Public Input No. 2-NFPA [Chapter F]

Transcription

1 1 of 66 1/26/2016 2:02 PM Public Input No. 19-NFPA [ Chapter 2 ] Chapter 2 Referenced Publications 2.1 General. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document. 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 405, Standard for the Recurring Proficiency of Airport Fire Fighters, 2010 edition. NFPA 412, Standard for Evaluating Aircraft Rescue and Fire-Fighting Foam Equipment, 2014 edition. NFPA 414, Standard for Aircraft Rescue and Fire-Fighting Vehicles, 2012 edition. NFPA 1003, Standard for Airport Fire Fighter Professional Qualifications, 2010 edition. 2.3 Other Publications Military Specification Publications. Naval Publications and Forms Center, 5801 Tabor Avenue, Philadelphia, PA U.S. Military Specification MIL-F-24385, Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF), Liquid Concentrate, for Fresh and Sea Water UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 162, Standard for Foam Equipment and Liquid Concentrates, 1994, Revised Other Publications. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, EN1568, Part 3: BS EN , Fire extinguishing media Foam concentrates Specification concentrates Part 3: Specification for low expansion foam concentrates for surface application to water-immiscible liquids, 2008, Corrigendum, ICAO Airport Services Manual Doc 9137, Part 8, Level B. 2.4 References for Extracts in Mandatory Sections. NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2010 edition. Statement of Problem and Substantiation for Public Input Updated edition. Related Public Inputs for This Document Related Input Public Input No. 2-NFPA [Chapter F] Relationship Updated edition. Submitter Information Verification Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ]

2 2 of 66 1/26/2016 2:02 PM Street Address: City: State: Zip: Submittal Date: Fri May 29 19:39:12 EDT 2015 Committee Statement Resolution: FR-23-NFPA Statement: The Technical Committee chose to updated editions and delete standards no longer used in the document.

3 3 of 66 1/26/2016 2:02 PM Public Input No. 20-NFPA [ Section No ] UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL UL 162, Standard for Foam Equipment and Liquid Concentrates, 1994, Revised Statement of Problem and Substantiation for Public Input The proposed change reflects an update/revision to the UL Standard. Submitter Information Verification Submitter Full Name: RONALD FARR Organization: UL LLC Street Address: City: State: Zip: Submittal Date: Mon Jun 15 10:35:48 EDT 2015 Committee Statement Resolution: Removed reference to UL 162 so no need to update

4 4 of 66 1/26/2016 2:02 PM Public Input No. 7-NFPA [ Section No ] Other Publications. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, EN1568, Part 3: Fire extinguishing media Foam concentrates Specification for low expansion foam concentrates for surface application to water-immiscible liquids. ICAO Airport Services Manual Doc 9137, Part 8, Level B. Part 1, Chapter 8 Statement of Problem and Substantiation for Public Input Committee Input: ICAO Level A, B and C foam tests are referenced in the standard, so ICAO reference was broadened. Also, additional inputs will remove acceptability of foam standards other than ICAO or Mil-Spec. Reference to EN standard removed. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:09:04 EDT 2015 Committee Statement Resolution: Removed not used in document

5 5 of 66 1/26/2016 2:02 PM Public Input No. 8-NFPA [ Section No ] Airport Air Traffic Control. A service established to provide air and ground traffic control for airports. Statement of Problem and Substantiation for Public Input Committee Input: The term "Air Traffic Control" aligns with NFPA 402 and the use of the term within 403. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:19:04 EDT 2015 Committee Statement Resolution: FR-2-NFPA Statement: The Technical Committee felt that the term "Air Traffic Control" aligns with NFPA 402 and the use of the term within 403.

6 6 of 66 1/26/2016 2:02 PM Public Input No. 26-NFPA [ Section No ] * Aqueous Film-Forming Foam Concentrate (AFFF). A concentrate based on fluorinated surfactants plus foam stabilizers to produce a fluid aqueous film for suppressing hydrocarbon fuel vapors and usually diluted with water to a 1 percent 1 percent, 3 percent 3 percent, or 6 percent solution. [ 11, 2010] 6 percent Statement of Problem and Substantiation for Public Input Consistent with 402, 11. Submitter Information Verification Submitter Full Name: STEPHEN LISTERMAN Organization: CINCINNATINORTHERN KENTUCKY I Street Address: City: State: Zip: Submittal Date: Wed Jun 24 13:16:12 EDT 2015 Committee Statement Resolution: FR-3-NFPA Statement: The Committee made changes in order to be consistent with 402, 11.

7 7 of 66 1/26/2016 2:02 PM Public Input No. 9-NFPA [ Section No ] Fluorine-Free Synthetic Foam (FFSF). Foam concentrate based on a mixture of hydrocarbon surface active agents that are fluorine free. Statement of Problem and Substantiation for Public Input Committee Input: The FFSF acronym is being used in the standard. It is being added it into the definition section. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:31:10 EDT 2015 Committee Statement Resolution: FR-4-NFPA Statement: The Committee added the FFSF acronym as it is being used in the standard.

8 8 of 66 1/26/2016 2:02 PM Public Input No. 29-NFPA [ Section No ] * Fluoroprotein Foam Concentrate (FP). A concentrate very similar to protein-foam concentrate but with a synthetic fluorinated surfactant additive. [11, 2010] Statement of Problem and Substantiation for Public Input Committee Input: Adding acronym used in the standard, as consistent with the definitions of other foam concentrates. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Tue Jun 30 18:01:02 EDT 2015 Committee Statement Resolution: FR-5-NFPA Statement: The Committee added the acronym used in the standard, as it is consistent with the definitions of other foam concentrates.

9 9 of 66 1/26/2016 2:02 PM Public Input No. 11-NFPA [ Section No ] * Protein Foam Concentrate (P). Concentrate consisting primarily of products from a protein hydrolysate, plus stabilizing additives and inhibitors to protect against freezing, to prevent corrosion of equipment and containers, to resist bacterial decomposition, to control viscosity, and to otherwise ensure readiness for use under emergency conditions. [11, 2010] Statement of Problem and Substantiation for Public Input Committee Input: Adding acronym used in the standard, as consistent with the definitions of other foam concentrates. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:32:05 EDT 2015 Committee Statement Resolution: FR-6-NFPA Statement: The Committee added the acronym used in the standard, as it is consistent with the definitions of other foam concentrates.

10 10 of 66 1/26/2016 2:02 PM Public Input No. 24-NFPA [ Section No ] * Foam Concentrate. A concentrated liquid foaming Foam fire-fighting agent as received from the manufacturer. [ 11, 2010] that must be diluted with water to make foam solution. Statement of Problem and Substantiation for Public Input Consistent with NFPA 1901, Submitter Information Verification Submitter Full Name: STEPHEN LISTERMAN Organization: CINCINNATINORTHERN KENTUCKY I Street Address: City: State: Zip: Submittal Date: Wed Jun 24 13:09:26 EDT 2015 Committee Statement Resolution: The TC chose to keep this definition.

11 11 of 66 1/26/2016 2:02 PM Public Input No. 25-NFPA [ Section No ] Mutual Aid. Reciprocal assistance by emergency services under a prearranged plan A written intergovernmental agreement between agencies and/or jurisdictions that they will assist one another on request by furnishing personnel, equipment, and/or expertise in a specified manner. Statement of Problem and Substantiation for Public Input Consistent with NFPA 1701, 402 Submitter Information Verification Submitter Full Name: STEPHEN LISTERMAN Organization: CINCINNATINORTHERN KENTUCKY I Street Address: City: State: Zip: Submittal Date: Wed Jun 24 13:12:39 EDT 2015 Committee Statement Resolution: FR-8-NFPA Statement: The TC chose to make the definition consistent with NFPA 1710.

12 12 of 66 1/26/2016 2:02 PM Public Input No. 3-NFPA [ New Section after ] Foams should be classified by their performance and not by their composition names. Fore example foams meeting performance standard XXX... Rather than AFFF or fluorine free. Additional Proposed Changes File Name Description Approved Hold_No._403-3_on_Proposal_403-12_Section_5.1.1.pdf Statement of Problem and Substantiation for Public Input. Comment on Proposal Section Hold This Public Input appeared as "Reject but Hold" in Public Comment No of the A2013 Second Draft Report for NFPA 403 and per the Regs. at Substantiation: To use current chemical based names for foams hinders future developments. The key criteria is that they should do the job, so use that as the criteria and not their composition Submitter Information Verification Submitter Full Name: TC On AIR-AAA Organization: NFPA Technical Committee on Aircraft Rescue and Firefighting Street Address: City: State: Zip: Submittal Date: Thu Apr 30 12:56:05 EDT 2015 Committee Statement Resolution: See PI-14

13 Report on Comments June 2013 NFPA Log #2 Simon Webb, UK Civil Aviation Authority Foams should be classified by their performance and not by their composition names. For example foams meeting performance standard XX. Rather than AFFF or fluorine free. To use current chemical based names for foams hinders future developments. The key criteria is that they should do the job, so use that as the criteria and not their composition. 1. The ICAO standard which includes Level C, has not been formally published. 2. Large scale fire test data (e.g sq foot or greater) has not been provided. 3. Unclear whether fluorine free foam can be used with non-air aspirating nozzles (AFFF performance assumes this). 4. ICAO Level C small scale tests uses kerosene. The Mil spec used for AFFF performance uses gasoline. 5. There is potential conflict between UL 162 and the ICAO Level C test performance. Retain proposal as published in the ROP. Affirmative: 28 5 Colet, R., Deniston, H., Krajnak, D., Podolske, Jr., J., Ulrich, D. HEALEY, O.: Agree with comments. Printed on 4/30/2015 1

14 Report on Comments June 2013 NFPA Log #3 Bernard Valois, Autopyro , AFFF (column, for High performance foam concentrate), (Fluoroprotein and FFFP,Fluorine Free Synthetic (column 2, for Medium performance foam concentrate) and Protein Foams (column 3 with General use foam concentrate) New headers and numbers for the three columns based on the revised numbers published by the ICAO and the EASA and the performance of the current US Mil specification. Below I am providing the numbers for the new first column in metric and I am prepared to produce the equivalent table in US if the proposal is retained. First column Note: New numbers based on ICAO level C and MIL spec testing application rates Second column Third column The current table Q1 and Q2 numbers of the first column are based on lesser (medium performance level) application rates ICAO level B of 5.5 LPM per M 2. The numbers have never been adjusted following the evolution of agents to higher performance requirements such as ICAO level C and Mil F and appropriate test application densities. Safety considerations: The safety factor margins have been retained in the ICAO numbers to a level equivalent to what it was in the 3 existing levels. As an example the test application rate of the ICAO level C is of 1.75 LPM per M 2 for a calculated operational requirement of 3.75 LPM per M 2. Trade issues in support of identifying concentrates by performance levels: Applying a type of agent such as an AFFF or FFFP to a column just by name may constitute a trade restriction. As a hypothetical example, a newly developed super protein foam could outperform some of the lesser performing AFFF. 1. The ICAO standard which includes Level C, has not been formally published. 2. Large scale fire test data (e.g sq foot or greater) has not been provided. 3. Unclear whether fluorine free foam can be used with non-air aspirating nozzles (AFFF performance assumes this). 4. ICAO Level C small scale tests uses kerosene. The Mil spec used for AFFF performance uses gasoline. 5. There is potential conflict between UL 162 and the ICAO Level C test performance. Retain proposal as published in the ROP. Affirmative: 28 5 Colet, R., Deniston, H., Krajnak, D., Podolske, Jr., J., Ulrich, D. HEALEY, O.: See my Comment on Affirmative on Comment (Log #2). Printed on 4/30/2015 2

15 Report on Comments June 2013 NFPA Log #4 Bernard Valois, Autopyro Revise text to read as follows: Fluorine-Free Synthetic Foams shall be tested to meet the appropriate level of performance requirements of the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 or, the EN1568, Part 3 are required to be listed as conforming to the US MIL specification-f24325 or the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 level C requirements and tested at an application rate of.04 US gal per square foot.are required to be listed as conforming to the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 Level B requirements or the EN1568, Part 3 06 US gal per square foot are required to be listed as conforming to the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 Level A requirements 1.0 US gal per square foot Appendix in A currently mentions that other international test methods may be acceptable to the AHJ. Aviation safety is of international scope and the original NFPA numbers were derived from the ICAO; consequently the ICAO and other international standards need to be mentioned. 1. The ICAO standard which includes Level C, has not been formally published. 2. Large scale fire test data (e.g sq foot or greater) has not been provided. 3. Unclear whether fluorine free foam can be used with non-air aspirating nozzles (AFFF performance assumes this). 4. ICAO Level C small scale tests uses kerosene. The Mil spec used for AFFF performance uses gasoline. 5. There is potential conflict between UL 162 and the ICAO Level C test performance. Retain proposal as published in the ROP. Affirmative: 28 5 Colet, R., Deniston, H., Krajnak, D., Podolske, Jr., J., Ulrich, D. HEALEY, O.: See my Comment on Affirmative on Comment (Log #2). Printed on 4/30/2015 3

16 13 of 66 1/26/2016 2:02 PM Public Input No. 13-NFPA [ Section No ] * All foam concentrates shall be listed based on the performance test requirements in through * Aqueous film-forming foam agents shall meet the requirements of U.S. Military Specification MIL-F-24385, Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF), Liquid Concentrate for Fresh and Sea Water Film-forming fluoroprotein foam (FFFP), protein foam (P), fluoroprotein foam (FP), and fluorine-free synthetic foam (FFSF) shall meet the applicable fire extinguishment and burnback performance requirements of Underwriters Laboratories Inc. Standard UL 162, Standard for Foam Equipment and Liquid Concentrates (Type 3 application), EN 1568, Part 3: Fire extinguishing media Foam concentrates Specification for low expansion foam concentrates for surface application to water-immiscible liquids, or ICAO Airport Services Manual Doc 9137, Part 8, Level B Any primary agent used at the minimum quantities and discharge rates for AFFF in Table 5.3.1(a) and Table 5.3.1(b) shall meet the applicable fire extinguishment and burnback performance requirements of the performance tests specified. Statement of Problem and Substantiation for Public Input Committee Input: This input is part of a series of modifications to address logs 2, 3, and 4 that were placed on hold last revision cycle. One aspect of these logs was to move away from classifying flow rates by surfactant type, and move to performance tests. In a review of the common foam tests, it was decided that there was too much variation to allow all available tests to be included. Therefore, the focus is to continue with standards/specifications specific to airport fire fighting. The change to this section removes test references and points to Table for the list of acceptable tests. There is also revised annex material that discusses acceptable performance tests. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:43:16 EDT 2015 Committee Statement Resolution: FR-9-NFPA Statement: In a review of the common foam tests, it was decided that there was too much variation to allow all available tests to be included. Therefore, the focus is to continue with standards/specifications specific to airport fire fighting. There is also revised annex material that discusses acceptable performance tests.

17 14 of 66 1/26/2016 2:02 PM Public Input No. 5-NFPA [ Section No ] Film-forming fluoroprotein foam (FFFP), protein foam (P), fluoroprotein foam (FP), and fluorine-free synthetic foam (FFSF) shall meet the applicable fire extinguishment and burnback performance requirements of Underwriters Laboratories Inc. Standard UL 162, Standard for Foam Equipment and Liquid Concentrates (Type 3 application), EN foam shall be tested to meet the appropriate level of performance of the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 or the EN 1568, Part 3: Fire extinguishing media Foam media. (Foam concentrates Specification for low expansion foam concentrates for surface application to water-immiscible liquids), or ICAO Airport Services Manual Doc 9137, Part 8, Level B the UL 162. Additional Proposed Changes File Name Description Approved Hold_403-5_Comment_on_Proposal_ pdf Hold Comment on Proposal Statement of Problem and Substantiation for Public Input This Public Input appeared as "Reject but Hold" in Public comment No of the A2013 Second Draft Report for NFPA 403 and per the Regs at Appendix in A currently mentions that other international test methods may be acceptable to the AHJ. Aviation safety is of international scope and the original NFPA numbers were derived from the ICAO; consequently the ICAO and other international standards need to be mentioned. Alternative log CP12 should the table amendment be retained (see Valois comments on table Log CP13-16 Note this new text would be replacing the current and "High Performance concentrates" are required to be listed as conforming to the US MIL specification-f24325 or the most recent version of ICAO Airport Services Manual DOC 9137 Chapter 8 level C requirements and tested at an application rate of.04 US gal per square foot "Medium performance concentrates" are required to be listed as conforming to the most recent version of ICAO Airport Services manual DOC 9137 chapter 8 Level B requirements or the EN1568, Part 3 Fire extinguishing media. (Foam concentrates. Specification for low expansion foam concentrates for surface application to waterimmiscible liquids) or of the UL 162 and tested at an application rate of.06 US gal per square foot "General use foam concentrates" are required to be listed as conforming to the most recent version of ICAO Airport Services manual DOC 9137 chapter 8 Level A requirements or an equivalent specification tested at an application rate of 1.0 US gal per square foot Submitter Information Verification Submitter Full Name: TC On AIR-AAA Organization: NFPA Technical Committee on Aircraft Rescue and Firefighting Street Address: City: State: Zip: Submittal Date: Thu Apr 30 13:31:33 EDT 2015

18 Report on Comments June 2013 NFPA Log #4 Bernard Valois, Autopyro Revise text to read as follows: Fluorine-Free Synthetic Foams shall be tested to meet the appropriate level of performance requirements of the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 or, the EN1568, Part 3 are required to be listed as conforming to the US MIL specification-f24325 or the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 level C requirements and tested at an application rate of.04 US gal per square foot.are required to be listed as conforming to the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 Level B requirements or the EN1568, Part 3 06 US gal per square foot are required to be listed as conforming to the most recent version of ICAO Airport Services Manual DOC 9137 chapter 8 Level A requirements 1.0 US gal per square foot Appendix in A currently mentions that other international test methods may be acceptable to the AHJ. Aviation safety is of international scope and the original NFPA numbers were derived from the ICAO; consequently the ICAO and other international standards need to be mentioned. 1. The ICAO standard which includes Level C, has not been formally published. 2. Large scale fire test data (e.g sq foot or greater) has not been provided. 3. Unclear whether fluorine free foam can be used with non-air aspirating nozzles (AFFF performance assumes this). 4. ICAO Level C small scale tests uses kerosene. The Mil spec used for AFFF performance uses gasoline. 5. There is potential conflict between UL 162 and the ICAO Level C test performance. Retain proposal as published in the ROP. Affirmative: 28 5 Colet, R., Deniston, H., Krajnak, D., Podolske, Jr., J., Ulrich, D. HEALEY, O.: See my Comment on Affirmative on Comment (Log #2). Printed on 4/30/2015 3

19 15 of 66 1/26/2016 2:02 PM Committee Statement Resolution: See PI 13 Need the FR #

20 16 of 66 1/26/2016 2:02 PM Public Input No. 14-NFPA [ Section No ]

21 17 of 66 1/26/2016 2:02 PM * 1

22 18 of 66 1/26/2016 2:02 PM The minimum amounts of water for foam production and the minimum amounts of complementary agents necessary shall be as specified in Table 5.3.1(a) or Table 5.3.1(b), based on the system of categorizing airports listed in Table Table 5.3.1(a) Extinguishing Agents, Discharge and Response Capability in U.S. Customary Units Complementary Airport Category Response Phases AFFF Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Protein Foam MIL-F and ICAO C ICAO B ICAO A Response Capability (sec) Complementary Agents a Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Quantity (lb) Discharge (lb/sec) 180 b Q2 c Q3 d TOTAL b Q2 c 210 c Q3 d TOTAL b Q2 c 210 c Q3 d 240 d,e TOTAL b Q2 c 210 c Q3 d 240 d,e TOTAL 1,340 1,620 1, b ,194 1,194 1,331 1, Q2 c 210 c Q3 d 240 d,e 1, , , TOTAL 2,760 3,340 3, b 1,245 1,245 1,725 1,725 1,920 1, Q2 c 210 c 1,245 1,725 1,920 Q3 d 240 d,e 1, , , TOTAL 3,740 4,700 5, b 1,585 1,585 2,192 2,192 2,437 2,

23 19 of 66 1/26/2016 2:02 PM MIL-F and ICAO C Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) ICAO B Discharge Capability (gpm) Required Water (U.S. gal) ICAO A Discharge Capability (gpm) Complementary Quantity 7 Q2 c 210 c 2,045 2,828 3,143 (lb) Agents a Q3 d 240 d,e 1, , , TOTAL 4,880 6,270 6,830 Discharge (lb/sec) 180 b 2,095 2,095 2,901 2,901 3,222 3, Q2 c 210 c 3,185 4,409 4,898 Q3 d 240 d,e 2, , , TOTAL 7,780 9,810 10, b 2,619 2,619 3,626 3,626 4,030 4, Q2 c 210 c 4,451 6,164 6,850 Q3 d,f 240 d,e 2, , , TOTAL 9,570 12,290 13, b 3,195 3,195 4,424 4,424 4,915 4, Q2 c 210 c 6,069 8,405 9,338 Q3 d 240 d,e 5, , , TOTAL 14,260 17,830 19,250 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Table 5.3.1(b) Extinguishing Agents, Discharge and Response Capability in SI Units Complementary Airport Category Response Phases AFFF Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Protein Foam MIL-F and ICAO C Required Water (L) Discharge Required Water (L) ICAO B Discharge Required Water (L) ICAO A Discharge bility Capability Capability Capability Response Capa- (sec) Complementary Quantity (kg) Agents a Discharge (kg/sec)

24 20 of 66 1/26/2016 2:02 PM (L/min) (L/min) (L/min) 180 b Q2 c Q3 d TOTAL b Q2 c 210 c Q3 d TOTAL 750 1,000 1, b 1,077 1,077 1,500 1,500 1,692 1, Q2 c 210 c Q3 d 240 d,e 1, , , TOTAL 2,500 3,050 3, b 1,772 1,772 2,468 2,468 2,722 2, Q2 c 210 c 1,028 1,432 1,578 Q3 d 240 d,e 2, , , TOTAL 5,050 6,150 6, b 3,257 3,257 4,514 4,514 5,029 5, Q2 c 210 c 2,443 3,386 3,771 Q3 d 240 d,e 4, , , TOTAL 10,450 12,650 13, b 4,700 4,700 6,525 6,525 7,250 7, Q2 c 210 c 4,700 6,525 7,250 Q3 d 240 d,e 4, , , TOTAL 14,150 17,800 19, b 5,983 5,983 8,297 8,297 9,214 9, Q2 c 210 c 7,717 10,703 11,886 Q3 d 240 d,e 4, , , TOTAL 18,450 23,750 25, b 7,937 7,937 10,992 10,992 12,202 12, Q2 c 210 c 12,063 16,708 18,548 Q3 d 240 d,e 9, , , TOTAL 29,450 37,150 40, b 9,907 9,907 13,722 13,722 15,259 15, Q2 c 210 c 16,843 23,328 25,941 Q3 d,f 240 d,e 9, , , TOTAL 36,200 46,500 50, b 12,103 12,103 16,759 16,759 18,603 18, Q2 c 210 c 22,997 31,841 35,347 Q3 d 240 d,e 18,900 1,890 18,900 1,890 18,900 1,890

25 21 of 66 1/26/2016 2:02 PM TOTAL 54,000 67,500 72,850 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Statement of Problem and Substantiation for Public Input Committee Input: This change addresses logs 2, 3, and 4 placed on hold the last revision cycle. The columns have been relabeled to indicate the required test requirements. Related Public Inputs for This Document Related Input Public Input No. 31-NFPA [Section No. B.6] Relationship Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:51:58 EDT 2015 Committee Statement Resolution: FR-10-NFPA Statement: See PI-14 The committee concluded that the applications rates should remain as is for the three performance levels, with the associated safety factors. The committee concluded that agent quantities should not be reduced.

26 22 of 66 1/26/2016 2:02 PM Public Input No. 21-NFPA [ Section No ]

27 23 of 66 1/26/2016 2:02 PM *

28 24 of 66 1/26/2016 2:02 PM The minimum amounts of water for foam production and the minimum amounts of complementary agents necessary shall be as specified in Table 5.3.1(a) or Table 5.3.1(b), based on the system of categorizing airports listed in Table Table 5.3.1(a) Extinguishing Agents, Discharge and Response Capability in U.S. Customary Units Airport Category 180 Response Phases Response Capability (sec) Required Water (U.S. gal) AFFF Discharge Capability (gpm) Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Required Water (U.S. gal) Discharge Capability (gpm) Protein Foam Required Water (U.S. gal) Discharge Capability 120 b Q2 c (gpm) Q Q3 d TOTAL b Q2 c c Q3 d TOTAL b Q2 c c Q3 d 240 d,e TOTAL b Q2 c c Q3 d 240 d,e TOTAL 1,340 1,620 1,730

29 25 of 66 1/26/2016 2:02 PM b ,194 1,194 1,331 1, Q2 c c Q3 d 240 d,e 1, , , TOTAL 2,760 3,340 3, b 1,245 1,245 1,725 1,725 1,920 1, Q2 c c 1,245 1,725 1,920 Q3 d 240 d,e 1, , , TOTAL 3,740 4,700 5, b 1,585 1,585 2,192 2,192 2,437 2, Q2 c c 2,045 2,828 3,143 Q3 d 240 d,e 1, , , TOTAL 4,880 6,270 6, b 2,095 2,095 2,901 2,901 3,222 3, Q2 c c 3,185 4,409 4,898 Q3 d 240 d,e 2, , , TOTAL 7,780 9,810 10, b 2,619 2,619 3,626 3,626 4,030 4, Q2 c c 4,451 6,164 6,850 Q3 d,f 240 d,e 2, , , TOTAL 9,570 12,290 13,

30 26 of 66 1/26/2016 2:02 PM b 3,195 3,195 4,424 4,424 4,915 4, Q2 c 180 c 6,069 8,405 9,338 Q3 d 240 d,e 5, , , TOTAL 14,260 17,830 19,250 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Table 5.3.1(b) Extinguishing Agents, Discharge and Response Capability in SI Units Airport Category 180 Response Phases Response (sec) Required Water (L) AFFF Discharge (L/min) Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Required Water (L) Discharge (L/min) Protein Foam Required Water 120 b Q2 c (L) Discharge Capability Capability Capability Capability (L/min) Q Q3 d TOTAL b Q2 c c Q3 d TOTAL 750 1,000 1, b 1,077 1,077 1,500 1,500 1,692 1, Q2 c

31 27 of 66 1/26/2016 2:02 PM c Q3 d 240 d,e 1, , , TOTAL 2,500 3,050 3, b 1,772 1,772 2,468 2,468 2,722 2, Q2 c c 1,028 1,432 1,578 Q3 d 240 d,e 2, , , TOTAL 5,050 6,150 6, b 3,257 3,257 4,514 4,514 5,029 5, Q2 c c 2,443 3,386 3,771 Q3 d 240 d,e 4, , , TOTAL 10,450 12,650 13, b 4,700 4,700 6,525 6,525 7,250 7, Q2 c c 4,700 6,525 7,250 Q3 d 240 d,e 4, , , TOTAL 14,150 17,800 19, b 5,983 5,983 8,297 8,297 9,214 9, Q2 c c 7,717 10,703 11,886 Q3 d 240 d,e 4, , , TOTAL 18,450 23,750 25, b 7,937 7,937 10,992 10,992 12,202 12, Q2 c 210

32 28 of 66 1/26/2016 2:02 PM c 12,063 16,708 18,548 Q3 d 240 d,e 9, , , TOTAL 29,450 37,150 40, b 9,907 9,907 13,722 13,722 15,259 15, Q2 c 180 c 16,843 23,328 25,941 Q3 d,f 240 d,e 9, , , TOTAL 36,200 46,500 50, b 12,103 12,103 16,759 16,759 18,603 18, Q2 c 180 c 22,997 31,841 35,347 Q3 d 240 d,e 18,900 1,890 18,900 1,890 18,900 1,890 TOTAL 54,000 67,500 72,850 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Additional Proposed Changes File Name Description Approved Table_5.3.1_proposed_changes.docx Table proposed changes Statement of Problem and Substantiation for Public Input See substantiation to companion change to Section Related Public Inputs for This Document Related Input Public Input No. 22-NFPA [Sections , ] Relationship codifies proposed response time change s from section in Table Submitter Information Verification

33 29 of 66 1/26/2016 2:02 PM Submitter Full Joseph Scheffey Name: Organization: JENSEN HUGHES Special expert, independent, not representing any particular Affilliation: interest Street Address: City: State: Zip: Submittal Date: Wed Jun 17 13:35:01 EDT 2015 Committee Statement Resolution: TC feels that the current standard is sufficient at this time however further research will be done.

34 It is not clear that the edited table accurately portrays the change in a clear manner. This attachment shows the intended change EXTINGUISHING AGENTS Table 5.3.1(a) Extinguishing Agents, Discharge and Response Capability in U.S. Customary Units Airport Category 1 Total 2 Total 3 Total 4 Total 5 Total 6 Total 7 Total 8 Total 9 Total 10 Total Response Phases Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d,f Q2 c Q3 d Response Capability (sec) Require d Water (U.S. gal) 180 b 120 b b 120 b 210 c 180 c 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e , ,250 2,760 1,245 1,245 1,250 3,740 1,585 2,045 1,250 4,880 2,095 3,185 2,500 7,780 2,619 4,451 2,500 9,570 3,195 6,069 5,000 14,260 AFFF Discharge Capability (gpm) Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Required Water (U.S. gal) , , ,250 3,340 1,245 1,725 1, ,250 4,700 1,585 2,192 2, ,250 6,270 2,095 2,901 4, ,500 9,810 2,619 3,626 6, ,500 12,290 3,195 4,424 8, ,000 17,830 Discharge Capability (gpm) Required Water (U.S. gal) ,730 1,194 1, ,250 3,580 1,725 1,920 1, ,250 5,090 2,192 2,437 3, ,250 6,830 2,901 3,222 4, ,500 10,620 3,626 4,030 6, ,500 13,380 4,424 4,915 9, ,000 19,250 Protein Foam Complementary Agents a Discharge Capability (gpm) Quantity (lb) Discharge (lb/sec) , , , , , , a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L).

35 Table 5.3.1(b) Extinguishing Agents, Discharge and Response Capability in SI Units Airport Category 1 Total 2 Total 3 Total 4 Total 5 Total 6 Total 7 Total 8 Total 9 Total 10 Total Response Phases Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d Q2 c Q3 d,f Q2 c Q3 d Response Capabilit y (sec) Required Water (L) 180 b 120 b b 120 b 210 c 180 c 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e 180 b 120 b 210 c 180 c 240 d,e , ,100 2,500 1,772 1,028 2,250 5,050 3,257 2,443 4,750 10,450 4,700 4,700 4,750 14,150 5,983 7,717 4,750 18,450 7,937 12,063 9,450 29,450 9,907 16,843 9,450 36,200 12,103 22,997 18,900 54,000 AFFF Discharge Capability (L/min) Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP Required Water (L) ,000 1,077 1, ,100 3,050 1,772 2,468 1, ,250 6,150 3,257 4,514 3, ,750 12,650 4,700 6,525 6, ,750 17,800 5,983 8,297 10, ,750 23,750 7,937 10,992 16, ,450 37,150 9,907 13,722 23, ,450 46,500 12,103 16,759 31,841 1,890 18,900 67,500 Discharge Capability (L/min) Required Water (L) ,150 1,500 1, ,100 3,300 2,468 2,722 1, ,250 6,550 4,514 5,029 3, ,750 13,550 6,525 7,250 7, ,750 19,250 8,297 9,214 11, ,750 25,850 10,992 12,202 18, ,450 40,200 13,722 15,259 25, ,450 50,650 16,759 18,603 35,347 1,890 18,900 72,850 Protein Foam Complementary Agents a Discharge Capability (L/min) Quantity (kg) Discharge (kg/sec) , , , , , , , ,603 1, a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior firefighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L).

36

37 30 of 66 1/26/2016 2:02 PM Public Input No. 4-NFPA [ Section No ]

38 31 of 66 1/26/2016 2:02 PM *

39 32 of 66 1/26/2016 2:02 PM The minimum amounts of water for foam production and the minimum amounts of complementary agents necessary shall be as specified in Table 5.3.1(a) or Table 5.3.1(b), based on the system of categorizing airports listed in Table Table 5.3.1(a) Extinguishing Agents, Discharge and Response Capability in U.S. Customary Units Protein Foam Airport Category Response Phases AFFF Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP High performance foam concentrate Medium performance foam concentrate General use foam comcentrate Response Capability (sec) Complementary Agents a Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Quantity (lb) Discharge (lb/sec) 180 b Q2 c Q3 d TOTAL b Q2 c 210 c Q3 d TOTAL b Q2 c 210 c Q3 d 240 d,e TOTAL b Q2 c 210 c Q3 d 240 d,e TOTAL 1,340 1,620 1, b ,194 1,194 1,331 1, Q2 c 210 c Q3 d 240 d,e 1, , , TOTAL 2,760 3,340 3, b 1,245 1,245 1,725 1,725 1,920 1, Q2 c 210 c 1,245 1,725 1,920 Q3 d 240 d,e 1, , , TOTAL 3,740 4,700 5, b 1,585 1,585 2,192 2,192 2,437 2,

40 33 of 66 1/26/2016 2:02 PM High performance foam concentrate Medium performance foam concentrate General use foam comcentrate Complementary Agents a Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Required Water (U.S. gal) Discharge Capability (gpm) Quantity (lb) Discharge (lb/sec) 7 Q2 c 210 c 2,045 2,828 3,143 Q3 d 240 d,e 1, , , TOTAL 4,880 6,270 6, b 2,095 2,095 2,901 2,901 3,222 3, Q2 c 210 c 3,185 4,409 4,898 Q3 d 240 d,e 2, , , TOTAL 7,780 9,810 10, b 2,619 2,619 3,626 3,626 4,030 4, Q2 c 210 c 4,451 6,164 6,850 Q3 d,f 240 d,e 2, , , TOTAL 9,570 12,290 13, b 3,195 3,195 4,424 4,424 4,915 4, Q2 c 210 c 6,069 8,405 9,338 Q3 d 240 d,e 5, , , TOTAL 14,260 17,830 19,250 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Table 5.3.1(b) Extinguishing Agents, Discharge and Response Capability in SI Units Protein Foam Airport Category Response Phases AFFF Fluorine-Free Synthetic Foam, Fluoroprotein, or FFFP High performance concentrate Medium performance concentrate General use foam concentrate Response Capability (sec) Complementary Agents a

41 34 of 66 1/26/2016 2:02 PM Required Water (L) Required Water (L) Discharge Required Capability Water (L) (L/min) Discharge Capability (L/min) Discharge Capability (L/min) Quantity (kg) Discharge (kg/sec) 180 b Q2 c Q3 d TOTAL b Q2 c 210 c Q3 d TOTAL 750 1,000 1, b 1,077 1,077 1,500 1,500 1,692 1, Q2 c 210 c Q3 d 240 d,e 1, , , TOTAL 2,500 3,050 3, b 1,772 1,772 2,468 2,468 2,722 2, Q2 c 210 c 1,028 1,432 1,578 Q3 d 240 d,e 2, , , TOTAL 5,050 6,150 6, b 3,257 3,257 4,514 4,514 5,029 5, Q2 c 210 c 2,443 3,386 3,771 Q3 d 240 d,e 4, , , TOTAL 10,450 12,650 13, b 4,700 4,700 6,525 6,525 7,250 7, Q2 c 210 c 4,700 6,525 7,250 Q3 d 240 d,e 4, , , TOTAL 14,150 17,800 19, b 5,983 5,983 8,297 8,297 9,214 9, Q2 c 210 c 7,717 10,703 11,886 Q3 d 240 d,e 4, , , TOTAL 18,450 23,750 25, b 7,937 7,937 10,992 10,992 12,202 12, Q2 c 210 c 12,063 16,708 18,548 Q3 d 240 d,e 9, , , TOTAL 29,450 37,150 40, b 9,907 9,907 13,722 13,722 15,259 15, Q2 c 210 c 16,843 23,328 25,941 Q3 d,f 240 d,e 9, , , TOTAL 36,200 46,500 50,650

42 35 of 66 1/26/2016 2:02 PM 180 b 12,103 12,103 16,759 16,759 18,603 18, Q2 c 210 c 22,997 31,841 35,347 Q3 d 240 d,e 18,900 1,890 18,900 1,890 18,900 1,890 TOTAL 54,000 67,500 72,850 a The minimum quantity is based on ISO qualified potassium bicarbonate. Powder can be substituted by a listed agent exceeding the performance of potassium bicarbonate. b Quantity of water for foam production for initial control of the pool fire. c Quantity of water for foam production to continue control or fully extinguish the pool fire. d Water available for interior fire fighting. e The 240-second requirement begins after arrival of the first ARFF apparatus. f For multiple passenger deck aircraft within this category, the Q3 discharge capability should be increased to 375 gpm (1420 L/min) and required water increased to 3750 gal (14,195 L). Additional Proposed Changes File Name Description Approved Hold_403-8_Comment_on_Proposal_403-15_ pdf NFPA_403_Log_3_Rec_A2013_ROC_Table.pdf Statement of Problem and Substantiation for Public Input NFPA 403 Comment on Proposal , NFPA 403 Log #3 Rec A2013 ROC Table This Public Input appeared as a "Reject but Hold" in Public Comment No of the A2013 Second Draft Report for NFPA 403 and per the Regs at Substantiation: The current table Q1 and Q2 numbers of the first column are based on lesser (medium performance level) application rates ICAO level B of 5.5 LPM per M2. The numbers have never been adjusted following the evolution of agents to higher performance requirements such as ICAO level C and Mil F and appropriate test application densities. Safety considerations: The safety factor margins have been retained in the ICAO numbers to a level equivalent to what it was in the 3 existing levels. As an example the test application rate of the ICAO level C is of 1.75 LPM per M2 for a calculated operational requirement of 3.75 LPM per M2. Trade issues in support of identifying concentrates by performance levels: Applying a type of agent such as an AFFF or FFFP to a column just by name may constitute a trade restriction. As a hypothetical example, a newly developed super protein foam could outperform some of the lesser performing AFFF. Submitter Information Verification Submitter Full Name: TC On AIR-AAA Organization: NFPA Technical Committee on Aircraft Resuce and Firefighting Street Address: City: State: Zip:

43 36 of 66 1/26/2016 2:02 PM Submittal Date: Thu Apr 30 13:15:01 EDT 2015 Committee Statement Resolution: TC feels that the current standard is sufficient at this time however further research will be done. See what the TC did on PI-14 or FR-10.

44 Report on Comments June 2013 NFPA Log #3 Bernard Valois, Autopyro , AFFF (column, for High performance foam concentrate), (Fluoroprotein and FFFP,Fluorine Free Synthetic (column 2, for Medium performance foam concentrate) and Protein Foams (column 3 with General use foam concentrate) New headers and numbers for the three columns based on the revised numbers published by the ICAO and the EASA and the performance of the current US Mil specification. Below I am providing the numbers for the new first column in metric and I am prepared to produce the equivalent table in US if the proposal is retained. First column Note: New numbers based on ICAO level C and MIL spec testing application rates Second column Third column The current table Q1 and Q2 numbers of the first column are based on lesser (medium performance level) application rates ICAO level B of 5.5 LPM per M 2. The numbers have never been adjusted following the evolution of agents to higher performance requirements such as ICAO level C and Mil F and appropriate test application densities. Safety considerations: The safety factor margins have been retained in the ICAO numbers to a level equivalent to what it was in the 3 existing levels. As an example the test application rate of the ICAO level C is of 1.75 LPM per M 2 for a calculated operational requirement of 3.75 LPM per M 2. Trade issues in support of identifying concentrates by performance levels: Applying a type of agent such as an AFFF or FFFP to a column just by name may constitute a trade restriction. As a hypothetical example, a newly developed super protein foam could outperform some of the lesser performing AFFF. 1. The ICAO standard which includes Level C, has not been formally published. 2. Large scale fire test data (e.g sq foot or greater) has not been provided. 3. Unclear whether fluorine free foam can be used with non-air aspirating nozzles (AFFF performance assumes this). 4. ICAO Level C small scale tests uses kerosene. The Mil spec used for AFFF performance uses gasoline. 5. There is potential conflict between UL 162 and the ICAO Level C test performance. Retain proposal as published in the ROP. Affirmative: 28 5 Colet, R., Deniston, H., Krajnak, D., Podolske, Jr., J., Ulrich, D. HEALEY, O.: See my Comment on Affirmative on Comment (Log #2). Printed on 4/30/2015 2

45

46 37 of 66 1/26/2016 2:02 PM Public Input No. 18-NFPA [ Section No ] The operational communications system shall provide a primary and, where necessary, an alternate effective means for direct communication between the following, as applicable (see Annex C): (1) Alerting authority such as the air traffic control tower or flight service station, airport manager, fixed-base operator, or airline office and the airport ARFF service (2) Air traffic control tower or flight service station and ARFF vehicles en route to an aircraft emergency or at the accident or incident site (3) Fire department alarm room and ARFF vehicles at the accident or incident site (4) Airport ARFF services and appropriate mutual aid organizations located on or off the airport, including an alert procedure for all auxiliary personnel expected to participate (5) ARFF vehicles (6) Responding vehicles and an aircraft in a situation of emergency using an established discreet VHF frequency Statement of Problem and Substantiation for Public Input Committee Input: Definition is for Air Traffic Control and it is an editorial change to this section to reflect the control tower is the Air Traffic Control Tower. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 14:00:13 EDT 2015 Committee Statement Resolution: FR-11-NFPA Statement: The TC updated the definition for Air Traffic Control to Air Traffic Control Tower.

47 38 of 66 1/26/2016 2:02 PM Public Input No. 30-NFPA [ Section No ] The minimum total number of trained personnel responding to an initial alarm, based on the minimum response times in Chapter 9 and extinguishing agent discharge rates and quantities required in Chapter 5, shall be in accordance with Table Table Minimum Required ARFF Personnel at Airports Airport Category ARFF Personnel Exception: Reduced manning is permitted subject to an analysis by the Authority Having Juristiction based on what would best meet the needs and demands of the ARFF department. Statement of Problem and Substantiation for Public Input The 2014 Edition revisions included an increase in response time to runways, elimination of a specific response time requirement to the movement area, and a reduction the number of responding ARFF vehicles. Supporting rationale for these reductions in the level of a safety included the concepts of: requirements based on currently accepted practices; what would best meet the needs and demands of each ARFF department; consideration of the practicality of requirements; and correlation with and possible recognition of NFPA 403 with FAA and ICAO regulations. Certainly, minimum manning requirements should meet this "practicality" test. Some relief should be provided, as proposed. To be clear, I don't necessary support this approach. But to be consistent, the committee should insert performance requirements where there are "practical" difficulties in meeting requirements, and where NFPA 403 is more stringent than FAA and ICAO requirements. Submitter Information Verification Submitter Full Name: Joseph Scheffey Organization: JENSEN HUGHES Affilliation: Special expert, not representing any client or interest Street Address: City: State: Zip: Submittal Date: Mon Jul 06 12:07:56 EDT 2015

48 39 of 66 1/26/2016 2:02 PM Committee Statement Resolution: FR-12-NFPA Statement: TC felt that task resource analysis would show justification to changes to staffing. Additional research will be done.

49 40 of 66 1/26/2016 2:02 PM Public Input No. 22-NFPA [ Sections , ] Sections , The response time of the first responding ARFF vehicle to reach any point on the operational runway and begin agent application shall be within 3 minutes of the time of the alarm. 2 minutes or less, and to any point remaining within the on-airport portion of the rapid response area shall be no more than 2 ½ minutes The response time of the first responding ARFF vehicle to reach any point remaining within the on-airport portion of the RRA with improved surface conditions shall be within 4 minutes from the time of the alarm an incident/accident involving any aircraft with passengers in the aircraft movement area beyond or outside the runway or rapid response area shall be 3 minutes or less. Statement of Problem and Substantiation for Public Input Return response time requirements to that which was in the 2009 Edition of NFPA See also original rationale for the 2 minute requirement, to be distributed at the Public Input committee meeting. 2.The basis of the original two minute response time is burnthrough of the fuselage and the onset of hazardous conditions to passengers and crew. In the change in the last edition from 2 minutes to 3 minutes, no technical data was submitted to substantiate increased response time due to increased burnthrough time, or reduced threat to occupants. This isn t surprising since there are no such data. While improvements in burnthrough time are being implemented for new aircraft, it will take decades until all fleets meet the increased burnthrough time. 3.Admittedly, piecing together the original data and rationale for the 2 minute response time is tedious and difficult, as I pointed out in my recent report published by the FAA1. No single technical report describes this. This was recognized by the committee many years ago, and as a result, past committee member and pilot Tom Lindemann published the basis of the rationale in Industrial Fire World2. 4.An argument has been made that many airports can t meet the response time requirement, therefore no one will adopt NFPA 403 and the standard serves no use with the lower, technically-based 2 minute response time criteria. This is a specious argument: a.the committee has always striven to be technically sound, not politically expedient. For example: i.the US Navy MIL SPEC or equivalent for AFFF was adopted by the committee based on a sound technical argument3. This was not recognized by any aviation regulatory authority at the time. Now it is essentially required by the US FAA. Some might argue that it has contributed to the development of the new ICAO Level C foam requirement. ii.nfpa 403 has minimum personnel requirements (Table ). No regulatory authority has adopted these requirements. Should they be deleted so that the potential of NFPA 403 being adopted are improved? No, the committee established a technical basis for this requirement which they deemed appropriate. b.the claim that most airports can t meet the 2 minute response time are not supported by NFPA s own literature. In a 1999 report by NFPA s Michael Karter4, ARFF resources in the US were compared to NFPA 403 requirements. The data from Table 7 of that report indicated that, of the 391 airports surveyed or contacted, the following airports met NFPA 403 response time requirements (which are more stringent than the FAA minimum required time): Airport Category % Airports Surveyed Meeting NFPA 403 Response Time Requirements FAA NFPA A

50 41 of 66 1/26/2016 2:02 PM A B C D E What a great success this shows for airports striving to achieve the NFPA technically-based response time requirement. While one might quibble with the analysis technique (time from alarm to leaving the station were not included), the technique was consistent for the farthest point on the runway, and identifies those situations where NFPA 403 criteria might reasonably be achieved (and those which probably can t). Performance differences are apparent; this demonstrates that technically sound requirements will filter into the field even when they exceed regulatory-mandated criteria. The fact that most small and large airports and nearly half the very largest airports in the US could potentially meet NFPA 403 response time requirements in itself validates the technically-based approach of the committee. c.an example outside the aviation industry shows how NFPA advocates for an appropriate level of life safety: Residential sprinklers for single family dwellings has been advocated by NFPA. This proposed protection criteria has encountered sometimes fierce opposition from regulatory bodies who reject adoption of residential sprinklers through the legislative process. Should NFPA withdraw its support, just because their residential sprinkler standards are not currently widely adopted? 5.The Hunt analysis for the FAA5 demonstrated that the 2 minute response might not handle the absolute worst case, i.e. immediate ignition of a large pool directly intimate with an aircraft fuselage. Any contention that the 2 minute response is for the absolute worst case is inaccurate. There may be a potential subset of incidents where 2 minutes is insufficient. Practically speaking, this might be where the fuselage breaks up upon impact and passengers are immediately, directly exposed. Structural improvements to aircraft have increased the probability of an intact fuselage at an airport crash. The 2 minute response has been considered a reasonable, practical, technically justified, and necessary requirement. The use of the Hunt data to evaluate response time per se distorts the intent of the report objective and analysis, which was to determine appropriate agent quantities. In simple terms, the variable of response time demonstrated a greater chance of failure to affect passenger safety by controlling a fire with a quantity of foam. 6.The NFPA Technical Committee on Airport Facilities has recognized the importance of a timely ARFF response to protect passengers discharging from aircraft at the terminal. A recent FPRF report describes the loss history and importance of ARFF response, particularly where passengers and crew may evacuate without a protected path (i.e. fire restive bridge/walkway)6. This committee has formally requested that NFPA 403 provide a 2 minute response, particularly to the terminal area (in NFPA 403 terms, the movement area for passenger-occupied aircraft). The change to the current edition of NFPA 403 totally eliminates any response time requirement to this area, which has had demonstrated fire loss and handles all embarking and disembarking passengers! 7.Summarizing, the technical basis for the 2 minute response time is unequivocal. The NFPA 403 technical committee should return to its roots and reestablish this criteria based on the technical merits. Alternately, those supporting a greater response time should demonstrate quantitatively that life-threatening conditions are unlikely to occur in the first 3 minutes of a crash. References (provided to the staff liaison for distribution to the TC and for public availability): 1.Scheffey, J.L., Darwin, R.L., and Hunt, S.P., A Technical Review of Methodologies for Calculating Firefighting Agent Quantities Needed to Combat Aircraft Crash Fires, DOT/FAA/(AR)-11/29, U.S. Department of Transportation, Federal Aviation Administration, April Lindemann, T., Aircraft Fire Fighting in Three Minutes or Less, Industrial Fire World, 5 (1), January March 1990, pp. 6, Scheffey, J.L. and Wright, J., Analysis of Test Criteria for Specifying Foam Firefighting Agents for Aircraft Rescue and Firefighting, Report No. DOT/FAA/CT-94/04, Federal Aviation Administration, Washington, DC, August, Karter, M.S., Who s Got What, NFPA Journal, May/June 1999, pp Hunt, S.P. and Scheffey, J.L., Analysis of Suppression Effects on Aviation Fuel Fires Around an Aircraft, Final Report, DOT/FAA/(AR)-11/27, U.S. Department of Transportation, Federal Aviation Administration, Washington, DC, November Swann, J.D., and Scheffey, J.S., Aircraft Loading Walkways Literature and Information Review, Fire Protection Research Foundation Technical Note, Quincy, MA, May 2014 Related Public Inputs for This Document

51 42 of 66 1/26/2016 2:02 PM Related Input Public Input No. 21-NFPA [Section No ] Relationship Submitter Information Verification Submitter Full Name: Joseph Scheffey Organization: JENSEN HUGHES Affilliation: Special Expert, independent, not representing any organization Street Address: City: State: Zip: Submittal Date: Wed Jun 17 15:17:51 EDT 2015 Committee Statement Resolution: The Technical Committee determined that the existing requirements are acceptable.

52 43 of 66 1/26/2016 2:02 PM Public Input No. 23-NFPA [ Section No ] The response time of the first responding ARFF vehicle to reach any point remaining within the on-airport portion of the RRA with improved surface conditions shall be within 4 minutes from the time of the alarm. Statement of Problem and Substantiation for Public Input See proposal and ration for change to and Submitter Information Verification Submitter Full Name: Joseph Scheffey Organization: JENSEN HUGHES Affilliation: Special Expert, independent, not representing any organization Street Address: City: State: Zip: Submittal Date: Wed Jun 17 15:34:25 EDT 2015 Committee Statement Resolution: TC feels that this is adequate.

53 44 of 66 1/26/2016 2:02 PM Public Input No. 33-NFPA [ New Section after ] Chapter 10: Special Events 10.1 General (It is our suggestion that a new chapter be added to 403 and that it be the chapter that includes information on ARFF response at special events at an airport. Section 10.1 would explain the purpose of this chapter and perhaps provide some definitions relevant to the items in this chapter. The first special event that would would like to see discussed -- and the reason that we want to add a new chapter -- is to provide details on appropriate response protocols for air shows held at civilian and military airfields 10.2 ARFF response at public air shows. Air shows are aviation events that are often conducted at civilian and military airfields. The unique nature of air show flying requires a non-standard level of preparedness. The non-standard environment in which air shows are conducted, the non-standard aircraft that are often fly at these events, and the non-standard manner in which those aircraft are flown requires a non-standard level of and type of ARFF preparedness and response. This document details the nature and specific details required for ARFF preparedness and response at a public air show ARFF vehicles and crew must be deployed in such a way that ARFF personnel can respond to an accident/incident and deploy firefighting agent within sixty (60) seconds in 90 percent of the incidents/accidents The entire period during which the aircraft are flying during the air show will be treated as an "announced" emergency To meet the standard, it is recommended that ARFF vehicles be tactically prepositioned to provide the shortest and most direct routes to the show center. In all cases, ARFF vehicles must not be positioned behind the crowd line or staged in the fire station To meet the standard at public air shows expected to include jet/turbine performances or any air show in which the length of the aerobatic box exceeds 8,000 feet or the width of the aerobatic box exceeds 2,000 feet, it is recommended that ARFF vehicles and Crash Fire Rescue (CFR) personnel will be deployed to the right and left of the air show/open house crowd area with unimpeded access to the area in which air show flight operations are conducted. In addition, an ARFF vehicle (preferably a small, rapid intervention-type vehicle) will be positioned at or near show center. All deployed vehicles will be positioned so that they have an unobstructed line of sight on the whole airfield, specifically, the aerobatic box (see illustration below) in which the majority of the air show flight operations are conducted. Historically, when an accident or incident occurs during a public air show, the aircraft wreckage comes to rest within the aerobatic box. By positioning ARFF vehicles at each end of the crowd area and one at show center, our response time will improve and may save lives To meet the standard at air shows where jets are not performing or air shows at which the length of the aerobatic box is less than 8,000 feet AND the wide of the aerobatic box is less than 2,000 feet, organizers may consider having a total of two (2) ARFF vehicles deployed to the left and right side of the crowd area (as described in item 1.3) above, but without an ARFF vehicle located at or near show center. In such cases, it is recommended that one of the two vehicles be a small, rapid-intervention-type vehicle. It is also recommended that there never be fewer than two (2) vehicles deployed and ready to respond to an incident/accident The Aerobatic Box. The Federal Aviation Administration (FAA) defines the aerobatic box as the airspace at an air show where participating aircraft are authorized to perform aerobatic maneuvers appropriate to their Category (CAT). This box begins at the appropriate CAT I/II/III show line shown below. (It appears that the program will not accept an illustration. At this juncture, we would include an illustration depicting the air show aerobatic box.) Note: The two-dimensional parameters of the aerobatic box are defined by the bright pink line. In addition to these two dimensions, there is a third dimension to the aerobatic box that ensures that the airspace in which air show flight operations are conducted is sterile. That third dimension varies (based primarily on the type of aircraft that are performing) from

54 Chapter 10: Special Events 10.1 General 10.2 ARFF response at public air shows. Air shows are aviation events that are often conducted at civilian and military airfields. The unique nature of air show flying requires a non-standard level of preparedness. The nonstandard environment in which air shows are conducted, the non-standard aircraft that are often fly at these events, and the non-standard manner in which those aircraft are flown requires a non-standard level of and type of ARFF preparedness and response. This document details the nature and specific details required for ARFF preparedness and response at a public air show ARFF vehicles and crew must be deployed in such a way that ARFF personnel can respond to an accident/incident and deploy firefighting agent within sixty (60) seconds in 90 percent of the incidents/accidents The entire period during which the aircraft are flying during the air show will be treated as an "announced" emergency To meet the standard, it is recommended that ARFF vehicles be tactically prepositioned to provide the shortest and most direct routes to the show center. In all cases, ARFF vehicles must not be positioned behind the crowd line or staged in the fire station To meet the standard at public air shows expected to include jet/turbine performances or any air show in which the length of the aerobatic box exceeds 8,000 feet or the width of the aerobatic box exceeds 2,000 feet, it is recommended that ARFF vehicles and Crash Fire Rescue (CFR) personnel will be deployed to the right and left of the air show/open house crowd area with unimpeded access to the area in which air show flight operations are conducted. In addition, an ARFF vehicle (preferably a small, rapid intervention-type vehicle) will be positioned at or near show center. All deployed vehicles will be positioned so that they have an unobstructed line of sight on the whole airfield, specifically, the aerobatic box (see illustration below) in which the majority of the air show flight operations are conducted. Historically, when an accident or incident occurs during a public air show, the aircraft wreckage comes to rest within the aerobatic box. By positioning ARFF vehicles at each end of the crowd area and one at show center, our response time will improve and may save lives To meet the standard at air shows where jets are not performing or air shows at which the length of the aerobatic box is less than 8,000 feet AND the wide of the aerobatic box is less than 2,000 feet, organizers may consider having a total of two (2) ARFF vehicles deployed to the left and right side of the crowd area (as described in item 1.3) above, but without an ARFF vehicle located at or near show center. In such cases, it is recommended that one of the two vehicles be a small, rapid-intervention-type vehicle. It is also recommended that there never be fewer than two (2) vehicles deployed and ready to respond to an incident/accident The Aerobatic Box. The Federal Aviation Administration (FAA) defines the aerobatic box as the airspace at an air show where participating aircraft are authorized to perform aerobatic maneuvers appropriate to their Category (CAT). This box begins at the appropriate CAT I/II/III show line shown below.

55 Illustration Note: The two-dimensional parameters of the aerobatic box are defined by the bright pink line. In addition to these two dimensions, there is a third dimension to the aerobatic box that ensures that the airspace in which air show flight operations are conducted is sterile. That third dimension varies (based primarily on the type of aircraft that are performing) from as low as 3,000 feet to as high as 20,000 feet The aerobatic box is the sterile area in which air show flight operations are conducted. The boundaries, dimensions and parameters of the aerobatic box are clearly and specifically defined as part of the application that air show organizers submit to the FAA to receive authorization to conduct an air show A written or graphic illustration of the aerobatic box must be presented to performers and emergency response personnel during the pre-air show safety briefing ARFF personnel will be staged to respond immediately to any incident or accident. Friends and family will not be located in the area of ARFF vehicle positions. Additionally, folding chairs or any other obstructions should never be positioned in front of pre-positioned ARFF vehicles ARFF personnel will don their firefighter PPE and/or have them positioned in such a way that they can put them on and still meet the requirement of applying fire agent within 60 seconds of an incident/accident. Vehicle engines will be running throughout the entire active flying portion of the air show To ensure clear lines of communications, the incident commander should consider positioning himself/herself or a liaison with the air boss throughout the air show Prior to the air show and not later than the first safety briefing on the rehearsal/practice day of the air show (typically Friday at most shows), firefighters will meet with the air show operations officer, the air show air boss and appropriate air traffic control personnel to discuss procedures and methods to reduce the standard radio communications and runway/taxiway clearances required for ARFF personnel to respond to an incident/accident during the air show. These procedures and methods will be developed with the goal of allowing firefighters to respond to an incident/accident without being delayed by procedural or communications issues.

56 Prior to the beginning of air show flight operations, at least one firefighter from each ARFF vehicle deployed in support of the show will make themselves available to meet with the pilot-in-command of each aircraft participating in the air show/open house to discuss emergency extraction, canopy release, fuel shut off, master switch on/off switch and aircraft lift points. If the firefighters are different on subsequent days of the event, at least one firefighter will make himself/herself available to each pilot and other firefighters to re-brief the emergency response information In consultation with the air show operations officer and the air show air boss, firefighters will either participate in a pre-event table top emergency response exercise or be available to conduct an emergency response drill on the practice/rehearsal day of the air show (typically a Friday for a Saturday/Sunday event).

57 45 of 66 1/26/2016 2:02 PM as low as 3,000 feet to as high as 20,000 feet The aerobatic box is the sterile area in which air show flight operations are conducted. The boundaries, dimensions and parameters of the aerobatic box are clearly and specifically defined as part of the application that air show organizers submit to the FAA to receive authorization to conduct an air show A written or graphic illustration of the aerobatic box must be presented to performers and emergency response personnel during the pre-air show safety briefing ARFF personnel will be staged to respond immediately to any incident or accident. Friends and family will not be located in the area of ARFF vehicle positions. Additionally, folding chairs or any other obstructions should never be positioned in front of pre-positioned ARFF vehicles ARFF personnel will don their firefighter PPE and/or have them positioned in such a way that they can put them on and still meet the requirement of applying fire agent within 60 seconds of an incident/accident. Vehicle engines will be running throughout the entire active flying portion of the air show To ensure clear lines of communications, the incident commander should consider positioning himself/herself or a liaison with the air boss throughout the air show Prior to the air show and not later than the first safety briefing on the rehearsal/practice day of the air show (typically Friday at most shows), firefighters will meet with the air show operations officer, the air show air boss and appropriate air traffic control personnel to discuss procedures and methods to reduce the standard radio communications and runway/taxiway clearances required for ARFF personnel to respond to an incident/accident during the air show. These procedures and methods will be developed with the goal of allowing firefighters to respond to an incident/accident without being delayed by procedural or communications issues Prior to the beginning of air show flight operations, at least one firefighter from each ARFF vehicle deployed in support of the show will make themselves available to meet with the pilot-in-command of each aircraft participating in the air show/open house to discuss emergency extraction, canopy release, fuel shut off, master switch on/off switch and aircraft lift points. If the firefighters are different on subsequent days of the event, at least one firefighter will make himself/herself available to each pilot and other firefighters to re-brief the emergency response information In consultation with the air show operations officer and the air show air boss, firefighters will either participate in a pre-event table top emergency response exercise or be available to conduct an emergency response drill on the practice/rehearsal day of the air show (typically a Friday for a Saturday/Sunday event). Additional Proposed Changes File Name Description Approved new_chapter_for_nfpa_403.docx new chapter for NFPA 403 Statement of Problem and Substantiation for Public Input There is currently not a standard that explains and establishes protocol for emergency response at public air shows. This has created dangerous situations and resulted in multiple, unnecessary fatalities. Passage of this new chapter would take a big step toward solving that problem. Submitter Information Verification Submitter Full Name: JOHN CUDAHY Organization: INTL COUNCIL OF AIR SHOWS Street Address: City: State: Zip: Submittal Date: Mon Jul 06 16:14:33 EDT 2015

58 46 of 66 1/26/2016 2:02 PM Committee Statement Resolution: FR-21-NFPA Statement: The TC had lengthy discussion on topic and edited the document with the submitter in order to have introductory language with the thought that further input will be required during the SD process

59 47 of 66 1/26/2016 2:02 PM Public Input No. 28-NFPA [ Section No ] Airport ARFF services shall develop/implement a plan for responding to an accident/incident involving any aircraft with passengers within the aircraft movement area beyond or outside the runway and RRA. Statement of Problem and Substantiation for Public Input See proposed change to and Response to the movement area should have a specific requirement. The FPRF boarding bridge report provides additional support for a specific requirement. Submitter Information Verification Submitter Full Joseph Scheffey Name: Organization: JENSEN HUGHES SPecial expert, independent, not representing any particular Affilliation: interest Street Address: City: State: Zip: Submittal Date: Fri Jun 26 11:29:22 EDT 2015 Committee Statement Resolution: TC felt that this is appropriate language.

60 48 of 66 1/26/2016 2:02 PM Public Input No. 17-NFPA [ Section No. A ] A The two test methods cited in have wide application in North America but might not be recognized in other areas of the world. In particular, ICAO has developed guidance that references foam evaluation methods having significantly different test parameters such as test fuel, application rate, and extinguishment density. The intent of this standard is that primary foam agents meet minimum performance criteria. It is the intent that aqueous film-forming foams achieve a level of performance consistent with the Acceptable standards for foam concentrates vary from country to country. In the U.S., the authority having jurisdiction is the U.S. FAA which requires foam concentrates be aqueous film-forming foam agents meeting all of the criteria of the U.S. Military Specification MIL-F-24385, Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF), Liquid Concentrate, for Fresh and Sea Water, when the lowest discharge rates/quantities in Table 5.3.1(a) and Table 5.3.1(b) are used. The national (ICAO State) civil aviation authority having jurisdiction can adopt or reference standards recognized in that particular part of the world. It is incumbent on the national (ICAO State) authority to determine that alternate test methods are consistent with the minimum agent rates/quantities they have adopted. The national (ICAO State) civil aviation authority having jurisdiction should make this determination to prevent inconsistencies at the local or regional level.. Freshwater or seawater can be used for the fire test. Concentrates that successfully pass this testing appear on the Qualified Products List (QPL ). This U.S. Military Specification standard contains a variety of physical property requirements that allow these concentrates to be interchangeable and still function properly if the proportioning system is not operating at the proper rate. This is in comparison to ICAO requirements which do not require a specific surfactant type. Foam concentrates that have passed the ICAO Level A, B, or C performance tests will have varying viscosities affecting proportioning and nozzle type (aspirating or non-aspirating) and are not considered interchangeable. The ICAO and U.S. Military Specification standards contain performance tests that are specific to the requirements for airport hazards and concentrates should be tested by an authorized body to conduct and certify compliance. Certification documentation from the foam concentrate manufacturer should be made available to the authority having jurisdiction. NFPA 412 contains additional foam quality and drainage time requirements along with the test methods for these properties. Statement of Problem and Substantiation for Public Input Committee Input: The requirement for AFFF foams to pass Mil-Spec have been removed from the body of the standard and this revised text discusses that various countries have differing requirements. It discusses that in the US, that the authority is the FAA and they require Mil-Spec foam. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:55:47 EDT 2015 Committee Statement Resolution: FR-13-NFPA

61 49 of 66 1/26/2016 2:02 PM Statement: Committee Input: The requirement for AFFF foams to pass Mil-Spec have been removed from the body of the standard and this revised text discusses that various countries have differing requirements. It discusses that in the US, that the authority is the FAA and they require Mil-Spec foam.

62 50 of 66 1/26/2016 2:02 PM Public Input No. 16-NFPA [ Section No. A ] A Aqueous film-forming foam agents meeting all of the criteria of the U.S. Military Specification MIL-F-24385, Fire Extinguishing Agent, Aqueous Film-Forming Foam (AFFF), Liquid Concentrate, for Fresh and Sea Water, appear on the Qualified Products List (QPL ). Other standards organizations have fire test criteria comparable to the U.S. Military Specification MIL-F The authority having jurisdiction should obtain from their foam manufacturer, certification documentation on the foam fire performance equivalency. Freshwater or seawater can be used for the fire test. Statement of Problem and Substantiation for Public Input Committee Input: The language from this annex section was moved into A Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:54:35 EDT 2015 Committee Statement Resolution: FR-14-NFPA Statement: The TC moved the language from this annex section to A

63 51 of 66 1/26/2016 2:02 PM Public Input No. 15-NFPA [ Section No. A ] A Table A provides fuel weight conversions. Table A Fuel Weight Conversions at 15 C (59 F) From/To Pounds Avgas Pounds Jet A Jet A-1 Jet A-2 Arctic Diesel Pounds Jet B JP-4 F-40 Pounds JP-6 JP-8 Gallons 6.01 Avgas Gallons 7.00 Jet A Jet A-1 Jet A-2 Arctic Diesel Gallons 6.68 Jet B JP-4 F-40 Gallons 6.50 JP-6 JP-8 Statement of Problem and Substantiation for Public Input Committee Input: This annex section provides unit conversions for various fuel types. This material does not directly relate to the corresponding section in the body and was deemed unnecessary. Submitter Information Verification Submitter Full Name: BRADFORD COLTON Organization: AMERICAN PACIFIC CORPORATION Street Address: City: State: Zip: Submittal Date: Mon May 04 13:52:36 EDT 2015 Committee Statement Resolution: FR-15-NFPA Statement: This annex section provides unit conversions for various fuel types. This material does not directly relate to the corresponding section in the body and was deemed unnecessary.

64 52 of 66 1/26/2016 2:02 PM Public Input No. 31-NFPA [ Section No. B.6 ] B.6 Today s Situation.

65 53 of 66 1/26/2016 2:02 PM The basic concepts developed by the ICAO RFFPs are still considered valid. However, the variables previously mentioned that are used to develop the f factor for Q 2 have been refined over time and are now expressed as follows: (1) Aircraft Size. Aircraft size reflects the potential level of risk. This risk factor is a composite of the passenger load, the potential internal fire load, flammable liquid fuel capacity, and the fuselage length and width. Careful consideration of all these factors allows the identification of a meaningful operational objective, that is, the area to be rendered fire free (controlled or extinguished). (2) Relative Effectiveness of Agent Selected. This variable is accounted for by the specific application rate identified for each of the common generic foam concentrate types. (3) Time Required to Achieve PCA Fire Control. Information from reliable large-scale fire tests, empirical data from a wide variety of sources, and field experience worldwide indicate that 1 minute is both a reasonable and a necessary operational objective. (4) Time Required to Maintain the Controlled Area Fire Free or to Extinguish the Fire. An operational objective that provides a safety factor for the initial fire attack on the PCA while waiting for the arrival of backup support or to complete extinguishment of remaining fires outside the PCA. The quantity of water for foam production required for 1-minute fire control of the PCA is still referred to as Q 1. However, data collected in the ensuing years now permit us to specify permitted specifying the required application rates for three generic foam types needed to extinguish fire in 1 ft 2 or 1 m 2 of the PCA as follows: (1) AFFF = 0.13 gpm/ft 2 or 5.5 L/min/m 2 (2) FP = 0.18 gpm/ft 2 or 7.5 L/min/m 2 (3) PF = 0.20 gpm/ft 2 or 8.2 L/min/m 2 These application rates were based primarily on full-scale studies conducted by Geyer (Geyer 1972) using both high volatility JP4 fuel and lower volatility fuel such as JP5 and Jet A. Over the years, NFPA 403 expanded the use of the FP application rate to other surfactants, such as FFFP and FFSF foams which could meet ICAO B level foam tests. The fourth edition, 2014, of the ICAO Airport Services Manual, Part 1, Rescue and Fire Fighting, introduced a more difficult performance test, Level C. The intent of the new ICAO Level C foam performance test was an attempt to match test parameters to those in MIL-F while keeping the test in line with the ICAO Level A and B test procedures. During the development process, under sponsorship from the CAA, 27 foams from 8 manufacturers were tested by CNPP (CNPP-Vernon, 2008). The result is a test that is rigorous, but in certain aspects do not quite a match to the performance of the Mil-Spec foams which are required to contain film forming fluorinated surfactants. Fire test differences related to pan size, fuel (gasoline versus Jet A), manual versus fixed foam application, and the allowance of 99% control versus full extinguishment at 1 minute. However, it has been shown that few foams have the ability to pass ICAO C reflecting the difficulty of this test procedure. There has been limited full scale testing of ICAO C foams, but tests to date have reflected extinguishments on Jet A within 1 minute at the ICAO application rate of gpm/ft 2 (3.75 L/min/m 2 ). The 0.13 gpm/ft 2 (5.5 L/min/m 2 ) application rate requirement for AFFF meeting Mil-Spec in NFPA 403 is 40% higher. ICAO Level C foams will have a safety margin when used at the 0.13 gpm/ft 2 (5.5 L/min/m 2 ) application rate. It was concluded that, for purposes of this standard, that ICAO Level C foam application rates could be set as equivalent to Mil-Spec foam. When considering the ICAO C foams, the committee also considered the classification designations used in NFPA 403 for application rates. Historically, these related to the constituents of the foam, e.g. protein, fluoroprotein, and fluorinated surfactants used in AFFF. There was a desire by the committee to eliminate the designation of foams by constituents, and use a performance based approach. The ICAO levels A, B and C provide such an approach. Foams are evaluated based on fire performance, not physical or chemical attributes. This allows future modifications of foam formulations, e.g. for environmental improvement, without changing the fire performance criteria. It was recognized that there are some limitations to this approach that users of ICAO C should be aware of. The intent of the MIL-F standard is to create AFFF foam concentrates that have similar physical properties and will be interchangeable between various manufacturers. The Mil-Spec also requires fire performance tests of the foam concentrate proportioned incorrectly, either too low or too high. It is noted that the ICAO tests are primarily fire performance tests and foams between manufacturers are not

66 54 of 66 1/26/2016 2:02 PM considered interchangeable and there are no requirements for testing of incorrectly proportioned foam. Airports adopting ICAO foam concentrates should evaluate equipment requirements any time a switch to a new manufacturer of foam concentrates is considered. Therefore, starting with the 2016 edition of NFPA 403, the following application rates by test standard are used: (1) MIL-F and ICAO Level C = 0.13 gpm/ft 2 or 5.5 L/min/m 2 (2) ICAO Level B = 0.18 gpm/ft 2 or 7.5 L/min/m 2 (3) ICAO Level A = 0.20 gpm/ft 2 or 8.2 L/min/m 2 UL 162 and EN 1568 have been recognized in past revisions of NFPA 403. In the move toward classification by performance testing, these referenced test standards were deleted since they were not developed with a focus of aircraft rescue and firefighting applications. Over time the changes in aircraft size factor have required revisions to the values of both Q 1 and Q 2 and the introduction of a third component, Q 3, which make up the total quantity of water (Q) required for the production of foam. For example, Q 1 changes as a function of the accepted foam application rates and the size of the operational aircraft common to the various airport categories. And, because Q 2 is a function of Q 1, it too is impacted by changes in aircraft size and requires revision from time to time to accurately reflect the changes in the operational aircraft fleet. The operational significance of the components making up Q is substantial in that Q relates to both the specific quantities of fire suppression agents required to control fire in the PCA and to the requirement that the specified quantity of agent be applied to the PCA within a time frame of 1 minute. In turn, Q 2 relates to the need to have sufficient fire suppression agents available to maintain conditions that do not pose a threat to life in the PCA until such time as rescue operations are completed. The secondary role of Q 2 is to extinguish all fires in and peripheral to the PCA. The development of the requirement for these two quantities of water is based on exterior aircraft fuel spill fire control parameters. Information from actual incidents in recent years has shown that with increased aircraft crash worthiness, water for interior fire-fighting operations is also necessary. This quantity of water, called Q 3, is based on the need for handlines to be used for interior fire fighting. Hence, the total quantity of water (Q) is now defined as follows: where: Q 1 = water requirement for control of PCA Q 2 = water requirement to maintain control or extinguish the remaining fire or both Q 3 = water requirement for interior fire fighting (See Figure B.6.) Figure B.6 Comparison of Water by Volume of Q 1, Q 2, Q 3, and Q for Producing Foam Solution Using AFFF.

67 55 of 66 1/26/2016 2:02 PM