Statement of Problem and Substantiation for Public Comment ......Related Item Public Input No. 3-NFPA 40-2013 [Sections 8.1.1.1, 8.1.1.2] ... or decay of nitrate film. In the text

Public Comment No. 23-NFPA 40-2014 [ Global Input ]

TheNFPA 40 Task Force recommends changing “standard roll”to “1,000 foot roll” throughout thecode.

Statement of Problem and Substantiation for Public Comment

1,000 foot rolls have not been “standard” in the motion picture industry for nearly 100 years. Although “standard roll” is defined in Chapter 3, the task force believes the language could cause confusion for readers.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 21-NFPA 40-2014 [Section No. 8.1.2]

Related Item

Public Input No. 3-NFPA 40-2013 [Sections 8.1.1.1, 8.1.1.2]

Submitter Information Verification

Submitter Full Name: Heather Heckman

Organization: MIRC, USC

Affilliation: NFPA 40 Task Force

Street Address:

City:

State:

Zip:

Submittal Date: Fri May 16 14:20:38 EDT 2014

Committee Statement

CommitteeAction:

Rejected

Resolution: The committee believes that the replacement of the word "standard" with "1000-foot roll" is new,which means it cannot be done at this stage. The committee agrees with the concept that ispresented, but would like specific actions to take in the next stage.

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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Public Comment No. 3-NFPA 40-2014 [ Section No. 2.3.1 ]

2.3.1 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2014edition.


date update

Related Item

Public Input No. 21-NFPA 40-2013 [Section No. 2.3.1]


Submitter Full Name: Marcelo Hirschler

Organization: GBH International

Street Address:

City:

State:

Zip:

Submittal Date: Sun May 11 16:25:57 EDT 2014

Committee Statement

CommitteeAction:

Rejected but see related SR

Resolution: SR-2-NFPA 40-2014

Statement: This revision updates the standard to the most recent edition. Public Comments 3 and 8 wereboth accepted.


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2.3.1 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959.

ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2014edition.


Update year dates

Related Item

First Revision No. 8-NFPA 40-2013 [Section No. 7.2]


Submitter Full Name: Steve Mawn

Organization: ASTM International

Street Address:

City:

State:

Zip:

Submittal Date: Thu May 15 15:19:48 EDT 2014

Committee Statement

CommitteeAction:



Statement: This revision updates the standard to the most recent edition. Public Comments 3 and 8 wereboth accepted.


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Public Comment No. 10-NFPA 40-2014 [ New Section after 3.3 ]

Decomposition

The chemical breakdown, deterioration, degradation, or decay of nitrate film. In the text of this code, it doesnot refer to combustion events.


Because the definition of "decomposition" carries different connotations for the fire safety and archival communities, it is of material benefit to define the term. Members of the film archival community have expressed confusion over its use in the standard, noting conflicts with AHJs. Clearly defining the term in the text of the standard would facilitate communication between the archival and safety communities.



Public Comment No. 11-NFPA 40-2014 [Sections 3.3.10.1, 3.3.10.2]

Public Comment No. 12-NFPA 40-2014 [Section No. A.3.3.1]

Public Comment No. 13-NFPA 40-2014 [Section No. B.1]

Related Item

Public Input No. 5-NFPA 40-2013 [Global Input]





Street Address:

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Committee Statement

CommitteeAction:

Rejected

Resolution: The technical committee believes that the Merriam-Webster definition for decomposition isappropriate for this standard as referenced in 2.3.3.


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Public Comment No. 11-NFPA 40-2014 [ Sections 3.3.10.1, 3.3.10.2 ]

Sections 3.3.10.1, 3.3.10.2

3.3.10.1 Decomposition Vent.

A vent to permit the escape of gases resulting from partial burning or decomposition of decomposition orfrom incomplete combustion of nitrate film.

3.3.10.2 Explosion Vent.

A vent to relieve explosion pressures resulting from ignition of a mixture of decomposition combustiongases and air.


This change eliminates potential conflict with the proposed definition for decomposition.



Public Comment No. 10-NFPA 40-2014 [New Section after 3.3]



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CommitteeAction:



Statement: The committee agrees that revisions to 3.3.10.1 provide clarity to the document, but 3.3.10.2should remain as written. The ignition materials are decomposition gases.


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Public Comment No. 16-NFPA 40-2014 [ Section No. 4.1.1 [Excluding any Sub-Sections]

]

Nitrate film shall be stored or handled only in buildings or enclosures of Type I construction as defined inNFPA 220.


Archives may be located in permanent structures that are not of Type I construction. This revised language allows for the modification of a room (or other area) to achieve a two-hour fire-rating within an existing building, reducing costs of compliance.

Related Item

Public Input No. 28-NFPA 40-2013 [Section No. 4.1.1 [Excluding any Sub-Sections]]





Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected

Resolution: An enclosure of Type 1 construction is not defined. In addition, Chapter 1 allows for equivalency. Ifan enclosure provides an acceptable level of safety then the AHJ may find it acceptable for use.


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Public Comment No. 4-NFPA 40-2014 [ Section No. 4.1.2 [Excluding any Sub-Sections] ]

All rooms where nitrate film is stored or handled shall be separated from each other and from all other partsof the building by partitions having a fire resistance rating of at least 1 hour, when tested in accordance withASTM E119 (Title) .

Also, add: ASTM E119 -12a Standard Test Methods for Fire Tests of Building Construction andMaterials into section 2.3.1 on referenced ASTM standards.


It is possible to determine fire resistance ratings in accordance with many different test methods, but ASTM E119 is the standard test method used by most US codes and standards. In the absence of the test method information ahjs may be required to accept fire resistance ratings based on on standard tests.





Public Comment No. 7-NFPA 40-2014 [Section No. 9.2.5.1]

Related Item

Public Input No. 23-NFPA 40-2013 [Section No. 4.1]




Street Address:

City:

State:

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Committee Statement

CommitteeAction:

Rejected

Resolution: There are other standards and test methods that are acceptable for fire resistance ratings,including all the referenced international standards in NFPA 220 and NFPA 221. This proposedrevision would eliminate materials only tested to these standards.


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4.1.3

Openings in partitions shall be protected by approved fire doors having a 1-hour fire resistance rating, inaccordance with ASTM E119 (title), and installed according to NFPA 80.

Also add ASTM E119 (2012a) (Title) into the section on referenced ASTM standards.


Just like in public comment 4, all NFPA documents refer to the appropriate standard test method for ensuring that the fire resistance rating is measured appropriately. NFPA 80 provides requirements for installation and not for fire resistance rating testing of partitions.



Public Comment No. 4-NFPA 40-2014 [Section No. 4.1.2 [Excluding any Sub-Sections]]



Related Item





Street Address:

City:

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Zip:


Committee Statement

CommitteeAction:

Rejected



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Public Comment No. 14-NFPA 40-2014 [ Section No. 6.1 ]

6.1* General.

Nitrate film that is not in process or being worked on shall be stored as follows:

(1) Amounts exceeding 11 kg (25 lb), or 5 standard rolls, but but not exceeding 340 kg (750 lb), or 150standard rolls, shall shall be stored in approved cabinets or in vaults. For reference, 11 kgcorresponds to approximately [5] 1,000 foot rolls of 35mm motion picture film, or approximately 6508x10” negatives, or approximately 1,300 5x7” negatives. 11 kg also corresponds to approximately 0.5cubic feet of motion picture film, or 1.5 cubic feet of individually sleeved flat film negatives. (SeeSections 6.2 and 6.3.)

(2) Amounts exceeding 340 kg (750 lb), or 150 standard rolls, shall shall be stored in vaults. Forreference, 340 kg corresponds to approximately [150] 1,000 foot rolls of 35mm motion picture film, orapproximately 45 cubic feet of individually sleeved flat film negatives. 340 kg also corresponds toapproximately 15 cubic feet of motion picture film, or 45 cubic feet of individually sleeved flat filmnegatives. (See Section 6.3.)

(3) Extended term storage film shall be stored in extended term storage cabinets or extended termstorage vaults, which are subject to the limitations of Section 6.1 (1) and 6.1 (2). (See Sections 6.4and 6.5.)


This change incorporates approximate equivalencies into the body of the code, where they are more likely to be recognized by archivists and AHJs. At the time of this writing, few institutions with flat film holdings are in compliance with NFPA 40. One reason for this lack of compliance appears to be a general understanding that NFPA 40 applies to motion picture film alone--an understanding that is somewhat encouraged by the text of the code.

This change also incorporates an equivalency based upon volume. The task force convened by NFPA 40 weighed sheet film stored in individual sleeves in a storage container measuring 4” x 9” x 10.5” (0.22 cubic feet). The total mass of cellulose nitrate in the box was 1.642 kg. We therefore estimate that a single cubic foot would contain approximately 7.5 kg of cellulose nitrate material.

Flat film storage contains a significant quantity of other flammable content. Best preservation practice calls for the storage of negatives in individual sleeves, usually constructed of paper or inert plastic. Due to the sheer quantity of this content in a typical flat film storage container, the task force believes it to be a mitigating factor for fire risk. In the storage container sampled by the task force, there was 1.38 kg of paper--a mass nearly equal to the mass of cellulose nitrate material.

Compelling, if anecdotal, evidence from fire events suggests that the fire risk posed by flat film is less than the fire risk posed by roll film. In the only two recent, documented cellulose nitrate fires in archives, aged flat film did not burn, even when roll film in the immediate area did ignite (Nishimura, Doug. “Nitrate fires - an update” Thu, 11 Aug 2005, AMIA Listserv).

Moreover, NFPA 40 relies heavily on the U.S.G.P.O. publication “Proceedings of the Board of Chemical Warfare Service Appointed for the purpose of investigating Conditions Incident to the Disaster at the Cleveland Hospital Clinic, Cleveland, OH, on May 15,1929.” That study indicates that still or flat film housed in paper envelopes combusts in a significantly and materially different manner than unhoused cellulose nitrate film of any kind (p.85). Safety benefits were observed to accrue as the ratio of paper to film increased.

Note: Supporting material was made available for review at NFPA Headquarters in the first round of public input.




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Public Comment No. 15-NFPA 40-2014 [Section No. A.6.1]

Related Item









Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:



Statement: The committee agrees with the Public Comment but moved some unenforceable, explanatory text toAnnex A.

This change incorporates approximate equivalencies into the body of the code, where they are morelikely to be recognized by archivists and AHJs. At the time of this writing, few institutions with flat filmholdings are in compliance with NFPA 40. One reason for this lack of compliance appears to be ageneral understanding that NFPA 40 applies to motion picture film alone--an understanding that issomewhat encouraged by the text of the code.

This change also incorporates an equivalency based upon volume. The task force convened byNFPA 40 weighed sheet film stored in individual sleeves in a storage container measuring 4” x 9” x10.5” (0.22 cubic feet). The total mass of cellulose nitrate in the box was 1.642 kg. We thereforeestimate that a single cubic foot would contain approximately 7.5 kg of cellulose nitrate material.

Flat film storage contains a significant quantity of other flammable content. Best preservationpractice calls for the storage of negatives in individual sleeves, usually constructed of paper or inertplastic. Due to the sheer quantity of this content in a typical flat film storage container, the task forcebelieves it to be a mitigating factor for fire risk. In the storage container sampled by the task force,there was 1.38 kg of paper--a mass nearly equal to the mass of cellulose nitrate material.

Annex: The new annex sections A.6.1(1) and A.6.1(2) make A.6.1 redundant.


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Public Comment No. 19-NFPA 40-2014 [ Section No. 7.2 ]

7.2* Containers Required.

All nitrate motion picture film shall be kept in closed , individual metal cans or DOT-approved containersunless in use actually being worked on or examined. All nitrate flat film shall be kept in closed boxes orDOT-approved containers unless actually being worked on or examined .


No metal containers are currently manufactured to house flat film.

Metal containers likely contribute to nitrate decay for roll film. In a 1990 paper, Edge et al. found results "[suggesting] that iron actively contributes to the decomposition of cellulose nitrate." Interactions between the film and the can are cited in appendix B.3 of this standard, and are regularly observed by archivists who work with cellulose nitrate roll film. What is disturbing about the Edge et al. research, though, is that it suggests that the can may the source of the reaction, rather than a mere indicator of the reaction.

Finally, the word “individual” is ambiguous in the current code. Its meaning is not clear to the members of the task force, and the task force recommends that it be removed. Multiple rolls might be stored in a single can, but in this case, the total quantity of cellulose nitrate film would be less than 1,000 feet. No 1,000 foot size 35mm cans known to the task force are currently manufactured that would store more than a single roll of approximately 1,000 feet.

Note: Supporting material was made available to the NFPA in the first round of public input.



Public Comment No. 20-NFPA 40-2014 [Section No. A.7.2]

Related Item






Street Address:

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Committee Statement

CommitteeAction:



Statement: DOT-authorized containers may be used in place of metal cans for motion picture film. This revisionalso specifies that DOT-authorized containers should be used to store flat film.

Annex material provides guidance on DOT-authorized containers and best practices for storing flat


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film.

The word “individual” is ambiguous in the current code. Its meaning is not clear to the members ofthe task force, and the task force recommends that it be removed. Multiple rolls might be stored in asingle can, but in this case, the total quantity of cellulose nitrate film would be less than 1,000 feet.No 1,000 foot size 35mm cans known to the task force are currently manufactured that would storemore than a single roll of approximately 1,000 feet.

Annex: Annex material proposed by Public Comment 20 has been attached to section 7.2.2 inSecond Revision 5. Section 7.2 is now a heading, and A.7.2 is to be deleted.


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8.1.2

No more than 34 kg (75 lb, 15,000 feet, [15] 1,000 foot rolls or [7.5] 2,000 foot rolls ) of nitrate film shall beallowed in the projection booth unless stored in an approved cabinet in accordance with Chapter 6.


Projectionists are accustomed to length, rather than weight, measurements. This additional language will help to clarify the amounts allowed. The typical reel size in a modern projection booth is 2,000 feet.



Public Comment No. 23-NFPA 40-2014 [Global Input]

Related Item

Public Input No. 3-NFPA 40-2013 [Sections 8.1.1.1, 8.1.1.2]





Street Address:

City:

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Zip:


Committee Statement

CommitteeAction:



Statement: Projectionists are accustomed to length, rather than weight, measurements. This additionallanguage will help to clarify the amounts allowed. The typical reel size in a modern projectionbooth is 2,000 feet.

The committee moved the explanatory material converting the mass of film to length of film to theannex.


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8.1.3

The projection room shall have a fire resistance rating of not less than 1 hour, when tested in accordancewith ASTM E119 (title) . The interior finish shall have a flame spread index that is no greater than 25 inaccordance with ASTM E 84, Standard Test Method for Surface Burning Characteristics of BuildingMaterials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials.


This is the same issue being discussed for sections 4.1.1 and 4.1.3. The fire resistance test method must be referenced.






Related Item


First Revision No. 11-NFPA 40-2013 [Section No. 8.1.3]




Street Address:

City:

State:

Zip:


Committee Statement

CommitteeAction:

Rejected



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Public Comment No. 22-NFPA 40-2014 [ Section No. 8.1.5 [Excluding any Sub-Sections]

]

Two openings shall be provided for each motion picture projection room or booth projector operating nitratefilm and each shall comply with 8.1.3: one for the projectionist’s view and one for the projector itself.


There is a conflict between 8.1.5 and 8.1.5.1. While 8.1.5 limits the total number of openings for the booth to 2, 8.1.5.1 permits additional openings for additional profjectors. This revision resolves the conflict by limiting the number of ports to 2 per projector--the customary number.




Related Item






Street Address:

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Committee Statement

CommitteeAction:

Rejected

Resolution: The proposed requirements focus attention on the projector rather than the room, and are notconsistent with the rest of NFPA 40. The section limits the number of openings in the room and thecommittee has not seen justification to add additional openings other than inconvenience of movingthe projectors.


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Public Comment No. 24-NFPA 40-2014 [ Section No. 8.1.9.2 ]

8.1.9.2.1

Exhaust capacity shall be neither less Each nitrate projector equipped with carbon arc bulbs shall have an

exhaust capacity of not less than 0.43 m3/min (15 ft3/min) nor more than 1.4 m3/min (50 ft3/min) for eachlamp, plus 5.7 .

8.1.9.2.2

Each nitrate projector equipped with xenon bulbs shall have a capacity of not less than 7.1 m 3 /min (

200

250 ft 3 /min)

for the room itself.

nor more than 22.8 m 3 /min (800 ft 3 /min) as specified by the lamphouse manufacturer.

8.1.9.2.3

The projection room itself shall have a minimum exhaust capacity of not less than 5.7 m 3 /min (200

ft 3 /min).


Although the first revision updated section 8.1.5 to better describe the kinds of additional projectors found in modern booths, it failed to address the fact that the exhaust capacity currently described in the standard is grossly inadequate for xenon projectors. Xenon illumination is standard today, and to the knowledge of the members of the NFPA 40 Task Force, no nitrate booth currently in operation uses the carbon arc light projectors for which this language was originally written. However, we recommend retaining carbon arc projectors in the standard to ensure backwards compatibility for booths that might be in compliance with older projectors.




Related Item





Affilliation: NFPA 40 Task Group

Street Address:

City:

State:

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Committee Statement

CommitteeAction:

Rejected


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Resolution: While the committee agrees that xenon bulbs should be addressed, the suggested language isincomplete. The submitter is encouraged to provide additional information in the next revision cycleon minimum exhaust for this type of bulb. This proposed language would result in the materialbeing exhausted into the occupied room.


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Public Comment No. 7-NFPA 40-2014 [ Section No. 9.2.5.1 ]

9.2.5.1

Partitions separating one nitrate film–handling room from another shall be of Type I construction and shallhave a fire resistance rating of not less than 1 hour, when tested in accordance with ASTM E119 (title) .


Same issue as in earlier public comments and public input.






Related Item

Public Input No. 24-NFPA 40-2013 [Section No. 9.2.5.1]




Street Address:

City:

State:

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Committee Statement

CommitteeAction:

Rejected



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Public Comment No. 9-NFPA 40-2014 [ Chapter A ]

Annex A Explanatory Material

Annex A is not a part of the requirements of this NFPA document but is included for informational purposesonly. This annex contains explanatory material, numbered to correspond with the applicable textparagraphs.


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A.1.1

Although the storage and handling of cellulose nitrate film have a good safety record, fire tests conductedprior to 1967 indicated the desirability of a modification of existing standards. The requirements of thisstandard, therefore, apply strictly to long-term storage of cellulose nitrate film.

A.1.1.1

Cellulose nitrate–based film includes, but is not limited to, original negative, duplicate negative,interpositive (fine grain), color separation master (YCM), successive exposure master (SEN), opticalsoundtrack negative or master, mattes, title bands, and release prints.

A.1. 2

In accordance with ARTICLE 2—PURPOSES AND POWERS of the NFPA Articles of Organization, thiscode will first to promote fire protection and prevention, and second secure cooperation of the public byallowing for protection and prevention methods which promote the preservation of cellulose nitratematerials where possible.

A.1. 3.2

For example, any process in a studio that, in the opinion of the authority having jurisdiction, is similar tosome process covered under laboratories would be covered by the requirements for that process givenunder laboratories.


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A.3.2.1 Approved.

The National Fire Protection Association does not approve, inspect, or certify any installations, procedures,equipment, or materials; nor does it approve or evaluate testing laboratories. In determining theacceptability of installations, procedures, equipment, or materials, the authority having jurisdiction maybase acceptance on compliance with NFPA or other appropriate standards. In the absence of suchstandards, said authority may require evidence of proper installation, procedure, or use. The authorityhaving jurisdiction may also refer to the listings or labeling practices of an organization that is concernedwith product evaluations and is thus in a position to determine compliance with appropriate standards forthe current production of listed items.

A.3.2.2 Authority Having Jurisdiction (AHJ).

The phrase “authority having jurisdiction,” or its acronym AHJ, is used in NFPA documents in a broadmanner, since jurisdictions and approval agencies vary, as do their responsibilities. Where public safety isprimary, the authority having jurisdiction may be a federal, state, local, or other regional department orindividual such as a fire chief; fire marshal; chief of a fire prevention bureau, labor department, or healthdepartment; building official; electrical inspector; or others having statutory authority. For insurancepurposes, an insurance inspection department, rating bureau, or other insurance company representativemay be the authority having jurisdiction. In many circumstances, the property owner or his or herdesignated agent assumes the role of the authority having jurisdiction; at government installations, thecommanding officer or departmental official may be the authority having jurisdiction.

A.3.2.4 Listed.

The means for identifying listed equipment may vary for each organization concerned with productevaluation; some organizations do not recognize equipment as listed unless it is also labeled. Theauthority having jurisdiction should utilize the system employed by the listing organization to identify alisted product.

A.3.3.1 Cellulose Nitrate Film.

The terms cellulose nitrate film and nitrate film are preferable to nitrocellulose; however, for practicalpurposes, the terms are synonymous. The film can be in the form of unexposed film, positive prints,negatives, or used film.

Cellulose nitrate contains chemically combined oxygen, sufficient in amount so that it can partially burn ordecompose without the presence of air. The gases formed during burning or decomposition are both toxicand flammable and can be produced so rapidly as to create dangerous pressures in building structuresand severe hazard to life. Free burning of the material results in the production of less toxic gases, but,due to the rapid burning, such fires are intense and still represent a serious life hazard. The actual heat ofcombustion of cellulose nitrate film is 13,944 kJ/kg to 18,921 kJ/kg (6000 Btu/lb to 8000 Btu/lb), comparedwith 16,268 kJ/kg to 18,921 kJ/kg (7000 Btu/lb to 8000 Btu/lb) for wood. However, the rate of combustionis about 15 times greater than the combustion rate of wood in similar form. (See Table B.1.)

For many years, motion picture film was manufactured with a supporting film base of cellulose nitrate,commonly called nitrocellulose. Since 1951, no cellulose nitrate film base of any kind has beenmanufactured in the United States. Also, the use of cellulose nitrate film in theaters has virtually ceased.However, large quantities of cellulose nitrate film still exist and will remain in storage for many years. (SeeAnnex B for additional information.)

A.3.3.2 Extended Term Storage.

Extended term storage is synonymous with archival storage.

A.3.3.5 Extended Term Storage Rack.

Such racks are constructed so that individual rolls or groups of two rolls are placed in insulatedcompartments.

A.3.3.6 Extended Term Storage Vault.

This type of vault is used for the extended term storage of cellulose nitrate motion picture film.

A.3.3.8 Standard Roll.

This definition is intended to establish a measure of length and weight. It is not intended to prohibit the useof double rolls [610 m (2000 ft)] of film in theaters and exchanges. The term is used in calculating theweight of film.

A.3.3.9 Vault.

This type of vault is used for the storage of cellulose nitrate motion picture film in quantities not exceeding341 kg (750 lb).


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A.4.1.1

See NFPA 220.

A.4.2.3

For illuminated exit signs, see Section 7.10 of NFPA 101.

A.4.3.1

For information on the design of explosion vents, see NFPA 68.

A.4.4

The purpose of Section 4.4 is to prevent congestion of workers in areas where large quantities of nitratefilm are handled.

A.4.7.4

The following text is extracted from the Eastman Kodak publication, Hazard in the Handling and Storageof Nitrate and Safety Motion Picture Film: “To reduce the chance of spontaneous ignition of nitrate films —even those which are not of special concern — we [Kodak] recommend that storage vaults be airconditioned where necessary to prevent temperatures in excess of 21°C (70°F), and relative humidity inexcess of 60 percent.” Provisions for refrigeration systems can be found in ASHRAE 15, Safety Code forMechanical Refrigeration.

A.4.8.2.1

Isolation devices, in this context, do not refer to a standard smoke or flame damper built for normal servicefor air-handling systems or to a blast damper that might be used in combustible dust isolation service. Thisis a purpose built or modified device specifically tested for the service. In particular, the temperaturecriterion far exceeds the UL 555 or 555S ratings for flame and smoke dampers.


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A.5.1

It is recommended that buildings used for the storage or handling of nitrate film, except for buildings thathouse small areas possessing no fire hazard and are so located that there is little opportunity for firegases to enter the area, be protected completely by automatic sprinklers. Also, although this section doesnot require automatic sprinklers for projection rooms, fire experience indicates that they do providedesirable protection, and their use is advised.

A.5.3

The intent of this section is to provide the capability to extinguish incipient exposure fires and not cellulosenitrate film fires.


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A.6.1

One 305 m (1000 ft) roll (commonly referred to as a 1 M roll) of 35 mm nitrate film weighs approximately2 kg to 2.3 kg (4.5 lb to 5 lb) (no core). For sheet film equivalency, one sheet of 200 mm × 254 mm (8 in.× 10 in.) nitrate negative film weighs approximately 0.018 kg (0.04 lb) (130 sheets are equivalent to a 1 Mroll). One sheet of 130 mm × 180 mm (5 in. × 7 in.) nitrate negative film weighs approximately 0.009 kg(0.02 lb) (260 sheets are equivalent to a 1 M roll).

A.6.2.4

For long lengths of vent pipe, a larger size could be necessary to overcome friction loss and turns in thepipe.

A.6.3

See Figure A.6.3. The illustration shows the location of sprinkler heads and the decomposition vent.

Figure A.6.3 Standard Film Vault (for Other Than Extended Term Storage Film).

A.6.3.1.2

See NFPA 220.

A.6.3.2

Vaults can have two door openings. Such an arrangement is often a great convenience, as inlaboratories, where the vault is located between rooms and is used for temporary storage of film inprocess. Approved, quick-operating devices for closing vault doors are recognized as having advantagesover the fusible link, and their use is recommended.

A.6.3.3

The life of nitrate film retained for its historical value is maximized when it is stored in individuallyair-conditioned and sprinklered extended term storage vaults. Often these vaults are maintained attemperatures as low as 1.7°C (35°F) and a relative humidity of 30 percent. Air changes to minimizedecomposition product accumulation can also be effective.

A.6.3.4.3

See Figure A.6.3.4.3. The figure shows the location of sprinkler heads, decomposition vents, andnoncombustible flame barriers.

Figure A.6.3.4.3 Decomposition Vent.


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A.6.3.4.4

The extension of a vent outlet by means of flues that extend a considerable distance adds appreciably tothe frictional resistance and greatly decreases the effectiveness of the vents. If it is necessary toconstruct vents longer than 7.6 m (25 ft), proper allowance should be made for frictional losses, and thecross-sectional area should be increased progressively to ensure venting. Such cases are regarded asspecial and are subject to the approval of the authority having jurisdiction.

A.6.3.4.6

Protection against sunlight can be obtained by painting the glass in the vent opening a dark color. Onemethod of effecting protection from radiated heat is to use a hinged insulated or hollow metal panel as avent. Another acceptable method uses two baffle walls inside the vault itself. The baffle wall closer to thevent extends down from the ceiling to within 0.9 m (3 ft) of the floor; the inner baffle wall extends up fromthe floor to within 0.9 m (3 ft) of the ceiling. These walls should be of substantial construction and spacedand arranged to afford the full required vent area from the film storage space to the outside.

A.6.3.4.7

The use of approved, quick-operating devices is recommended.

A.6.3.5

This protection can be achieved by providing roof parapets or extended wing walls between suchopenings.

A.6.4.3

Good engineering judgment recommends that the vent lines be no longer than 3 m (10 ft). (SeeNFPA 68.

A.6.5

See Figure A.6.5.

Figure A.6.5 Extended Term Storage Vault.

A.6.5.6.4

One acceptable nozzle spray pattern would be such that at a 2.4 m (8 ft) distance the cone is about 1.5m (5 ft) in diameter. See Figure A.6.5.6.4.

Figure A.6.5.6.4 Typical Nozzle Spray Pattern.


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A.6.5.6.6

Figure A.6.5.6.6(a) shows an example of a nozzle layout consistent with the recommended arrangementfor a vault design as shown in Figure A.6.5.6.6(b).

Figure A.6.5.6.6(a) Nozzle Layout for Typical Vault.

Figure A.6.5.6.6(b) Typical Vault Layout.

A.6.5.6.9.2

It is good practice to set notification levels lower than the actuation set point to permit emergencyresponse at the early stage of the incident.

A.7.2

This requirement is essential for life safety and from the standpoint of fire hazard.

A.7.4

Nitrate film in the form of clippings and short lengths is very hazardous. Safety precautions in thehandling of such scraps are essential. Baling and burning of film are processes that present distinct firehazards. Waste nitrate film should be disposed of in accordance with federal, state, and local statutes.

A.8.1.1

For new construction, an enclosure not less than 2.4 m (8 ft) wide, 3 m (10 ft) long, and 2.4 m (8 ft) highis recommended for one projection machine, and not less than 3 m (10 ft) wide, 4.3 m (14 ft) long, and2.4 m (8 ft) high is recommended for two machines.

A.8.1.4

For new construction, it is recommended that at least two doors be provided, each not less than 76 cm(30 in.) wide and 183 cm (72 in.) high. In all cases, it is recommended that exit requirements of theauthority having jurisdiction be complied with, particularly those regarding size and locations. At leastone door should be of the conventional stairway type, having a landing at the top or opening directly intoa corridor.


Article 2 reads, “The purposes of the corporation (hereinafter referred to as the Association) shall be to promote the science and improve the methods of fire protection and prevention, electrical safety and other related safety goals; to obtain and circulate information and promote education and research on these subjects and to secure the cooperation of its members and the public in establishing proper safeguards against loss of life and property.”

Acknowledging the importance of preservation to the user community that stores cellulose nitrate material in an annex to the purpose of this document constitutes an important first step toward “securing the cooperation of … the public” affected by this standard.

Related Item


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Committee Statement

Committee Action: Rejected

Resolution: The NFPA articles of organization are not applicable to NFPA 40 in their entirety.


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Public Comment No. 12-NFPA 40-2014 [ Section No. A.3.3.1 ]

A.3.3.1 Cellulose Nitrate Film.

The terms cellulose nitrate film and nitrate film are preferable to nitrocellulose; however, for practicalpurposes, the terms are synonymous. The film can be in the form of unexposed film, positive prints,negatives, or used film.

Cellulose nitrate contains chemically combined oxygen, sufficient in amount so that it can partially burndecompose or decompose incompletely combust without the presence of air. The gases formed duringburning or decomposition are both toxic and flammable and can be produced so rapidly as to createdangerous pressures in building structures and severe hazard to life. Free burning of the material results inthe production of less toxic gases, but, due to the rapid burning, such fires are intense and still represent aserious life hazard. The actual heat of combustion of cellulose nitrate film is 13,944 kJ/kg to 18,921 kJ/kg(6000 Btu/lb to 8000 Btu/lb), compared with 16,268 kJ/kg to 18,921 kJ/kg (7000 Btu/lb to 8000 Btu/lb) forwood. However, the rate of combustion is about 15 times greater than the combustion rate of wood insimilar form. (See Table B.1.)

For many years, motion picture film was manufactured with a supporting film base of cellulose nitrate,commonly called nitrocellulose. Since 1951, no cellulose nitrate film base of any kind has beenmanufactured in the United States. Also, the use of cellulose nitrate film in theaters has virtually ceased.However, large quantities of cellulose nitrate film still exist and will remain in storage for many years. (SeeAnnex B for additional information.)


These changes eliminate potential conflicts with the proposed definition of decomposition.






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Committee Statement

CommitteeAction:

Rejected

Resolution: The proposed definition of decomposition was rejected. Therefore the committee decided thatthe original language is more clear.


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Public Comment No. 15-NFPA 40-2014 [ Section No. A.6.1 ]

A.6.1

One 305 m (1000 ft) roll (commonly referred to as a 1 M roll) of 35 mm nitrate film weighs approximately 2kg to 2.3 kg (4.5 lb to 5 lb) (no core). For sheet film equivalency, one sheet of 200 mm × 254 mm (8 in. × 10in.) nitrate negative film weighs approximately 0.018 kg (0.04 lb) (130 sheets are equivalent to a 1 M roll).One sheet of 130 mm × 180 mm (5 in. × 7 in.) nitrate negative film weighs approximately 0.009 kg (0.02 lb)(260 sheets are equivalent to a 1 M roll).


Proposed revisions to 6.1.1 make this section redundant.



Public Comment No. 14-NFPA 40-2014 [Section No. 6.1]

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Statement: The committee agrees with the Public Comment but moved some unenforceable, explanatory text toAnnex A.

This change incorporates approximate equivalencies into the body of the code, where they are morelikely to be recognized by archivists and AHJs. At the time of this writing, few institutions with flat filmholdings are in compliance with NFPA 40. One reason for this lack of compliance appears to be ageneral understanding that NFPA 40 applies to motion picture film alone--an understanding that issomewhat encouraged by the text of the code.

This change also incorporates an equivalency based upon volume. The task force convened byNFPA 40 weighed sheet film stored in individual sleeves in a storage container measuring 4” x 9” x10.5” (0.22 cubic feet). The total mass of cellulose nitrate in the box was 1.642 kg. We therefore


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estimate that a single cubic foot would contain approximately 7.5 kg of cellulose nitrate material.

Flat film storage contains a significant quantity of other flammable content. Best preservationpractice calls for the storage of negatives in individual sleeves, usually constructed of paper or inertplastic. Due to the sheer quantity of this content in a typical flat film storage container, the task forcebelieves it to be a mitigating factor for fire risk. In the storage container sampled by the task force,there was 1.38 kg of paper--a mass nearly equal to the mass of cellulose nitrate material.

Annex: The new annex sections A.6.1(1) and A.6.1(2) make A.6.1 redundant.


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Public Comment No. 17-NFPA 40-2014 [ New Section after A.6.4.3 ]

A.6.4 Freezers for Extended Term Storage

Low temperatures slow nitrate decay. Freezing temperatures halt nitrate decay. Laboratory-graderefrigerators or freezers are recommended for extended term storage of amounts of cellulose nitrate filmnot exceeding 11 kg.

A freezer or refrigerator complying with 6.4.1 through 6.4.3.1 is acceptable for extended term storage ofamounts of cellulose nitrate film in amounts exceeding 11 kg but not exceeding 340 kg.

Low or freezing temperatures are also recommended for vault storage complying with 6.5.1 through 6.5.9for amounts exceeding 340 kg.


The best available data suggests that the majority of archival institutions can (and do already) pragmatically implement similar storage. 63% of CoSA members who are subject to special extended term storage requirements under NFPA 40 already use some sort of freezer storage for their nitrate, while 9% use NFPA 40 compliant extended term vault or cabinet storage.

Subfreezing temperatures halt cellulose nitrate decay. Freezing is the only known method for halting the secondary autocatalytic mechanisms of decay. (Heckman 2010, p. 500 citing Bigourdan,”From the Nitrate Experience” p 61.)

This revision covers configurations for varying quantities.

Note: Supporting documentation was provided in the first round of public input.

Related Item

Public Input No. 30-NFPA 40-2013 [New Section after 6.4]





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Statement: This revision adds Annex A material to section 6.4. The committee agrees with Public Comment 17but made a minor change to the language.

The best available data suggests that the majority of archival institutions can (and do already)pragmatically implement similar storage. 63% of CoSA members who are subject to specialextended term storage requirements under NFPA 40 already use some sort of freezer storage fortheir nitrate, while 9% use NFPA 40 compliant extended term vault or cabinet storage.


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Subfreezing temperatures halt cellulose nitrate decay. Freezing is the only known method for haltingthe secondary autocatalytic mechanisms of decay. (Heckman 2010, p. 500 citing Bigourdan,”Fromthe Nitrate Experience” p 61.)

This revision covers configurations for varying quantities.

Note: Supporting documentation was provided in the first round of public input.


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Public Comment No. 20-NFPA 40-2014 [ Section No. A.7.2 ]

A.7.2

This requirement is essential for life safety and from the standpoint of fire hazard Flat film should be storedin individual sleeves within closed boxes or DOT-approved containers .


Best practice is to store flat films in individual sleeves. This is likely a mitigating factor in combustion events, due to the sheer quantity of non-cellulose nitrate material in flat film storage containers. Compelling, if anecdotal, evidence from fire events suggests that the fire risk posed by flat film is less than the fire risk posed by roll film. In the only two recent, documented cellulose nitrate fires in archives, aged flat film did not burn, even when roll film in the immediate area did ignite (Nishimura, Doug. “Nitrate fires - an update” Thu, 11 Aug 2005, AMIA Listserv). Moreover, NFPA 40 relies heavily on the U.S.G.P.O. publication “Proceedings of the Board of Chemical Warfare Service Appointed for the purpose of investigating Conditions Incident to the Disaster at the Cleveland Hospital Clinic, Cleveland, OH, on May 15,1929.” That study indicates that still or flat film housed in paper envelopes combusts in a significantly and materially different manner than unhoused cellulose nitrate film of any kind (p.85). Safety benefits were observed to accrue as the ratio of paper to film increased.



Public Comment No. 19-NFPA 40-2014 [Section No. 7.2]

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Statement: DOT-authorized containers may be used in place of metal cans for motion picture film. This revisionalso specifies that DOT-authorized containers should be used to store flat film.

Annex material provides guidance on DOT-authorized containers and best practices for storing flatfilm.

The word “individual” is ambiguous in the current code. Its meaning is not clear to the members ofthe task force, and the task force recommends that it be removed. Multiple rolls might be stored in asingle can, but in this case, the total quantity of cellulose nitrate film would be less than 1,000 feet.No 1,000 foot size 35mm cans known to the task force are currently manufactured that would store


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more than a single roll of approximately 1,000 feet.

Annex: Annex material proposed by Public Comment 20 has been attached to section 7.2.2 inSecond Revision 5. Section 7.2 is now a heading, and A.7.2 is to be deleted.


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Public Comment No. 13-NFPA 40-2014 [ Section No. B.1 ]

B.1 Hazards.

The most dangerous aspects of cellulose nitrate motion picture film are its ease of ignition, its very high rateof combustion, and its extremely poisonous combustion gases.

Cellulose nitrate film decomposes readily when heated to temperatures above ambient but below its ignitiontemperature. The decomposition is both exothermic and autocatalytic. The quantity of heat produced bydecomposition is such that, if not dissipated, it can rapidly raises raise the temperature of the film to theignition point. Even local heating can raise the temperature of the film to a dangerous level, initiatingdecomposition combustion in the entire mass. Cellulose nitrate also contains enough oxygen within itsmolecule so that decomposition or combustion proceeds rapidly, even in a limited air supply. A fire incellulose nitrate film, therefore, cannot be extinguished by smothering.

Cellulose nitrate film is not itself explosive and is less flammable than certain other nitrated compounds. Itsignition temperature is given generally as about 149°C (300°F), but the exact value depends on theduration of exposure, size and purity of film, and other factors. For example, in a laboratory test a sample offresh nitrate film base ignited in air at 163°C (325°F) within 80 seconds; at 204°C (400°F), ignition occurredin 10 seconds; and at 260°C (500°F), in only 3 seconds. Residual chemicals from processing, dirt, orforeign material can lower the ignition temperature. Investigations conducted after the Cleveland Clinic fireof 1929 showed that temperatures above 93°C (200°F) were unsafe for nitrate film and that exposed steampipes and unprotected light bulbs were dangerous in rooms containing nitrate film.

Improperly cared-for nitrate film has caused fires after several hours storage at temperatures as low as49°C (120°F). Also, spontaneous ignition is believed to have been responsible for a number of nitrate filmfires that have occurred in storage vaults in the summer, following periods of 38°C (100°F) weather(Cummings, Hutton, and Silton, “Spontaneous Ignition of Decomposing Cellulose Nitrate Film”).

The actual heat of combustion of cellulose nitrate film is low compared with that of more common fuels.(See Table B.1.)

Table B.1 Heat Rates of Combustion

Nitrate Film vs. Common Fuels kJ/kg Btu/lb

Nitrate film 13,944–18,592 6000–8000

Wood 16,268–18,592 7000–8000

Alcohol 27,005 11,620

Coal, bituminous 23,240–32,536 10,000–14,000

Gasoline 52,900 22,750

However, the rate of combustion of nitrate film is about 15 times greater than the combustion rate of woodin any form so that the heat evolved per minute is initially much greater. This rate results in a rapidtemperature increase and a very intense fire. A nitrate film fire burns so fiercely and spreads so quickly thatit is virtually impossible to control or extinguish it except by automatic sprinklers.


This revision eliminates potential conflicts with the proposed definition for decomposition.






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Committee Action: Rejected but see related SR


Statement: This revision aligns with the rejected definition of decomposition.


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Public Comment No. 18-NFPA 40-2014 [ Section No. B.3 ]

B.3 Detection and Disposal of Unstable Nitrate Film.

New nitrate film was made to be as stable as possible, and some many nitrate films, which are 30 or 40years old regardless of age , still appear to be in reasonably good condition. However, all nitrate cellulosebase film deteriorates with age, and the deterioration can be increased by chemical contamination andimproper storage conditions. Nitrate film in advanced stages of deterioration can be less stable and canignite at lower temperatures than nitrate film in good condition. All nitrate films that are to be saved forfuture reprocessing or for extended term storage purposes should be examined carefully throughout theirlength prior to being stored in a vault. Further, they should be re-examined periodically. For moderatestorage temperatures and where both temperature and humidity are controlled, inspections should bemade at least once annually. Where conditions are not controlled, examinations should be made every sixmonths. In tropical climates, inspection intervals might have to be decreased to two or three months.

Any films that, upon examination, show yellow discoloration, fading of the image, undue brittleness,stickiness of the emulsion, or any other signs of deterioration should be copied onto safety film reformattedas soon as practical possible . Any films in cans that are corroded on the inside should be recanned. Suchcorrosion can indicate an imminent deterioration problem. Films that have degraded to the point ofcomplete image loss should be disposed of.

The disposal of deteriorated or unstable nitrate film presents a problem needs to be handled as hazardouswaste . Nitrate film should not be mixed with ordinary rubbish. Such film should be kept under water in asteel drum an approved container until disposal can be arranged. Safe disposal should be arrangedthrough proper authorities.


The changes to this section more accurately reflect the observed and measured variable nature of nitrate decay. In accelerated aging trials and archival observations, many nitrate pieces--some more than 100 years old today--have proved extraordinarily stable. Others decayed decades ago. Evidence for the idea that increased degradation correlates in a straightforward way with heightened fire risk is mixed at best.

They also remove language suggesting that annual inspections are mandatory. Archivists and AHJs do not always understand that the annex is for informational purposes only. Removing the section about annual inspections allows more flexibility, especially for large institutions. Nitrate holdings are increasingly centralized at a handful of institutions, many of which have such vast holdings that annual inspections are simply not feasible.

Finally, the task force recommends removing the phrase “steel drum,” and replacing it with the more flexible “approved container” to accommodate a wider range of equally safe practices.

Related Item

Committee Input No. 19-NFPA 40-2013 [Section No. B.3]





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CommitteeAction:



Statement: The changes to this section more accurately reflect the observed and measured variable nature ofnitrate decay. In accelerated aging trials and archival observations, many nitrate pieces--some morethan 100 years old today--have proved extraordinarily stable. Others decayed decades ago.Evidence for the idea that increased degradation correlates in a straightforward way withheightened fire risk is mixed at best.

The committee believed that including local, state, and federal regulations removed the need for anapproved container.

They also remove language suggesting that annual inspections are mandatory. Archivists and AHJsdo not always understand that the annex is for informational purposes only. Removing the sectionabout annual inspections allows more flexibility, especially for large institutions. Nitrate holdings areincreasingly centralized at a handful of institutions, many of which have such vast holdings thatannual inspections are simply not feasible.

Finally, the task force recommends removing the phrase “steel drum,” and replacing it with the moreflexible “approved container” to accommodate a wider range of equally safe practices.


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Documents

Statement of Problem and Substantiation for Public Comment ......Related Item Public Input No. 3-NFPA 40-2013 [Sections 8.1.1.1, 8.1.1.2] ... or decay of nitrate film. In the text