revise paragraph under 4-5.2.1 ~ read:

4-5.2.1 Storage of Level 2 and Level 3 aeroso l , products shall be in a segregated area separated ~Pom the rest of the warehouse by' interior walls, phai~ link fencing, or a separation area~ in accordance wi[h ~ the requirements of 4-5.2.1.1 thPdqgh 4-5.2.1.3. 1

4-5.2.1.1 Interior walls shaTl~ have a f i r~ ' resistance rating of one or twoho~s~--and shall be continuous from floor to the underside of the roof deck or ceiling.

(a) For interior walls having a f i re resistance rating of two hurs, the aggregate floor area util ized for aerosol product storage shall not exceed 25 percent of the total f loor area of the warehouse, up to a maximum of 40,000 sq f t (3,660 m).

(b) For interior walls having a f i re resistance rating of one hour, the aggregate floor area uti l ized for aerosol product storage shall not exceed 20 percent of the total f loor area of the w~rehouse, up to a maximum of 30,000 sq f t (2,745 me).

4-5.2.i.2 Chain link fencing shall extend from the floor to the underside of the roof deck or ceiling and shall meet the following requiremets:

(a) The aggregate area uti l ized for aerosol product storage shall not exceed 20 percent of the total area of the w~rehouse, up to a maximum of 20,000 sq f t ( l ,830 mL).

(b) Fencing shal l not be l i g h t e r than 9 gage steel wire woven in to a 2 in . diamond mesh.

(c) Storage of commodities whose hazard exceeds that of a Class I I I commodity, as defined by NFPA 23l, shall

104

be kept outside of the segregated area and at least 8 f t (2.4 m) from the fence, except as allowed by 4-5.2.6.

(d) The area of the design for the required sprinkler system shall extend I0 f t (3.0 m) beyond the segregated area.

(e) A minlmom of two personnel exits shall be provided.

4-5.2.1.3 A separation area shall extend outwards from the periphery of the segregated aerosol product storage area and shall meet the following requirements:

(a) The aggregate area used for aerosol product storage shall not exceed 15 percent of the total area of the w~rehouse, up to a maximum of 20,000 sq f t 91,830 m~).

(b) The l imits of the aerosol product storage area shall be clearly marked on the floor.

(c) The separation area shall be a minimum of 20 f t (6.0 m) and shall be maintained clear of all mterials that have a commodity classification greater than I I I , according to NFPA 231, Standard for Indoor General Storage. ~UBSTANTIATION: The separation area option was added to the draft code at a fa i r ly late stage, when i t was convenient to include i t as an "Exception" to the chain link fencing option. I t deserves ful l status, alongside the other three options. The phrase "When acceptable to the authority having Jurisdiction, . . ." was also deleted because i t unnecessarily denigrates the separation area option. In addition, 4-5.2.1.3(d) would allow Class I I I commodities to be stored in this barrier area.

The labyrintlh fencing option should be deleted as untenable to most warehouse l i f t - t ruck operators, due to twists and turns, consumption of excess warehouse area, and cost-equivalency to the automatic-closing gate alternatives. The reference to rocketing aerosol cans is unwarranted on the basis of numerous warehouse f i re tests funded by the industry in order to identify sprinkler specificatins and other parameters required for good f i re control Rocketing cans with the potential for "sate l l i te" ignitions do not occur, except possibly when a f i re involving aerosols is total ly out of control. Many dozens of aerosol f i re tests sponsored by CSMA have shown that no "flaming rockets" occur unless the aerosol f i re is total ly out of control, a situation that wil l not occur in fac i l i t ies with even marginally adequate sprinkler protection, and certainly not in fac i l i t ies protected by the requirements of this code.

These sections were also modified to increase the maximum size of the segregated areas according to selection of f i re wall, fencing or separation option. With adequate sprinkler protection, these limits are far more reasonable. COMMITTEE AqTI~: Accept in Principle.

Use the submitter's proposed wording, but make the following changes:

4-5.2.1.2(d): revise to read: " . . . the required ceiling sprlnker system shall

extend 20 f t . . ." Add 4-5.2.1.2(f) to read: "All openings in the fencing shall be provided with

self-closing or automatic-closing gates or shall be protected with a labyrinth arrangement."

4-5.2.1.3: Begin sentence with: "Subject to the approval of the authority having

jur isdict ion." 4-5.2.1.3(c): Change "20 f t " to "25 f t . " Add 4-5.2.1.3(d) to read the same as 4-5.2.1.2(d).

COMMITTEE STATEMENT: While the Committee essentially agrees with the thrust of this revision, i t feels that the additional changes proposed are necessary to maintain the desired level of safety.

(Log #18), (Log #19), Log #20), (Log #21), (Log #22), (Log #23) (Log #24), Log #25), (Log #26), (Log #27), (Log #28) (Log #29), Log #30), (Log #31), (Log #32), (Log #33) (Log #34), Log #35), (Log #36), (Log #39), (Log #40) (Log #42), Log #44), (Log #45), (Log #48), (Log #49) (Log //61), Log #62), (Log #64}, (Log #67), (Log #68) (Log #70), Log #72), (Log #83), (Log #87), (Log #117 (Log #121), (log #189), (Log #207), (Log #209) 30B- 181 - (4-5.2.1 thru 4-5.2.1.2): Reject ~ : Ralph Dudley, Ritter Food Corp. (Log #18)

Joe E. Timberlake I I I , Timberlake Grocery Company (Log #19)

Kenneth A. Kluener, Kluener Foods Co. (Log #20) Steve Gragg, Dot Foods, Inc. (Log #21) James A. Cremins, Carmine Foods, Inc. (Log #22) James Potter, Super Food Services, Inc. (Log #23) Ed Fox, The Grocers Supply Company, Inc. (Log #24) Warren Nedegaard, Gateway Foods, Inc. (Log #25) George Zammar, Wetterau Incorporated (Log #26) Chester A. Harkonen, Fairway Foods, Inc. (Log #27) Harold Harwood, Mid-Mountaln Foods, Inc. (Log #28) John F. Shephard, Jr., Martin Brothers Distributing,

Inc. (Log #29) Jim Roth, West Coast Grocery Co., (Log #30) Jerry Jones, West Coast Grocery Co. (Log #31) David Perry, Malone & Hyde Inc. (Log #32) Chuck Mil ler, Food Marketing Inst i tute (Log #33) John W. Ebert, Associated Grovers of New England,

Inc. (Log #34) Rick W. Hinton, Hogg Restaurant Service (Log #35) Herbert M. Burns, The Kroger Co. (Log #36) William D. Mills, Jr., Master Merchants, Inc. (Log

#39) Bruce Chesnut, Laurel Grocery Company, Inc. (Log #40) H. P. Gunderson, Super Food Services, ~nc. (Log #42) J. B. Sasser, Ira Higdon Grocery Company (Log #44) Ralph Matile, United Grocers, Medford Division (Log

#45) William I. Grif f is, T. O. Morris Company (Log #48) Blake P. Auchmoody, Pocahontas Food Group, Inc. (Log

#49) Glenn P. Landry, Doerle Food Services, Inc. (Log #61) Ron Dierks, Dierks Foods, Inc. (Log #62) Jim Murphy, Copps Distributing Company (Log #64) Andy Matt, General Merchandise Services (Log #67) Herbert L. Jaffe, S. E. Rykoff & Co. (Log #68) Scott Swaggerty, Scrivner of Pennsylvania (Log #70) Jerry Sullivan, S. Abraham & Sons, Inc. (Log #72) John E. Foley, Super Valu At]anta Retail Support

Center (Log #83) Michael S. Gieser, Nash Finch Company (Log #87) George Toloff, Foodland Distributors (Log #]2]) Robert J. Frick, Sysco Corporation, (Log #]89) Tom Loggia, Ralphs Grocery Company (Log #207)

COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Paragraphs 4-5.2.1, 4-5.2.1.I and 4-5.2.1.2 should be deleted. SUBSTANTIATION: This section requires containment of aerosol storage via walls or chain l ink fence, the type of containment to be determined by quantity of storage. I question the need for this containment as the sprinkler systems required by 30(b) have been proven adequate to control or suppress aerosol fires without the need for any containment. This has been demonstrated in the over $I,000,000 worth of testing sponsored by CSMA in addition to the f i re testing done by FM. In requiring containment, this standard is responding to a perceived need rather than the facts. The sprinkler systems required have been proven effective, the requirement for fencing is unnecessary, and excessive. The purpose of the NFPA 30(b) standard is to provide minimum requirement (Section ]-2). By requiring containment, the standard goes well beyond i ts stated purpose and in fact impinges on a business right to select or reject additional control measures based on their specific concerns. COMMITTEE ACTION: Reject. COMMITTEE ~TATEMENT: The Committee feels that some kind of separation is needed for certain amounts of aerosol product, the degree and kind of separation being dependent on the amount of storage and protection provided. See also changes to 4-5.2.1 et seq. adopted via Comment 30B-180 (Log #280).

(Log #43) 30B- 182 - (4-5.2.1 thru 4-5.2.1.2): Reject SUBMITTER: Steve Stratton, West Coast Grocery Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Paragraphs 4-5.2.1, 4-5.2.1.1 and 4-5.2.1.2 should be deleted. SUBSTANTIATION: The sections listed above require containment of aerosol storage within walls or chain link fencing. Fire testing done by Factory Mutual & CSMA has shown the sprinkler systems required by NFPA 30B to be adequate to control or suppress aerosol fires without containment. By requiring aerosol containment,

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NFPA 30B goes beyond i ts stated purpose of providing minimum requirements. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-181 (Leg #18).

(Log #65) 30B- 183 - (4-5.2.1 thru 4-5.2.1.2): Reject ~ : George A. Zucconi, Wetterau Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Paragraphs 4-5.2.1, 4-5.2.1.1 and 4-5.2.1.2 should be deleted. S U B S T A ~ : I t is not necessary for a l l f a c i l i t i e s to engage in the construction of a walled or fenced area for aerosol items. Suff icient, re l iable data supports the fact that apparent sprinkler systems alone are equally adequate in the suppression of aerosol f i res. The NFPA Is recognized as the nations leading f i re code expert and do not advocate that the insta l lat ion of a walled or fenced aerosol room wi l l provide greater protection. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-181 (Log #18).

(Log #71) 30B- IB4 - (4-5.2.1): Reject ~ : Patrick Maloney, West Coast Grocery Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: 4-5.2.1, 4-5.2.1.1, and 4-5.2.1.2 shoul be deleted. SUBSTANTIATION: The sections l is ted above require containment of aerosol storage within walls or chain l ink fencing. Fire testing done by Factory Mutual & CSMA has shown the sprinkler systems required by NFPA 30B to be adequate to control or suppress aerosol f i res without containment. By requiring aerosol containment, NFPA 30B goes beyond i ts stated purpose of providing minimum requirements. COMMITTEE ACTION: Reject. COMHITTEE STATEMENT Same as for Comment 30B-181 (Log #18).

(Log #75) 30B- 185- (4-5.2.I : Accept in Principle ~ : Ronald W. Vath, The Mennen Company COMMENT ON PROPOSAL NO, : 30B-1 RECOMMENDATION: Revised text:

4-5.2.1 Storage of aerosol products shall be in a segregated area that is separated from the rest of the warehouse by either in ter ior walls or chain l ink fencing or a separation area in accordance with the requirements of 4-5.2.1.I through 4-5.2.1.3. SUBSTANTIATION: Add an option for a separation area and a description paragraph (shown on sheet 5) 4-5.2.1.3.

The separat ion area opt ion was added to the d ra f t code at a fa i r l y late stage, when i t was convenient to include i t as an "Exception" to the chain l ink fencing option. I t deserves fu l l status, alongside the other three options. (Deletion of exception under 4-5.2.1({) shown on sheet 7. COMMITTEE ACTION: Accept in Principle.


_ _ I

(Log #136) 30B- 186 - (4-5.2.1): Accept in Principle ~UBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: 4-5.2.1 The code language can be summarized as follows:

For segregated aerosol product storages of over 12,000 pounds (5,455 kg) of Level 2 or 3 in pi les, or over 24,000 pounds (1,091 kg) of Level 2 or 3 in racks, in general purpose warehouses:

a. Provide a segregated area, with these options: Two-hour f i re wall. (Store up to 20 percent of area

or to 40,000 f t 2)

One-hour f i r e wa l l . (Store up to 10 percent of area or to 20,000 f t 2)

Chain-l~nk fencing. (Store up to 10 percent or to ZO,O00 f t ~)

Floor to cei l ing. Openings to have self-closing gates or labyrinth

arrangement. At least two personnel exits. Sprinkler protection to extend 20 f t (6,0 m) beyond

fencing. Buffer area outside fencing:

No flammable commodity within 8 f t (2.4 m) of fence No high risk commodity within 25 f t (7.6 m) of

fence. Area boundaries to be marked on f loor. *Defined as flammable or combustible l iquids in

nonmetallic containers, or in metal containers of one gallon or larger.

Recommend: 4-5.2.1 Storage of Level 2 and Level 3 aerosol

products shall be in a segregated area separated from the rest of the warehouse by in ter ior walls, chain l lnk fencing, or a separation area, in accordance with the requirements of 4-5.2.1.1 through 4-5.2.1.3.

4-5.2.1.1 In ter ior walls shall have a f i re resistance rating of one or two hours, and shall be continuous from f loor to the underside of the roof deck or cei l ing.

(a) For in ter ior walls having a f i re resistance rating of two hours, the aggregate f loor area ut i l ized for aerosol product storage shall not exceed ZO percent of the total f loor area of the warehouse, up to a maximum of 40,000 sq f t (3,660 m).

(b) For in ter ior walls having a f i re resistance rating of one hour, the aggregate f loor area ut i l ized for aerosol product storage shall not exceed 15 percent of the total f loor area of the w~rehouse, up to a maximum of 30,000 sq f t (2,745 me).

4-5.2.].2 Chain l ink fencing shall extend from the f loor to the underside of the roof deck or cei l ing and shall meet the following requirements:

(a) The aggregate area u t i l i zed for aerosol product storage shall not exceed 15 percent of the total area of the w~rehouse, up to a maximum of 20,000 sq f t (1,830 m~).

(b) Fencing shall not be l ighter than 9 gage steel wire woven into a 2 in. diamond mesh.

(c) Storage of commodities whose hazard exceeds that of a Class I I I commodity, as defined by NFPA 231, shall be kept outside of the segregated area and at least 8 f t (2.4 m) from the fence, except as allowed by 4-5.2.6.

(d) The area of the design for the required sprinkler system shall extend 10 f t (3.0 m) beyond the segregated area.

(e) All openings in the fencing shall be provided with self-closing or automatic-closing gates.

(f) A minimum of two personnel exits shall be provided.

4-5.2.1.3 A separation area shall extend outward from the periphery of the segregated aerosol product storage area and shall meet the following requirements:

(a) The aggregate area used for aerosol product storage shall not exceed 15 percent of the total area of the w~rehouse, up to a maximum of 20,000 sq f t (1,830 me). SUBSTANTIATION: The separation area option was added to the draft code at a f a i r l y late stage when i t was convenient to include i t as an "Exception to the chain l ink fencing option. I t deserves fu l l status, alongside the other three options.

For the separation area, the code says "Nhen acceptable to the authority having j u r i s d i c t i o n . . . " This was deleted because i t denigrates the separation area option, has obviousness, and has very limited practical u t i l i t y .

The labryinth fencing option was deleted as unacceptable to a number of warehouse l i f t - t r uck operators, due to twists and turns, consumption of excess warehouse area, and cost-equlvalency to the automatic-closing gate alternatives. Addit ional ly, the reference to rocketing aerosol cans was considered unwarranted on the basis of numerous warehouse f i re tests, funded by the industry in order to identi fy sprinkler specifications and other parameters required for good f i re control.

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A smoother and sl ight ly more l lberal transition of the size of the segregated area has been made, according to se lect ion of f i r e wa l l , fencing or separation opt ion. I t re f l ec ts an opinion that the Code Committee acted conservat ive ly in th is area. COMMITTEE ACTION: Accept in Pr inc ip le .

By means oF act ion on Comment 30B-180 (Log #280). COMMITTEE STATEMENT: See Comment 30B-180 (Log #280).

(Log #306) 30B- 187 - (4 -5 .2 .1) : Hold fo r Further Study 5UBMITTER: Sheridan Vogel, Johnson & Higgins COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add following wording to end of paragraph " . . except fencing or walls are not needed when ESFR sprlnkers are installed in accordance with this standard." SUBSTANTIATION: The testing done by Factory Mutual shows prompt control of f i re without aisle jumping. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: This proposes a new concept that the Committee has not studied, nor has i t had public review.

(Log #76) 3OB- 190 - (4-5.2.1.1): Accept in Principle SUBMITTER: Ronald W, Vath, The Mermen Company COMMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: Revised text:

4-5.2.1.1 Interior walls shall have a f i re resistance ra t ing of one or two hours and shal l be continuous from f l o o r to the underside of the roof deck.

(a) For i n t e r i o r wal ls having a f i r e resistance ra t ing of two hours, the aggregate f l o o r area u t i l i z e d fo r aerosol product storage shal l not exceed 40 percent of the to ta l f l o o r area of the warehouse, up to a maximum of 40,000 sq f t (3700 sq m).

(b) For i n t e r i o r wal ls having a f i r e resistance ra t ing of one hour, the aggregate f l o o r area u t i l i z e d for aerosol product storage shal l not exceed 20 percent of the to ta l f l o o r area of the warehouse, up to a maximum of 20,000 sq f t (1850 sq m). SUBSTANTIATION: Percentage of warehouses fo r aerosol product storage has been increased because i t is f e l t the recommended f i re protection requirements wil l protect these levels as well as the lower conservative levels shown in the proposal draft. COMMITTEE ACTION: Accept in Principle.


(Log #311) 30B- 188 - (4-5.2.11: Reject SUBMITTER: Arnold G. Dolejsl, Scrivner, Inc. ~OMMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: 4-5.2.1, 4-5.2.1.I and 4-5.2.1.2 should be deleted. SUBSTANTIATION: This section requires containment of aerosol storage via walls or chain l ink fence, the type of containment to be determined by quantity of storage. I question the need for this containment as the sprinkler systems required by 30B have been proven adequate to control or suppress aerosol fires without the need for any containment. This has been demonstrated in the over $I,000,000 worth of testing sponsored by CSMA in addition to the f i re testing done by FM. In requiring containment, this standard is responding to a perceived need rather than the facts. The sprinkler system required in 308 have been proven effective, the requirement for fencing is unnecessary, and excessive. The purpose of the NFPA 30B standard is to provide minimum requirements, (Section I-2). By requiring containment, the standard goes well beyond its stated purpose and in fact impinges on a business right to select or reject additional control measures based on their specific concerns. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-181 (Log #18).

(Log #312) 30B- 189 - (4-5.2.1 thr 4-5.2.1.2): Reject SUBMITTER: James D. Camp, McLane Company, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Paragraphs 4-5.2.1, 4-5.2.1.I and 4-5.2.1.2 should be deleted. SUBSTANTIATION: The f i re hazard associated with the storage of flammables, and aerosols have been clearly substantiated by testing by FH and CSMA. This section requires containment of aerosols storage via walls or chainlink fence. I question the need for this containment as the sprinkler systems required by 30(B) have been proven adequate to control or supress aerosol fires without the need for any containment. The sprinkler system required in 30(b) have been proven effective, the requirement for fencing is unnecessary, and excessive. The purpose of the NFPA (b) standard is to provide minimum requirements, (Section 1-21. By regaining containment, the standard goes well beyond i ts stated purpose and in fact impinges on a business right to select or reject additional control measures based on their specific concerns. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-181 (Log #181.

(Log #208M) 30B- lg l - ( 4 - 5 . 2 . 1 . I ( a ) ) : Accept in Pr inc ip le ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise to read:

(a) For i n t e r i o r wal ls having a f i r e resistance ra t ing of two hours, the aggregate f l o o r area u t i l i z e d fo r aerosol product storage shal l not exceed 40,000 sq f t . SUBSTANTIATION: The "40,000 sq f t " maximum represents the real r e s t r i c t i o n sought. The "20% serves only to penal ize the small warehouse operator who, perhaps only by the nature of his business, may have lesser square footage in the non-aerosol occupied por t ion, thus, he would be un fa i r l y penal ized. Keep i t simple. COMMITTEE ACTION: Accept in Pr inc ip le .

By means of act ion on Comment 308-180 (Log #280). COMMITTEE STATEMENT: See Comment 30B-180 (Log #280).

(Log #77) 308- 192 - (4-5.2.1.2): Accept in Principle SUBMITTER: Ronald W. Vath, The Mermen Company COMMENT ON pROPOSAL NO,: 308-I RECOMMENDATION: Revised text:

4-5.2.1.2 Chain l lnk fencing shall extend from the floor to the underside of the roof deck and shall meet the following requirements:

(a) The aggregate area uti l ized for aerosol product storage shall not exceed 20 percent of the total area of the warehouse, up to a maximum of 20,000 sq f t (1850 sq m).

(b) Fencing shal l not be l i g h t e r than 9 gage steel wire woven in to a 2 in . (5 cm) diamond mesh.

(c) Storage of commodities whose hazard exceeds that of a Class I I I commodity, as defined by NFPA 23l. Standard for General Storage, shal l be kept outside of the segregated area and at least 8 f t (2.4 m) from the fence. SUBSTANTIATI~N: Percentage of warehouses for aerosol product storage has been increased because i t is fe l t the recommended f i re protection requirements wil l protect those levels as well as the lower conservative levels shown in the proposed draft. COMMITTEE ACTION: Accept in Principle.

By means of act ion on Comment 308-180 (Log#280). COMMITTEE STATEMENT: See Comment 308-180 (Log #280).

(Log #197) 30B- 193 - (4-5.2.1.21: Reject SUBMITTER: Robert Malanga/Willlam Webb, Rolf 3ensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Reword the phrase to read:

107

"Chain l lnk fencing shall extend from the floor to the underside of the roof deck, covering al l openings, including roof vents and windows, and shall meet the following requirements." SUBSTANTIATION: The standard does not address the protection for rocketing cans that may pass through existing openings such as automatic roof vents and windows. These openings may operate or fa i l thereby providing another means of f i re extension. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: To adopt this proposal would constitute a potential l i f e safety hazard. The Committee considers i t to be unnecessary and not enforceable.

(Log #198) 30B- 194 - (4-5.2.1.2 Exception): Reject SUBMITTER: Robert Malanga/William Webb, Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete the second exception that allows a 20 f t separation in l ieu of fencing. SUBSTANTIATION: Actual f i re incidents have demonstrated that aerosol cans can rocket much further than 20 f t . The exception allows the removal of one of the most effective vehicles for aerosol f l re control. COMMITTE~ ACTION: Reject. COMMITTEE STATEMENT: See Comments 30B-181 (Log #18) and (Log #280).

(Log #100) 3OB- 195 - (4-5.2.1.2 Exception): Reject SUBMITTER: William P. Thomas, Kemper National P & C Companies. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete exception. SUBSTANTIATION: The exception under paragraph 4-5.2.1.2 allows aerosol storage (up to 20,000 sq f t ) in a general purpose warehouse to be segregated by separation only. This, in my opinion, is far too liberal and creates the need for very close supervision by the owners/managers as well as the AHJ. Even i f i t could be polciied, the chance for rocketing cans being blown into adjacent storage and staring multiple fires has increased tremendously. Why take the chance? COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-181 (Log #18).

(Log #78) 30B- 196 - (4-5.2.1.2(f) Exception): Accept in Principle ~_VBMITTER: Ronald W. Vath, The Mennen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete "Exception" under 4-5.2.1.2(f). SUBSTANTIATION: Exception to be replaced by language shown on sheet 4. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30B-180 (Log #280). COMMITTEE STATEMENT: See Comment 3OB-180 (Log #280).

(Log #79) 30B- 197 - (4-5.2.1.3 (New)): Accept in Principle SUBMITTER: Ronald W. Vath, The Mermen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: New text:

4-5.2.1.3 A separation area shall extend outwards from the periphery of the segregated aerosol product storage area and shall meet the following requirements:

(a) The aggregate area used for aerosol product storage shall not exceed 20 percent of the total area of the w~rehouse, up to a maximum of 20,000 sq f t (1,830 mL).

(b) The limits of the aerosol product storage area shall be clearly marked on the floor.

(c) The separation area shall be a minimum of 20 f t (6.0 m) and shall be maintained clear of al l materials that have a commodity classification of I I I or greater, according to NFPA 231.

SUBSTANTIATION: None submitted. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 3OB-IBO (Log #280). COMMITTEE STATEMENT: See Comment 30B-180 (Log #280).

(Log #206) 30B- 198 - (4-5.2.6): Reject ~ : Stephen M. Stuart, Johnson & Higgins COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Withdraw this paragraph and rethink the rationale for automatically closing off entrances to the aerosol storage area. SUBSTANTIATION: As presently worded, a f i re which operates sprinklers in the same warehouse as, but remote from, the aerosol storage area could automatically isolate the aerosol room and anyone in i t . This could create a l l f t safety exposure. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The provisions of the Life Safety Code address this issue, as does the action taken on Comment 30B-180 (Log #280).

(Log #8) 30B- 199 - (4-5.2.6 and 4-5.2.1.2(c) Exception): Accept ~ : Edward Hildebrandt, Village of Morton Grove COMMENT ON PROPOSAL NO.: 30B-I RECOt~dENDATION: Revise wording of 4-5.2.6 to read:

4-5.2.6 Storage of flammable and combustible liquids shall be separated from the segregated area by a minimum distance of 25 f t (8 m) or by the segregating wa11.

Delete subsections (a) and (b). Delete the exception to 4-5.2.1.2(c).

SUBSTANTIATION: In my opinion, i t is beyond the scope of proposed 30B to specif~ the type of flammable liquid storage allowed in generam purpose warehouses. The separation distance of aerosols to flammable or combustible liquids should be included here. COMMITTEE ACTION: Accept.

(Log #15) 30B- 200 - (4-5.2.6): Reject ~ : Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete this paragraph. SUBSTANTIATION: I t specifies requirements for the storage of flammable and combustible liquids in General Purpose Warehouses that are consistent wlth requirements in NFPA 30. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that the action on Comment 30B-199 (Log #8) addresses the concerns of the submitter.

(Log #92) 30B- 201 - (4-5.2.6(a)): Reject ~ : Michael J. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read as follows:

(a) Flammable and combustible liquids in metal containers of l gal (3.B L) or less capacity shall be permitted to be stored in the segregated area. SUBSTANTIATION: I believe the original intent of the Committee was to prohibit the storage of flammable or combustible liquids in containers other than metal adjacent to the aerosol products, and also to l imit the size of a potential pool f i re adjacent to the aerosol products. The proposed revision does not prohibit larger containers or nonmetal containers of flammable or combustible liquids in a general purpose warehouse, i t only restricts them from the segregated aerosol storage area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-200 (Log #15).

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(Log #137) 30B- 202 - (4-5.2.6(a)): ReJect ~ : Dale Cook, Peterson Puritan, Inc. COMMENT ON PROPOSAL NO,: 30B-1 RECOMMENDATION: Revised text:

(a) Flammable and combustible liquids in metal containers of less than I gallon capacity shall be permitted to be stored in the segregated area. Recommend: "Flammable and combustible liquids in

metal containers of l U.S. gallon 3.784 liters) or less shall be permitted to be stored in the segregated area. SUBSTANTIATION: See 4-4.2(b). COMMITTE~N: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-200 (Log #15).

(Log #281) 30B- 203 - (4-5.2.6(a)): Reject ~ : D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 4-5.2.6(a) to read:

"Flammable and combustible liquids in metal containers of one U.S. gallon (3.784 l i ters) or less shall be permitted to be stored in the segregated area." SUBSTANTIATION: The current l imit would simply encourage new packaging sizes to come within the one gallon l imitation. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-200 (Log #15).

(Log #93) 30B- 204 - (4-5.2.6(b)): Reject ~ : Michael 5. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read as follows:

(b) Flammable and combustible liquids in containers other than metal, or in containers of greater than one gallon capacity shall be separated from the segregated area by a minimum distance of 25 f t or by the segregating wall. SUBSTANTIATION: The proposed revision would allow one gallon metal containers of flammable and combustible liquids or containers of lesser capacity to be stored adjacent to aerosol products. This "greater than one gallon" is more appropriate based on typical packaging practices and is more in line with NFPA 30. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The action taken on Comment 30B-180 (Log #280) addresses this issue.

(Log #138) 30B- 205 - (4 -5 .2 .6 (b ) ) : Reject SUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

(b) Flammable and combustible liquids in containers other than metal or in containers of greater than I gallon capacity shall be separated from the segregated area by a minimum distance of 25 f t .

Recommend: "Flammable and combustible liquids in containers other than metal or in containers of greater than l U.S. gallon capacity (3.784 l i ters) shall be separated from the segregated area by a minimum distance of 20 f t (6.0 m)." SUBSTANTIATION: The 20 f t distance coincides with the width of the separation area specified elsewhere in the code. Assuming warehouse floors are relatively f la t , a large number of units would have to rupture or be spilled to spread across the 20 f t separation. The additional 5 f t provides only a marginal improvement. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-200 (Log #15).

(Log #282) 30B- 206 - (4-5.2.6(b)): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT QN PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 4-5.2.6(b) to read:

"Flammable and combustible liquids in containers other than metal or in containers of greater than 1 U.S. gallon capacity (3.784 l i ters) shall be separated from the segregated area by a minimum distance of 20 f t (6.0 m)." SUBSTANTIATION: According to the Industrial Fire Hazards Handbook, on page 722, Richard C. Stalker states, "In an unconfined sp i l l , each gallon of liquid wil l cover about 20 s q f t of level surface, for the l ighter and more volat i le l iquids." This equates to a puddle of about S f t in diameter for one gallon, 7.1 f t in diameter for a spillage of two gallons, 8.7 f t in diameter for three, and so on. Admittedly, there are other aspects, such as inclined floors and splashing, but the data suggests that a 20 f t distance is essentially as conservative as 25 f t . The 20 f t distance also coincides with the width of the separation area, now a part of 4-5.2.1.2 in the draft code. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-200 (Log #15).

(Log #199) 30B- 207 - (4-6.2.1 (New)): Reject SUBMITTER: Robert Malanga/William Webb, Rolf Jensen and Associates, Inc. COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Add the following section:

4-6.2.1 Water supply and control valves for automatic sprinkler systems protecting aerosol warehouses shall be located outside of the exterior walls of the building in a heated, 2-hour f i re resistant enclosure, readily accessible to the Fire Department. SUBSTANTIATION: In the event that a f i re overwhelms suppression efforts and the f i re department decides that the f i re should be allowed to burn the hazardous contents, the water supply(ies) should be readily accessible for shut-down to prevent/minimize

~ roundwater contamination. OffMITTEE ACTION: Reject

COMMITTEE STATEMENT: This issue is outside the scope of NFPA 30B. I t is in the scope of NFPA 13 and NFPA 24.

(Log #139) 30B- 208 - (4-6.3): Reject ~ : Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-6.3 Aerosol warehouses shall be separate, detached buildings or shall be separated from other occupancies by free-standing 4-hour f i re walls, with communicating openings protected on each side by automatic closing, listed 3-hour f i re (A) f i re doors.

Recommend: "Aerosol warehouses shall be separate, detached buildings, or shall be separated from other occupancies by f i re walls, with communicating openings protected by automatic closing, l isted f i re doors." SUBSTANTIATION: The requirement of a f i re door on each side is unnecessarily conservative and raises cost with marginal improvement in safety. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Dual f i re doors are needed to protect the opening in case of roof collapse.

(Log #184) 30B- 209 - (4-6.3) : Reject B~S_U_~T~: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

4-6.3 Aerosol warehouses shall be separate, detached buildings, or shall be separated from other occupancies by f i re walls, with communicating openings protected by automatic closing listed f i re doors, subject to the following:

109

(a) For walls having a f i re resistance rating of 2 hours, and having 2-hour (A) f i re doors at communicating openings, the aggregate f loor area ut i l ized for Level 2 and Level 3 aerosol product storage shall not be l imited. SUBSTANTIATION: The use of a f i re door on each side of an opening is too rest r ic t ive. There is l i t t l e precaution added by supplying excess f i re doors.

Paragraph (a) is inserted to keep consistency with 4-5.2.I.1(a). COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-208 (Log #139).

(Log #200) 30B- 210 - (4-6.3): Reject ~LLB_MITTER: Robert Malanga/William Webb, Rolf Jensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add the following wording:

" . . . by freestanding 4-hour f i re walls equipped with parapets, with communicating . . . " SUBSTANTIATION: The intense heat from a contained aersol container f i re wi l l undoubtly cause an unrated roof to fa i l and/or propagate f i re either across or under i t ( i .e . metal deck roof f i re ) . The requirement of a parapet can prevent a metal deck roof f i re from spreading beyond the f i re area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee feels that the submittal should spell out where parapets are needed.

(Log #284) 30B- 211 - (4-6.7): Accept in Part SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify paragraph 4-6.7 to read:

4-6.? Combustible commodities, excluding flammable or combustible l iquids in containers of capacity of greater than one U.S. gallon shall be permitted in aerosol warehouse provided the warehouse is protected in accordance with Tables 4-I through 4-6. SUBSTANTIATION: The current language which excludes "flammable or combustible l iquids in containers of one gallon capacity or greater" from aerosol storages would simply provide incentive for a 0.99 gallon size. Aerosol warehouses in this code have extremely effective automatic sprinkler protection, and one-gallon containers of flammable and combustible l iquids should be allowed in such f ac i l i t i e s . The current Code 30 indeed requires flammable aerosols to be stored with flammable l iquids, potent ia l ly with lesser sprinkler protection than required in this code. COMMITTEE ACTION: Accept in Part.

I Delete the phrase "excluding one U.S. Gallon." o o Q

COMMITTEE STATEMENT: The deletion eliminates a potential conf l ict with NFPA 30.

(Log #140) 30B- 212 - (4-6.7): Accept in Principle SUBMITTER: Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-6.7 Combustible commodities, excluding flammable or combustible l iquids in containers of one gallon capacity or greater, shall be permitted in an aerosol warehouse provided the warehouse is protected in accordance with Tables 4-I through 4-6.

Recommend: " . . . in containers of greater than one U.S. gallon capacity, s h a l l . . . " SUBSTANTIATION: See 4-4.2(b) and 4-4.3(b), rationale. COMMITTEE ACTION: Accept in Principle.


(Log #94) 30B- 213 - (4-6.7): Accept in Principle SUBMITTER: Michael 3. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read as follows:

4-6.7 Combustible commodities excluding flammable or combustible l iquids in containers of greater than one gallon capacity shall be permitted in an aerosol warehouse . . . (remainder of paragraph to remain as is) . SUBSTANTIATION: The proposed "greater than one gallon" restr ict ion is more appropriate based on typical packaging practices and is more in l ine with NFPA 30. COMMITTEE ACTION: Accept in Principle.


(Log #9) 30B- 214 - (4-7.1, 4-7.2): Accept SUBMITTER: Edward Hildebrandt, Vil lage of Morton Grove COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised text:

4-7.1 Storage of aerosol products shall be permitted in separate inside flammable l iquid storage rooms of 500 sq f t or less that meet the requirements of NFPA 30, Flammable and Combustible Liquids Code, up to a maximum quantity of 1000 pounds of Level 2 aerosol products or 500 pounds of Level 3 aerosol products or lO00 pounds of combined Level 2 and Level 3 aerosol products.

4-7.2 Storage of aerosol products shall be permitted in separate inside flammable l iquid storage rooms of greater than 500 sq f t that meet the requirements of NFPA 30, Flammable and Combustible Liquids Code, up to a maximum quantity of 2500 pounds of Level 2 aerosol products or lO00 pounds of Level 3 aerosol products or 2500 lbs of combined Level 2 and Level 3 aerosol products.

Exception: Storage of Level 2 and Level 3 aerosol products shall be permitted in separate inside storage rooms up to a maximum of 5000 Ibs, i f the separate inside storage room is protected by an automatic sprinkler system that is designed in accordance with Tables 4-I through 4-6, whichever is applicable. SUBSTANTIATION: The suggested revision reflects the small size of inside rooms as allowed in NFPA 30. I t also allows for aerosol storage within the restrictions of cut-off rooms and attached buildings as found in NFPA 30.

Reference to Appendix D in NFPA 30 should be deleted since i t speci f ical ly excludes application of the tables to aerosol storage. COMMITTEE ACTION: Accept.

(Log #285) 30B- 215 - (4-7.1): Accept in Principle SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify 4-7.1 to read as follows:

4-7.1 Storage of aerosol products shall be permitted in separate inside flammable l iquid storage rooms subject to the requirements of NFPA 30, Flammable and Combustible Liquids Code. SUBSTANTIATION: Flammable aerosols have been allowed in flammable l iquid storage under the requirements of NFPA Code 30 for many years with no hlstor ial evidence that such storages are unsafe. NFPA Code 30B is being developed to provide further alternatives for aerosol storage beyond requirements currently allowed under Code 30. No reasonable cause exists to l im i t the current Code 30 requirements. COMMITTEE ACTION: Accept in Principle.


(Log #4) 30B- 216 - (4-7.2) : Accept ~UBMITTER: O. M. Slye, Loss Control Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Delete wording "or with the requirements of Appendix B, whichever is more r e s t r i c t i v e " from the l as t sentence.

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SUBSTANTIATION: Reference to Appendix matrial conflicts with NFPA Manual of Style and is inappropriate since Appendix material is advisory and not part of the requirements of a standard. COMMITTEE ACTION: Accept.

By means of action on Comment 30B-214 (Log #g). COMMITTEE STATEMENT: See Comment 30B-214 (Log #9).

Warehouses that are not used for storage of aerosol products, as well as to require compliance with appendix material in NFPA 30 which specif ical ly states that i t is not a part of the requirements of the NFPA 30 Code. COMMITTEE ACTION: Accept.

(Log #16) 30B- 217 - (4-7.2): Accept ~ : Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Place a period after "applicable" and delete the remainder of the paragraph. SUBSTANTIATION: I t is in confl ict wlth NFPA 30 to require compliance with material in the appendix of NFPA 30 which spec i f i ca l l y states that i t is not a part of the requirements of the NFPA 30 Code. Also, the material referred to is spec i f i ca l l y marked "Flammable Aerosols Not Included." COMMITTEE ACTION: Accept.

By means of action on Comment 30B-214 (Log #9). COMMITTEE STATEMENT: See Comment 308-214 (Log #9).

(Log #243) 308- 218 - (4-7.2): Reject ~ : C. P. Clapp, Creative Products COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Deleted text:

"up to maximum quantity of 5000 Ibs (2270 kg)." SUBSTANTIATION: 4-7.2 Requires ESFR sprinkler system or greater for the segregated area which has been proved to control Level I I I aerosol f i res so there is no need to restr ic t quantity in such a protected area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Some l imits are needed, as stated in Comment 30B-214 (Log #9).

(Log #286) 30B- 219 - (4-7.2): Reject ~_VBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: Delete paragraph 4-7.2. ~UBSTANTIATION: See substantiation for 4-7.1. In addition, this section could result in Code 30B protection being applied to flammable liquids rooms, in direct confl ict with Code 30. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 308-218 (Log #243).

(Log #10) 30B- 220 - (4-8.2): Accept ~ : Edward Hildebrandt, Vil lage of Morton Grove COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete 4-8.2 completely. SUBSTANTIATION: In my opinion, i t is beyond the scope of proposed 30B to specify a level of protection for the storage of flammable and combustible liquids. NFPA 30, section 4-5.7.6 allows unprotected l iquid warehouses under certain conditions. Proposed 4-8.2 is also inconsistent wlth the exception to 4-8.3. I f i t is the intent of 30B to only store aerosol products in sprinklered buildings, then a section requiring f i re wall separation of aerosols and unprotected flammable l iquid storage should be added. COMMITTEE ACTION: Accept.

(Log #5) 30B- 222 - (4-8.2): Accept in Principle SUBMITTER: Orvi l le M. Slye, Jr. , Loss Control Associates, Inc. COMMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: Modify paragraph to properly reflect that the provisions are only applicable to protected l iquid warehouses and eliminate references to appendix material as follows:

The areas of "a protected l iquid warehouse . . ." and delete "in Appendix D . . . " SUBSTANTIATION: The paragraph incorrectly required sprinkler protection in unprotected l iquid warehouses in confl ict with section 4-8.3 and the 4-8.3 exception and provisions of NFPA 30, Section 4-5.7.

Reference to Appendix material is not consistent with NFPA Style Manual and is inappropriate since Appendix material is advisory and not part of the requirements of a standard. COMMITTEE ACTION: Accept in Principle.

By means of action on Comments 308-220 (Log #10) and 308-221 (Log #17). COMMITTEE STATEMENT: See Comments 308-220 (Log #10) and 308-221 (Log #17).

(Log #104) 308- 223 - (4-8.3, 4-8.3.1, 4-8.3.2, 4-8.7): Accept in Principle SUBMITTER: Greg Heying, Super Valu Stores, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-8.3 Storage of aerosol shall be in a segregated area of the l iquid warehouse that is protected in accordance with the Tables 4-I through 4-6.

4-B.3.1 Spill control or drainage should be provided in al l flammable l iquid storage areas to prevent the flow of l iquids to within 8 f t of segregated aerosol storage.

4-B.3.2 (a) through (g) delete. 4-8.7 delete.

SUBSTANTIATION: These comments are based on our review of the relevant f i re tests completed by FM and CSMA over the last 8-9 years in addition to actual f i re experience at one of our distr ibut ion fac i l i t i es . None of the data from the previously mentioned f i re tests or from our own f i re experience substantiate the need for fenced or walled containment where aerosols have been adequately protected with the fixed sprinkler systems currently required in the 30B proposal. In requiring containment as an addition to fixed f i re protection systems, the standard is responding to a perceived hazard and the well published consequences of improperly protected aerosols, rather than documented testing and research. Containment places an increased cost on f i re protection systems, impacts on operational efficiency, and adds no value. I f in fact the purpose of the NFPA 30 standard is to provide minimum requirements (Section I-2), requiring containment in the standard goes well beyond the standard's stated purpose. We strongly urge the Committee to re-evaluate i ts position on containment and modify the standard accordingly. COMMITTEE ACTION: Accept in Principle.

By means on action taken on Comment 30B-224 (Log #287). COMMITTEE STATEMENT: See Comment 30B-2Z4 (Log #287).

(Log #17) 30B- 221 - (4-8.2): Accept ~_UBMITTER: Donald M. Johnson, WSPA COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete this paragraph. SUBSTANTIATION: I t is outside the scope of NFPA 308 to specify code requirements for those portions of Liquid

(Log #287) 30B- 224 - (4-8.3.1(b)) : Accept in Pr inclple SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 308-I RECOMMENDATION: Revise paragraph 4-8.3.1(b) to read:

"For in ter ior walls having a f l re resistance of one hour, the aggregate f loor area ut i l ized for the storage

111

of Level 2 and 3 aerosol products sha l l not exceed 20 percent o f the t o t a l f l o o r area o f the warehouse, up to a maximum of 20,000 sq f t . " SUBSTANTIATION: See Substantiation for 4-5.2.1; Level 2 and 3 addition c la r i f ies the requirement. COMMITTEE ACTION: Accept in Principle.

In 4-8.3.1(a), change "20 percent" to "25 percent" in 4-8.3.1(b) revise per submitter's proposal, but change "20,000" to "30,000."

COMMITTEE STATEMENT: These changes eliminate inconsistencies between these two paragraphs and the action taken on Comment 30B-180 (Log #280).

(Log #141) 30B- 225 - ( 4 - 8 . 3 . 1 ( b ) ) : Accept in P r i n c i p l e B_~H!_U_~: Dale Cook, Pe te rson /Pur i tan , Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-8.3.1(b) For in te r io r walls having a f i re resistance of one hour, the aggregate f loor area ut i l ized for the storage of aerosol products shall not exceed I0 percent of the total f loor area of the warehouse, up to a maximum of 20,000 sq f t .

Recommend: "For in ter ior walls having a f i re resistance of one hour, the aggregate f loor area ut i l ized for the storage of aerosol products shall not exceed 15 percent of the total f loor area of the w~rehouse, up to a maximum of 30,000 s q f t (2.745 m~).,, SUBSTANTIATION: See 4-5.2.1 rationale; last paragraph.

Note: for c la r i ty , 4-8.3 should indicate that i t covers only Level 2 and Level 3 aerosol products, such as, "Storage of Level 2 and Level 3 aerosol products shall . . . COMMITTEE ACTION: Accept in Principle.

By means of action taken on Comment 30B-224 CLog #287). COMMITTEE STATEMENT: See Comment 30B-224 (Log #287).

(Log #288) 30B- 226 - (4-8.3.2(a)): Accept B~_U_~_I_T_T_~R: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph 4-8.3.2(a) to read:

Ca) The aggregate f loor area u t i l i zed for the storage of Level 2 and Level 3 aerosol products shall not exceed 20 percent of the total f loor area of the warehouse, up to a maximum of 20,000 sq f t . SUBSTANTIATION: See substantiation for 4-5.2.1, and 4-8.3.1(b). COMMITTEE ACTION: Accept.

(Log #142) 30B- 227 - (4-8.3.2(a)): Accept in Principle F~U_B_M]~U~_~: Dale Cook, Peterson/Puritan, Inc. COMHENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revised t e x t :

4 -8 .3 .Z (a ) The aggregate f l o o r area u t i l i z e d f o r the storage of aerosol products sha l l not exceed 10 percent o f the t o t a l f l o o r area o f the warehouse, up to a maximum of 20,000 sq f t .

Recommend: Change lO percent to 15 percent. SUBSTANTIATION: See 4-5.2.1 rationale; last paragraph. COMMITTEE ACTION: Accept in Principle.

By means of action taken on Comment 30B-226 (Log #288). COMMITTEE STATEMENT: See Comment 30B-226 (Log #288).

CLog #7) 30B- 228 - (4-5.2.1.2(a), 4-8.3.2(a)): Accept in Principle SUBHITTER: Edward Hildebandt, Vil lage of Morton Grove COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Change both sections to read:

" . . . shall not exceed 5 percent of the total f loor area of the warehouse, up to a maximum of 10,000 sq f t . "

SUBSTANTIATION: Since the area l imi ts are the same for one hour f i r e res is tance rated rooms and the chain l i n k fence enc losure, what i ncen t i ve would I have to cons t ruc t the more expensive room. I suggest the l i m i t s be lowered as ind ica ted to r e f l e c t the d i f f e r n c e in protection between a one hour rated wall and a fence. COMMITTEE ACTION: Accept in Principle.

By means of action taken on Comment 30B-226 (Log #288). COMMITTEE STATEMENT: See Comment 30B-226 (Log #288).

(Log #201) 30B- 229 - (4-8.3.2(b)): Accept SUBMITTER: Robert Malanga/William Webb, Rolf Oensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add the following wording:

" . . . wire woven into a maximum 2 in. (5 cm ) diamond mesh." SUBSTANTIATION: The standard should recognize that wire mesh fencing of smaller size is also acceptable. This also eliminates any unintentional product endorsement. COMMITTEE ACTION: Accept.

Make this same change to 4-5.2.1.2(b).

(Log #143) 30B- 230 - (4-8.3.Z(f)): Accept in Principle SUBMITTER: Dale Cook, Peterson/Purltan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

4-8.3.2(f) All openings in the fence shall be provided with self-closing or automatic-closing gates or shall be protected with a labyrinth arrangement so that aerosol cans are presented from rocketing through the openings.

Recommend: "All openings shall be protected with either self-closing gate, automatic closing gate or a labyr inth." SUBSTANTIATION: The reference to "rocketing cans" is unwarranted. Tests show aerosol cans do not become project i les unless a f i re is out of control; a situation this code is to preclude. COMMITTEE ACTION: Accept in Principle.

Replace current wording in 4-8.3.2(f) with the wording agreed to in Comment 30B-180 (Log #280) for 4-5.2.1.2Cf). COMMITTEE STATEMENT: This maintains consistency between the two paragraphs.

(Log #289) 30B- 231 - (4-8.3.1(f)): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Delete paragraph 4-8.3.1(f). SUBSTANTIATION: See substantiation for 4-5.2.1.2. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30B-180 (Log #280).

(Log #95) 30B- 232 - (4-9.3): Accept SUBMITTER: Michael 3. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise the last sentence to read as follows:

"Trailers shall also be located a minimum of 50 f t (15 m) from any property l lne which can be bu i l t upon." SUBSTANTIATION: Paragraph 4-9.3 requires that storage t ra i le rs be located a minimum of 50 f t from buildings and unprotected outdoor storage on the same property. Since the code can not regulate what occurs on the adjacent property, the same 50 f t requirement should apply to the property l lne separation distance. COMMITTEE ACTION: Accept.

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(Log #203) 3OB- 233 - (Table 4-1): Accept ~ : Stephen M. Stuart , 3ohnson & Higgins COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Reformat the table so that the phrase "12 spr ink lers" appears under the column labeled "Max Cei l ing Ht 25 f t " and "Maximum Pi le Ht 20 F t . " SUBSTANTIATION: Table 4-1 is obviously not proper ly formatted. COMMITTEE ACTION: Accept.

(Log #269) 308- 234 - (Table 4-I ) : Hold for Further Study ~ : D. Douglas Fratz, Chemical Special t ies Manufacturers Association COMMENT ON PROPOSAL NO.: 308-1 RECOMMENDATION: Modify Table 4-I to read as follows:

SUBSTANTIATION: These rev is ions serve to correct an inadvertent word-processing e r ro r in the tab le , and to add an add i t iona l al ternative for fac i l i t i es having ceil ing height~ of 20 f t or ~ess, using 17/32 in. heads at 0.60 gpm/ft ~ over 2500 f t L.

This add i t iona l a l t e r n a t i v e was demonstrated in a CSHA-sponsored intermediate-scale f i re test in 3une 1981 (Phase I , Series 3, Test 1) as provid ing adequate protect ion fo r the 3 -pa l le ts -h igh array. 0nly 4 spr ink lers were operated, a l l w i th in lZ seconds of the i n i t i a l can rupture, and the f i r e was under control w i th in a few more minutes, and suppressed by 15 minutes a f t e r i gn i t i on . 0nly 20 percent of the product in the 2x2x3 array was damaged in the tes t . COHHITTEE ACTION: Hold fo r Further Study. COHHITTEE STATEMENT: The new mater ia l must be evaluated by the Committee before being added to the tab le .

Table 4-I Arrangement and Protection of Palletized and Solid-Pile Storage of Level 2 Aerosol Products

Max Ceiling 30 20 30 25 25 Ht ( f t )

Maximum Pile 5 15 15 18 20 Ht ( f t )

Sprinkler 1/2 in. 17/32 ESFR large drop ESFR or

17/32 in.

Temp. 2 High High Ordinary Ordinary Ordinary Rating

Spr ink ler 100 max. 100 max 80-100 80-100 80-100 Spacing ( f t 2)

Spr ink ler 0-70 gpm/ O.fiO gpm/ 12 15 12 Demand f t c f t c spr ink lers spr ink lers spr ink lers

over over at 50 psi at 50 psi at 50 pst 2500 f t 2 2500 f t 2

Hose Stream Demand (gpm)

Duration (hr)

See Subsection 2-6.4

2 2 1 2 1

NOTE 1: A l l f i r e tests on which th is table is based were conducted with standard spray, large drop or ESFR spr ink le rs . This does not include large drop spr ink lers equipped with quick response ] inks . The Response Tj~ff Index (RTI) of standard spray and large drop spr ink lers shal l not be less than 181 ( f t / sec ) '~c.

NOTE 2: When use of higher temperature rated spr ink lers is necessary, such as near un i t heaters, re fer to NFPA 13, Standard for the I n s t a l l a t i o n of Spr ink ler System.

113

(Log #275) 30B- 235 - (Table 4-2): Hold fo r Further Study ,~L~T~T_F~: D. Douglas Fratz, Chemical Specia l t ies Manufacturers Associat ion COMMENT ON PROPOSAL NO.: 308-1 RECOMMENDATION: Modify Table 4-2 to read as follows:

Max Ceiling Ht ( f t )

Maximum Pile Ht ( f t )

Sprinkler

Temp. 2 Rating

Sprinkler _ Spacing ( f t z)

Sprinkler Demand

Hose Stream Demand (gpm)

Duration (hr)

Table 4-2 Arrangement of Protection of Palletlzed and Solid-Pile of Level 3 Aerosol Products

30 30 25 20

5 15 20 15

I/2 in. ESFR ESFR large drop or 0.64 in.

17/32 in.

High Ordinary Ordinary Ordinary

100 max. 80 max 80-100 80-100

O.fiO gpm/ 12 12 15 f t ~ spr ink lers spr ink lers spr ink lers over at 75 psi at 50 psi at 75 psi 2500 f t 2

See Subsection 2-6.4

2 l l 2

NOTE 1: All f i re tests on which this table is based were conducted with standard spray, large drop sprinklers equipped with quick response links. The RespoQ§~ Time Indext (RI),9 ~ standard spray and large drop spr ink lers shal l not be less than 181 ( f t / sec ) ~/c [100 (meter /sec) '~c] .

NOTE 2: When use of higher temperature rated sprinklers is necessary, such as near unit heaters, refer to NFPA 13, Standard for the Instal lat ion of Sprinkler System,

SUBSTANTIATION: Two revisions are being recommended to the maximum pi le height l imitat ions in this table, based on the results of aerosol f i re tests sponsored by the CSMA.

The ESFR alternative for f ac i l i t i es with 25 f t (or lower) ceilings is based primarily on CSMA's Phase I I I , Series 2, Test 3 conducted in 1987. In this test, the f i re in the 4-pallets-high array rapidly suppressed, demonstrating the extremely high effectiveness of ESFR protection for palletized arrays of even Level 3 aerosols. The convincing f i re suppression in this test provides solid evidence that 4-pallets-high Level 3 storage is protectable with ESFR, and that storage up to 20 f t high should be allowed.

The 0.64 in. sprinkler alternative should, based on the weight of evidence from several CSMA-sponsored f i re tests, allow storage heights of 15 f t , not just I0 f t . Although CSMA's f i r s t test in this configuration in 1981 (Phase I, Series 3, Test 4) was only marginally controlled, only 4 sprinklers were activated in the test. The higher density from those i n i t i a l heads that would occur in an actual warehouse instal lat ion could very l i ke ly have led to rapid control or even suppression. A subsequent test in 1982 of this configuration evidenced rapid f i re control with just four heads activated, despite the only change being a 150 RTI l lnk that appeared to have l i t t l e or no effect on sprinkler activation speed. A final f i re test of this configuration was conducted in 1983 by CSMA (Phase I f , Series I, Test 3), and rapid f i re control and suppression was evidenced with 9 sprinklers activated when a declining density scheme was used to simulate an actual sprinkler instal lat ion. In this test, although 50 RTI links were installed in the 0.64 in. heads, the ceil ing height was actually 25 f t , not 25 f t .

The preponderance of evidence indicates that 3-high storage of Level 3 aerosols should be well protected by a properly installed 0.64 in. sprinkler system for fac i l i t i es wlth low ceil ing heights (20 f t or less). COMMITTEE ACTION: Hold for Further Study. COMMITTEE ~TATEMENT: Same as for Comment 30B-234 (Log #269).

(Log #313) 30B- 236 - (Table 4-2): Hold for Further Study SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Add an additional column to Table 4-2 to represent an additional protection alternative as follows:

Max. Ceiling Ht ( f t ) 20 Max. Pile Ht ( f t ) 5 Sprinkler I/2 in. Temp. Rating High Sprinkler Spacing I00 max _ Sprinkler Demand 0.30 gpm/ft Z

Hose Stream Demand (gpm) See Subsection 2-6.4 Duration (hr) 2

SUBSTANTIATION: This additional a~ternative a11ows a lower sprinker density (0.3 gpm/ft L) for 5 f t storage under lower (20 f t ) ceilings. The effectiveness of this lower density for lower ceil ing heights was demonstrated by CSMA testing in 1980 (Phase I, Series I , Tests 1, 3, and 6) in 2-pallet sprinklered f i re tests using Level 3 aerosol spray paint, which activated only four sprinklers in two tests, and five in the remaining test. The f i re was controlled in 6 to 10 minutes in al l three tests. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: Same as for Comment 30B-234 (Log #269).

(Log #56) 30B- 237 - (Table 4-6): Accept SUBMITTER: Salvatore A. Gilardi, Jr., American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-l RECOMMENDATION: Change the word "Back" to the word "Rack" in the t i t l e of the table. SUBSTANTIATION: Editor ial . COMMITTEE ACTION: Accept.

1 1 4

(Log #290) 30B- 238 - (5-1.2 Exception No. Z (New)): Accept ~UBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add a second exception to paragraph 5-1.2 to read:

Exception No, 2: Cartoned display of Level 2 and 3 aerosol products shal l be permitted provided cartons are display-cut, so that only the bottom and lowest 2 in. (50 mm) of the side panels is retained. SUBSTANTIATION: I t is common practice for retai lers to perform display cuts on cartons, typical ly removing 60 to 70 percent of the carton, but retaining a t ray- l ike area of the bottom and lower sides to provide can uniformity and s tab i l i t y to stacked merchandise. De-stabilizing stacked Level 2 and 3 aerosols is considered more conducive to fall-down and accidental actuation problems than the retention of a minor amount of corrugate would be to the flammability. COMMITTEE ACTION: Accept.

(Log #185) 30B- 239 - (5-1.2): Accept in Principle ~ : Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add new text.

5-1.2 Level 2 and Level 3 aerosol products shall be removed from combustible cartons when located in sales display areas.

Exception: (a) Cartoned display of Level 2 and Level 3 aerosol products shall be permitted provided the area is protected in accordance with Tables 4-I through 4-6.

(b) Cartoned display of Level 2 and Level 3 aerosol products shall be, permitted with display cuts to the carton. SVBSTANTIATION: Retailers commonly use display cuts, which removes approximately 60 percent of the carton, for displaying aerosol products. This is done to provide support for the cans. By removing the cartons the cans would have less support and more potential to be disrupted. COMMITTEE ACTION: Accept in Principle.


(Log #144) 30B- 240 - (5-1.2): Accept in Principle ~ : Dale Cook, Peterson/Puritan, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

5-1.2 Level 2 and Level 3 aerosol products shall be removed from combustible cartons when located in sales display areas.

Exception: Cartoned display of Level 2 and Level 3 aerosol products shall be permitted provided the area is protected in accordance with Tables 4-I through 4-6.

Recommend: Add another exception: Exception: Cartoned display of Level 2 and Level 3

aerosol products shall be permitted provided that cartons are display-cut to form a tray with the bottom and up to 2 in. of side panels remaining intact. SUBSTANTIATION: Many large volume retai lers dlsplay-cut cartons as a means of improving s tab i l i t y of displayed merchandise. The improved s tab i l i t y provided by the resulting tray reduces the potential for accidental actuation due to fa l ls and more than offsets the impact that the corrugated would have on flammability. COMMITTEE ACTION: Accept in Principle.


(Log#80) 30B- 241 - (5-1.3.1): Reject ~ : Ronald W. Vath, The Mennen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

5-I.3.1 In sales display areas that are unsprinklered or whose sprinkler system does not meet the requirements of 5-1.3.2, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed the following:

Max Net Weight Floor Per Floor, Ibs (kg)

Basement Not permitted Ground 5000 (2270) Upper lO00 (454)

SUBSTANTIATION: Levels shown in the proposal do not ref lect the fact that incipient f ires in these areas in most cases wi l l begin when the area is occupied. Under that circumstance action to mitigate the problem wi l l begin immediately. For this reason i t is fe l t the quantities are very conservative. COMMITTEE ACT~OM: Reject. COMMITTEE ~TATEMENT: The Committee feels that the quantities now allowed are adequate.

(Log #227) 30B- 242 - (5-I.3.1): Reject ~ : 3oseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

5-I.3.1 In sales display areas that are unsprinklered or whose sprinkler system does not meet the requirements of 5-I.3.2, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed the following:

Floor Maximum Net Wt per Floor, Ibs (kg)

<50,000 sq f t >50,000 sq f t

Basement 500(227) 500(227) per 50,000 sq f t or part thereof

Ground 2500(1135) 2500(1135) per 50,000 sq f t or part thereof

Upper 500(227) 500(227) per 50,000 sq f t or part thereof

SUBSTANTIATION: The addition of this column is made to permit acceptable display in large reta i l occupancies. Proposed quantity restrictions based on small occupancy conditions should not be imposed on large reta i l establishments. As well, the allowable l im i t of 500 lbs for display in basements is based on the removal of combustible ( i .e . corrugated) materials while on display. The removal of cartons signif icantly lowers the flammable hazard of the product. COMMITTEE ACTION: Reject. COMMITTEE ~TATEMENT: Same as for Comment 30B-241 (Log #80).

(Log #291) 30B- 243 - (5-1.3.1): Reject ~UBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise table under paragraph 5-1.3.1 to read:

Floor Maximum Net Weight in Any 50,000 Sq Ft Area

Basement 500 Ibs (227 kg) Ground 3,500 Ibs (1590 kg) Upper 750 Ibs (341 kg)

115

SUBSTANTIATION: The quantity l imitat ions are set unusually low. There has been no history of f i re accidents in stores containing aerosols, when the f i re began with aerosols or went out of control due to impaction of aerosols. Eliminating aerosols from the (well venti lated) basements of Sears-Roebuck and other stores would force such stores to either discontinue sel l ing these items or move them out of the customary home improvement and automotive sales areas and into ground or upper f loor locations where they do not have a good marketing f i t . For the larger stores the draft code l imits may not provide displays of reasonable size or diversi ty. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-241 (Log #BO).

(Log #228) 30B- 244 - (5-1.3.2): Reject SUBMITTER: Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

5-1.3.2 In sales display areas that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard Group 2 occupancies, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed 2 ]b net weight per s q f t of gross sales f loor area. However, no single lO f t by lO f t (3 m by 3 m) section of sales f loor area shall contain more than 50 Ib per s q f t net weight of aerosol products. SUBSTANTIATION: This section is revised to accommodate commercial rea l i ty and s t i l l be s igni f icant ly be,~eath the volume found protectable by large-scale f i re tests. Attached are test data representing f i re testing in support of this point. As well, the combustibles, i .e . corrugated, is removed in reta i l occupancies for display purposes. The removal of corrugatin reduces the flammable hazard of aerosol products.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-241 (Log #go).

(Log #186) 30B- 245 - (5-1.3.2): Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read;

5-I.3.2 In sales display areas that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard Group 2 occupancies, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed 2 lbs net weight per s q f t of gross sales f loor area. However, no single 10 f t by lO f t (3 m by 3 m) section of sales f loor area shall contain more than 3,500 Ibs (554 kg) net weight of aerosol products. SUBSTANTIATION: The lO00 Ibs l im i t is overly conservative and unrealist ic with respect to large reta i l display area. Also according to S-l.2, al l cartons would be removed thus reducing the flammability hazard even further. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-241 (Log #80).

(Log #86) 30B- 246 - (5-1.3.2): Hold for Further Study ~UBMITTER: Gene Wolfe, Los Angeles County Fire Department COMMENT ON pROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

5-1.3.2 In sales display area that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard Group 2 occupancies, the total aggregate quantity of aerosol products shall not exceed two pounds net weight

per square f t of gross sales f loor area or 5000 pounds, whichever is less. However, no single lO f t by 10 f t section of sales f loor areas shall contain more than lO00 pounds net weight of aerosol products. SUBSTANTIATION: There is no jus t i f i ca t ion for allowing larger quantities of aerosol products in reta i l occupancies than in storage occupancies. Retail occupanies have a much higher occupant load and therefore a much higher loss of l i f e potential. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: The concept presented here represents new material.

(Log #208N) 30B- 247 - (5-1.3.2): Hold for Further Study ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read:

5-I.3.2 In sales display areas that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard Group 2 occupancies, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed 2 Ibs net weight per s q f t of gross sales f loor area. However, no single 10 f t by lO f t (3 m by 3 m) section of sales f loor area shall contain more than 2500 Ibs (I135 kg) net weight of aerosol products provided that the aerosol array is located on fixed shelving or is otherwise sat is factor i ly secured by noncombustible storage systems. SUBSTANTIATION: This section is revised to provide greater consistency with Sections 5-1.3.1 and 5-1.4, and recognizes the improved safety inherent in uncartoned, shelf-stored aerosol products vs. cartoned and palletized aerosol products - a greater hazard. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: This constitutes new material.

(Log #81) 30B- 248 - (5-I.3.2): Reject ~ : Ronald W. Vath, The Mennen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revised text:

5-1.3.2 In sales display areas that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard-Group 2 occupancies, the total aggregate quantity of Level 2 and Level 3 aerosol products shall not exceed 2 Ib net weight per square f t of gross sales f loor area. However, no single lO f t by 10 f t (3 m by 3 m) secton of sales f loor area shall contain more than 2000 Ibs (I0,I08 kg) net weight of aerosol. SUBSTANTIATION: Levels shown in the proposal do not ref lect the fact that incipient f ires in these areas in most cases wi l l begin when the area is occupied. Under that circumstance action to mitigate the problem wil l begin immediately. For this reason i t is fe l t the quantities are very conservative.

Also the proposed amount is viewed as excluding conservative reta i l establishments. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-241 (Log #80).

(Log #292) 30B- 249 - (5-I,3.2): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph 5-1.3.2 to read:

"In sales display areas that are sprinklered in accordance with NFPA 13 for at least Ordinary Hazard - Group 2 occupancies, the total aggregate quantity of aerosol products shall not exceed 2 Ib net weight per square foot of gross sales f loor area. However, no single 10 f t x 10 f t section of sales f loor area shall contain more than 2500 Ibs net weight of aerosol products."

116

SUBSTANTIATION: The 1000 Ibs l imi t is overly conservative and would impose unwarranted display restrictions and marketing l imits on a large number of larger retai l establishments. COMMITTEE ACTION: Reject. COMMITTEE STATEMNE_~!: Same as for Comment 30B-241 (Log #80).

(Log #293) 3DB- 250 - (5-1.3.3 (New)): Hold for Further Study SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add a new paragraph 5-1.3.3 to read as follows:

5-1.3.3 In sales display areas that are sprlnklered in accordance with Tables 4-I through 4-6, quantities may be increased according to the limitations found in Section 4-4 or Section 4-5 as applicable. SUBSTANTIATION: None. COMMITTEE ACTION: Hold for Further Study. COMMITTEE STAT~MNF~NI; This represents new material and a new protection concept.

(Log #294) 30B- 251 - (5-1.4): Accept in Principle SUBMITTEJ: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-i RECOMMENDATION: Modify paragraph 5-1.4 to read as follows:

5-l.4 Level 2 and Level 3 aerosol products shall not be stacked more than 6 f t (I.8 m) high from base to top of the storage array unless on fixed shelving or otherwise satisfactori ly secured. Shelving shall be of stable construction and shall not exceed eight f t in height. SUBSTANTIATION: Th change from 3 f t to 6 f t is needed to prevent undue restrictions on retail promotional (especially end-of aisle) displays. There has been no history of f i re problems due to such aerosol displays in retai l sales areas.

I OMMITTEE A~TION: Accept in Principle. Use the submitter's wording, but add "be securely

stacked to not" in place of "not be stacked." Also, end f i rs t sentence after "fixed shelving." COMMITTEE STATEMENT: The Committee feels that i ts revisions are clearer.

(Log #229) 30B- 252 - (5-1.4): Accept in Principle ~ : Joseph Sessa, Lehn & Fink Products Group COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

5-1.4 Level 2 and Level 3 aerosol products shall not be stacked more than 6 f t (1.8 m) high from base to top of the storage array unless on fixed shelving or otherwise satisfactori ly secured. Shelving shall be of stable construction and shall not exceed eight f t in height. SUBSTANTIATION: This change is made to reflect acceptable display heights for aerosols based on testing, Drop tests have shown that aerosols can withstand fa l ls of eight f t due to the integrity of the aerosol container.

NOTE: Supporting material~s available for review at NFPA Headquarters.


COMMITTEE STATEMEN__!: See Comment 30B-251 (Log #294).

(Log #57) 308- 253 - (5-2): Reject SUBMITTER: Salvatore A. Gilardi, Jr., American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Remove the word "Backstock" from the heading leaving the wording "Storage Areas."

SUBSTANTIATION: Clarity and to avoid confusion and misinterpretation of storage areas not necessarily located in the "back" of a store. COMMITTEE ACTION: Reject. CQMMITTEE STATEMENT: Same as for Comment 30B-14 (Log #52).

(Log #58) 30B- 254 - (5-2.1): Reject SUBMITTER: Salvatore A. Gilardi Jr., American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Replace the word "backstock" with the word "storage" which is what these areas are. ~UBSTANTIATION: Clarity and to avoid confusion and mistinterpretation of storage areas not necessarily located in the "back" of a store. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-14 (Log #52).

(Log #295) 30B- 255 - (5-2.1 Exception (New)): Reject SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Add an exception to paragraph 5-2.1 to read:

Exception: One swinging door of nonrated f i re resistance shall be permitted, provided the inside face is constructed of metal sheeting or other nonflammable material. SUBSTANTIATION: The required construction of 5-2.1 is commonly done, except for the door, which is not a rated f i re door, but a swinging type. A f i re door cannot be reasonably installed in such passageways because i t would generally block the swinging door. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This violates NFPA 80. Since these doors are installed on the face of the wall, rather than within the plane of the wall, collapse of the roof on one side of the wall wil l l ikely tear down the door on that side. Thus, the need for double doors.

(Log #187) 30B- 256 - (5-2.1): Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise paragraph to read:

5-2.1 When backstock areas are separated from a sales display area by construction having a minimum I hour f i re resistance or distance of 20 f t , storage of Level 2 and Level 3 aerosol products shall meet the requirements of Chapter 4. ~UBSTANTIATION: Some retailers do not have I hour barriers between display and backstock areas. To be consistent with 4-5.2.1.2 Exception. The 20 f t barrier wil l provide sufficient separation to l imit flammability hazard. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Adoption of this proposal would greatly increase the amount of aerosol storage beyond that which the Committee considers to be safe.

(Log #96) 30B- 257 - (5-2.2): Reject SUBMITTER: Michael J. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise to read as follows:

"When backstock areas are not separated from sales display areas by construction having a minimum 1 hour f i re resistance, the quantity of level 2 and 3 aerosol products in back stock areas shall be included in the total allowable quantities specified in 5-I.3. The

117

maximum quantity of aerosol products allowed in the backstock area shall be l imited to the fol lowing quanti t ies:

(a) A maximum of 2500 Ibs (I135 kg) net weight of level 2 aerosol products,

or (b) A maximum of IO00 Ibs (454 kg) net weight of

level 3 aerosol products. In no case shall the combined net weight of level 2 and 3 aerosol products exceed 2500 Ibs (I135 kg). SUBSTANTIATION: This proposal c l a r i f i e s the issue of allowable quanti t ies of aerosol products in backstock areas. When the backstock area is not separated from the sales area by one hour construction, then the quantit ies in backstock shall be included in the quantity l imi ts established in section 5-1.3. The maximum quantity l imi ts proposed would apply to sprinklered backstock areas, taking into account the poss ib i l i t y that aerosols in the back stock area are stored in cartons simi lar to a warehouse operation. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as fo r Comment 30B-256 (Log #187).

(Log #3) 30B- 258 - (5-2.2): Reject SUBMITTER: Charles B. Barnett, ASCOA Fire Systems COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Change the last two l ines of 5-2.2 so that 5-2.2 reads as follows:

"When backstock areas are not separated from sales display areas by construction having a minimum l hour f i r e resistance, the quantity of Level 2 and Level 3 aerosol products in back stock areas shall be included in the tota l allowable quanti t ies specified in 5-1.3 and stored as specif ied in 5-1.4. For quanti t ies of Level 2 and Level 3 aerosol products exceeding the quantit ies specif ied in 5- I .3, protection shall be in accordance with Tables 4-I through 4-6." SUBSTANTIATION: I t is believed necessary to give guidance regarding the height of storage permitted in backstock areas. For this reason, reference to section 5-1.4 was added to 5-2.2.

The last phrase of 5-2.2 o r ig ina l l y stated "protection shall be provided in accordance with 5-2.1"; however, 5-2.1 addresses protection required when a l-hour f i r e resistant wall separates the sales area from the backstock area and is, therefore, not applicable to 5-2.2.

I t is believed that the intent of the Committee was to provide protection for backstock storage in the manner stated in the comment above; namely, the same backstock protection as in the Sales area i f the quantity and stacking of aerosol products in the backstock area plus the sales area did not exceed the Sales area requirements of 5- I .3 and 5- I .4. I f the backstock area exceeds the l imi ta t ions of 5-1.3 and 5-1.4, then protection in accordance with Tables 4-I through 4-6 should be required. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-256 (Log #187).

(Log #188) 30B- 259 - (5-2.2): Reject SUBMITTER: Douglas Raymond, Sprayon Products, Div. of Sherwin-Williams Co. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Revise paragraph to read:

"When backstock areas are not separated from sales display areas by construction having a minimum ] hour f i r e resistance or a distance of 20 f t , the quantity of Level 2 and Level 3 aerosol products in backstock areas shall be included in the total allowable quanti t ies specified in 5- I .3 and protection shall be provided in accordance with 5 -2 . l . " SUBSTANTIATION: Modif ication has same reason as 5-2.1.

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as fo r Comment 30B-256 (Log #187).

(Log #59) 30B- 260 - (5-2.2): Reject ~ : Salvatore A. Gi lardl , J r . , American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Remove the word "backstock" and replace i t with the word "storage" which is what these areas rea l ly are. SUBSTANTIATION: Clar i ty and to avoid confusion and misinterpretat ion of storage areas not necessarily located in the "back" of a store. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-14 (Log #52).

(Log #60) 30B- 261 - (5-2.3): Reject ~ : Salvatore A. Gi lard i , J r . , American Insurance Services Group, Inc. COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Remove the word "backstock" and replace i t with the word "storage" which is what these areas rea l l y are. SUBSTANTIATION: CTarity and to avoid confusion and misinterpretat ion of storage areas not necessarily located in the "back" of a store. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Same as for Comment 30B-14 (Log #52).

(Log#82) 30B- 262 - (5-2.5 (New)): Reject SUBMITTER: Ronald W. Vath, The Mermen Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: New text :

5-2.5 Whre backstock areas are physically separated from sales display areas by a distance of 40 f t or more, regardless of intervening walls, storage allowances shall not exceed those specified in 5- l .3.1. SUBSTANTIATION: The large distance between the sales area display and backstock area, for a l l intents and purposes make each a singular separate, independent exposure. As such, each should be afforded equal exposure allowances. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The Committee considers this to be unfeasible.

(Log #97) 30B- 263 - (6-3.3): Accept in Principle SUBMITTER: Michael J. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO,: 30B-I RECOMMENDATION: Add the fol lowing "aerosol products" to the f i r s t sentence to read as follows:

6-3.3 Welding, cutting, and simi lar spark-producing operations shall not be permitted in areas that contain aerosol products or flammable l iquids . . .

Remainder of paragraph to remain as is. SUBSTANTIATION: Welding rest r ic t ions should also apply in areas where aerosol products are stored. COMMITTEE ACTION: Accept in Principle.

Replace, in current 6-3.3, the words "flammable l iqu ids" with the words "aerosol products." COMMITTEE STATEMENT: This is a correction of an error.

(Log #208P) 3OB- 264 - (6-7 thru 6-7.2): Accept in Part ~ : David C. Tabar, The Sherwin-Will~ams Company COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: New tex t : :

118

6-7 Static Electr ici ty. 6-7.1 All process equipment and piping involved in

the transfer of flammable liquids or gasses shall be connected to a statlc-dissipatlng earth ground system to prevent accumulations of static charge.

6-7.2 The maximum allowable resistance in the bonding and grounding path shall not be greater than 25 ohms. SUBSTANTIATION: The Committee original ly supported this provision until confusion arose at the 3/2/89 meetin~ regarding the maximum allowable resistance cr i ter la. Due to the fact that many aerosol f i l l e rs handle flammable liquids or gases, i t is imperative that such an important issue be addressed. Control of static e lectr ic i ty prevents fires. Rather than drop the provision, due to inconsistencies between conflicting maximum allowable resistance criterias, i t is cr i t ical to face up to the issue and set a standard • . . one that makes sense• A 25 ohms cr i ter ia has long been used within the paint and coating industry, with good reason• Minimum ignition energies (MIE) for flammable solvents, interestingly, are similar to the MIE's for flammable gases. E. G., an ether/air MIE is 0,2 mj; flammable liquids generally 0.15-2 mj; and flammable propellants 0.2-0.3 mj. 25 ohms has proven to be a good reasonable cr i ter ia for the maintenance person, plant engineer, or electrician, responsible for testing such systems, to make a logical determination as to ground path acceptability. Generally, routine testing of most ever grounding system wil l result in readings of less than l ohm. Therefore, i f a grounding system begins deteriorating, and readings of lO ohms are reached, why should a person wait until he gets to l megohm until corrections have been made? For reasons that have long been tested and found to be effective in flammable liquids operations, a 25 ohms standard should be required for testing purposes• As support for this, I am incorporating supporting documentation from John D. Owens, in his le t ter dated 3/28/89.


COMMITTEE ACTION: Accept in Part. Use only proposed 6-7.1 and add the following "(See

NFPA 77 for further information)." COMMITTEE STATEMENT: The Committee agrees with the submltter's intent, but feels that NFPA 77 should govern specifics•

(Log #296) 30B- 265 - (A-I-4): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Modify appendix item A-I.4 to read as follows:

"This section should not be interpreted as discouraging the upgrading of existing aerosol manufacturing or storage fac i l i t ies• Improvements to f i re protection systems in existing fac i l i t ies should be allowed without requiring retroactive compliance with al l of the requirements of this Code. I t is the intent of this Code, however, that major renovations to such a fac i l i t y should meet, to the greatest extent practical, the requirements of this Code." SUBSTANTIATION: We believe that this wording states more clearly the intent that the threat of retroactive compliance not serve as a deterrent to the upgrading of existing fac i l i t ies . COMMITTEE ACTION: Accept•

(Log #88) 30B- 266 - (Figure A-2): Accept SUBMITTER: Michael ,l. Madden, Phoenix Fire Department COMMENT ON PROPOSAL NO. : 30B-1 RECOMMENDATION: Replace the word "clar i f icat ion" with

I I I I the word classification in the t i t l e of Figure A-2. ~UBSTANTIATION: This should be an editorial change. Figure A-2 is a decision tree for aerosol classification. COMMITTEE ACTION: Accept.

(Log #297) 30B- 267 - (A-3-4 (New)): Accept in Part SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add to appendix a new section A-3-4:

J A-3-4 I t is essential that any flammable propellant charging room be specifically designed by qualified professionals• The requirements of this section should not be viewed as obviating the need for qualified professionals to be employed in the design and construction of aerosol charging rooms. SUBSTANTIATION: I t is importnt that i t is understood that this Code cannot serve as the sole guidelines for designing, building and operating an aerosol f i l l i ng room. COMMITTEE ACTION: Accept in Part.

J Use only the f i r s t sentence and delete the word "specif ical ly." COMMITTEE STATEMENT: The deleted word adds nothing. The second sentence appears to reiterate the f i rs t .

(Log #298) 30B- 268 - (Appendix B): Accept in Principle SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO.: 30B-I RECOMMENDATION: Add a new introductory section at the start of Appendix B and replace the current section entitled " I I . Palletized Storage Arrays" as follows:

"The automatic f i re protection alternatives given in Chapter 4 of this Code are derived from more than a dozen aerosol product f i re tests conducted by a major insurance company in the 1970s and more than 50 small, medium, and large-scale f i re tests sponsored by the aerosol industry in the 1980s. This aerosol f i re research represents a significant body of knowledge regarding aerosol f i re development and control for various types of aerosol products in various storage and protection scenarios•

A complete and detailed history of these aerosol storage research efforts can be obtained on request from the Chemical Specialities Manufacturers Association, Inc., 1913 I Street N.W., Washington D.C. 20006, Attn: D. Douglas Fratz, Director of Scientific Affairs, in the form of a series of articles entitled "An Industry Responds: A Technical History of the CSMA Aerosol Warehouse Storage Fire Protection Research Program."

Aerosol warehouse storage fires, using standard f i re test ignitors, begin as cardboard f ires. The f i re grows up the flue, burning off the aerosol carton faces, and there is usually a flame 5 to lO f t above the top of the array before the f i r s t aerosol can ruptures, and aerosols become involved in the f ire. Depending on the type of aerosol, the f i r s t can rupture tends to occur at 30-60 seconds after ignition in rack storage arrays, and 90-120 seconds in palletized storage arrays.

When aerosol containers begin to rupture, some of the heat from the fuel added by the aerosol goes quickly to the ceiling, while some is absorbed into other aerosol containers, bringing them closer to, or exceeding, their burst pressure• Early application of adequate densities of sprinkler water is the most effective way to control or suppress an aerosol f i re, avoiding a "chain reaction" that can lead to loss of control. For this reason, ESFR protection is especially effective for aerosol products•

I I . Palletized Storage Arrays.

Palletlzed storage does not offer the same conducive conditions for fast f i re growth as rack storage, but can result in persistent fires i f sprinklers are not designed fo r proper pro tec t ion .

Early aerosol f i re tests showed that standard spray sprinkler protection had d i f f icu l ty controlling Level 2 and Level 3 aerosol products stacked more than 5 f t high under a 30-ft ceiling. A major testing program sponsored by the aerosol industry was therefore begun

119

to seek more cost effective storage and protection aIternatlves.

The f i rs t series in that program investigated packaging and formulation alternatives in a series of small scale tests on Level 3 aerosol paint products, protected by standard spray sprinklers (1/2 in. orif ice) under a 20-ft ceiling. The packaging variables were rlm-vent-release cans, shrlnk-wrap replacing cardboard cartons, metal instead of plastic over-caps, f ire-resistant cardboard cartons, and methylene chloride replacing some of the petroleum d is t i l l a te solvents.

None of these alternatives proved significantly beneficial as compared to the standard "control" aerosol product. The rlm-vent release, shrink-wrap, and methylene chloride alternatives resulted in harder-to-control fires. The meta] overcap product was essentially equivalent to the control. The fire-resistant cartons primarily resulted only in delaying the f i re build-up, but had l i t t l e benefit once aerosols were involved.

Further aerosol f i re testing evaluated higher water densities and larger-orif lce sprinkler heads to protect higher stacking in palletized storage arrays of Level I, 2 and 3 aerosol products under low to medium ceiling heights (20 to 25 f t ) . Numerous successful protection alternatives were found. To properly protect each class of aerosol product stored in higher stack height and higher ceiling height scenarios was found to require higher water densities from larger ori f ice (17/32 in. to 0.64 in.) sprinklers f i t ted with low temperature (160°F) fusible links.

The final improvement in aerosol f i re protection was found through the use of an even faster response sprinkler. ESFR sprinklers, which are f i t ted with extreme]y fast-responding, low-temperature links (160°F, Response Time Index = 50), were found able to protect high-stack palletized aerosol product storage under ceilings up to 30 f t high, as well as rack storage without inrack sprinklers. In v i r tual ly al l of the successful ESFR tests, the f i re was not only controlled, but quickly suppressed and, in some cases, total ly extinguished. The success of ESFR protection for aerosol product storage may be primarily due to the abi l i ty of these sprinklers to activate due to the cardboard f i re and begin to fight the f i re before any aerosols are involved. SUBSTANTIATION: The current version of Appendix B fai ls to provide a balanced overview of the broad range of aerosol f i re tests which have been conducted and provide the basis for many of the requirements in this Code. This rewrite wi l l provide additional basic information of value to those enforcing this Code as well as those seeking to comply with i t . COMMITTEE ACTION: Accept in Principle.

1. Revise the f i r s t sentence of the f i r s t paragraph to read:

" . . . derived from more than a dozen aerosol product f i re tests conducted by a major insurance company in the late 1970s and early 1980s (see Tables 1 and 2) and more than 50 small, medium, and large-scale tests sponsored by the aerosol products industry in the 1980s (See Tables 3 through 7).

2. In second paragraph, delete "D. Douglas Fratz" 3. Add the tables from Public Comment 30B-269 (Log

#69) in the following order: (a) Table B-l, Standard Spray Sprinkler Tests (Table

I, page 1 in Comment 30B-269 (Log #69)) (b) Table B-2 Standard Spray Sprinkler Tests (Table

I, page 2, in Comment 30B-269 (Log #69)) (c) Table B-3. Tests on Product and Packaging

Changes (Data Summary Series 1 from Comment 30B-269 (Log #69))

(d) Table B-4 Intermediate Scale Tests (Data Summary Series 2 from Comment 30B-269 (Log #69).

(e) Table B-5 Large-Drop Sprinkler Tests - Intermediate Scale (Data Summary Series 3 from Comment 30B-269 (Log #69))

(f) Table B-6 Large-Drop Sprinkler Tests - Intermediate and Large Scale (Data Summary Series 4 from Comment 30B-269 (Log #69).

(g) Table B-7 ESFR Tests. (Table 2 from Comment 30B-269 (Log #69).

COMMITTEE STATEMENT: Inclusion of this data Presents the basis for the sprinkler protection requirements in Chapter 4.

(Lo~ #69) 30B- 269 - (Appendix X): Accept in P r l nc l p l e ~ : Henry C. Scuotequazza, Factory Mutual Research Corp. COMMENT ON PROPOSAL NO.: 30B-1 RECOHH~NDATION: Add the f o l l o w i n g t e x t in a new Appendix, t i t l e d Aerosol Test Experience.

This code is based on ex tens ive f u l l - s c a l e t es t i ng that was conducted between 1979 and 1989, These tests include standard spray, large-drop and Early Suppression Fast Response (ESFR) sprinklers. The following tables summarize the results.

Standard Spray Sprinkler Tests (Tables 1 and 2) Tables 1 and 2 show the results with standard, I/2

in. and 17/32 in. sprinkler heads. These tests show that, for adequate control, Level 2 aerosols need one l ine of longitudinal sprinklers abqve every t ier (except the top) and a 0.30 gpm/ft L ceiling density. Level 3 aerosols need the same in-rack ~rran~ement as Level 2 aerosols but with a 0.60 gpm/ft ~ ceiIing densit X or longitudinal and face sprinklers with a 0.30 gpm/ft c ceiling density. The rack array used in these tests was a double row with 5 f t between tiers and a total of 4 tiers for a total of about 20 f t storage height.

These tests also demonstrate the d i f f i cu l t of controlling palletlzed storage in heights greater than one-high when protected with standard spray sprinklers.

Product and Packaging Changes (Table 3) This test series was conducted (see Table 3) to

determine whether changing the product formula or packaging would reduce the hazard. All tests used two pallets of a Level 3 aerosol located side-by-slde on a platform to simulate a 20 f t ceiling height. Test l was conducted as a control test to establish the base line for the tests that followed on various packaging and formula. In Test 2 rim vent release cans (RVR) prevented rocketing, but they created a very intense, stable f i re that was more severe than the control test. Fire retardant cartons were tested in Test 3. The results show that the treated cartons just slow the in i t ia l f i re development but do not reduce the overall f i re severity.

In Test 4 the cardboard cartons were replaced with plastic shrink wrap. Calculations showed that the amount of heat content in the packaging should be reduced since the plastic wrap, being only several mils thick, would have less total heat content than cardboard. The test, however, was much more intense than the control test. There are two possible explanations. First, the lesser thickness of the shrink wrap created many openings within the pallet load which would allow the flammable contents of the ruptured cans to spread between the packages of aerosols. Second, the plastic sheds water and does not absorb the water as cardboard does, so the plastic does not act as a heat absorber and i t prevents the water from cooling the cans.

To reduce the hazard of the paint formula used in the aerosols, 30 percent of the toluene that was used as the base solvent was replaced with methylene chloride, which is almost noncombustible. The test was more severe. This is probably caused by the lower boiling point of methylene chloride. This would increase the pressure in the cans faster, thereby causing the cans to fai l sooner and contribute the remaining flammable contents to the f i re at a faster rate. The data seems to support this conclusion: the f i rs t can ruptured earl ier and the rate of ruptures seemed to be higher.

The last test was conducted to determine i f replacing the plastic overcaps with metal would lower the combustible content of the pallet load enough to make a difference. I t did not.

Intermediate Scale Tests (Table 4) Tests I and 2 of Table 4 show the test results for

two intermedlate-scale tests on a level 2 aerosol which were conducted to evaluate the effectiveness of faster

120

response, lower temperature sprinklers with higher discharge densities on 2 and 3 high arrays (under a 20 f t cei l ing). Neither test showed good control.

The remaining four tests were conducted to gather data on a series of products containing an increasing amount of flammable l iquids. The flammable l iquid content of each product was as follows: a i r freshner, 8.8%; furniture polish, 23.4%; laundry pre-wash, 53.8% and a prototypical Level 3 paint, 100%. (Note: This does not mean al l such products sold on the market have the same flammable l iquid content. Each product encountered should be evaluated according to the classi f icat ion scheme described in this code). The results of these tests were incorporated into devising the present c lassi f icat ion method.

Large-Drop Sprinkler Tests (Table 5) The purpose of this test series was to determine

whether the use of large-drop sprinklers would allow aerosols to be stored in higher palletized arrays than with standard sprinklers. Test I was run f i r s t to provide a direct comparison with large-or i f ice (17/32 in.) sprinklers under similar conditions. I t should be noted that these tests are intermediate-scale and were done to determine which arrangements merited further tesLih~. The results of Test l should not be interpreted to indicate this protection can be applied,

Tests 2 showed that the large-drop sprinkler, operating at about the same pressure as the large-or i f ice sprinkler, controlled the f i re faster. (The somewhat higher cei l ing temperature was caused by tile simultaneous ruptures of several cans. In Test 3 the operating pressure was dropped to 25 psi but the f i re was not controlled. Tests 4 and 6 evaluated the effectivenss of increasing the discharge pressure to 75

~ si for Level 3 aerosols. Test 4 shows tht three t ie r igh storage cannot be adequately protected, whereas

Test 6 demonstrates that 2 pal let high storage can be controlled.

Test 5 repeated the conditions of Test 2 except that the product was changed to laundry pre-wash which had almost 55 percent flammable l iquid (not soluble in water) content. This confirmed the va l id i t y of the def in i t ion of a Level 2 aerosol.

Test 7, a small-scale test using I/2 in. sprinklers, confirmed that the combination of RVR cans and substituting some of the flammable base product with methylene chloride increases the f i re hazard.

Large-Drop Sprinkler Tests - Large Scale (Table 6) Based on the data from these tests, fu l l -scale tests (I and 2) were designed and run to confirm whether or not large-drop sprinklers would be successful. The tests showed this protection can be used. Test 3 confirmed that the laundry pre-wash can be protected with Level 2 cr i ter ia . Even though only 7 sprinklers opened in Test 4 with antiperspirant (which contains 78 percent hydrocarbon propellant), the f i re damage indicates that a larger array probably would not have been controlled.

Test 5 dup l ica ted the cond i t i ons o f an e a r l i e r t es t except tha t each s p r i n k l e r had a 150 RTI l i n k instead of a 300 RTI l i n k . The f a s t e r response did not e x h i b i t any b e n e f i t , which conf irms the work done wi th ESFR s p r i n k l e r s : f a s t response alone does not turn a s p r i n k l e r i n to an ESFR. The s p r i n k l e r d ischarge a lso has to be such tha t the amount and c h a r a c t e r i s t i c s of the water reaching the top of the ar ray is enough to penet ra te the f i r e plume, reach the seat of the f i r e and suppress i t . This requ i res a d i f f e r e n t s p r i n k l e r design than what i s used in the la rge-d rop or o ther sprinklers. One factor, for instance, is that currently ESFR sprinklers are of pendent design while large-drop sprinklers are upright, which means the pipe creates a "shadow" in the discharge pattern.

ESFR Tests (Table 7) The final series used ESFR sprinklers to determine

whether mul t i t ie r pal let ized and rack arrays can be protected. The rack arrays did not have in-rack sprinklers. The f i r s t f ive tests were performed under a 25 f t high cei l ing. Tests l , 2 and 3 were conducted with the ignit ion point centered below four sprinklers. In each test, the f i re was suppressed by 4 sprinklers. The f i re in Test 4 was ignited between 2 sprinklers with a low clearance between the top of storage and the cei l ing as this represents the worst case for this ignit ion location.

The igni ter was located d i rect ly below a ceil ing sprinkler in Test 5 because data from tests with other commodities showed that this could be a worst case for higher clearances (lO f t or more). The f i re opened only one sprinkler. Because of this test, the next test, Test 6, was conducted with the same arrangement except that the cei l ing height was increased by 5 f t to 30 f t . This difference caused 61 sprinklers to open and showed that igni t ion under one sprinkler is a problem for clearances greater than 10 f t for aerosols.

Given this result, Test 7 with Level 2 aerosols was ignited below one sprinkler. The f i re was suppressed. This array height was increased in Test 8 to almost 19 f t but the ESFR sprinklers did not suppress the f i re . The final test duplicated Test 6 except that the discharge pressure was increased to 75 psi. The f i re was suppressed. SUBSTANTIATION: This proposed appendix summarizes the test data upon which this code is based. I t is needed to explain and jus t i f y the technical approach taken. (NFPA 30 includes such information as background for the flammable l iquid code.) This helps the user see that the requirements are based on substantial test experience, which adds c red ib i l i t y , and may assist them is applying this code to situations that may not f i t the code. COMMITTEE ACTION: Accept in Principle.


121

I. Test Location:

2. Igni t ion:

3. Protection/ Ceiling:

4. Protection/In- Rack:

Table I Test Results

Factory Mutual Test Center, West Gloucester, Rhode Island, 30 f t (9 m) high Test Site.

Two cellucotton rol ls - 3 in. dia. x 3 in. long, (7.5 x 7.5 cm) each soaked in 4 oz (I18 ml) of gasoline;

I/2 in. (12.7 mm) or i f ice, 286°F (14l°C) [165°F (74°C) in Test No. 6]; lO f t x lO f t (2.5 m x 2.5 m) spacing; approx. 0.30 gpm/ft 2 (12.2 mm/min) density.

Three I/2 in. (12.7 mm) or i f ice, 165°F (74°C) rated, upright sprinklers at the f i r s t , second and third t i e r levels; 30 psi (207 kPa) discharge pressure.

5. Test No. 1 2 3 4 5 6

6. Type of Aerosol Alcohol Alcohol Toluene Alcohol T o l u e n e Alcohol Base Product

7. No. of Pallet Loads: 8 24 8 12 12 8

8. Storage Config- uration Rack Rack Rack Palletized Palletized 2x2x2

9. No. of Ceiling Sprinklers Operated 13 16 43 4 92 64 36

10. Time of Operation of First Sprinkler (Min:Sec) 1:52 2:06 2:19 3:05 3:03 1:26 9:23

I I . No. of In-Rack Sprinklers Operated 5 6 5 . . . . .

12. Maximum Near- Ceiling Gas Temperature 1292 1334 1493 938 2216 1789 1905 °F (°C) (700) (723) (812) (503) (1213) (976) (1040)

13. Time of Maximum Gas Temperature (Min:Sec) 3:19 5:41 3:48 3:09 4:54 4:26 9:58

14. Time Above lO00°F ( 5 3 8 ° C ) . . . . . . . . 2:16 3:32 0.52

15. Maximum Near- Ceiling Steel Temperature 642 815 973 378 1439 - - OF (°C) (339) (435) (503) (192) (782) - -

16. Aisle Jump? No No Yes No Yes - -

17. Fire Controlled? Yes Yes No Yes No No

7

Toluene

1

Pal I eti zed

626 (330)

No

122

I. Test Location:

2. Igni t ion:

3. Protection/ Ceil ing:

4. Protection/ In-Rack:

Table 2 TEST RESULTS

Factory Mutual Test Center, West Gloucester, Rhode Island, 30 f t (g m) high Test Site

Two cellucotton ro l l s - 3 in. dlam x 3 in. long (7.5 x 7.5 cm) each soaked in 4 oz (I18 ml) of gasoline.

17/32 in. (13.5 mm) o r i f i ce , 286OF (141oc); 10 f t x I0 f t (2.5 m x 2.5 m) spacing. [Test I-3, 5 and 9]

I /2 in. (12.7 mm) o r i f i ce 286°F (141°C); 10 f t x I0 f t (2.5 m x 2.5 m) spacing [Test 4, 6-8, and I0]

Three I/2 in, (12.7 mm) o r i f i ce , 165°F (74°C) rated, upright sprinklers per t i e r ; 30 psi (207 kPa) discharge pressure.

5. Test No: I 2 3 4 5 6 7 8 9 10

6. Ceil ing Sprinkler Density: 0.6 0.6 0.6 0.3 0.6 0.3 0.3 0.3 0.6 0.3

(24) (24) (24) (12) (24) (12) (12) (12) (24) (12)

7. Type of Aerosol: Tolu- Tolu- Tolu- Tolu- Paint Alco- Per- Deodo- Tolu- Butane Base ProducL erie ene ene ene hol fume rant ene

8. No. of Pallets: 8 12 24 24 lO 1 1 l 24 l

9. Storage Con- r p r r p - - - p (2 high) - f igurat ion: ( r = tack, p = pal let lzed, 3 x 4 x I high)

lO. No. of Ceil ing Sprinklers Operated: 12 4 5 5 18 4 0 3 44

I f . Time of Operation of Fi rst Sprinkler: (min:sec) 1:37 2:33 3:37 2:15 2:35 4:21 - 4:13 2:07 -

12. No. of In- Rack Sprinklers Operated: 6 - 5 l . . . . . .

13. Maximum Near- Ceil ing Gas Temperature 1527 1177 790 1410 1343 697 165 520 2162 372 OF (°C): (830) (636) (421) (765) (728) (369) (74) (271) (1183) (189)

14. Time of Maximum Gas Temperature (min:sec): 3:32 2:34 3:32 2:17 4:02 4:27 4:50 3:57 4:03 6:13

15. Time Above "lO00°F (538°): 2:2B 0:04 0:2B 0:44 0:06 - - 4:56 -

16. Maximum Near- Ceil ing Steel Temperature 835 417 213 375 323 170 I00 177 1557 243 OF (°C): (446) (214) (I01) (191) (162) (77) (38) (80) (847) (117)

17. Aisle Jump? Yes No Yes No Yes - - Yes -

18. Fire Controlled? Yes Yes Yes Yes Yes Yes Yes Yes No Yes

123

Test

Aerosol Base Product

Packaging Variable

TEST RESULTS

Sprinklers Operated

Maximum Ceiling Temp.

Time of First Can Rupture

Ist Sprinkler Activation

Final Sprinkler Activation

Est. Product Damage

Comments

All Tests:

Table 3 Tests on Product and Packaging Changes

DATA SUMMARY SERIES I

l 2 3 4 5 6

Paint Paint Paint Paint Paint Paint

- - - R im-Ven t - Fire Shrink- Methy lene Metal Release Retardant Wrapped Chloride Overcaps Cans Cartons Pallets Solvent

4 33 4 30 28 5

I010 2141 980 1525 1881 1220

1:31 1:20 I:56 1:25 1:18 1:36

2:15 1:40 2:40 2:13 1:45 I:55

2:22 5:09 4:12 5:22 4:55 3:06

60% 70% 40% 80% 70% 75%

Fire Fire Fire Increased Increased Fire Controlled bui l t Controlled f i re f i re controlled by four rapidly out by four intensity intensity by f ive sprinklers of control, sprinklers after after 3 sprinklers in 9 -10 reaching in 6 min., 4 minutes minutes in 9-10 minutes, maximum after slow required requ i red minutes.

intensity f i re test to be test to be at 6 development aborted at aborted at minutes. 5:20. 4:30.

20-foot Ceiling (tests conducted on 40-foot by 40-foot metal p la t form) ; 1/2 inch or i f ice sprinklers with 286°F links installed I0 feet apart; 29 psi constant water pressure delivering 0.3 gpm per sq f t ; 2-pallet array spaced l - foot apart with ignit ion between pallets by two half- ignitors (plastic bags containing 4 oz. heptane on cotton ro l ls ) .

124

Test I

Aerosol Base Product Hairspray

Pallet Configuration 2 X 2 X 2

Sprinkler I/2 in.

Link Temp. OF 160

Water Pressure, psi 30

Water Density, 0.3 gpm/sq f t

TEST RESULTS

Sprinklers Operated 33

Maximum Ceiling Temp., OF 1761

Time of First Can Rupture 1:48

1st Sprinkler Activation 2:02

Final Sprinkler Activation 6:36

Est. Product Damage 50%

Comments Poor control ; intense f i re for 15 minutes

Table 4 Intermediate Scale Tests

DATA SUMARY SERIES 2

2 3 4 5 6

Air Furniture Laundry Toluene/ Hai rspray Freshner Poli sh Pre-Wash A-70

2 X 2 X 3 I X 2 X 1 1 X 2 X 1 I X 2 X I I X 2 X 1

17/32 in. I/2 in. 1/2 in, I/2 in. I/2 in.

160 280 280 280 280

30 30 30 30 30

0.43 0.3 0.3 0.3 0.3

23 1 3 3 16

1475 659 603 653 1855

1:50 1:45 1:54 1:51 1:50

2:05 3:05 6:08 4:17 2:16

4:50 - - 6:10 4:20 4:48

75% 20% 50% 75% 65%

Intensi ty Fire easi ly Fire Fire Intense of f i r e control led control led reasonably f i r e for required in 5 in 9 well 8-10 min. test to be minutes by minutes control led before any aborted at single a f ter slow in 10-12 control 8:20. spr ink ler f i r e bu i ld - minutes, established.

up.

Al l Tests: 20-foot ce i l ing (tests conducted on 40-foot by 40-foot metal platform); ign i t ion by two ha l f - i gn l to rs (p las t ic bags containing 4 oz. heptane on cotton r o l l s ) ; sprinklers installed on 10 foot grid.

125

Table 5

Test

Paint

Aerosol Base Product

Pallet Configuration

Sprinklers

Link Temp., OF

Water Pressure, psi

Water Density, gpm/ft 2

TEST RESULTS

Sprinklers Operated

Maximum Ceiling Temp., °F

Time of First Can Rupture

Ist Sprinkler Activation

Final Sprinkler Activation

Est. Product Damage

Comments

Large-Drop Sprinkler Tests - (Intermediate-Scale) DATA SUMMARY

SERIES 3

2 3 4 5

Furniture

Hai rspray Hal rspray Mai rspray Pal nt Pol i sh

2 X 2 X 3 2 X 2 X 3 2 X 2 X 3 2 X 2 X 3 2 X 2 X 3

17/32 in. 0.64 in. 0.64 in. 0.64 in. 0.64 in.

160 160 160 160 160

56 50 25 75 50

0.6 0.8 0.56 0.96 0.8

*Rim-vent-release container; methylene chloride

4 4 18 4

1080 1645 1439 1350

1:48 1:45 1:46 1:35

1:56 1:54 1:53 1:43

2:00 2:01 4:52 1:47

20% 20% 50% 40%

Fire Fire fu l ly Inadequate Fire controlled suppressed control marginally in 6--8 min in 10 min. led to 18 controlled, and sup- sprinkler but poten- pressed by activations; ial for 15 min. potential f i re

for f i re spread spread.

solvent.

6 7

Paint ( RVR/MECI )"

2 X 2 X 2 I X 2 X 1

0.64 in. I/2 in.

160 280

75 30

0.96 0.3

4 4 36

1068 1111 2163

1:56 1:47 1:20

2:27 2:01 1:47

2:28 2:0B 3:24

20% 20% 90%

Fire Fire well Very controlled controlled intense in 5-7 min in 4-5 min f i re; test

aborted at 3:20.

126

Table 6 Large-Drop Sprinkler Tests - (Large Scale and Intermediate-Scale)

DATA SUMMARY SERIES 4

Test 1 2 3 4 5

Laundry Anti- Aerosol Base Product Paint Hairspray P r e - W a s h Perspirant Paint

Pallet Configuration 2-High 3-High 2 X 2 X 2 2 X 2 X 3 2 X 2 X 3

Sprinkler 0.64 0.64 0.64 0.64 0.64

Link Temp. °F 160 160 160 160 160 (150 RTI)

Water Pressure, psi 75 50 50 75 75

Water Density, 0.96 0.8 0.8 0.96 0.96 gpm/sq f t

TEST RESULTS

Sprinklers Operated 4 7 4 7

Maximum Ceiling Temp. °F 1158 1337 1116 1520

Time of First Can Rupture 1:30 1:33 2:24 1:45

Ist Sprinkler Activation 1:49 1:44 2:52 1:49

Final Sprikler Activation 1:52 3:42 3:09 6:43

Est. Product Damage . . . . . . 15% 50%

Comments Fire well Fire well Fire well Moderate controlled controlled controlled control, in 3-4 in 6-7 in 5 f i re minutes; minutes, m i n u t e s ; persisted suppressed despite 2 suppressed 25 minutes; in 15-20 sprinkler within probability min. No malfunctions, 10-15 for f i re f i re spread. No f i re minutes, spread.

spread. Fire spread unlikely.

*Response Time Index of 150

4

895

1:34

1:43

1:48

25%

Fire well control led in 5 minutes; suppressed in 15-20 minutes. Fire spread un l lke ly .

127

Test I Aerosol Base Product Hair

Spray

Table 7 ESFR Tests

2 3 4 Paint Paint Paint

Aerosol Product C1asslfication Level 2 Level 3 Level 3 Level 3

Array Rack Rack Palletized Rack Stack Ht. 18'10" 13'10" 15'6" 13'7" (meters) (5.7) (4.2) (4.7) (4.1)

Ceiling 6'2" 11'2" 9'6" 4'2" clearance (meters) (1.9) (3.4) (2.9) (I.3)

No. of Sprinklers 4 4 4 2 Above Ignition Point

Time of First Sprinkler Operation (min:sec) I:02 0:42 0:49 0:55

Time of Last Sprinkler Operation (min:sec) 1:11 I:06 1:36 6:33

Total Sprinklers Operated 4 4 4 5

Peak Temp., OF 1045 565 713 1421

Time of First Container Rupture 1:03 I:01 1:29 0:52

5 Paint

Level 3

Rack 13'10" (4.2)

11'2"

(3.4)

l

0:35

0:35

1

256

None

Test 6 7 8 9 Aerosol Base Product Paint Hair Hair Paint

Spray Spray

Aerosol Product Classification Level 3 Level 2 Level 2 Level 3

Array Rack Rack Rack Rack

Stack Ht. 13'10" 13'I0" 18'10" 13'10" (meters) (4.2) (4.2) (5.7) (4.2)

Ceiling 15'0" 15'0" 10'0" 15'0" clearance (4.5) (4.5) (3 m) (4.5) (meters)

No, of Sprinklers l 1 2 1 Above Ignition Point

Time of First Sprinkler Operation 0:36 0:34 0:56 1:15 (min:sec)

Time of Last Sprinkler Operation (min:sec) 2:06 0:34 3:44 - - -

Total Sprinklers Operated 61 l 14 1

Peak Temp., OF 1447 223 995 200

Time of First Container Rupture 0:44 0:46 1:01 1:10

NOTE: Al l of the above tests, except for Test 9, were conducted with 50 psi (3.45 bar) operating pressure. Test No. 9 used 75 psi (5.2 bar)

128

(Log #299) 30B- 270 - (Appendix C): Accept SUBMITTER: D. Douglas Fratz, Chemical Specialties Manufacturers Association COMMENT ON PROPOSAL NO,: 30B-] R~_COMMENDATION: Retitle Appendix C as "Determining the Classification Level of Aerosol Products," and replace the current f i rs t paragraph with the following (retain the current language for al l other paragraphs in the Appendix):

Section I-7 of this Code provides formulation-based cr i ter ia for classifying aerosol products into three categories requiring different levels of protection. These cr i ter ia are based on dozens of sprinklered f i re tests and other relevant data on current aerosol product formulations. Since exact aerosol formulation data is often proprietary, i t wil l be necessary for aerosol manufacturers to classify each aerosol product and communicate that information to those who require such information, through carton marking, Material Safety Data Sheets, or other appropriate means.

There are also standard f i re test procedures that may be used to detew~ine the classification levels of aerosol products. Where such data exists, i t should be used to identif~r that product's classificatlon, and serve as the b#sis for further modifications in the formulation-based cr i ter ia.

The most reliable test protocol currently available is the 12-pallet aerosol classification test, developed by Factory Mutual Research Corporation. This test consists of a 2--pallet by 2-pallet by 3-pallets high array, with sprinkler protection using upright sprinkler heads having 0.64 in. orifices (K-factor - If .2), and 160°F (RTI : 300) links, spaced I0 f t by 10 f t on a 2S ft ceillng, with water Rressure at a constant 50 psi to provide 0.8 gpm/ft L. Classification is determined from considering the "cr i t ical performance parameters" in the test, which include the number of sprinklers opened, maximum temperature of a steel beam on the ceiling, maximum plume velocity, maximum plume temperature, maximum heat flux, maximum weight loss rate, and net percent weight loss. The overall consideration in this test is whether control or suppression is achieved and number of sprinklers operated. Roughly speaking, fires involving Level I aerosol products are well-controlled or suppressed; tests with Level 2 aerosol products are well- to margirally-well controlled, and tests with Level 3 aerosol products are not well controlled. ~ _ Q _ N : This revision provides basic information on the 12-pallet aerosol classification test wil l be valuable to those seeking to classify aerosol products. CQMMITTEE ACTI(~: Accept.

(Log #150) 30B- Z71 - (Appendix C): Accept ~ : 3ames R. Quiter/3erome E. Cunningham, Roll aensen & Associates, Inc. COMMENT ON PROPOSAL NO.: 30B-1 RECOMMENDATION: Revise the last paragraph of Appendix E as follows:

Change the section number and table number from Section 1-8 and T~ble 1-8 to Section I-7 and Table 1-7, respectively. SUBSTANTIATION: Errata. COMMITTEE ACTID_~: Accept.

PART I I

(Log #6) 30A- ] - (I-1.2): Reject SUBMITTER: William H. Pomroy, U.S. Bureau of Mines COMMENT QN ProPOSAL NO.: N/A RECOMMENDATION: Propose adding the following to 1-1.2:

"This code shall not apply to nonpublic fueling fac i l i t ies at remote locations." SUBSTANTIATION: Paragraph 8-3.5 of NFPA 30A states that Class I and Class I I liquids may not be dispensed from above-ground tanks exceeding 6000 gallons capacity. This provision creates a severe compliance problem for the mining industry, where fuel usage is high (lO,O00 to 20,000 gallons per day not uncommon), fueling fac i l i t ies are remote and accessible only by authorized personnel, minimum fuel deliveries from the fuel supplier are often 10,000 gallons or more, and f i re risks are minimized through sound and safe engineering design of tanks and dispensing systems. The proposed wording change for paragraph 1-1.2 would rectify this problem by excluding fueling fac i l i t ies at mining operations in remote locations from coverage in NFPA 30A. This change would not affect f i re risk to the public, as i t specifically addresses nonpublic fac i l i t ies at remote locations. COMMITTEE ACTION: Reject. COMMITTEE ~TATEMENT: The concerns of the submltter are adequately addressed by the proposed new I- I .3 because the entire fac i l i t y wil l be exempt from compliance with NFPA 30A and any vehicle wil l be able to be refueled. Also, to change the wording to that proposed by the submitter would broaden the exemption beyond what the Committee feels is warranted.

(Log #5) 30A- 2 - (4-2.7): Reject SUBMITTER: John R. McPherson, American Petroleum Institute COMMENT ON PROPOSAL NO.: 30A-I0 RECOMMENDATION: Revise 4-2.7 to read:

"Provision shall be made for the disengagement of the nozzle/hose assembly from the vehicle f i l l pipe in the event of a drlveaway. The means for disengagement may be located anywhere between and including the nozzle spout to the f i t t i ng that attaches the hose to the dispenser. The devlce shall retain the liquid in the nozzle/hose assembly. The device shall be listed and shall be installed in accordance with the manufacturer's instal lation instructions." SUBSTANTIATION: Industry agrees that protection against the f i re and safety consequences of driveaways is warranted,

The current industry practice is a nozzle equipped with a spout designed to shear in the event of a drlveaway. The flow valve in the nozzle is designed to close as the result of the shock as the spout shears, or the nozzle strikes the pavement, or as the attitude of the nozzle changes as i t exits the f i l l pipe on a driveaway situation. The emergency shut-off valve under the dispenser serves as a back up to the nozzle shear spout. The emergency valve is actuated by the shearing forces associated with pulling over a dispenser or thermal actuation due to a f i re. In addition, a significant impact to the dispenser wil l actuate this emergency shut off valve. Industry's impressive f i re and safety record regarding the consequences of driveaways confirms the overall effectiveness of this form of protection.

As information, additional protection against driveaways is provided by the current generation of electronic dispensers and control consoles installed in many new fac i l i t ies . The equipment substantially prohibits driveaways, rather than providing protection against the potential consequences of driveaways. A l ight on the console alerts the console operator that the customer has not returned the nozzle to the dispenser. The completion of the sales transaction is blocked until the nozzle is returned. The customer who has to go to the console operator to settle up for the sale (sign the credit card, pay cash, receive the change, get a receipt) are informed that they have not hung up the nozzle. Although the pre-pay, exact cash customer has no reason to return to the console operator to complete the transaction, some additional protection is provided with this system. The pre-set $ value/gallons are controlled by closing the solenoid valve in the dispenser. This additional closed valve at the end of the pre-pay transaction, before the

129

nozzle is hung up/dispenser cut off , offers an additional protection against driveaways with this type of transaction.

The several generations of hose breakaway devices that have been developed in recent years have been ut i l ized, to varying degrees, by industry members. These devices have achieved very l imited acceptance by industry to date. The primary use has been to comply with the requirement, where enforced, that was introduced into the 1987 edit ion of NFPA 30A. Four API member companies have voluntar i ly instal led breakaways on some of their new instal lat ions of high hang hose dispensers. Perceived protection of this more expensive equipment, not f i re and safety concerns, has been the driving force in these decisions.

The opinion of the vast majority of industry members with signif icant experience is that the Jury is s t i l l out on the overall effectiveness of these devices in contributing any quantif iable improvement to an impressive f i re and safety record in this area of concer~. The API does not support, at this time, a requirement for these types of devices as the sole specific remedy in a model code that is adopted by a substantial number of state and local authorit ies.

The API would prefer that the current requirement be deleted from the code unti l such time that experience can identi fy any meaningful improvements to the current industry practice. However, the Committee's concerns about the total deletion of this item from the code are understood. Therefore, the API proposes a modification to the code for the Committee to consider in l ieu of deletion.

The intent of the modification proposed is to recognize the need for driveaway protection, provide the current industry practice as an acceptable remedy, and to provide wording general enough to encourage and accommodate future product development.

Service Stations Fires in Perspective

NFPA Annual Survey '81 - 85

Service Station Fires Compared to Total U.S. Fires - 0.01% of All Fires Reported - 0.02% of All Property Damage Reported

Average Annual Frequency was one Fire for Every 491 Stations

All Fires were Confined to Station Site

API Annual Survey '84 - '87

Service Station Fires (Z$2SOO/Incident) Compared to Total Petroleum Fires - 7.6% of All Industry Fires Reported - 0.5% of All Industry Property Damage Reported

Average Annual Frequency was one Fire for Every 4591 Stations

The Consequence of Driveaways

One Oil Company Study ('85 - '87)

Based on Company Operated Locations

Location/Cause of Station Fires - Other than Island - Island Fires

+ Faulty Wiring + Drove into Dispensers + Driveaways

+ Other

70%

I0% B% 7% (One every 75

Mil l ion Fuel- ings, or 789 Years for Average Volume Station)

5%

Fires Resulting from Driveaways - No Deaths - No Personal Injuries - Fires Confined to Site - Proportional Spl i t between Self Serve and Full Serve Frequency

Another 011 Company Study ('83 - 4/88)

Reported Consequency of Driveaways

Fatal i t ies: One Full Service Attendant (Only one known to Industry)

Personal Injury: Annual Frequency - One for Every 9821 Stations Confined to Full Service Attendants

Property Damage Z$2500, a l l Fires, Annual Frequency One for Every g821 Stations Z$IOOO; Annual Frequency - One for Every 4911 Service Stations; Average Cost/Incident: $138

Other Oil Companies' Reports

Based on '87 - '88 Experience: No Driveaway Fires or Personal Injuries Reported

Based on 1988 Experience: No Driveaway Fires, no Personal Injuries, Frequency of Z$2500 incidents w a s one Every 230 Years for Average Faci l i ty

aased o n ' 8 4 - '88 Experience: No Driveaway Personal Injuries

Lumma~z

The Overall Fire and Safety Record at Service Stations is Impressive on both a Relative and an Absolute Basis

- Part icular ly Considering the Number of Fueling Transactions (Approximately 12.6 B i l l i on /y r . ) and Public Involvement (Self Service Represents more than 70% of These Transactions)

The Consequences of Driveaways are Typically not Severe

- One known Fatal i ty in Industry (Not Fire Related)

Very Low Frequency Personal Injury Rate

Oriveaways are not a Major Contributor to Fires at Service Stations

- Fire Frequency is Low, Confined to Property

- When Property Damage does Occur, Average Cost is Several Hundred Dollars

Conclusions

Current Equipment Inventory and Operating Practices have Produced an Impressive Record

State of the Art Equipment, Training and Faci l i ty Design wi l l Result in an Improvement in this Historical Fire and Safety record

Any Proposed Enhancement should be Evaluated Carefully to Ensure that the Net Effect on the Industry's Performance wi l l be Positive

API BREAKAWAY SURVEY RESULTS

Response

17 Companies

Range of Company Owned Chain Size: 120 - 4000 Locations

Experience

14 have Significant Operating Experience with Breakaways

130

Company's Posture

Total # Respondents

Ins ta l la t ion Policy New MPD's New Conventional

14 2 All l ( in Conjunction I Discretion with MPO's) of Field

I Limited to Specific Osgn.

Support Code

Only Where Req'd Yes No

10 1 13

Comments - 4 Companies with "NEW MPD" Ins ta l la t ion Policy

Company "A"

- Does Not Support Code"

- Malntai~s Driveaway Records

- Specified on MPD's for Past Two Years to Reduce Repair Expense

- No Fires or In jur ies with Conventional Dispensers not Equipped with Breakaways

- Adds to I n i t i a l Cost, Another Piece of Hardware to Inspect/Maintain

Company "B"

- Does Not Support Code

- Does Not Maintain Driveaway Records

- Specifies on New MPD's and Associated Conventional Dispensers

- Useful in Protecting MPD

Company "C"

- Does Not Support Code

- Maintains Driveaway Records

- Specified on S/S MPO's Only

- Cost Cannot be Just i f ied by Past Experience

Company "D"

- Supports Code

- Does Not Maintain Driveaway Records

- Specifies on New MPD's

- Breakaways have Disconnected when Customer Crimps Hose

Comments - IO Companies with "Only Where Required" Policy

Do Not Support Code

6 of 10 Maintain Driveaway Records

Comments of Those who Maintain Records

- Not had any Major Damage, Injury or Safety Hazard occur from Drive-of fs .

- Costs and Lack of Safety Enhancement make i t an ine f fec t ive , Unnecesary, and Undesirable Expense

- Overk i l l . Frequency of Incidents does not Just i fy Cost and Nuisance Value of "Remedy,"

- Cost is High, Experience Shows that Occurrence is infrequent. Consequence of Driveaway not costly.

- Costly, Bulky, Leak.

- Redundant to other Safety Devices - Impact Valves and Breakaway Nozzles.

- Hose Decoupled with Pressure Surge and nearly Struck Customer.

- Vandalism (a l l hoses jerked down at closed stat ion) .

- Breakaways Appear to Operate Correctly 98% of the Time.

- State-of-Art breakaway Equipment is improved; hoever, s t i l l not Desirable to Locate at the Nozzle.

- Breakaways should be l e f t to Discretion each Marketer.

Representative Comments of Those Who Don't Maintain Records

- Experience indicates that re la t i ve ly few drlveaways involve f i res and none Involved Signi f icant Claims of Injury or Property Damage

- Consequences of Driveaways do not warrant an Additional Safety Device.

- Experience does not j u s t i f y .

- Redundant to other Safety Devices - Nozzle Spout Shears at 150 f t lbs (Equivalent to 200 lbs Breakway separation force), Impact Valves, Remote Consoles Signal and Block Transaction i f Nozzle not Hung up.

- Concerned about Re l i ab i l i t y . One Decoupled and Sprayed Customer when Valve Failed to Close. Of 24 Instal led at one Location, 6 separated in Daily Use.

- Experience Considerable Decoupling Failures when Breakaways are insta l led next to Nozzle.

- Adversely af fects Weight and Handling Characteristics with Stage I I Vapor Recovery.

- Creates an Additional Flow Restr ict ion.

- Lab tests showed that Force 45% Higher than Advertised Required to Decouple or one Supplier's Breakaway.

- May change policy i f equipment considered to be reliable as a safety device without Contributing to Maintenance Costs or Hazarous Conditions, becomes Available.

Driveaway Frequency

Not determinate because Some Number of Driveaways Do Not Result in a Service Call.

The Average Station Experiences a Driveaway that Results in a Service Call/Equipment Damage every I0.8 years.

131

Consequences o f Driveaways

Fatal i t ies

- One Fatal i ty Among the 17 Companies Attributed to Flying Object, Not Fire.

Personal Injuries

- Data Not Requested

- Data Available From Two Companies that Have Concluded more Extensive Studies.

Inspection and Repair Expense (Measure of Severity)

- Average $233/incident

- Two Company Studies Over Longer Periods o f Time Average $22g/ inc iden t .

- Quite often includes Replacement of Nozzle Because Spout Shears as Designed.

Summary

Four Companies Specify Breakaways on a Limited Basis. They have "Equipment Protection," not Fire and Safety Concerns, as the Driving Force.

- Two specify on All MPD's

- One Specifies as Option on MPD's at Discretion of Field Operating People

- One Specifies on a Particular MPD Configuration regarded as Particularly Susceptahle to Damage.

- Three of These Four Companies do Not Support the Requirement in a National Model Code

Experience and Data of 13 of the 14 Companies do not Result in Support of National Model Code Requirement.

- Fire and Safety Records, and Input of Knowledgeable, Experienced People do not Support the Need.

- Protection Proposed by the Breakaway is Considered an Unnecessary Redundancy to Impact Valves, Nozzles with Shear Spouts, and the Warning Provided by State of the Art Electronic Consoles.

- An additional Fi t t ing provides another opportunity for Product Leaks. Malfunction Frequency May Create as many Problems as Potentially Solved with the Addition of this Device.

Breakaways Present Operational Concerns

- Hoses and Nozzles are Subjected to theft even during daylight. Expensive Stage I I Equipment is Particulary Tempting.

- When Installed at the Nozzle, Adversely Affects Weight and Handling Characteristics especially with Stage IT Vapor Recovery.

- Further Reduces an Already Unacceptable Flow Rate Associated with Stage IT Equipment.

- Customers Stretching/Crimping Hose can Increase the Affect of Hydraulic Shock and Cause a Decoupling.

Conclusions

The Current General Industry Practice of Impact Valves under the dispenser and Nozzles with Shear Spouts has Resulted in an Impressive Fire and Safety Record.

- The Nozzle Spout Provides the "Breakaway Function" by Decoupling the Nozzle and Hose System from the Car During a Driveaway.

- The Impact Valve under the Dispenser Protects Against Vehicle Impact Damage to the Dispenser. This Valve also Provides Backup to the Nozzle Shear Spout.

The Breakaway May Prove to Be a Viable Protection Option that has been Introduced Prematurely into a National Model Code.

The Companies recognize that Improvements have been and wi l l continue to be made.

- I t is currently not Possible to Quantify the Net Effect the device wi l l have on the I~ressive Fire and Safety Experience in Retail Fueling.

- The "Operational Concerns" cited above may Prove to be the Ultimate Limiting Factor as an Attractive Alternative.

Current Generation Electronic Consoles Provide Additional Safety by Alerting the Console Operator that the Nozzle has not been hung up After Fueling. The Completion of the Transaction is Blocked Untll the Nozzle is Hung Up.

- The Feature Offers an Enhanced Level of Protection from Drlveaways. The Potential Consequences of a Oriveaway are Prevented, as Compared to Minimized with "Breakaway Devices."

Recommended Alternatives

Modify the Language in the IggO Edition to Require a Decouple Device. 0o not include Specific Equipment Remedy(ies) at this Time.

Modify the Language in the 1990 Edition to Require a Decouple Device for the Hose and Nozzle Assembly. Cite State of the Art Options.

- Leave Breakaways in the Code as an Equipment Option at this Time. The 3ury is S t i l l Out on the V iab i l i t y and Overall Effectiveness.

- Recognize the Nozzle equiped with a Shear Spout as an Equipment Option. Industry Experience Confirms the Effectiveness of this Solution.

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The submitter's proposed wording omits the requlre~nt that l iquid be retained on both sides of the point of separation, a requirement the Committee feels is essential to prevent spi l ls . Also, this language would allow the shear point of the spout of the dlspenser nozzle to be used to satisfy this requirement. The Committee considers the shear point to be too unreliable because in certain cases the spout wi l l fa i l in tension, rather than in shear, and at much grea te r fo rces than des i r ab l e , Such cases inc lude overhead hose drops on mu l t l - p roduc t d ispensers and refueling of autos whose fuel f i l l e r tube is located just above the rear bumper. In these cases, the bending moment necessary to "snap" the spout at the shear point cannot be attained and the hose fa i ls or the dispenser is pulled over before the spout fa i ls. Also, the hydraulic shock created when the hose stretches and snaps is great enough to cause fai lure of l iquid seals in the dispenser housing, resulting in leaks.

Finally, the newly-added equivalency statement wi l l allow new devices to satisfy the requirement.

(Log #2) 30A- 3 - ( 5 -1 .1 ) : Reject SUBMITTER: Edward Hildebrandt, Village of Morton Grove COMMENT ON PROPOSAL NO.: 30A-3 RECOMMENDATION: Add a second sentence to 5-1.I:

'~Floor openings shall be protected by a curb not Tess than 4 in. high above the f loor . " SUBSTANTIATION: Add i t i on o f a curb around l u b r i c a t i o n serv ice openings in the f l o o r w i l l a id in prevent ing s p i l l s and accumulat ions o f vapors from en te r ing the pi t or below grade area.

132

[

COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: This requirement would not prevent vapor or l iquid from entering the service p i t or below-Brade work area because the l ike ly source of any fuel leak w i l l be the veh ic le that happens to be d i r e c t l y over the p i t . Also, 4 in . w i l l be too high fo r many subcompact autos to c lear , f l n a l l y , the service p i t or below-grade work area is required to be ventilated.

(Log #3) 30A- 4 - (5-1 .3) : Accept in P r inc ip le ~ : Edward Nt ldebrandt , V i l l age of Morton Grove COMMENT ON PROPOSAL NO.: 30A-3 RECOHHENDATION: Add a second sentence to 5-1.3:

"Exhausted a i r shal l be taken from a po in t w i th in 12 in. of the f l o o r wi th one or make-up a i r i n l e t s located on the opposi te side of the p i t or area w i th in 12 in . of the f l o o r . " SUBSTANTIATION: Add i t ion of the suggested sentence c l a r i f i e s how the v e n t i l a t i o n a i r is to be c i rcu la ted so that accumulation of heav ie r - than -a i r flammable vapors is minimized. COMMITTEE ACTION: Accept in P r i nc ip l e .

1, Amend proposed new 5-1.3 to read: " . . . shal l be provided with exhaust v e n t i l a t i o n at

a rate of . . .'

2. Add a second sentence to proposed new 5-1.3 to read:

"Exhaust a i r shall be taken from a point within 12 in. of the floor of the p i t , below-grade work area, or sub-floor work area." COMMITTEE STATEMENT: The Committee believes its version wil l more clearly explain how to achieve the desired ventilation.

(Log #4) 30A- 5 - (Table 6): Reject SUBMITTER: Edward Hi ldebrandt , V i l l age of Morton Grove ~OI~IENT ON PROPOSAL NO.: 30A-3 RECQI~ENDATIQN: 1. Delete TCR rev is ion to Table 6.

2. Revise Table 6:

Lubr icat ion or serv ice room -wi thout dispensing

Area up to 18. above level of p i t , below- grade area, or sub- f l o o r area.

SUBSTANTIATION: Proposed language in item 4 of Proposal 30A-3 seems inappropr ia te in l i g h t of the v e n t i l a t i o n requioments of 5 - ] . 3 . The revised language recognizes the po ten t ia l accomulatlon of heavier- than a l r -vapors at f l o o r leve l should the v e n t i l a t i o n required in 5-1.3 become blocked or temporar i ly i n e f f e c t i v e in an area. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: Bas ica l l y , Proposal 30A-3 already requires th i s area c l a s s i f i c a t i o n fo r unvent i la ted below-grade areas. Also, the submi t ter 's proposal would penal ize below-grade work areas that have adequate v e n t i l a t i o n .

(Log #1) 30A- 6 - (8-8, 8-8 .1) : Reject ~ : T. Vann Baxter, Department of Fire Prevention COMHENT ON PROPOSAL NO,: 30A-19 RECOMMENDATION: My proposal was accepted in p r i nc i p l e wi th the 50 f t t rave l d istance changed to 100 f t as stated in 8-8.1. SUBSTANTIATION: I feel that 100 f t t rave l distance to

reach a f i r e ex t ingu isher is an excessive amount of t r a v e l . The t rans ien t pub l i c , as mentioned in the Committee's Statement, could in actua l i ty have to t rave l a distance up to 200 f t to get a f i r e ex t ingu isher and put out a f i r e in or on t h e i r veh ic le . As stated in my previous recommendation, 50 f t would be a more reasonable t rave l d istance. As stated in NFPA 10, Section 3-3, paragraph 3-3.1, Table 3-3.1, ex t ra (high) hazard requires 40B f i r e ex t ingu isher wi th a t rave l d istance of 30 f t maximum t r a v e l to a f i r e ex t ingu isher . I feel that th is 30 f t maximum would be too r e s t r i c t i v e at se l f - se rv i ce s ta t ions open to the pub l i c , a more p rac t i ca l t rave l d istance would be the 50 f t as stated in my proposal. COHMITTEE ACTION: Reject. COMHITTEE STATEMENT: The cur ren t l y proposed wording al lows ex t ra distance to accommodate and recognize the need fo r secur i t y of the ex t ingu isher from the f t or vandalism and the need for the ex t ingu isher to be located c loser to the at tendant .

133

PART I I I

(Log #24) 30- 1 - ( I - I .Z ) : Accept SUBMITTER: R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-4 RECOMMENDATION: Add NFPA 4g and NFPA 325, together with their o f f i c ia l t i t l e s to the l i s t of references given in section 6 - I . I . SUBSTANTIATION: My Committee notes indicate the Committee agreed to this change as part of the Committee Action on this proposal. COMMITTEE~TION: Accept.

(Log #3) 30- 2 - ( I-1.7.5): Accept ~J~_t~TJ_I!T~: Edward Hildebrandt, Vi l lage of Morton Grove ~ O M M E ~ P O S A L NO,: 30-I RECOMMENDATION: Add a new I-1.7.5 to read:

l - I .7 .5 Storage and Handling of Aerosol Products. These requirements are covered separately in NFPA 30B, Code for the Hanufacture and Storage of Aerosol Products.

Renumber existing I-1.7.5 to I-1.7.6 and delete al l material in parenthesis. SUBSTANTIATI!~O_N: I believe, from my notes, that the above wording reflects the Technical Committee's intent when we decided to delete references to flammable aerosols. Aerosols would be added to section I-1.7 which l i s t s materials or situations when NFPA 30 does not apply. COMMITTEE ACTION: Accept.

(Log #23) 30- 3 - (I-2, I - I .7 .5 , 4-1.6, 4-I.3 and Appendix D): Reject SUBMITTER: R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-I R E C O M ~ : All of the changes proposed relat ive to "aerosol" and "flammable aerosols" should be deleted, thus reverting to exist ing text. SUBSTANTIATION: According to Part I of the Report by the Committee on Flammable Liquids NFPA 30B is presented in the TCR as being rejected, thus i t would be premature to make changes in NFPA 30, deleting references to "aerosols" and "flammable aerosols," until a satisfactory correlation takes place between the Committee on Aerosol Products and the Committee on Flammable and Combustible Liquids. I t is also noted that correlation with the Committee on General Storage, representing NFPA 231 and 231C may also be required. COMMITTEE ACTION: Reject. COMMITTEE STATEM NE_NZ: The Correlation problems that resulted in NFPA 30B not passing Correlating Committee bal lot have been resolved by means of public review and comment. I t is anticipated that NFPA 30B wi l l be adopted by the Association.

(Log #25) 30- 4 - ( I -2 . ) : Accept SUBMITTER: R. 1. Spencer, IR1 COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise def in i t ion of "Hazardous Materials Storage Locker," changing the last sentence to read as follows:

" I t is intended to meet local, state and federal requirements for outside storage of hazardous materials." SUBSTANTIATION: Edi tor ia l . Rephrasing to c la r i f y intent and is revised to include "state" requirements, arl uversight. COMMITTEE ACTION: Accept.

(Log #1) 30- 5 - (I-2, 4-9, 4-9.1 and 4-4.1): Reject SUBMITTER: Anthony G. Martino, Minneapolis, MN COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Change wording in paragraphs to:

"Hazardous Liquid Storage Building." Change def in i t ion Section I-2: Hazardous Liquid Storage Building. A relocatable

prefabricated structure, manufactured primarily at a site other than the final location of the structure and transported completely assembled or in a ready-to-assemble package to the final location. I t is designed to meet the requirements of model local ordinances and federal regulations for the storage of Class IA and the storage and dispensing of Class IB, Class IC, and combustible l iquids, primarily outside of buildings. SUBSTANTIATION: Hazardous materials according to Appendix VIA of the 19B8 Uniform Fire Code, includes explosives, blasting agents, compressed gases, flammable solvents, oxidizers, organic peroxides, unstable (reactive) materials, water reactive materials, cryogenic f lu ids, toxic materials and radioactive materials. Many of these are outside of the scope of NFPA 30, but are within the code of federal regulations, T i t le 29 (CFR-29). In fact, some manufacturer's buildings can't be used for storage of al l hazardous materials, As an example, they are not designed as a magazine and therefore cannot be used for storage of explosives. Also the UL l i s t ing covers only a part of Group H occupancies as defined above.

The proposed modification of the def ini t ion wi l l allow the use of these buildings - but as defined by the scope of NFPA 30 - not as defined by building codes, federal regulations or other sources.


COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The concerns of the submitter have been addressed by the current definit ions and scope of new Section 4-9.

(Log #20) 30- 6 - (2-9.3): Reject SUBMITTER: Pr isc i l la O. Young, The American Petroleum Inst i tute COMMENT ON PROPOSAL NO.: 30-24 RECOMMENDATION: Delete 2-9.3. SUBSTANTIATION: The pending change (addition) in NFPA 30-24-(2-9.3) is premature. API has petitioned EPA for a change in the unduly rest r ic t ive l imitat ion of "90 percent fu l l by restr ic t ing the flow of l iquid into the tank or tr iggering a high-level alarm."

API has provided documentation that a float-vent valve restr ic t ion in a large tank can be set to activate at 98 percent of tank capacity and s t i l l allow an extraordinary long period of time for the driver to recognize the conditions and respond.

I f reason prevails, the 90 percent l imi tat ion wi l l be changed. NFPA 30 should not embody this language until the 1993 code revisions. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: New subsection 2-9.3 is considered to be necessary for f iresafety. Also, the API pet i t ion has not been ruled on by EPA. To accept this change prior to an EPA ruling is premature.

(Log #57) 30- 7 - (2-9.3(c) and (d) (New) : Reject ~ : Thomas Schruben, US EPA ~OMMENT ON PROPOSAL NO.: 30-24 RECOMMENDATION: Change the current option (c) to option (d) and insert a new option (c) as follows:

(c) Restrict flow 30 minutes pr ior to over f i l l ing , a ler t the operator with a high level alarm one minute before over f i l l i ng , or automatically shut off flow into the tank so that none of the f i t t i ngs located on top of the tank are exposed to product due to over f i l l ing ;

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SUBSTANTIATION: The American Petroleum Institute (API) submitted a petition for rulemaking to the U.S. Environmental Protection Agency (EPA) requesting revision of the overf i l l prevention requirements. API pointed out that the overf i l l prevention requirements unnecessarily restricted the usable volume of larger tanks. EPA is about to issue a proposal for an additional performance standard for this section of i ts technical standards. I t shou]d be published in the Federal Register by the time NFPA Committee meets to discuss these public comments. EPA believes that i ts proposed revision wil l not be controversial as i t allows additional f l e x i b i l i t y without reduction in environmental protection. EPA suggests that i f NFPA is going to address overf i l l requirements that language along the lines suggested above be included. COMMITTEE ACTIOt~: Reject. COMMITTEE STATEMENT: The API petition has not been ruled on by EPA, so this change is premature. Also, i t is not clear to the Committee whether all three actions stated in proposed new (c) are required or just one of them.

(Log #6) 30- 8 - (3-3.3): Accept SUBMITTER: Edward Hildebrandt, Village of Morton Grove COMMENT ON PROPOSAL NO.: 30-29 RECOMMENDATION: Second line of the Committee Statement should reference Proposal 30-28 (Log #2). SUBSTANTIATION: Editorial. The wrong proposal was cited in the Committee Statement. COMMITTEE ACTION: Accept.

(Log #7) 30- 9 - (4-2.3): Accept ~UBMITTER: Edward Hildebrandt, Village of Morton Grove COMMENT ON PROPOSAL NO.: 30-37

I RECOMMENDATION: Delete the second sentence. SUBSTANTIATION: The changes proposed in the second sentence are a duplication of Proposal 30-36. COMMITTEE ACTION: Accept.

(Log #36) 30- 10 - (4-4.2.5, 4-5.1.4): Accept in Principle SUBMITTER: Robert Treiber/Bill Spain, Systech Environmental Corporation COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: The submitted text in Proposal 30-39 should be deleted and the existing text in NFPA 30, paragraph 4-4.2.5 should remain as is. The proposal as submitted needs to be returned to the Committee for reevaluation. I t appears that the Committee is attempting to address the f i re spread problem associated with aerosol and plastic containers and is proposing to apply those safety constraints to all flammable and combustible l iquid operations and storage fac i l i t ies . SUBSTANTIATION: Proposal 30-39 in i ts substantiation states that recent f i re incidents have pointed out the need for additional f i re control. We would question tile appl icabi l i ty of these data to across the board applications o( al l fac i l i t ies which have operations and storage involving flammable and combustible liquids. We would concur that recent f i re data does indicate that serious spi l l control (product flow and projectile) problems do exist with aerosol and plastic containers. We would l ike to see the substantiation of f i re loss data or research data that would indicate that a foam sprinkler protected fac i l i t y u t i l iz ing metal containers and portable tanks with emergency vent rel ief has need for the Emergency Drainage as would be required per Proposal 30-39. We would also question the following criteria of the proposal:

Why 4000 square feet? (4-4.2.5.2/4-5.7.14) Why one (I) hour f i re flow capacity for the

holding faci l i ty?

NOTE: The Uniform Fire Code, Article 80 only requires 20 minutes per Division I I I , paragraph 3, Item G ( i ) . Paragraph (e) would require a 5000 square feet room with a sprinkler density of .41 to have a minimum holding capacity of 123,000 gallons. In some cases, the density requirements from the insurance carrier are as high as .60 which would require a holding capacity of 180,000 gallons. Where do you obtain 180,000 gallon tanks? What is the cost comparison of a 5000 square foot warehouse space versus the installation of a 123,000 or 180,000 gallon holding tank/holding faci l i ty? Why 25 feet from the building for the holding

faci l i ty? The present code allows an underground tank to be within one (I) foot of the building or three (3) feet of a property line 2-3.1.

What is a holding faci l i ty /sui table disposal system? Would underground containment require double wall requirements? Proposal 30-39 does not provide a definition, nor does i t give defined standards in which to construct an Emergency Drainage System/holding fac i l i ty or whatever i t may be called.

Was the concept of a sacrif icial structure considered?

Will this proposal encourage the use of outside storage without f i re protection? Is this in the best interest of the environment?

In summary, we believe that the f i re loss record does not indicate that all flammable and combustible liquid fac i l i t ies have the recent f i re loss experience to require Emergency Drainage System. Would i t not be in the best interest of the environment, f i re service, and the owner/operator to take a pro-actlve versus a reactive approach to spi l l control by the use of effective f i re suppression system and primary containment (impounding) where possible or " I f i t is Not Broken, Don't Fix I t . " COMMITTEE ACTION: Accept in Principle.

Retain existing 4-4.2.5 as currently worded in the 1987 Edition.

Add new 4-5.7.14 to read: "For new liquid warehouses, where automatic sprinkler

protection is provided, curbs, scuppers, special drains, or other suitable means shall be provided to prevent the flow of liquids, under emergency conditions, throughout the building. The drainage system, i f used, shall have sufficient capacity to carry off expected discharge of water from f ire protection systems and hose streams." COMMITTEE STATEMENT: The Committee agrees with the submltter that there are too many unanswered questions regarding the basis for the original ly proposed requirements. The Committee has restated the drainage requirements in s t r i c t l y performance terms to allow drainage designs to be tailored to individual circumstances. A Task Group has been established to develop more specific cr i ter ia.

(Log #1l) 30- 11 - (4-4.2.5, 4-5.7.1.4): Accept in Principle ~ : Robert H. Woodcock, Aetna Life & Casualty COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Delete last phrase "as required by paragraph 4-4.2.5.2(e)" from paragraph 4-4.2.5.1.

Delete section 4-4.2.5.2 and 4-5.7.14. SUBSTANTIATION: Compliance with the new proposals would be prohibit ively expensive. COMMITTEE A T ~ : Accept in Principle.

By means of action on Comment 30-10 (Log #36). COMMITTEE STATEMENT: See Comment 30-10 (Log #36).

(Log #43) 30- 12 - (4--4.2.5.1): Accept in Pr inciple ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Change paragraph to read:

4-4.2.5.1 All cut-off rooms and attached buildings shall be provided with noncombustible, l iquid-t ight, raised s i l l s or ramps to a height calculated to prevent the flow of liquids to adjoining areas of buildings, which in no case shall be less than 3 in. in height.

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SUBSTANTIATION: A 1:50 gradient is necessary to allow safe travel of powered industrial trucks with flammable l iquid loads over ramps. Many cutoff rooms and attached buildings with 4 in. (or greater) ramps are unsafe, due to an insuff icient length of approach which clearly increases the l ikelihood of product spillage during l i f t t ruck handling. A 12 I/2 f t approach is necessary at each side of the f irewall ( to ta l : 25 f t ) to safely allow vehicles over a 3 in. high ramp. Since many cutoff rooms are small, especially in mercantile occupancies, i t is essential that this minimum standard provide for the safe movement of flammable liquids over ramps, while not increasing the probabil i ty for product spillage, which in turn, increases the risk of f i re . COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30-10 (Log #36). ~MMITTEE STATEMENT: See Comment 30-10 (Log #36).

(e) What are the drainage options? The standard gives no guidance about how the trenches should be located re la t i ve to the racks. Is a one-way slope to the drain acceptable, or is two-way required? The extensive trenching and sloping great ly l im i t the f l e x i b i l i t y of the f ac i l i t y to change i ts storage configuration; redoing a drainage system would be prohibi t ively expensive. What is the guidance relative to trench size and pitch? Would not an interceptor tank be required so that spi l ls do not reach the primary containment area? What are recommended flame trap designs which wi l l be amenable to viscous as well as nonviscous l iquids. COMMITTEE ACTION: Accept in Principle.


(Log #53) 30- 13 - (4-4.2.5, 4-5.7.14): Accept in Principle SUBMITTER: Michael A. Hoppe, E. I . DuPont deNemours & Co., Inc. COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Delete entire proposed changes; retain existing section 4-4.2.5, ~BSTANTIATION: The proposed changes have been offered without also providing supporting evidence that these changes would have signlf icant]y reduced the property-loss outcome of the "recent f i re incidents," nor that the very specific drainage and containment requirements provide the most cost-effective way of dealing with the environmental concerns relat ive to fire-water runoff. A Lest program to resolve the many drainage/containment issues raised by this proposal is needed, leading to a research-based and performance-oriented amendment to NFPA 30 with options suitable for both new and existing fac i l i t i es .

Examples of specific concerns around the proposed changes (which could be resolved by the test program) are:

(a) Why was the holdup requirement based on two drainage areas (2500 sq f t ) for 60 minutes? Why not use the design demand of the system for 30 minutes (or use as the duration the required supply duration)?

(b) Why is external containment the only option? Could not internal containment be ef fect ively (and in many cases more economlcally) used?

(c) Why is 25 f t required between the external containment and the building? What should the distance from the property l lne be? Could not the external containment be next to the building i f there is a 4-hour f i re wall separating the building from the containment? I f the property l ine distance from the containment is taken as 50 f t per Table 4-8, a distance of 75 f t to the property l ine from the building would be needed. This frequently exceeds the available distance.

(d) A f loor slope i f 0.5 percent is not rel iably attainable. I f i t were possible, the implications relat ive to safety for even this small slope on l i f t - t ruck operations and rack integr i ty would not be acceptable for any scenario other than one where al l of the slope was completely under the racks.

(Log #56) 30- 14 - (4-4.2.5 Exception (New) and 4-5.7.14 Exception (New)): Accept in Principle ~ : Byron L. Brlese, Oak Ridge, TN COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Add an exception to the proposed text of sections 4-4.2.5 and 4-5.7.14 to read as follows:

Exception: Those fac i l i t i es provided with foam based f i re suppression systems designed in accordance with NFPA 11, 16 and/or 16A shall-be equipped with holding capacity designed to contain the flow of the foam based system for a period of 20 minutes. Further, individual drainage areas l isted in the preceding section may be tr ip led. SUBSTANTIATION: Foam based f i re suppression systems have the capabil i ty of extinguishing a potential f i re. In most cases, water based protection in f]ammable storage areas can merely cool the structure. Thus, much ]arger quantities of water are required. This suggested change to the Committee's comment merely recognizes foams capabil i ty. COMMITTEE ACTION: Accept in Principle.


(Lop #45) 30- 15 - (4-4.Z.5 and 4-5.7.14); Accept in Principle SUBMITTER: David C. Tabar, The Sherwln-Williams Company COMMENT ON pROPOSAL NO.: 30-39 RECOMMENDATION: Revise 4-4.2.5, 4-4.2.5.1 and 4-4.2.5.2 to read:

4-4.2.5 Emergency Sprink]er Water Retention and Control.

4-4.2.5.1 Al l new cut -of f rooms and attached buildings ut i l ized for l iquid storage shall comply with Table 4-4.2.5.1 provided that l iquid quantities in such rooms or buildings exceed the minimum amounts identi f ied in 4-5.6(a) through (e) General Purpose Warehouses.

Also revise 4-5.7.14 to read: 4-5.7.14 All new ]iquid warehouses shall comply with

Table 4-4.2.5.1, provided that l iquid quantities in such warehouses exceed the minimum amounts identif ied in 4-5.6(a) through (e) General Purpose Warehouses.

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Li quid Storage Area Size

Up to 2,500 sq f t

2,501 to 25,000 sq f t

Over 25,000 sq f t

Table 4-4.2.5.1 Emergency Sprinkler Water Retention fo r Protected and Non-Protected Inside Liquid Storage Areas

Primary Containment Secondary Containment Drainage and Floor Gradients Required? Construction Required? Construction Required? Construction

Yes Noncombustible No No l i q u l d - t l g h t mtn.3 in . s i l l s or ramps

Yes Noncombustible No No l i q u i d - t l g h t min. 3 in. s i l l s or ramps. Retention capacity designed for the maximum sprinkler demand and 500 gpm hose stream allowance over a 10 mln. durat ion; or 500 gpm allowance for nonprotected areas.

Yes Noncombustible l i q u l d - t i g h t perimeter curbing Minimum 3 in. ramps at f i r e - wall openings

Yes Retention capacity designed fo r maximum spr ink le r demand and 500 gpm hose stream allowance fo r 1 hr. durat ion; or 500 gpm allowance fo r 1 hr fo r non-

p rotected areas. rov is ion shal l be

made fo r automatic or manual remote re tent ion system closure, in the event of a f i r e condi t ion.

No Areas protected by foam-water spr ink lers which meet or exceed NFPA 16 need not be provided with secondary equipment.

No Exception: New l i qu id storage areas in excess of of 50,000 sq f t non-protected or protected wi th water- only sp r ink le r systems shal l employ the use of graded f loors or drainage trenches to provide for sp r ink le r water retention and control.

137

SUBSTANTIATION: Thousands of mercantile and warehouse operations are in existence throughout North America which distr ibute and sell a wide range of consumer products containing flammable and combustible l iquids. Examples include hardware, grocery, paint, automotive, and many others. A large percentage of reta i l and distr ibut ion f a c i l i t i e s are leased l o c a t i o n s . . , many of which have no capabil i ty to provide elaborate drainage and containment f ac i l i t i e s . In new construction, the costs involved to provide trenches every 30 f t with a remote impounding basin approximates $7.33/sq f t for a 150,000 sq/f t f a c i l i t y ; in other words, over $1,000,000. Retrofits involving exist ing f ac i l i t i es are cost-prohibit ive; provisions involving "drainage trenches" in a l l occupancies over 4,000 sq f t wi l l have a far greater impact on U.S. re ta i l ing than l i ke ly perceived by the Committee. The costs involved in requiring " . . . a holding f a c i l i t y that is located at least 25 f t from the building . . . " wi l l cause retai lers to take the far less-costly alternative; dropping the product l ine. Further, f i re experience in mercantile occupancies with "cutoff rooms or attached buildings" has shown that far more f i res could be prevented by dealing with such causal factors as building e lect r ica l , arson, smoking, or neighboring occupancies. The insta l la t ion of arb i t rar i ly- required trenching systems and f loor gradients (1) establishes a building "permanence" which wi l l not benefit future changes in layout; (2) may be of questionable value due to potential clogging from packaging under f i re conditions; (3) creates concerns specific to vapor travel and f i re spread; (4) is based on l i t t l e knowledge as to physical r e l i a b i l i t y under heavy-vehicle t ra f f i c and warehouse loads; (5) presents safety concerns relat ive to h igh - l i f t powered industrial trucks handling elevated loads above sloped floors; and (6) most importantly, is not based on f i re research data which clearly establishes drainage and gradient design c r i te r ia relat ive to the protection provided. The fact that research is clearly lacking is evidence that "the jury is out" on the value of trenching systems.

Lastly, the value of AFFF sprinkler systems which seek to suppress and extinguish f i res . . . as opposed to "control l ing" with water-only systems, must be considered. A foam-water sprinkler system should clearly negate the need for trenching and drainage systems. This has been clearly demonstrated in one of the most severe f i re tests involving flammable l iquids ever performed under roof - Loddby Test No. 10 performed by Scandia Insurance of Stockholm. 16,000 l i t e rs of flammable l iquids inplast ic containers and no trenching were controlled by an AFFF closed-head foam-water sprinkler system. More f i re research is planned in 1990 by the NFPRF National Foam-Water Sprinkler Research P r o j e c t . . . which wi l l not consider trenching systems. The bottom l ine is that industry needs f l e x i b i l i t y with f i re safety . . . this needs to be reflected by more thought given to the many alternatives available to designers. While a larger dedicated remote impounding area might ideal ly be located 25 f t from the building, consideration should be given to u t i l i z i ng available dock areas, parking lots, etc. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30-I0 (Log #36). COMMITTEE STATEMENT: See Comment 30-I0 (Log #36).

(Log #17) 30- 16 - (4-4.2.5.2, 4-5.7.14): Accept in Principle SUBMITTER: Robert S. Ajemian, Motor Vehicle Manufacturers Assoc. (MVMA) COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: 4-4.2.5.2 and 4-5.7.14 wi l l require that a holding or handling f a c i l i t y be required to handle drainage for a minimum of 1 hour duration. As an example, for a new cut-off room, attached building, or l iquid warehouse that has a sprinkler system designed for 0.60 or l iquid warehouse that has a sprinkler system designed for a 0.60 gpm/sq f t over 4000 sq f t , a flow of 2400 gpm is required. Add to this 10 percent for hydraulic imbalance and a flow of 2640 gpm is obtained. For a one hour duration, a total gallonage of 158,400 is obtained. I f a f a c i l i t y does

not have a disposal system, then a tank of at least 158,400 gallons capacity is required. Since the flow of material would probably be by gravity, the tank would have to be underground. Since this tank would be handling flammable or combustible l iquids i t would require secondary containment per EPA. SUBSTANTIATION: In addition to the unreasonableness of this construction the cost would be prohibit ive. This requirement also seems to border on EPA requirements, rathr than l l f e safety or property conservation. COMMITTEE ACTION: Accept in Principle,


(Log #14) 30- 17 - (4-4.2.5.2, 4-5.7.14): Accept in Principle SUBMITTER: J. William Sheppard, IFPS/NFPA COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Delete 4-4.2.5.2 and 4-5.7.14 in their ent irety. S_~BSTANTIATION: To provide the amount of drainage required by this proposal would entail a considerable expense, and is considered impractical. As indicated by one Committee member's negative bal lot , a holding tank would have to be quite large and in addition to size, a buried tank wi l l require considerable modification to be in compliance with recently enacted envlornmental regulations.

I f fixed suppression systems in the form of carbon dioxide or foam water are used as the primary extingulshln~ agent within these hazards, the need for drainage f a c l l i t i e s are greatly minimized. Viscosity of f luids has a substantial impact on the ab i l i t y of drainage systems to operate properly.

The time element of one hour for the size of the holding tank is not always jus t i f i ab le based on the type of l iquids in use, or the extinguishing agent provided. COMMITTEE ACTION: Accept in Principle.


(Log #2) 30- 18 - (4-4.2.5.2(e)): Accept in Principle ~.]~I_T_T_~_~: Anthony G. Martino, Minneapolis, MN COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: Delete last phrase in last sentence:

" for not less than one hour." Add this phrase in the appendix as a suggested

minimum or eliminate i t ent i re ly. SUBSTANTIATION: Substantiation indicates that the Committee has factual data regarding sp i l l control requirements in f i re incidents. Mr. Roslcky, in his negative vote, implies that i t is unknown whether one hour, two hours or maybe only a half hour is adequate for holding or handling drainage areas. I f something is unknown, i t is better to a) str ike i t ent irely until facts are known, or b) offer i t as a suggested minimum in the appendix ( i t is important - but the degree of importance is uncertain).

I agree with Mr. Rosicky that the NFPA must be careful that code requirements are based on known facts, and not on regulations by governmental units. COMMITTEE ACTION: Accept in Principle.

By means of action on Comment 30-10 (Log #36). COMMITTEE STATEMENT: See Comment 30-I0 (Log #36).

(Log #8) 30- 19 - (4 -5 .6 .4 ) : Accept ~ : Edward Hi ldebrandt , V i l l age of Morton Grove COMMENT ON PROPOSAL NO.: 30-42 RECOMMENDATION: Committee Statement should read:

"See Proposal 30-44 (Log #69)." SUBSTANTIATION: E d i t o r i a l . Provides the correct reference fo r the Committee Statement. COMMITTEE ACTION: Accept.

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(Log #37) 30- 20 - (4-5.6.4): ReJect ~ : Michael S. Gieser, Nash Finch Company COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATIQN: TCR Proposal No. 30-43 (Log #71) wi l l change the effective date of paragraph 4-5.6.4 from September l , 1990, to September l , 1992. Mash Finch Company is opposed to this change in the effective date and urges the NFPA Technical Committee on Flammable and Combustible Liquids to reject Proposal No. 30-43 and retain the current effective date of September hal's]990" SUBSTANTIATION: Factory Mutual Research Corp. pursued tests to assess the f i re safety risks of storing flammable and combustible liquids in plastic containers. The results showed that:

Flammable liquids in plastic containers produce a more severe f i re than similar products stored in metal containers.

Plastic containers in a f i re lose integr i ty faster than metal containers and release the flammable contents.

This creates a spi l l f i re underneath the pal let load and exposes the other cartons that have not ignited yet.

When the other pallets ignite, they create an even larger spi l l f i re .

Flammable l iqu id sp i l l f i res present a severe challenge to spr inklers. COMMITTEE ACTION: ReJect. COMMITTEE STATEMENT: The Committee's opinion is that the extension of the date from 9-1-90 to 9-1-92 is s t i l l j u s t i f i e d for the reasons stated in Proposal 30-43. The additional time wi l l allow further development of both test protocols and inherently safer packaging systems. Also, the Committee points out that this date is a d ~ , not the ~ of compliance.

(Log#38) 30- 21 - (4-5.6.4): ReJect ~ : Greg Heying, Super Valu Stores, Inc. COMMENT ON PROPOSAL NO.: 30-43 RECQMMENDATIQN: TCR Proposal No. 30-43 (Log #71) wi l l change the effective date of paragraph 4-5.6.4 from September 1, 1990 to September I, 1992. Super Valu Stores, Inc. is opposed to this change in the effective date and urges the NFPA Technical Committee on Flammable and Combustible Liquids to reject Proposal No. 30-43 and retain the current effective date of September l , 1990. SUBSTANTIATION: The f i re hazard associated with the storage of flammable and combustible liquids in plastic containers has been clearly substantiated by testing at Factory Mutual, Hughes & Associates and The Scandla Insurance Company of Sweden. Furthermore, flammable and combustible liquids in plastic containers have been major contributors to catastrophic large loss f i res. The forward of NFPA 30 states, "I ts provisions are intended to reduce the hazard to a degree consistent with reasonable public safety, without undue interference with public conveyance and necessity which require use of flammable and combustible l iquids." I t would appear acceptance of this two year extension is in clear opposition to the stated purpose of the flammable and combustible liquids code. Given the documented nature of this problem, i t is inappropriate to further delay the implementation of paragraph 4-5.6.4. I t should be noted that Exceptin No. 2 already permits the acceptance of "approved" packaging systems. This exception wi l l go into effect immediately, as soon as "approved" packaging systems become commercially available. COMMITTEE ACTION: ReJect. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

container can be stored in a general purpose warehouse. Therefore, i t is premature to extend the effective date of Sectin 4-5.6.4 beyond September I, lggo. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #39) 30- 23 - (4-5.6.4): Reject ~ : Steve Ermert, Malone & Hyde COMMENT ON PROPOSAL NO,: 30-43 RECOMMENDATION: Delete TCR Proposal No. 30-43 !4-5.6.4). (Log #71) Change effective date from September ], 1990" to "September 1, 1992."

SUBSTANTIATION: Testin~ has shown that flammable/combustlble llquids in plastic containers represent a severe challenge for standard automatic sprinkler systems and f i re fighters. Any delay in implementing the standard wi l l only provide the opportunity for continued poor f i re experience with flammable/combustible liquids in plastic containers.

In addition, there is no need to delay the implementation to perform further research. Should industry develop an acceptable container, then Exception No. 2 would apply. COMMITTEE ACTION: ReJect. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #58) 30- 24 - (4-5.6.4): ReJect ~ : James D. Camp, McLane Company, Inc. COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: TCR Proposal No. 30-43 (Log #71) wi l l change the effective date of paragraph 4-5.6.4 from September I, 1990, to September I, 1992. The McLane Company, Inc. is opposed to this change in the effective date and urges the NFPA Technical Committee on Flammable and Combustible Liquids to reject Proposal No. 30-43 and retain the current effective date of September I, 1990. SUBSTANTIATION: This proposed change in the effective date wil l create inordinate confusion in the f i e ld . The 1987 Edit ion of NFPA 30 indicates that paragraph 4-5.6.4 w i l l go into ef fect on September l , 1990. I f Proposal No. 30-43 is approved, the 1990 Edition w i l l include on ef fect ive date of September 1, 1992. In a l l l ikel ihood, the 1990 Edition (with the new effective date) wi l l not be published by September I, 1990. As a result, users wi l l be confused as to the real effective date of this paragraph. This problem wi l l be further compounded by the state and local adoption process. For those Jurisdictions that have adopted the 1987 Edition, the September I, 1992 effective date wi l l not become effective unti l the 1990 Edition of NFPA 30 is adopted. The confusion that this situation wi l l create is self-evident.

The f i re hazard associated with the storage of flammable and combustible liquids in plastic containers has been clearly substantiated by testing at Factory Mutual. Furthermore, flammable and combustible liquids in plastic containers have been implicated in several large loss f i res. Given the documented nature of this problem, i t is inappropriate to further delay the implementation of paragraph 4-5.6.4. I t should be noted that Exception No. 2 already permits the acceptance of "approved" packaging systems. This Exception wi l l go into effect immediately, as soon as "approved" packaging systems become commercially available. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #40) 30- 22 - (4-5.6.4J: ReJect SUBHITTER: Henry C. Scuoteguazza, Factory Mutual Research Corp. COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: Revise text back to the original date of September I, 1990. SUBSTANTIATION: Please see my comment on TCR Proposal No. 30-44. I argue that the proposed test methodology is not suitable for determining whether a plastic

(Log #46) 30- 25 - (4-5.6.4): None ~ : Richard Gottwald, Society of the Plastics COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: SPI supports the Committee Action to change the effective date from September I, 1990 to September I, 1992 (Proposal 30-43, Log #71). A recent large scale test has further substantiated the work showing that flammable l iquid fires can be controlled

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using specific packaging scenarios. Changing the effective date wi l l allow manufactures time to implement the necessary changes into their packages. SUBSTANTIATION: None. COMMITTEE ACTION: None. COMMITTEE STATEMENT: No change to text is recommended by the submltter.

(Log #12) 30- 26 - (4-5.6.4): Reject }_~L~I~ITTER: George W. Schiele, Arnox Corporation COMMENT ON PROPOSAL NO.: 30-71 RECOMMENDATION: Do Not change effective date from September I, Iggo to September l , 1992 for containers of flammable and combustible liquids of I Quart or less; CHANGE effective date from September I, 1990 to September I, 1991 for containers of flammable and combustible liquids larger than 1 Quart. ~STANTIATION: An acknowledged high-order hazard which can otherwise be reduced in September 1990, wi l l be needlessly continued. Placing thousands of warehouses and bi l l ions of dollars of property and some unknown number of l ives at risk for an aditlonal two years without over-riding cause is contrary to the public interest.

The arguments for delay put forward by Mr. Buck and accepted by the Committee wi l l s t i l l apply in 1991 and at al l times subsequent. The packaging industry, having responded with technology and capital investment to the need stipulated by the original regulation and effective date, cannot reasonably be ent i rely stopped at this juncture and asked to restart i ts efforts in future; when yet another delay can just as easily be proposed.

I f For any reason the membership cannot support adherence to the original effective date of September I, 1990, staging the effective date by some form of product classlf lcation would mitigate the damage otherwise imposed on the packaging industry and on the prospects for implementing the requirement i t se l f .

I t is therefore proposed: Recommendation: Do Not change effective date from

September I, 1990 to September I, 1992 for containers of flammable and combustible liquids of I Quart or less; change effective date from September I, 1990 to September I, 1991 for containers of flammable and combustible liquids larger than l quart. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #13) 30- 27 - (4-5.6.4): Reject ~ : George W. Schiele, Arnox Corporation COMMENT ON PROPOSAL NOt: 30-71 ~QMMENDATION: Do not change effective date from "September l , 1990 to September l , 1992." SUBSTANTIATION: Tests have demonstrated that f ires involving flammable and combustible liquids in plastic containers can be controlled in general purpose warehouse environments and under various packaging parameters.

I t was proposed by Daniel M. Buck, Air Products and Chemicals, Inc., and accepted by the Committee, that "An extension of this effective date" (to September I, 1992) "wi l l allow formulators and container suppliers to develop appropriate container configurations to meet the revised f i re safety codes and allow material suppliers to scale up to meet market demands. . . and allow nationally recognized f i re safety laboratories to test specific packaging configurations to determine compliance."

As agreed by the proposer and the Committee, i t has been demonstrated that f ires involving flammable and combustible liquids can be controlled in general purpose warehouse environments by appropriate f i re resistant packaging.

(I) No substantial technical problem remains which wi l l prevent the use of existing, tested products to meet the requirement by the original implementation date of September I, 1990.

(2) Significant commercial f i re resistant packaging production capacity is already in place as a result of government packaging requirements implemented in 1988. There is no scale-up l im i t within the packaging industry which wi l l prevent the production of f i re resistant corrugated boxes in adequate quantities to meet NFPA 30 requirements by the original implementation date.

(3) Should the implementation of the regulation be delayed to September, 1992 (a) no significant further technical progress is l i ke ly to be made with the mere passage of additional time, and (b) the packaging industry cannot economically jus t i f y the scale-up of commercial production for NFPA 30 demand more than one year before the effective date: be i t now for 1990 or in two years from now for the proposed 1992 date.

(4) The packaging industry wi l l be damaged and discouraged i f the additional capacity already planned for instal lat ion in 1989 ~n response to the 1990 implementation date is rendered premature and/or useless by a two year delay. Instead of promoting the orderly ava i lab i l i t y of product, an implementation delay makes i t less l i ke ly that capacity wi l l be available fo the 1992 date.

(5) An acknowledged high-order hazard which can otherwise be reduced in September 1990, wi l l be needlessly continued. Placing thousands of warehouses and bi l l lons of dollars of property and some unknown number of l ives at risk for an additional two years without over-riding cause is contrary to the public interest.

(6) The arguments for delay put forward by Mr. Buck and accepted by the Committee wi l l s t i l l apply in 1991 and at al l times subsequent. The packaging industry, having responded with technology and capital investment to the need stipulated by the original regulation and effective date, cannot reasonably be entirely stopped at this juncture and asked to restart i ts efforts in future; when yet another delay can just as easily be proposed.

I t is therefore proposed: Recommendation: Do not change effective date from

"September I, 1990 to September I, 1992." COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #48) 30- 28 - (4-5.6.4): Reject ~ : Richard G. Gewain, Hughes Associates, Inc. COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: Reject Proposal 30-43 and revert to original effective date, change from September l , 1992 to September I, 1990. SUBSTANTIATION: Adequate test data does not exist to demonstrate that f ires involving flammable l iquid storage in plastic containers can be controlled in general purpose warehouses. No fu l l scale test results have been presented to substantiate this position. Existing published data from FMRC and AISI indicate that control of flammable l iquid f ires in plastic containers is very d i f f i cu l t to achieve. The NFPRF/UL test data is for laboratory mockups of such storage. Furthermore, granting an additional delay to the three years already embodied in the 9/I/90 deadline is not just i f ied. These issues should have been resolved before these products were introduced to the market. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #18) 30- 29 - (4-5.6.4): Reject ~J~T~_R: Robert C. Coleman, Brockway Standard, Inc. COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: Change effective date from "Septembe F l , 1990" to "September I, 1992." SUBSTANTIATION: Effective testing by rel iable

• laboratories has clearly demonstrated that available metal packaging for flammable and combustible liquids strongly resists involvment in a f i re while plastic packaging promotes the spread of f i re and obscures the f i re scene with black, noxious smoke making f i re

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f ighting almost impossible. The probabil i ty of incurr ing another mult i -mi l l ion do l l a r loss and potential loss of l i f e is increased unreasonably by this extension. COMHITTEE ACTION: Reject. COMMITTEE ~TATEME~: See Comment 30-20 (Log #37).

(Log #19) 30- 30 - (4-5.6.4): Reject ~ : Robert C. Coleman, Brockway Standard, Inc. COMMENT ON PROPOSAL NO.: 30-43 RECOMMENDATION: Change effective date from "September I, 1990" to "September I, 1992." SUBSTANTIATION: I t has been my experience as a suppl ier that exclusion from a piece of business un t l l I "mended by ways," provoked a fas ter reso lu t ion to an existing problem. The plastic container industry has had a decade to ponder the po ten t ia l impact of t h e i r products in a warehouse f i r e v i s a v is The Pathmark Fire in 1979. This was demonstrated again with the K-Mart Fire four years later. The probabil i ty of incurring another" mult i -mi l l ion dol lar loss and potential loss of l i f e is increased unreasonably by this extension. COMMITTEE ACTION:: Reject. COMMITTEE STATEMENT: See Comment 30-20 (Log #37).

(Log #42) 30- 31 - (4 -5 .6 .4) : None B H ~ : Damon W. Snow, The Society of the Plast ics Industry COMMENT ON PROPOSAL NO.: 30-43 and 30-44 RECOMMENDATION: The Society of the Plastics Industry supports the action of the NFPA 30 Technical Committee taken on code change Proposal 30-44 (Log #69). The proposal, submitted by 3ohn F. Thorne of VanLeer Containers, was accepted in principle.

Since the proposal was f i led, the National Fire Protection Research Foundation research project on flammable l iquid container storage has conducted another large scale test. The test, on four pallets of gallon containers of isopropanol, again involved exposing the containers to a small ignit ion source. The resulting l iquid f i re was controlled by sprinklers - as had been predicted in an ear l ier small scale test.

Based on the latest results, we have requested a third party l i s t ing agency to develop a program under which packaging systems can be tested using the NFPRF Lest protocol. Those systems that pass the test c r i te r ia may then be l isted and labeled by the agency.

SPI also supports the Committee Action to change the effective date from September l , 1990 to September 1, 1992 (Proposal 30-43 (Log #7])). The recent large scale test has further substantiated the work showing that flammable l iquid f ires can be controlled usin~ spec i f ic packaging scenarios. Changing the e f fec t i ve date w i l l a l low manufacturers time to implement the necessary changes in to t h e i r packages. SUBSTANTIATION: None. COMMITTEE ACTION: None. C Q ~ ~ E N T : The submitter does not propose any changes to the text.

assumptions or heaps of f a i t h . Water was appl ied by an array of spray nozzles allegedly simulating the pattern from an automatic sp r ink le r system. The spray system was not located at t yp ica l storage array to spr ink le r head clearances, nor were typical sprinkler spray pattern densities or drop size distributions or v e l o c i t i e s used. Hence, there is no confidence that sprinkers w i l l control these f i r es , only confidence that the spray system used wi l l control these f ires.

A second major assumption is in relating activation time to c r i t i c a l f i r e size. The method proposed in the TCR uses a computer model of sp r ink le r actuat ion. The method proposed in the TCR assumes that i f the predicted ac t i va t i on time occurs before a c r i t l c a l f i r e size is reached (beyond which the f i r e cannot be con t ro l l ed ) , then f i r e control w i l l be achieved. This assumes a very r e l i a b l e and/or very conservative est imat ion of ac t i va t i on time. DETACT assumes smooth, f l a t ce i l ings with no obstruct ions. This is not general ly the case. Furthermore, no analysis of the s e n s i t i v i t y of the approval to inaccuracies in the method was performed.

These two major untested assumptions cast serious doubt on the e f f icacy of the proposed approval method. Unless and unti l fu l l scale ver i f icat ion test resul ts are provided the exception should not be permitted.

NOTE: Hughes Associates has been retained by the American Iron and Steel Inst i tute to evaluate proposed changes to NFPA 30 and to respond as appropr iate. COMMITTEE ACTION: Accept in Part .

(a) Reject. (b) Accept in Principle. Revise proposed A-4-5.6.4

to read: A-4-5.6.4 Based on work done by the Factory Mutual

Research Corp., i t was determined that flammable l i qu ids in p las t i c containers could cause uncont ro l lab le f i r es under cer ta in condit ions of storage in general purpose warehouses. A research pro jec t carr ied out by Underwriters Laborator ies, Inc. , under the auspices of the National Fire Protect ion Research Foundation, on flammable l i qu ids container storage has suggested a tes t protocol which can judge the capabil ity of packaging systems to withstand a small ignit ion source or to minimize the rate at which the lading is released from the containers, so that the f i re can be controlled by automatic sprlnklers.

There is currently (as of December, 1989) no nationally-recognized consensus standard for conducting such tests. COMMITTEE STATEMENT: (a) The submitter's substantiation for deleting Exception No. Z is based on a presumption that the Research Project was not complete. The Committee's position is that the Exception is not dependent on the resul ts of the Research Project . By means of the Exception, the Committee wishes to provide an incent ive for the development of inherently more f ire-safe packaging systems.

(b) The Committee agrees that the or ig inal ly proposed Appendix item was too deta i led and assumed that the Research Project would identi fy a standard test protocol. The proposed rewording of the Appendix item correctly describes the status of the research conducted to date.

(Log #49) 30- 32 - (4-4.6.4 and A-4-5.6.4): Accept in Part B~S_U_~e~TJ_T_E_~: R/chard G. Gewain, Hughes Associates, Inc. COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: a. Delete the proposed revision of section 4-5.6.4, Exception 2.

b. Delete A-Zi-5.6.4, Exception 2. SUBSTANTIATION: The work done by the NFPRF and referenced in the TCR is incomplete. The documentation provided to us describes laboratory mock-up tests of plastic container storage arrays and a single ver i f icat ion test. The approach described in the TCR hinges on the ab i l i t y of a sprinkler system located near the roof/cei l ing to actuate and control a f i re in plastic container/flammable l iquid storage arrays, before the f i re exceeds a cr i t ica l threshold size. The proposed method requires one to accept two major

(Log #16) 30- 33 - (4-5.6.4): Reject SUBMITTER: Salvatore A. Gilardi Jr. , American Insurance Service Group COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: Reject Comment 30-44. SUBSTANTIATION: At present time there are no approved packaging systems ava i l ab le . This should not be included in the standard unti l there is a test procedure in place. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: See Comment 30-32 (Log #49).

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(Log #50) 30- 34 - (4-5.6.4 and A-4-5.6.4): Accept in Principle ~ : Richard G. Gewain, Hughes Associates, Inc. COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: a. Delete A-4-5.6.4, Exception No. 2.

b. Delete the proposed rev is ion of Section 4-5.6.4, Exception 2. SUBSTANTIATION: The proposed acceptance protocol hinges on major assumptions and simplifications relative to ignition source strength and location and storage array and geometry.

The acceptability of such storage is very sensitive to the type of ignition source, i ts strength and location. Based on the referenced UL/NFPRF reports, no work was done on the relevance of the igniter used or the sensit ivity of the test results to varying ignition locations or source strengths. Since the approval method is part ia l ly driven by the selection of the ignition source parameters, this appears to be a serious shortcoming.

As a minimum, the relevance of the igniter chosen to typical storage condition ignition scenarios should be established. Preferably alternative ignition methods should be evaluated. A partial l i s t of ignition variables includes:

(a~ Igniter heat flux to package surface (I0-50 kw/m ) to account for various types of exposure fires from ignition of incidental combustibles.

(b) The ignition source should be sized to represent the largest exposure f i re that can be sustained without operating the installed automatic sprinkler system.

(c) An ignition scenario involving the spillage of I/2 to l gallon of flammable liquid adjacent to and under the plastic storage of flammable liquid array.

This range of variation in ignition scenario is entirely possible. I t is imprudent and premature to base an entire approval protocol on the relatively small and unrealistic ignition source chosen, especially when the ignition source can be reasonable expected to have substantial impact on the test results.

The second set of issues concerns th= storage array and geometry. Representative storage arrays are not defined in the Appendix. Full scale testing conditions, i .e. number of pallets, location, igniter, ceiling height, etc. are also not defined. I t is not possible to evaluate the efficiency of the proposed acceptance procedure without such detail.

Until such issues are resolved and publicly available documentation (for fu l l scale tests) is provided, i t is premature to specify this approval protocol.

NOTE: Hughes Associates has been retained by the American Iron and Steel Institute to evaluate proposed changes to NFPA 30 and to respond as appropriate. COMMITTEE ACTION: Accept in Principle.


(Log #41) 30- 35 - (4-5.6.4): Reject SUBMITTER: Henry C. Scuoteguazza, Factory Mutual Research Corp. COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: Delete recommended change to paragraph 4-5.6.4, Exception No. 2. SUBSTANTIATION: The proposed revision to paragraph 4-5.6.4, Exception 2 would allow the use of a three-pronged test method for determining the sui tabi l i ty of plastic containers for flammable liquid storage. There are serious questions about the adequacy of these tests.

I. Single face array. This is not representative of the real world conditions under which such containers would be stored nor does this array reproduce the re-radiation effect that is created when two pallets are located close to one another. In the typical warehouse these products wil l be stored next to one another or next to other commodities such as to i le t tissue or plastics. A f i re that started in these commodities can provide a significant exposure to the flammable liquids. A second way these liquids can become involved in a f i re is by a spi l l created by a leaking or punctured container. The test method, which uses a single igniter placed on the bottom of the face of the pallet, does not duplicate this.

At the meeting where th is proposal was accepted, i t was claimed that th is re - rad ia t i on e f fec t may be a worst case exposure for ordinary cardboard boxes but not for f i re retardant boxes. I t was also claimed that a single face was a more severe exposure for f ire retardant cartons. This is false. This implies that the basic principles of f i re behavior do not apply to f i re retardant cartons.

This procedure also does not create the flues which exist in actual storage. Test experience has shown that a f i re wil l grow more rapidly and be more severe with parallel faces than with a single face because the energy release is absorbed by the exposed face which causes i t to burn and expose the other face. This mutual feedback of energy, as well as the chimney effect created by the flue, causes the f ire to grow more quickly and release more heat. This is a basic concept in f i re testing, yet this was not applied in this method.

Similar comments can be made for the test on the 55 gal drum. Additionally, the test report upon which the proposal was made, suggests that drums are not a problem because the drum did not burn. This was due to having an unrealistic igniter and the lack of a flue. The typical loss involving drums occurs when a drum leaks, usually due to spearing by a fork l i f t . This creates a spi l l f i re which then exposes the undamaged drums. We have recently conducted a test involving several plastic drums containing a combustible powder. The drums were placed to create a flue typical of what would be found in a warehouse, Igniters were placed between the drums. A significant f i re resulted which burned through the drums and spilled the contents. I f the drums had contained flammable l iquid, a severe spi l l f i re would have been created. Since the test method does not duplicate this condition, the results do not represent the actual warehouse situation.

2. The second part of the test_uses a water applicator to spray a 0.30 gpm/ft Z density on top_of the array. This is not the same as a 0.30 gpm/ft Z density coming out of ceiling sprinklers. To create the 0.30 density on top of the storage, the ceiling sprinklers have to discharge much more, at least two to three times. This is due to the intense f i re plume created by flan~able liquid fires which vaporizes or blows away much of the water being discharged from ceiling sprinklers.

Section 4-5.6.3 under General Purpose Warehouses, allows certain quantities of flammable liquids to be stored in the warehouse i f the sprinklers are designed according to the cr i ter ia for a ClasA IV commodity (per NFPA 23X this would be a 0.19 gpm/ft ~ density over a 2900 f t ~ operating area). This protection cri teria is significantly less than the density used in this part of the test. Thus, a container that performs well in this test could s t i l l cause problems when stored in warehouses which, i f designed according to Section 4-5.6.3, wi l l have a much lower ceiling density. Therefore, this part of the test method does not represent the conditions that wi l l be found in actual warehouses.

There are problems with the DETACT model that was used to determine sprinkler actuation. The DETACT computer code for calculating sprinkler/detector atuatlon times has several limitations that render i t inappropriate for use in this test. First, the version DETACT-QS used in these tests is based on a quasi-steady approximation of the ceiling gas flows. This quasi-steady approximation is not valid for the rapid f i re development that occurs when flammable liquid is released from plastic containers. The error involved in using the quasi-steady correlation can cause the calculated sprinkler opening to be ten or more seconds earl ier than the actual opening in a fast growing f i re.

Second, the original ceiling flow correlation was based on theoretical heat release rates (100 percent combustion efficiency), while the test generates chemical heat release rates with the actual combustion efficiency.

Third, the computer code neglects conduction heat losses from the sprinkler l ink to the sprinkler frame. These conduction heat losses can be substantial and delay the actual sprinkler opening time in slow growing fires that may occur i f f i re retardant cardboard is the primary fuel involved.

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Fourth, the correlation in DETACT does not account for the depth of the sprinkler below the ceiling. Pendent sprinklers are often located sufficiently far below the ceiling for their opening times to be substantially later than the calculated opening times. All of these limitations can be overcome with more recent correlations and computer codes. When the more real ist ic code is run for a typical single-face test wlth f i re retardant cartons, the sprinkler actuation is delayed about 17 minutes from what DETACT calculates.

Pass/fail cr i ter ia needs to be established for using the rate of heat release (RHR) curve. For instance, i t is possible that after water is applied the RHR would level off, indicating a steady-state f i re. This should be interpreted as a failure because a larger array of flammable liquid or even other commodities mixed in would become involved in the f i re and cause the RHR to increase. The wording of the proposal could be interpreted to mean a f la t RHR curve is a success.

Also, there is no proven method to relate sprinkler RTIs to sprinkler performance without also tying in the discharge, distribution and penetration characteristics of the sprinkler to address the specific challenge posed by the hazard being protected. To date, there are no sprinklers: in the suggested RTI range which have been either designed or evaluated to ensure that they possess the characteristics needed to perform in the manner intended hy Proposal 30-44.

3. The third part of the proposed method claims to use a "large scale" test consisting of four pallets. The ceiling density is 0.30 gpm/ft ~. The f i rs t thing to note is that ~:his density is not the same as the one used in part (b). The cr i ter ia for success is to open no more than the third ring of sprinklers. I f these are spaced tO f t by I0 f t - - a typical sprinkler spacing - - thls means 29 sprlnkle~s wil l have opened over an operating area of 2900 f t ~. The f i re test uses only four pallets or about 800 gallons maximum. Although Section 4-5.6.3 allows only 660 gallons of Class IB and IC flammable liquids in a general warehouse, i t also allows 1375 gallons of Class I I liquids, which m~ans the quantity of liquids found in a warehouse could be at least 3 pallets more than what was tested. Adding the additional pallets of flammable liquids would probably extend the operating area beyond this.

Lastly, the igniter used is not real ist ic in relation to the hazard being protected. A "sp i l l " f i re was suggested as being more representative of the hazard under scrutiny. However, the suggestion was rejected because such an exposure would almost certainly result in failure. To base a protocol on a scenario which represents neither the real world or the documented field experience does an extreme disserve to al l parties involved with the eventual use of this standard.

The technical data does not support the proposal. COMMITTEE ACTION: Reject. COMMITTEE STATEMN~_T: See Comment 30-32 (Log #49).

(Log #51) 30- 36 - (A-4-5.6.4 Exception 2(b)): Accept in Pr inc ip le SUBM~ITTER: Ph i l i p J. DiNenno, Hughes Associates, Inc. COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: Delete A-4-5.6.4 Exception 2(b). SUBSTANTIATION: DETACT is a computer program which uti l izes correlatlons of ceiling jet velocity and temperature as a function of radial position from the f i re. The correlations original ly developed by Alpert (I) are based on a theoretical and comparison with 7 large scale tes~:s in buildings similar in scale to warehouses. The original work was done assuming f lat , smooth, unobstructed ceilings.

The proposed approval procedure depends very strongly on predicting accurately the actuation time of the sprinkler relative to the f l re growth of the f i re. These fires exhibit very rapid rates of increase in heat release rate. Hence errors in the prediction of the actuation time wi l l have substantlal impact on the assumed size of the f i re at the time of actuation. The test protocol depends quite strongly on applying water to the f i re at or below a specific point in the f i re growth curve. Differences in actuation time of I0-20 seconds can inrease the f i re size at activation by 300 to 400 percent.

There is sufficient uncertainty in the accuracy of the predictions in the situations of interest to require additional work to establish these accuracy bounds and to relate the sensit ivity of the test procedure to the accuracy of the method.

The method is approximate in high ceiling areas for the application anticipated in this approval procedure for the following reasons:

(1) The development and analysis assumes f lat , smooth, unobstructed and unconfiend ceilings.

(2) Testing of the DETACT model in high ceiling spaces has been very limited.

(3) The DETACT model does not account for variations in ceiling je t temperature and velocity across a vertical profi le. I t is well known that the temperature and velocity of the jet varies as one moves down with the ceiling (I-3). The DETACT model uses correlations of peak values of temperature.

I f the sprinkler head is not located at a distance from the ceiling corresponding to the position where these peak values occur, the response/actlvation time wil l be mispredicted. The sprinkler head wil l activate slower than predicted, the f i re size wil l be much larger than tested against (since these fires grow very rapidly) and the f i re wil l not be controlled. COMMITTEE ACTION: Accept in Principle.


(Log #52) 30- 37 - (A-4-5.6.4 Exception 2(b)): Accept in Principle SUBMITTER: Philip O. DiNenno, Hughes Associates, Inc. COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: I f previous comments to delete A-4-5.6.4 Exception 2(b) is rejected, add to A-4-5.6.4, Exception 2(b): This use of DETACT is limited to the following:

l) Smooth, f la t , unobstructed and unconfined ceilings.

2) The spr ink le r head to ce i l i ng clearance corresponds to a locat ion in the ce i l l ng Jet where maximum temperature and v e l o c i t y condit ions occur.

3) The storage of flammable and combustible liquids is not against a wall or in a corner.

4) There is no forced or natural ventilation openings near the ceiling which can intefere with the ceiling je t caused by the f i re.

5) When differences of 10-20 percent in predicted versus actual actuation time wi l l result in f i re sizes in excess ~f those tested for sprinkler densltltes of , 0.3 gpm/ft C. SUBSTANTIATION: There are several assumptions, limitations and areas of uncertainty on the accuracy of DETACT particularly in high ceiling spaces. This is especially important where the f i re growth rates are very high. The proposed wordinv bounds the use of DETACT to condit ions corresponding to i t s known range of val id i ty .

DETACT is a computer program which uti l izes correlations of ceiling je t velocity and temperature as a function of radial position from the f ire. The correlations originally developed by AIpert (1) are based on a theoretical and comparison with 7 large scale tests in buildings similar to scale to warehouses. The original work was done assuming f lat , smooth, unobstructed ceilings.

The proposed approval procedure depends very strongly on predicting accurately the actuation time of the sprinkler relative to the f i re growth of the f i re. These fires exhibit very rapid rates of increase in heat release rate. Hence errors in the prediction of the actuation time wi l l have substantial impact on the assumed size of the f i re at the time of actuation. The test protocol depends quite strongly on applying water to the f i re at or below a specific point in the f i re growth curve. Differences in actuation time of I0-20 seconds can increase the f i re size at activation by 300 to 400 percent.

There is sufficient uncertainty in the accuracy of the predictions in the situations of interest to require additional work to establish these accuracy bounds and to relate the sensit ivity of the test procedure to the accuracy of the method.

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The method is approximate in high cei l ing areas for the application anticipated in this approval procedure for the following reasons:

(1) The development and analysis assumes f l a t , smooth, unobstructed and unconfined ceil ings.

(2) Testing of the DETACT model in high cei l ing spaces has been very l imited.

(3) The DETACT model does not account for variations in cei l ing je t temperature and velocity across a vert ical prof i le . I t is well known that the temperature and velocity of the je t varies as one moves down from the cei l ing (I-3). The detact model uses correlations of peak values of temperature.

I f the sprinkler head is not located at a distance from the cei l ing corresponding to the position where these peak values occur, the response/activation time wi l l be mispredicted. The sprinkler head wi l l activate slower than predicted, the f i re size wi l l be much larger than tested against (since these f i res grow very rapidly) and the f i re wi l l not be controlled.

(4) There is no way to account for natural or mechanical vent i lat ion effects on the temperature of the cei l ing Jet or activation time of the f i r s t sprinkler.

(5) The effects of materials stored in corners or against walls have not been established.

These l imitat ions and assumptions must be considered relat ive to the use of DETACT in the approval procedure.

At this point in time the state-of-the art does not permit predictions of activation time in high cei l ing spaces (>20 f t ) with suff ic ient confidence to permit the use of such predictions in establishing the size of the f i re at the time of sprinkler activation.

NOTE: Hughes Associates has been retained by the American Iron and Steel Inst i tu te to evaluate proposed changes to NFPA 30 and to respond as appropriate.

REFERENCES: (1) AIpert, R. L., "Turbulent Ceiling-Jet by

Large-Scale Fires," Combustion Science and Technology, 1973, Vol 17 pp 197-213.

(2) Evans, D. D., Stroup, David W., "Methods to Calculate the Response Time of Heat and Smoke Detectors Installed Below Large Unobstructed Ceil ings," NBSIR 85-3167, NBS, Washington, DC, July 1985.

(3) Cooper, L. Y., Stroup, David W., "Test Results and Predictions of Near Ceiling Sprinkler Links in a Full-Scale Compartment Fire," NBSIR 87-3633, NBS, Gaithersburg, MD, Sept. 1987. COMMITTEE ACTION: Accept in Principle.


(Log #47) 30- 38 - (4-5.6.4 Exception No. 2): None SUBMITTER: Richard Gottwald, Society of the Plastics Industry COMMENT ON PROPOSAL N~).: 30-44 RECOMMENDATION: The Society of the Plastics Industry supports the action of the NFPA 30 Technical Committee taken on Code change Proposal 30-44 (Log #69). The proposal, submitted by John F. Thorne of Van Leer Containers was accepted in principle.

Since the proposal was f i led , the National Fire Protection Research Foundation research project on flammable l iquid container storage has conducted another large scale test. The test, on four pallets of gallon containers of isopropanol, again involved exposing the containers to a small ignit ion source. The resulting l iquid f i re was controlled by sprinklers - as had been predicted in an ear l ier small scale test.

Based on the latest results, we have requested a third party l i s t i ng agency to develop a program under which packaging systems can be tested using the NFPRF test protocol. Those systems that pass the test c r i te r ia may then be l isted and labeled by a nationally recognized testing laboratory. SUBSTANTIATION: None. COMMITTEE ACTION: None. COMMITTEE STATEMENT: The submitter does not propose any changes to the text.

(Log #9) 30- 39 - (A-4-5.6.4 Exception 2): Accept SUBMITTER: Edward Hildebrandt, Vil lage of Morton Grove COMMENT ON PROPOSAL NO.: 30-44 RECOMMENDATION: Revise the Commitee Action for A-4-5.6.4(c) so that the f i f t h l ine of (c) reads:

"RTI on lO f t centers . . ." SUBSTANTIATION: Edi tor ia l . Reference should be to lO f t centers, not lO in. centers. COMMITTEE ACTION: Accept.

(Log #15) 30- 40 - (4-5.7.15 (New)): Hold for Further Study ~ : Richard Y. LeVine, CHEC Inc. COMMENT ON PROPOSAL NO.: 30-39 RECOMMENDATION: New text:

A-4-5.7.15 Drums of flammable l iquids and/or l iquefied gases with NFPA 704 Health Hazard Ratings of 3 or 4 and/or react iv i ty ratings of 2, 3 or 4 shall not be stored in l iquid warehouses without automatic sprinklers or automatic extinguishing systems approved by the authority having jur isd ic t ion,

Drums of flammable l iquids and/or l iquefied gases with Reactivity Ratings of 3 or 4 shall be stored in dedicated warehouses suitably detached on the basis of the quantity distance principal used for explosive materials. SUBSTANTIATION: The indiscriminate mixing of ordinary flammable hazards with high toxic hazard material or high react iv i ty materials which are also flammable l iquids or flammable l iquefied gases is a practice that must eventually result in either a catastrophic release of toxic materials or catastrophic explosion. Safety minded chemical companies do not do this on their own premises but warehouses o f f -s i te and hazardous waste warehouses condone this practice because there is nothing in HFPA 30 to prohibi t i t . COMMITTEE ACTION: Hold for Further Study. COMMITTEE STATEMENT: This recommended text constitutes new material that has not been subject to public review and comment.

(Log #44) 30- 41 - (4-7.5): Reject ~ : David C. Tabar, The Sherwin-Williams Company COMMENT ON PROPOSAL NO.: 30-48 RECOMMENDATION: Change the (New) proposed 4-7.5 as follows, along with a new 4-7.6:

4-7.5 Where flammable l iquids are stored, area classi f icat ion shall be made in accordance with NFPA 505, Fire Safety Standard for Powered Industrial Trucks.

4-7.6 Where Class I flammable l iquids are stored in excess of the permissible quantities ident i f ied in NFPA 30 4-5.6.3, and the area classi f icat ion is determined to be "Ordinary" or "Unclassified," only powered industrial trucks l isted or approved as EE, DY, or EX may be ut i l ized to transport such commodities. SUBSTANTIATION: There is a need for the Flammable and Combustible Liquids Code to make a clear reference to HFPA 505. A new 4-7.6 is part icular ly necessary, as most warehouses and mercantile occupancies throughout North America have not classif ied areas where flammable l iquids are stored as "Class I Group D Division 2" areas, which would subsequently warrant a "Hazardous" electr ical determination.

Since area classi f icat ion in warehouses ultimately impacts alarm pull stations, dock area, electr icals and al l building wiring, an arbitrary area classif ication as "Hazardous" could require signif icant electr ical upgrades beyond powered industrial trucks.

Since there has been a handful of major f i re losses where the igni t ion source has appeared to be the powered industrial truck, i t ' s time that the Code shoul say what i t means by dealing d i rect ly with the problem; tht is, to require EE and DY (minimum) powered industrial trucks only. This also conforms with Factory Mutual and Industrial Risk Insurers current standards, and at the same time, wi l l remove the opportunity for vagueness. Further, the suggested change wi l l prevent the misuse of the "ES," "LPS" and "DS" vehicles (considered acceptable by OSHA) which are not intended for use in a "Class I Group D Division 2" area.

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As a side note Mr. Hi ldebrandt 's suggestion change, whi le commendable, would not have served to prevent the Dayton, Ohio f i re loss. That warehouse was provided with ordinary wiring throughout . . . and had never been classified e lect r ica l ly as "hazardous" by the local authority, insurance carrier, or property owner. Therefore the mixed use of Underwriters Laboratories l isted "E," "ES" and "EE" vehicles met code, I t ' s time that this be changed, and that the Code deal direct ly with the specific type of vehicle necessary for flammable l iquid storage areas. COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: NFPA 505 does not have responsibil i ty for area classif ication. Proposed 4-3.6 conflicts with NFPA 505.

(Log #26) 30- 44 - (4-9.2) : Accept ~ : R. I . Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.2 (New), f i r s t sentence to read as fo l lows:

"The design and construct ion of a locker shall meet a l l appl icable l oca l , state and federal regulat ions and requirements and shal l be subject to the approval of the au tho r i t y having j u r i s d i c t i o n . " SUBSTANTIATION: Revised language to agree with proposed rev is ion to d e f i n i t i o n of hazardous mater ia ls storage locker (Docket No. ), p r imar i l y to include "s ta te regu la t ions , " i f appl icable. COMMITTEE ACTION: Accept.

(Log #54) 30- 42 - (4-8.2): Accept in Part ~ : Rodney A. McPhee, Canadian Wood Council COMMENT ON PROPOSAL NO.: 30-49 RECOMMENDATION: I) In (a) i t should be c lar i f ied as to whether the Fire resistance rating is required from the inside, outside, or both, depending on the intent.

2) Delete the Exception. SUBSTANTIATION: (The text) I t suggests that by providing noncombustible construction, not necessarily having a f i re resistance rating, i t w i l l provide a level of f i re safety equivalent to other types of construction having a rating of 2 hours. Unprotected l ight frame steel construction (noncombustible construction) may only provide up to 10 min. of structural f i re resistance (thermal transmission of f i re may occur much sooner).

In regards to the l imits on openings adjacent outdoor storage, i t seems to be nonsensical to restr ic t openings in certain buildings to prevent the collection of flammable vapors in the in ter ior of the building while waiving al l restrictions on openings (even i f they lead to a basement) simply because the building is of noncombustible construction. Openings in exterior walls of any building housing indoor storage should not be restricted simply on the basis of construction type. COMMITTEE ACTIOFF: Accept in Part.

I. Accept in principle by adding the word "exterior" before the words " f i re resistance" in 4-8.2(a).

2. Reject. COMMITTEE STATEMENT: The action taken in (I) meets the submitter's intent. Rejection of item (2) is based on the fact that the adjacent building is primarily a liquids warehouse and poses an equal exposure hazard to outdoor storage as the outdoor storage does to the building.

(Log #4) 30- 43 - (4-9.1, 4-9.3.4.2 and Table 4-9.3): Accept ~ : Edward Hildebrandt, V i l l age of Morton Grove COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: 4-9.1: Change the las t word in the th i rd l i ne to " lockers . "

4-9.3.4.2: Change the las t word in the second l i ne to "s i te ."

Table 4-9.3: Revise the heading of the f i r s t column to read:

Area of Designated Site

(1) (sq f t )

SUBSTANTIATION: The suggested changes wi l l correct a spelling error in 4-9.1; make 4-9.3.4.2 consistent in wording with the remainder of the section; and the chan~e to Table 4-9.3 column heading wi l l c lar i fy the meanlng of the column by eliminating any confusion between the word "design" and the abbreviation of designated (design). COMMITTEE ACTION: Accept.

(Log #27) 30- 45 - (4-9.2.1): Accept B=S~I~I_U_F=_R: R. I . Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.2.1 (New), second sentence to read as follows:

"Vertical stackin~ of lockers shall not be permitted." SUBSTANTIATION: Edltorial c lar i f icat ion, COMMITTEE ACTION: Accept.

(Log#28) 30- 46 - (4 -9 ,2 .5 .2) : Accept SUBMITTER: R. I . Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: 4-9.2.5.2 (New) regarding container storage should be deleted from the section and addressed under 4-9.3.4 Storage Practices. SUBSTANTIATION: I t seems out of place to address the subject of container storage under section 4-9.2.5, Sp i l l or Leakage Control . Paragraph 4-9.3.4.1 adequately addressed the subject of container storage, as proposed. COMMITTEE ACTION: Accept.

(Log #29) 30- 47 - (4-9.3): Accept SUBMITTER: R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.3 (New) to read as follows:

"Designated sites shall be provided for the location and use of lockers and shall be subject to the approval of the authority having jur isdict ion. The designated sites shall be arranged to provide at least the minimum separation distance between individual lockers, distance from locker to property l lne that is or can be bui l t upon and distance from locker to nearest side of public ways or to important buildings on the same property, as given in Table 4-9.3 and explanatory notes 1, 2, 3 and 4 as app l icab le . " SUBSTANTIATION: Editorial to c lar i fy original intent. COMMITTEE ACTION: Accept.

(Log #30) 30- 48 - (4-9.3.1): Accept in Principle ~VBMITTER: R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.3.1 (New) to read as follows:

"Once the designated site is approved, the locker(s) located thereon, shall not be relocated or moved without the approval of the authority having jur isdict ion." SUBSTANTIATION: Editorial c lar i f icat ion of intent. COMMITTEE ACTION: Accept in Principle.

Revise 4-9.3.1 to read: "Once the designated site is approved, i t shall not

he changed without the approval of the authority having jur isd ic t ion." COMMITTEE STATEMENT: Lockers can be moved around within the designated site. I t is the site i t se l f that must be approved, i f changed.

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(Log #31) 30- 49 - (4-9.3.2): Accept ~_V_BMITTER: R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.3.2 (New) to read as follows:

"More than one locker shall be as permitted on a designated s i te , provided that separation distance between individual lockers is maintained in accordance with Table 4-9.3." SUBSTANTIATION: C la r i f i es or ig inal intent. COMMITTEE ACTION: Accept.

(Log #21) 30- 54 - (5-3.3.1(a)) : Accept SUBMITTER: D. L. Blomquist, Chevron Corporation COMMENT ON PROPOSAL NO.: 30-51 RECOMMENDATION: Add:

" . . . anticipated fug i t i ve emissions (see Appendix F fo r the calculat ion method): or" SUBSTANTIATION: The addition of the appendix reference wi l l improve c la r i t y on what is required for calculations based on the "anticipated fug i t ive emission" method. COMMITTEE ACTION: Accept•

(Log #32) 30- 50 - (4-9.3.3): Reject SUBMITTER: R. I. Spencer, IRI COMMENT ON PROPQSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.3.3 (New) to read as follows:

" I f the designatated s i te is accessible to the general public, i t shall be protected from tampering or trespassing in a manner acceptable to the authori ty having j u r i s d i c i t i o n . " SUBSTANTIATION: Edi tor ia l and c l a r i f i e s intent . COMMITTEE ACTION: Reject. COMMITTEE STATEMENT: The authori ty having ju r i sd ic t ion does not need to be involved in security. The Committee feels that the current text is adequate.

(Log #33) 30- 51 - (4-9.3.4.1): Accept in Part ~ : R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9•3.4.1 (New) to read as follows:

"Containers of l iqu id in the i r or ig inal shipping packages shall be permitted to be stored ei ther pal let ized or so l id-p i led. Unpackaged containers shall be permitted to be stored on shelves or d i rec t ly on the Floor of the locker. Containers over 30 gal (I13.5 L} capacity storing Class I or Class I I l iquids shall not be stored more than one container high. In a l l cases, the storage arrangement shall provide unrestricted access to and egress from the locker." SUBSTANTIATION: Incorporates pr inciples of 4-9.2.5.2, which is recommended for deletion under Comment 30-47 (Log #28). Thus removing the confusion. Also ed i to r ia l rearrangement to c l a r i f y orignal intent• COMMITTEE ACTION: Accept in Part.

In th i rd sentence of 4-9.3.4.1, change to read: " . . . more than two containers high."

COMMITTEE ~TAT~MENT: I t was the intent of the Committee to allow two-high storage.

(Log #34} 30- 52 - (4-9.3.4.3}: Accept ~ : R. I. Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise 4-9.3.4.3 to read as follows:

"Placarding or warning signs for lockers, shall be in accordance with applicable local , state and federal regulations or with NFPA 704." SUBSTANTIATION: Edi tor ia l to eliminate possible confusion caused by use of the word " label ing", a defined term having other meaning in this code. Also c la r i f i ca t i on or or ig inal intent. COMMITTEE ACTION: Accept.

(Log #35) 30- 53 - (Table 4-9.3): Accept SUBMITTER: R. I . Spencer, IRI COMMENT ON PROPOSAL NO.: 30-9 RECOMMENDATION: Revise Table 4-9.3 as follows:

(a) Revise caption of l e f t hand column to read as follows:

"Area of Designated Site." (b) Revise caption of 3rd column from l e f t to read

as follows: "Distance from locker to property l ine that is or can

be bu i l t upon." (c) Delete the words "hazardous material storage"

From Notes (1) and (4)• $OBSTANTIATION: Ed i tor ia l . COMMITTEE ACTION: Accept.

(Log #22) 30- 55 - (5-3.3.1(b}): Accept ~ : D. L. Blomquist, Chevron Corporation COMMENT ON PROPOSAL NO.: 30-51 RECOMMENDATION: Replace the "Committee Action" sentence under (b) with the fol lowing:

(b) Sampling of the actual vapor concentration under normal operating conditions. The sampling shall be conducted at a 5 f t radius from each potential vapor source extending to or toward the bottom and the top of the enclosed processing area. The vapor concentration used to determine the required vent i la t ion rate shall be the highest measured concentration during the sampling procedure.

NOTE: Equipment in enclosed processing areas may deter iorate over time and periodic sampling should be conducted to assure that leakage rates have not increased or that the vent i la t ion rate is adequate for any increase in leakage rates.

SUBSTANTIATION: The or ig inal wording only included a sampling 5 f t hor izontal ly from "equipment." By sampling at a 5 f t radius around the potential vapor source, vapors which are l igh te r than a i r or heavier than a i r wi l l be detected. These vapors might not be detected at a horizontal sample point. The term "equipment" has been replaced by "potential vapor source" for c la r i t y . Vent i lat ion at a rate based on the highest measured concentration wi l l maintain a reasonable safety margin. The note is added to point out that equipment, such as valve glands, shaft seals, or gaskets, can deter iorate and increase the vapor concentration above 25 percent of the LFL i f these components are not maintained or i f the vent i la t ion rate is insuf f i c ien t • COMMITTEE ACTION: Accept.

(Log #5) 30- 56 - (A-3-5): Accept ~_U_BMITTER: Edward Hildebrandt, Vi l lage of Morton Grove COMMENT ON PROPOSAL NO.: 30-30

I Change eighth l ine to read: RECOMMENDATION: • . . coated . . ."

~V_BSTANTIATION: Ed i tor ia l . Mispelled word. COMMITTEE ACTIQB: Accept.

(Log #I0} 30- 57 - (Appendix F): Accept SUBMITTER: Edward Hildebrandt, Vi l lage of Morton Grove COMMENT ON PROPOSAL NO.: 30-56 RE.COMMENDATION: ~) In the example, Step 9, the calculation in the last l ine should read:

"(359)(460+88)/(460 + 32), or 400 c u f t " 2) In the example, Step 11, last paragraph, second

l ine should read: "methane is assumed (5 percent concentration), and i t

is • . ." 3) Add "Committee Action: Accept."

SUBSTANTIATIQN: Item 1} is an ed i tor ia l correction to the mathematics in the example.

Item 2) should be changed to 5 percent to re f lec t the LFL for methane, which makes the paragraph consistent with the fol lowing calculat ion.

Item 3) adds a Committee Action to the Proposal. COMMITTEE ACTION: Accept•

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Documents

1990 Annual Meeting Technical Committee …...submitted to letter ballot of the Technical Committee on Aerosol Proucts, which consists of 20 voting members, in two segments. Segment