Technical Committee on Laboratories Using … Committee on Laboratories Using Chemicals ... Technical Committee on Laboratories Using Chemicals ... LAB-AAA Michael F. Cooper

Technical Committee on Laboratories Using Chemicals NFPA 45 – First Draft Meeting

Exxon/Mobile Annadale, NJ May 1-3, 2013

AGENDA

1. Call to order and roll call at 8:00 a.m. each day. 2. Approval of Minutes from April 23, 2009 ROC Meeting held at Hughes Associates. 3. Staff Liaison’s Report

a. Committee Membership b. Update – New Standards Process

4. Task Groups:

a. Task Group 1: Ajay Prasad b. Task Group 2: Mike Cooper c. Task Group 3: Rich Palluzi d. Task Group 4: Andy Minister

5. Committee action on Public Input.

6. Action on committee proposals.

7. Future meetings and locations. The next meeting is the Public Comment/Second Draft

Meeting. The public comment closing date November 15, 2013 and the last day to meet is May 2, 2014.

8. Adjournment – Will adjourn at 5 pm each day except for Friday, May 3rd, when we

will adjourn at 3 pm.

1

Technical Committee on Laboratories Using Chemicals

Minutes of Meeting Report on Comments (ROC)

Hughes Associates, Inc. Baltimore, MD April 23, 2009

Attendance: Principal and Alternate Members / Staff: Andy Minister – Battelle, Pacific Northwest Laboratory, WA – Committee Chair Martha H. Curtis – NFPA Staff Liaison, MA Bill Barlen – Barlen and Associates, CT – Rep. Airgas (on conference call) Michael Cooper, Harley Ellis Devereaux, MI William Eckholm, Firetrace International, AZ Kevin Gilkison – Labconco Corp., MO Brian Goodman – Lawrence Livermore National Lab, CA Craig Hofmeister – The RJA Group, Inc., NC Don Kohn – Kohn Engineering, PA Joseph J. Milligan – GlaxoSmithKline, PA – Rep. Industrial Fire Protection Section Richard Palluzi, ExxonMobil Research & Engineering, NJ Paul Pelczynski, Siemens Building Technologies, IL Rudy Poblete – Kewaunee Scientific Corp., NC Michael Pokorny – Montgomery County Permitting, MD Ajay Prasad, Hughes Associates, Inc., MD David Quigley – BWXT Y-12, TN James Riley – Riley Laboratory Consulting, LLC, GA Steve Waller – CUH2A, Inc., NJ (on conference call) Guests: Ryan Bierwerth – Summit Fire Consulting, MN Absent Principal Members with no Alternate present Richard Anderson – Anderson Risk Consultants, NJ (sent in comments by email)

Ray Arntson – Rayden Research LLC, WI (Ryan Bierwerth was representing Ray Arnston at the ROC meeting.)

Hal Cohen – HCC and Associates, Inc., DE John Dembishack – CT Office of the State Fire Marshal, CT Diane Kroll – US Dept of Veterans Affairs, MN J.P. McCabe – US NIH, MD Robert Myers – Myers & Associates (Amoco), GA Peter Puhlick – University of Connecticut, CT

2

David S. Rausch – Phoenix Controls Corporation, MA Michael St. Clair – Industrial Fire Protection Section, OH 1. Call to order and welcome. The meeting was called to order at 8:40 AM. TC Chair Andy

Minister welcomed the Committee. Ajay reviewed the exits from the Conference room. Two members of the Committee participated on a conference call during the meeting.

2. Self-Introduction. The Committee Members and guest were welcomed and introduced themselves.

3. Minutes Approval. The minutes from the July 2008 ROP meeting at NFPA HQ (see Committee webpage to review minutes) and from the Conference call held on March 19, 2009 were approved without amendment.

4. Staff Liaison’s Report: a. Committee Membership Update and review of TC size and balance. b. Martha gave a PowerPoint presentation that addressed the procedures for the ROC meeting. 5. Committee Action on Public Comments. The public comments were reviewed and acted

upon. Committee comments were created as needed. Balloted Committee actions will be published in the Fall 2009 Report on Comments (ROC) which will be sent to all TC members and submitters of comments by August 28, 2009. Anyone else who would like to receive a free copy can call our Publications Department at (800) 344-3555 or view the ROC via the NFPA website at www.nfpa.org.

6. Task Groups. There were no task group reports given. The Task Group on Building Code Coordination consisted of the following members: Michael Cooper (Chair), Rich Anderson, John Dembishack, Craig Hoffmeister, Andy Minister, Richard Palluzi, Mike Pokorny, Ajay Prasad, Jim Riley, and David Rausch.

7. Next Meeting. The Committee will not meet again in this revision cycle unless there is a NITMAM received on NFPA 45 by Oct. 23, 2009. If there is a NITMAM received, there may be a conference call held to discuss the NITMAM prior to the document being debated at the NFPA World Safety Conference in Las Vegas, NV in June 2010.

8. Adjournment. The meeting adjourned at 5 PM on April 23, 2009. Respectfully submitted,

Martha H. Curtis

Staff Liaison to the TC on Laboratories Using Chemicals

http://www.nfpa.org/

Address List No PhoneLaboratories Using Chemicals LAB-AAA

Susan Bershad03/26/2013

LAB-AAAAndrew MinisterChairBattelle Northwest Laboratory902 Battelle Blvd., MSIN J2-50PO Box 999Richland, WA 99352Alternate: Jeffrey J. Foisel

U 4/1/1995LAB-AAA

Richard R. AndersonPrincipalAnderson Risk Consultants209 Goat Hill RoadLambertville, NJ 08530

SE 4/17/1998

LAB-AAARaymond E. ArntsonPrincipalRayden Research, LLC1041 174th StreetHammond, WI 54015

SE 1/1/1991LAB-AAA

William H. BarlenPrincipalBarlen and Associates, Inc.24 Gettysburg CourtAllentown, NJ 08501Airgas, Inc. and Purification Technologies Inc.

M 1/1/1991

LAB-AAAMichael F. CooperPrincipalHarley Ellis Devereaux26913 Northwestern Hwy, Suite 200Southfield, MI 48033Alternate: Louis Hartman

SE 7/16/2003LAB-AAA

John L. Dembishack, IIIPrincipalConnecticut Department of Construction ServicesOffice of State Fire Marshal1111 Country Club RoadMiddletown, CT 06457Alternate: Darren G. Cooke

E 7/1/1996

LAB-AAAWilliam A. EckholmPrincipalFiretrace International8435 North 90th Street, Suite 2Scottsdale, AZ 85258Alternate: David Hoffman

M 10/23/2003LAB-AAA

Barbara L. FosterPrincipalWest Virginia UniversityC. Eugene Bennett Department of ChemistryClark Hall100 Prospect Street, Room 217Morgantown, WV 26505Alternate: Stephanie Graham-Sims

U 10/27/2009

LAB-AAAScott T. FransonPrincipalThe Viking Corporation210 North Industrial Park RoadHastings, MI 49058National Fire Sprinkler AssociationAlternate: Joseph R. Fowler

M 8/2/2010LAB-AAA

Kevin C. GilkisonPrincipalLabconco Corporation8811 Prospect AvenueKansas City, MO 64132Alternate: Luke Savage

M 4/1/1996

LAB-AAABrian K. GoodmanPrincipalLawrence Livermore National Laboratory7000 East AvenuePO Box 808, L-344Livermore, CA 94551-0808Alternate: John A. Sharry

U 1/14/2005LAB-AAA

William F. GuffeyPrincipalUniversity of MarylandOffice of the Fire Marshal3115 Chesapeaike BuildingCollege Park, MD 20742

E 03/05/2012

1



LAB-AAACraig E. HofmeisterPrincipalThe Fire Consultants, Inc.182 Briarfield DriveApex, NC 27502-7007

SE 1/16/2003LAB-AAA

Michael E. HudkinsPrincipalHillsborough County Fire RescueFire Prevention Division4523 New Dawn CourtLutz, FL 33558

E 03/05/2012

LAB-AAAJeffrey S. KiddPrincipalHiller New England Fire Protection, Inc.240 Ballardvale StreetWilmington, MA 01887Fire Suppression Systems AssociationAlternate: Mark L. Robin

IM 8/2/2010LAB-AAA

Robert C. KleinPrincipalYale UniversityEnvironmental Health & Safety135 College StreetNew Haven, CT 06510

U 10/27/2009

LAB-AAADiane L. KrollPrincipalUS Department of Veterans AffairsVeterans Health Administration6636 Cedar Avenue SouthSuite 350, Room 317Richfield, MN 55423Alternate: Richard K. Hofman

U 7/29/2005LAB-AAA

John P. McCabePrincipalUS National Institutes of HealthDivision of the Fire MarshalSecurity and Emergency Response Program9000 Rockville Pike, Bldg. 15G-2Bethesda, MD 20892-2660Alternate: Samuel A. Denny

E 1/1/1989

LAB-AAARichard P. PalluziPrincipalExxonMobil Research & Engineering Company1545 Route 22 EastAnnandale, NJ 08801

U 7/29/2005LAB-AAA

Paul PelczynskiPrincipalSiemens Building Technologies, Inc.1000 Deerfield ParkwayBuffalo Grove, IL 60089

M 7/16/2003

LAB-AAARudolph PobletePrincipalKewaunee Scientific CorporationPO Box 1842Statesville, NC 28687-1842

M 1/1/1985LAB-AAA

Ajay V. PrasadPrincipalHughes Associates, Inc.3610 Commerce Drive, Suite 817Baltimore, MD 21227-1652

SE 1/25/2007

LAB-AAAPeter PuhlickPrincipalUniversity of ConnecticutFacilities OperationsUnit 3038 Co-Generation/Central Utilities PlantStorrs, CT 06269-3038

U 7/22/1999LAB-AAA

David R. QuigleyPrincipalBabcock & Wilcox Y-12, LLCPO Box 2009, MS8048Oak Ridge, TN 37831-8048

U 4/17/2002

LAB-AAARicardo A. RamirezPrincipalTokio Marine Management, Inc.800 East Colorado BoulevardPasadena, CA 91101

I 3/1/2011LAB-AAA

David S. RauschPrincipalPhoenix Controls Corporation75 Discovery WayActon, MA 01720Alternate: Kenneth Crooks

M 3/15/2007

2



LAB-AAAStephen E. WallerPrincipalHDR CUH2A, Inc.7200 Wisconsin Avenue, Suite 501Bethesda, MD 20814

SE 10/23/2003LAB-AAA

Jason D. JohnsonVoting AlternateThe RJA Group, Inc.Rolf Jensen & Associates, Inc.13831 Northwest Freeway, Suite 330Houston, TX 77040Voting Alt. to RJA Rep.

SE 3/2/2010

LAB-AAADarren G. CookeAlternateUniversity of ConnecticutOffice of the Fire Marshal1111 Country Club RoadPO Box 2794Middletown, CT 06457Principal: John L. Dembishack, III

E 10/1/1996LAB-AAA

Kenneth CrooksAlternatePhoenix Controls Corporation75 Discovery WayActon, MA 01720Principal: David S. Rausch

M 10/29/2012

LAB-AAASamuel A. DennyAlternateUS National Institutes of HealthDivision of the Fire Marshal9000 Rockville Pike, Bldg. 15G-2Bethesda, MD 20892-2660Principal: John P. McCabe

E 10/1/1999LAB-AAA

Jeffrey J. FoiselAlternateDow Corning CorporationPO Box 994, Mail Stop CO42M1Midland, MI 48686Principal: Andrew Minister

U 3/1/2011

LAB-AAAJoseph R. FowlerAlternateS.A. Comunale Company, Inc.2900 Newpark DriveBarberton, OH 44203National Fire Sprinkler AssociationPrincipal: Scott T. Franson

M 8/2/2010LAB-AAA

Stephanie Graham-SimsAlternateWest Virginia UniversityHealth Sciences Center Safety OfficePO Box 9004Morgantown, WV 26554Principal: Barbara L. Foster

U 08/09/2012

LAB-AAALouis HartmanAlternateHarley Ellis Devereaux26913 Northwestern Hwy, Suite 200Southfield, MI 48034Principal: Michael F. Cooper

SE 4/1/1996LAB-AAA

David HoffmanAlternateFiretrace International8435 North 90th Street, Suite 2Scottsdale, AZ 85258Principal: William A. Eckholm

M 10/29/2012

LAB-AAARichard K. HofmanAlternateUS Department of Veterans AffairsVeterans Health Administration810 Vermont Avenue, NWVHACO 10NA8, Office of OSHA & GEMSWashington, DC 20420Principal: Diane L. Kroll

U 10/29/2012LAB-AAA

Joseph J. Milligan, IIIAlternateGlaxoSmithKlineOne Franklin PlazaPO Box 7929Philadelphia, PA 19101-7929

U 1/12/2000

3



LAB-AAAMark L. RobinAlternateDuPont Fluoroproducts107 Saint Andrews CourtMiddletown, DE 19709Fire Suppression Systems AssociationPrincipal: Jeffrey S. Kidd

IM 03/05/2012LAB-AAA

Luke SavageAlternateLabconco Corporation8811 Prospect AvenueKansas City, MO 64132Principal: Kevin C. Gilkison

M 10/29/2012

LAB-AAAJohn A. SharryAlternateLawrence Livermore National LaboratoryPO Box 808, L-388Livermore, CA 94551Principal: Brian K. Goodman

U 08/09/2012LAB-AAA

Hal CohenMember EmeritusHCC and Associates, Inc.3 Mill Park CourtNewark, DE 19713

SE 1/1/1995

LAB-AAAJohn FresinaMember Emeritus2101 Avalon DriveBedford, MA 01730

SE 1/1/1978LAB-AAA

Norman V. SteereMember EmeritusNorman V. Steere & Associates, Inc.17060-116th Street NorthStilwater, MN 55082

SE 1/1/1969

LAB-AAASusan BershadStaff LiaisonNational Fire Protection Association1 Batterymarch ParkQuincy, MA 02169-7471

09/05/2012

4

There are only three actions a TC can take at the First Draft (ROP) meeting: 1. Resolve a Public Input (no change to the document) 2. Create a First Revision (change to the document) 3. Create Committee Input

Resolve Public Input (no change to the document)

• TC must provide a response (Committee Statement/CS) to ALL Public Input (proposal). • CS for not doing what is suggested • Sample Motion: “I make a motion to resolve PI#_ with the following committee

statement__.” Approval by meeting vote (simple majority). Not subject to Ballot. Create a First Revision (change to the document)

• TC must create a First Revision (FR) for each change they wish to make to the document, either using Public Input for the basis of the change or not using a Public Input for the basis. One or more Public Input can be considered for the FR.

• All Public Input requires a response • TC can use a Public Input for basis

i. Sample Motion: “I make a motion to revise section __ using PI#_ as the basis for change.” Approval by meeting vote (simple majority) and final approval through ballot.

• TC develops revision without a Public Input for basis i. Sample Motion: “I make a motion to revise section __ as follows___.”

Approval by meeting vote (simple majority) and final approval through ballot.

• First Revisions require a committee statement Committee Input

• TC may create a Committee Input (CI). This replaces the old system “rejected” Committee Proposals. CIs will get printed in the report but will not be balloted or shown as a change in the draft. CIs are used to solicit public comments and/or as a placeholder for the comment stage.

i. Sample Motion: “I make a motion to create a CI with a proposed revision to section__ as follows___.” Approval by meeting vote (simple majority). Not subject to ballot.

• Requires a committee statement to explain the intent of making a CI.

Comparison to Previous Process: PREVIOUS ACTIONS NEW PROCESS ACTIONS Sample Motion

Accept or any variation of Accept (APA, APR, APP) on a public proposal

1) Committee generates a First Revision and Substantiation (CS) for change 2) Committee provides response (CS) to each PI that is associated with the revision

1) “I make a motion to revise section __ using PI#_ as the basis for change.”

2) “ I make a motion to resolve PIs#_ through ## with the following statement__”

Rejected Public Proposal Committee provides response (CS) to PI

“I make a motion to resolve PI#_ with the following committee statement__.”

Accepted Committee Proposal Committee generates a First Revision and Substantiation (CS) for change

“I make a motion to revise section __ as follows___.” Committee generates a statement for reason for change.

Rejected Committee Proposal Committee generates a Committee Input (CI) and reason (CS) for proposed change

“I make a motion to create a CI with a proposed revision to section__ as follows___.” Committee generates a statement for reason for CI.

Notes: 1) All meeting actions require a favorable vote of a simple majority of the members present. 2) All First Revisions will be contained in the ballot and will require a 2/3 affirmative vote to

confirm the meeting action. 3) Only the First Revisions will be balloted. PIs and CIs will be contained in the report but will

not be balloted. 4) Comments may be submitted on all PIs, FRs and CIs

New Terms:

NEW TERM OLD TERM

Input Stage ROP Stage

Public Input (PI) Proposal

First Draft Meeting ROP Meeting

Committee Input Committee Proposal that Fail Ballot

Committee Statement (CS) Committee Statement

First Revision (FR) Committee Proposal or Accepted Public Proposal

First Draft Report ROP

First Draft ROP Draft

Comment Stage ROC Stage

Public Comment Public Comment

Second Draft Meeting ROC Meeting

Committee Comment Committee Comment that Fail Ballot

Committee Action Committee Action

Second Revision Committee Comment or Accepted Public Comment

Second Draft Report ROC

Second Draft ROC Draft

Note: The highlighted terms are the ones that will be most applicable at the First Draft Meeting.

Public Input No. 30-NFPA 45-2012 [ Global Input ]

Revise Tables 10.1.1(a) and 10.1.1(b) to be consistent with NFPA Codes 1, 400, and 5000. See proposed revision to Table 10.1.1(b) in U.S. customary units. A similarTable 10.1.1(a) can be created with equivalent metric units.

***Insert Table 10.1.1(b) here***

Additional Proposed Changes

File Name Description Approved45_tbl10.1.1(b)_A2014_R.doc

Statement of Problem and Substantiation for Public Input

The annex note to 9.2.3.1 indicates that the committee was attempting to provide some correlation of maximum allowable quantities between the fire and buildings codes and the laboratory standard. However, the quantities for flammable and combustible liquids in Chapter 10 differ, in some cases, from the quantities specified in the fire and building codes. This creates a conflict between NFPA Standard 45 and NFPA Codes 1, 400, and 5000. Each of the NFPA Codes 1, 400, and 5000 state that if there is a conflict between a requirement in the Code and a requirement in a standard, the requirement in the Code shall apply. The proposed revision to Table 10.1.1(b) is intended to resolve this conflict. The revised quantities are consistent with quantity limits in NFPA 1, 400, and 5000.The maximum allowable quantities for flammable liquids in Chapter 10 are arbitrarily

different than those specified in the Fire Code, the Hazardous Materials Code, and the Building Code. There is no technical justification presented for the different (in some cases much lower) maximum allowable quantities in NFPA 45. Having lower limits for well-protected, well-arranged, and regulated laboratories than for unprotected, unregulated general occupancies is counterintuitive. Having to design, construct, operate, and regulate laboratory maximum allowable

quantities to NFPA 45 limits in addition to fire and building code limits creates an unnecessary burden which Is not justified. Laboratories using chemicals should follow the same maximum allowable quantities as specified by the applicable fire and building codes.

Submitter Information Verification

Submitter Full Name: Wayne HolmesOrganization: Submittal Date: Wed Jun 06 09:26:53 EDT 2012

Copyright Assignment

I, Wayne Holmes, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. Except to the extent that I may lack authority to make an assignment of content identified above, I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

Page 1 of 39National Fire Protection Association Report

3/5/2013http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentParams=%28Comment...

NFPA45_tbl10.1.1(b)_A2014_R 1

Proposed

Table 10.1.1(b)

Maximum Quantities of Flammable and Combustible Liquids in Sprinklered Laboratory Units Outside of Inside Liquid Storage Units (U.S. Customary Units)

Quantities In-Usea Quantities In-Usea and Storage

Lab Unit Fire Hazard Class

Flammable and Combustible Liquid Classa

Maximum Quantityb per 100 ft2 of Laboratory

Unitc gal

Maximum Quantityb per Laboratory Unit

gal

Maximum Quantityb per 100 ft2 of

Laboratory Unitc

gal

Maximum Quantityb per Laboratory

Unit gal

A (high fire hazard)

I

10

480

20

480

I, II, and IIIA

20 800 1140 40 1600 1640

B (moderate fire

hazard)

I

5 300 480 10 480

Id, II, and IIIA

10 400 1140 20 800 1640

C (low fire hazard)

I

2

150 480 4 300 480

I, II, and IIIA

4 200 1140 8 400 1640

D (minimal fire

hazard)

I

1

75 480

2

150 480

I, II, and IIIA

1 75 1140 2 150 1640

Note: For maximum container sizes, see Table 10.1.2. a The maximum amount in-use in open systems is limited to 10 percent of the quantities listed. b See 4.2.2 for additional requirements for instructional and educational laboratories. cThe quantities per 100 ft2 do not imply the quantities must be with that 100 ft2 are; the quantities per 100 ft2 are for calculation purposes to determine the total quantity allowed per laboratory work area and the total amount overall in the laboratory unit.

By checking this box I affirm that I am Wayne Holmes, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

Origin (from sources other than the submitter)

Quantities are from NFPA 1, 400, and 5000.



Public Input No. 1-NFPA 45-2012 [ New Section after 1.3.4 ]

Add new text to read as follows:1.3.4 Code Requirements. When the requirements of this standard differ from the

requirements of applicable building or fire codes, the requirements of the code shall govern.


Current Paragraph 1.3.3 implies that that the requirements of NFPA 45 modify any requirements that might exist in applicable building and fire codes. This creates a conflict with codes such as NFPA 5000, NFPA 1, and NFPA 400. Each of the codes specify that “Where the requirements of a referenced code or standard differ from the requirements of this Code, the requirements of this Code shall govern.” The NFPA Standards Council has officially confirmed that it is the official position that NFPA Code requirements have priority over NFPA standards requirements whenever there is a conflict. The proposed Paragraph 1.3.4 is necessary to resolve the conflict between this standard and the codes to provide for effective enforcement of codes, where applicable.


Submitter Full Name: Wayne HolmesOrganization: Submittal Date: Tue Jun 05 14:31:33 EDT 2012


I, Wayne Holmes, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement ofProblem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.




Public Input No. 33-NFPA 45-2012 [ Section No. 2.3.4 ]

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

ASTM D 5, Standard Test Method of Penetration of Bituminous Materials, 2006 e1 .

ASTM E 84, Standard Test Method for Surface Burning Characteristics ofBuilding Materials, 2010 2012c .


standards date updates


Submitter Full Name: Marcelo HirschlerOrganization: GBH InternationalSubmittal Date: Mon Dec 17 18:15:02 EST 2012


I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, bychecking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




2.3.6 UL Publications. Underwriters Laboratories, Inc. 333 Pfingsten Road, Northbrook, IL 60062-2096.

ANSI/UL 723, Standard for Test for Surface Burning Characteristics ofBuilding Materials, 2008, revised 2010 .

UL 1275, Standard for Flammable Liquid Cabinets, 2005, revised 2009 .


Update referenced standards to most recent edition as indicated.


Submitter Full Name: John BenderOrganization: UL LLCSubmittal Date: Fri Dec 28 08:30:19 EST 2012


I, John Bender, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am John Bender, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature




3.3.7 Canopy 7* Canopy Hood. A suspended ventilating device used only to exhaust heat, water vapor, odors, and other nonhazardous materials. This is not a chemical fume hood and generally is not effective for exhausting toxic or flammable materials.


The second sentence is not part of the definition but rather is explanatory material. As such, it should appear in Annex A.









3.3.31 Instructional 31* Instructional Laboratory Unit. A laboratory unit used for education past the 12th grade and before post-college graduate-level instruction for the purposes of instruction of six or more persons for four or more hours per day or more than 12 hours perweek. A.3.3.31 Experiments and tests conducted in instructional laboratory units are under the direct supervision of an instructor. Laboratory units used for graduate or post-graduate research are

should not

to

be considered instructional laboratory units.


Definitions should not have requirements - The second and third sentence are requirements which should be in the body of the standard or in an annex. The recommendation is that they be placed in the annex.


Submitter Full Name: Marcelo HirschlerOrganization: GBH InternationalSubmittal Date: Thu Dec 27 13:49:43 EST 2012







3.3.36 Laboratory Unit. An enclosed space used for experiments or tests. A laboratory unit can include offices, lavatories, and other incidental contiguous rooms maintained for or used by laboratory personnel, and corridors within the unit. It can contain one or more separate laboratory work areas. It can be an entirebuilding. A laboratory unit is classified as A, B, C, or D in accordance with (See also Section 4.2 . (See also and Annex D.)


The definition should not contains requirements that address a specific section of the standard but should be generic.


Submitter Full Name: Marcelo HirschlerOrganization: GBH InternationalSubmittal Date: Thu Dec 27 13:45:51 EST 2012







3.3.36 Laboratory 36* Laboratory Unit. An enclosed space used for experiments or tests. A laboratory unit can include offices, lavatories, and other incidental contiguous rooms maintained for or used by laboratory personnel, and corridors within the unit. It can contain one or more separate laboratory work areas. It can be an entirebuilding. A laboratory unit is classified as A, B, C, or D in accordance withSection 4.2 . (See also Annex D .)


The text following the first sentence of 3.3.36 is not part of the definition. Rather, it is explanatory material that belongs in Annex A. The change is needed to comply with the NFPA Manual of Style.









3.3.57 * Storage Cabinet. A cabinet for the storage of flammable and combustible liquids constructed in accordance with Section 9.5 of NFPA 30, Flammable and CombustibleLiquids Code .


The existing definition contains requirements to comply with NFPA 30. The NFPA Manual of Style prohibits requirements in definitions. A definition of Storage Cabinet is not needed and can be deleted. Requirements for storage cabinets are contained in 9.2.3.3 and 10.5.1.Note that the term, Storage Cabinet, is used in NFPA 30 but is not defined.









4.3.2 A laboratory unit shall not be considered to contain an explosion hazard unless a laboratory work area within that unit contains an explosion hazard great enough to cause major property damage or serious injury outside that laboratory work area.


The phrase, “an explosion hazard great enough to cause major property damage or serious injury” is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.









5.1.1 The required construction of laboratory units shall be in accordance with Table 5.1.1.Table 5.1.1 Separation Requirements and Height Allowances for Laboratory Units Protected by Sprinklers

Laboratory

Unit aArea of Lab Unit Fire

Separation b

PermittedStories

Above

Grade

A ≤929 m 2 (≤10,000 ft 2 )

2 hours 1–3 c

>929 m 2

(>10,000 ft 2 )Not permitted d

B ≤929 m 2 (≤10,000 ft 2 ) 1 hour 1–3 c

≤929 m 2 (≤10,000 ft 2 ) 2 hours 4–6 c

>929 m 2

(>10,000 ft 2 )Not permitted d

C Any size Not required 1–3

Any size 1 hour 4–6

Any size 2 hours Over 6D Any size Not required No limit

aRefer to Table 10.1.1 for laboratory unit classification.bSeparation in this table refers to separation from laboratory unit(s) to non-laboratory areas and/or separations from laboratory unit(s) of equal or lower hazard classification.cNot allowed in structures below grade.dLabs of this classification and size are not permitted.




NFPA 45 requires automatic sprinkler protection only for new laboratories. Existing laboratories are not required to be protected by automatic sprinklers. Table 5.1.1 applies only to laboratories protected by sprinklers. The additional text in the title is needed to clarify that the separation and height requirements only apply to sprinklered laboratories and not to existing, non-sprinklered laboratories.








Public Input No. 9-NFPA 45-2012 [ New Section after 5.1.5 ]

Add new text to read as follows:5.1.5 Table 5.1.5 for separation requirements applies to existing, nonsprinklered

laboratory units.See proposed Table 5.1.5.

***Insert Table 5.1.5 here***

Additional Proposed Changes

File Name Description Approved45_tbl5.1.5_A2014_R.doc


Only new laboratories are required to be protected by automatic sprinklers in 6.2.1.1. Existing laboratories are permitted to be nonsprinklered. Table 5.1.1 provides separation requirements only for sprinklered laboratory units. Separation requirements for nonsprinklered laboratory units are needed to be specified in the standard. Proposed Paragraph 5.1.5 and Table 5.1.5 provide the needed information. Proposed Table 5.1.5 is based on NFPA 45-1996, Table 3-1(b) for nonsprinklered laboratory units.








NFPA45_tbl5.1.5_A2014_R 1

Proposed Table 5.1.5 Separation Requirements

For Existing, Nonsprinklered Laboratory Units

Required Fire Separation

Laboratory Unit Fire

Hazard Class

Area of Laboratory

Unit (ft2)

Construction Types I and II

Construction Types III, IV,

and V

A

<1,000 1 hr 2 hr 1,001 – 2,000 1 hr Not permitted 2,001 – 5,000 2 hr Not permitted

5,001 – 10,000 Not permitted Not permitted

>10,001 Not permitted Not permitted

B <20,000 1 hr 1 hr >20,000 Not permitted Not permitted

C <10,000 1 hr 1 hr >10,000 1 hr 1 hr

D <10,000 1 hr 1 hr >10,000 1 hr 1 hr


5.6.2 Laboratory work areas, laboratory units, and chemical fume hood interiors shall be considered as unclassified electrically with respect to Article 500 of NFPA 70, National Electrical Code.Exception : Under some conditions of hazard, it could be necessary to classify a laboratory work area, or a part thereof, as a hazardous location, for the purpose of designating the electrical installations. [See 10.5.5(electric motors) and 12.2.2.2 (refrigerators).]


The NFPA Manual of Style prohibits exceptions used in this manner. The text is more appropriately explanatory material and should appear in Annex A.









6.1.1 All laboratory units shall be provided with fire protection appropriate to the fire hazard, as follows:

(1) Portable fire extinguishers (see Section 6.4 )

(2) Fire alarm systems (see Section 6.5 )

(3) Evacuation and emergency plans (see 6.6.3 )


The phrase, “appropriate to the hazard” is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. The requirements in 6.1.1 are adequately covered in 6.4, 6.5, and 6.6. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.









6.1.2 In addition to the fire protection specified in 6.1.1 , laboratory units under some conditions shall be provided with automatic extinguishing systems (see Section 6.2 ) and inside standpipe and hose systems (see Section 6.3 ) .


The phrase, “under some conditions” is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. The requirements in 6.1.2 are adequately covered in 6.2 and 6.3. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.








Public Input No. 14-NFPA 45-2012 [ Section No. 6.6.1.2 ]

6.6.1.2 Certain critical areas shall require special consideration, including, but not limited to, the following:

(1) Handling and storage of chemicals, flammable and combustible liquids, and gases

(2) Open flame and spark-producing equipment work permit system

(3) Arrangements and use of portable electrical cords

(4) Smoking area controls


This entire paragraph is very vague. Except for the listed items, the “certain critical areas”, which are not limited to the listed items, are not specified. For the listed items, the “special considerations” are not specified. The NFPA Manual of Style prohibits unenforceable terms in standards. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.









7.1.1 When a laboratory work area or a laboratory unit is considered to contain an explosion hazard, as defined in 4.3.1 and 4.3.2 , appropriate protection shall be provided for the occupants of the laboratory work area, the laboratory unit, adjoining laboratory units, and non-laboratory areas as specified in 7 .1.2. (See Annex C for further information.)


The phrases “is considered to” and “appropriate” are vague and unenforceable and should be removed. The required protection is described in 7.1.2.








Public Input No. 16-NFPA 45-2012 [ Section No. 7.2 ]

7.2 Explosion-Resistant Construction. When explosion-resistant construction is used, adequately designed explosion resistance shall be achieved by the use of one of the following methods:

(1) Reinforced concrete walls

(2) Reinforced and fully grouted concrete block walls

(3) Steel walls

(4) Steel plate walls with energy-absorbing linings

(5) Barricades, such as those used for explosives operations, constructed of reinforced concrete, sand-filled/wood-sandwich walls, wood-lined steel plate, or earthen or rock berms

(6) Specifically engineered construction assemblies


The phrase is vague and unenforceable.









8.2.1 *Laboratory ventilation systems shall be designed to ensure that fire hazards and risks are minimized.


Minimization of hazards and risks is a highly subjective concept. Paragraph 8.2.1 is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.









8.4.1 *Air exhausted from chemical fume hoods and other special local exhaust systems shall not be recirculated. (See also 8.3.1 .)


8.3.1 prohibits recirculation of fumes, vapors, or gases. 8.4.1 prohibits recirculation of air from chemical fume hoods. 8.4.2 allows energy conservation devices, such as ductless hoods, that recirculate filtered air under certain conditions. 8.4.1 creates a conflict with 8.4.2 and should be deleted.









8.4.9 *Canopy hoods shall not be used in lieu of chemical fume hoods.


By definition, a canopy hood is a suspended device use only to exhaust heat, vapor, odors, and other nonhazardous materials. This is not a chemical hood and generally is not effective for exhausting toxic or flammable materials.By definition, a chemical fume hood is a ventilated enclosure designed to contain and

exhaust fumes, gases, vapors, mists, and particulate matter generated within the hood interior.To state that canopy hoods shall not be used in lieu of chemical fume hoods is simply

restating the difference in their definitions. This paragraph adds noting to the standard and should be deleted.








Public Input No. 20-NFPA 45-2012 [ Section No. 8.8 [Excluding any

Sub-Sections] ]

(See also alsoSection 8. 2.2 and Section 8. 11.)


8.2.2 covers ventilation and not construction and should not be referenced in 8.8 on construction.









8.10.2.1 The fire extinguishing system shall be suitable to extinguish fires within the chemical fume hood under the anticipated conditions of use.


A “suitable” fire extinguishing system is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. Providing a fire protection system in accordance with 8.10.2 would be deemed to comply with the intent of 8.10.2.1. Paragraph 8.10.2.1 can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.









8.10.5 Proper door Door operation for egress shall be maintained when the supply system shuts down and the lab exhaust system operates, creating a pressuredifferential.


"Proper” door operation is vague. It should be sufficient to simply state that “Door operation shall be maintained . . .”If the committee desires to be more specific on door operation, the standard might specify that the force to open existing side-hinged swinging doors shall not exceed 50 lbf (222 N) applied to the latch style, which is the requirement for egress doors in NFPA 101.









8.11.1*Perchloric acid heated above ambient temperatures shall only be used in a chemical fume hood specifically designed for its use and identified as follows:

FOR PERCHLORIC ACID OPERATIONSException : Hoods not specifically designed for use with perchloric acid shall be permitted to be used or in hoods where the perchloric vapors aretrapped and scrubbed before they are released into the hood. (See also12.1.2.5 .)


To delete the exception in accordance with the NFPA Manual of Style.








Public Input No. 32-NFPA 45-2012 [ New Section after 9.2.1.3 ]

9.2.1.4 The organization should maintain a compatible spill kit for the chemicals stored or used within the lab. All personnel should be trained at least annually in its use.


While quantities are limited, any liquid that may be corrosive could erode other containers resulting in an adverse reaction with other chemicals. Additionally, occupants of the lab trying to contain a spill or clean a spill without the proper training and equipment could make the situation worse.


Submitter Full Name: Kelly NicolelloOrganization: Western Regional Fire Code DevSubmittal Date: Thu Aug 16 11:50:53 EDT 2012


I, Kelly Nicolello, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I herebywarrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Kelly Nicolello, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Public Input No. 24-NFPA 45-2012 [ Section No. 9.2.3.1 [Excluding

any Sub-Sections] ]

Chemical inventories in each laboratory unit shall be maintained within the maximum allowable quantities specified in the applicable fire prevention code or building code except as modified in Chapter 10 for buildings with more than three stories .


The annex note to 9.2.2.1 indicates that the committee was attempting to provide some correlation of maximum allowable quantities between the fire and buildings codes and the laboratory standard. However, the quantities for flammable and combustible liquids in Chapter 10 differ, in some cases, from the quantities specified in the fire and building codes. This creates a conflict between NFPA Standard 45 and NFPA Codes 1, 400, and 5000. Each of the NFPA Codes 1, 400, and 5000 state that if there is a conflict between a requirement in the Code and a requirement in a standard, the requirement in the Code shall apply. The proposed revision to 9.2.2.1 is intended to resolve this conflict.The maximum allowable quantities for flammable liquids in Chapter 10 are arbitrarily

different than those specified in the Fire Code, the Hazardous Materials Code, and the Building Code. There is no technical justification presented for the different (in some cases much lower) maximum allowable quantities in NFPA 45. Having lower limits for well-protected, well-arranged, and regulated laboratories than for unprotected, unregulated general occupancies is counterintuitive. Having to design, construct, operate, and regulate laboratory maximum allowable









Public Input No. 25-NFPA 45-2012 [ Sections 9.2.3.1.1, 9.2.3.1.2,

9.2.3.1.3 ]

Sections 9.2.3.1.1, 9.2.3.1.2, 9.2.3.1.39.2.3.1.1 Maximum allowable quantities shall be reduced by 50 percent for Class B inlaboratory units located above the third floor.9.2.3.1.2 Maximum allowable quantities shall be reduced by 25 percent for Class C and Class D laboratory units located on the fourth through sixth floors of a building.9.2.3.1.3 Maximum allowable quantities shall be reduced by 50 percent for Class C and Class D laboratory units located above the sixth floor.first floor shall be reduced as follows:

(a) Second Floor 75%

(b) Third Floor 50%

(c) Fourth through Sixth Floor 12.5%

(d) Seventh through Ninth Floor 5%


Despite the difference between Laboratory Units in this standard and Control Areas in the building and fire codes, there is no justification for having different reductions in maximum allowable quantities for upper stories in the standard which differ from those in the codes. The proposed change harmonizes the MAQ reductions in the standard with the MAQ reductions in the codes. The MAQ reductions in Chapter 9 differ from the MAQ reductions specified in the fire and

building codes. This creates a conflict between NFPA Standard 45 and NFPA Codes 1, 400, and 5000. Each of the NFPA Codes 1, 400, and 5000 state that if there is a conflict between a requirement in the Code and a requirement in a standard, the requirement in the Code shall apply. The proposed revision to 9.2.2.1 is intended to resolve this conflict.The maximum allowable quantity reductions in Chapter 9 are arbitrarily different than

those specified in the Fire Code, the Hazardous Materials Code, and the Building Code. There is no technical justification presented for the different factors in NFPA 45. Having to design, construct, operate, and regulate laboratory maximum allowable












10.5.5 Electric motors shall be suitable for Class I, Division 2 locations when flammable and combustible liquids or flammable gas concentrations can produce hazardous concentrations of flammable mixtures.Exception : Electric motors shall be exempt from this requirement if they

10.5.6 Electric motors that are located in chemical fumehoods or provided with special localventilationthat the will prevent flammable concentrations of gases or vapors from reaching the motor shall not be required to be listed or labeled for Class I, Division 2 hazardous locations .


The NFPA Manual of Style prohibits the use of exceptions in this manner. The proposed revision deletes the exceptions and creates an new paragraph that contains the intent of the deleted exception.









11.2.3.4 An emergency gas shutoff device in an accessible location near at the least one room exit access door shall be provided in addition to the manual point-of-use valve in each educational and instructional laboratory space that has a piped gas–dispensing valve.


Some code officials are interpreting the phrase "exit" to mean at the stairway door or door that leads to the outside. I think the intent was to have the device inside the room near the exit access door that typically leads to a building corridor.


Submitter Full Name: Hal CohenOrganization: HCC and Associates, Inc.Submittal Date: Wed Jun 06 09:32:04 EDT 2012


I, Hal Cohen, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and fullrights in copyright in this Public Input (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Input in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Input and that I have full power and authority to enter into this copyright assignment.

By checking this box I affirm that I am Hal Cohen, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature



Public Input No. 27-NFPA 45-2012 [ Section No. 12.2.2.2.1 ]

12.2.2.2.1*Domestic refrigerators Refrigerators , freezers, and other cooling equipment which are not approved for Class I hazardous locations shall be permitted to store or cool flammable liquids if modified as follows:

(1) Any electrical equipment located within the outer shell, within the storage compartment, on the door, or on the door frame shall meet the requirements for Class I, Division 1 locations, as described in Article 501 of NFPA 70, National Electrical Code.

(2) Electrical equipment mounted on the outside of the storage compartment shall be installed in one of the following ways:

(a) To meet the requirements for Class I, Division 2 locations

(b) To be located above the storage compartment

(c) To be located on the outside surface of the equipment where exposure to hazardous concentrations of vapors will be minimal


The concern covered by this paragraph is not limited to domestic (e.g., household use) refrigerators but also includes commercial refrigerators which are not approved for hazardous locations. The revised text is more inclusive and reflects the primary intent to apply to cooling equipment which is not listed for hazardous locations but which may be suitable if modified as required by this paragraph.









12.2.2.3 Refrigerators, freezers, and cooling equipment located in a laboratory work area designated as a Class I location, as specified in the Exception to5.6.2 , shall be approved for Class I, Division 1 or 2 locations and shall be installed in accordance with Article 501 of NFPA 70, National Electrical Code.


To conform to the NFPA Manual of Style, the exception to 5.6.2 should be deleted. (See separate proposal.) The reference to the Exception to 5.6.2 can be deleted in 12.2.2.3 without creating any change in the intent of the requirement stated in 12.2.2.3.









12.2.6.3 Hazards to personnel from high voltage, vapors or fumes, radiation, flames, flashbacks, and explosions shall be minimized.


Minimization of hazards to personnel is a highly subjective concept. Paragraph 12.2.6.3 is vague, subjective, and unenforceable. The NFPA Manual of Style prohibits unenforceable terms in standards. This paragraph can be deleted from NFPA 45 without resulting in any significant change in the intent of the standard.








Public Input No. 3-NFPA 45-2012 [ New Section after A.3.3.4 ]

Add a new A.3.3.7 as follows: A.3.3.7 A canopy hood is not a chemical fume hood and generally is not effective

for exhausting toxic and flammable materials.


The second sentence is not part of the definition but rather is explanatory material. As such, it should appear in Annex A.








Public Input No. 5-NFPA 45-2012 [ New Section after A.3.3.30 ]

Add a new A.3.3.36 as follows:A.3.3.36 A laboratory unit can include offices, lavatories, and other incidental

contiguous rooms maintained for or used by laboratory personnel, and corridorswithin the unit. It can contain one or more separate laboratory work areas. It can be an entire building. A laboratory unit is classified as A, B, C, or D in accordance with Section 4.2. (See also Annex D.)


The text following the first sentence of 3.3.36 is not part of the definition. Rather, it is explanatory material that belongs in Annex A. The change is needed to comply with the NFPA Manual of Style.








Public Input No. 11-NFPA 45-2012 [ New Section after A.5.5 ]

Add a new A.5.6.2 to read as follows:A.5.6.2 Under some conditions of hazard, it could be necessary to classify a

laboratory work area, or a part thereof, as a hazardous location, for the purpose of designating the electrical installations. [See 10.5.5 (electric motors) and 12.2.2.2 (refrigerators).]


The NFPA Manual of Style prohibits exceptions used in this manner. The text is more appropriately explanatory material and should appear in Annex A.








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