Report on Proposals F2006 Copyright, NFPA NFPA 12 Report of the Committee on

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1 Report of the Committee on George Unger, Underwriters Laboratories of Canada, Canada [RT] (Alt. to George E. Laverick) Gaseous Fire Extinguishing Systems Nonvoting Jeffrey L. Harrington, Chair Harrington Group, Incorporated, GA [SE] Ronald C. Adcock, Marsh USA Incorporated, AZ [I] Maurizio Barbuzzi, North American Fire Guardian Technology, Incorporated, Italy [M] Douglas J. Barylski, US Department of the Navy, DC [E] Todd A. Dillon, GE Insurance Solutions, OH [I] Philip J. DiNenno, Hughes Associates, Incorporated, MD [SE] William A. Eckholm, Firetrace International, AZ [M] Dale R. Edlbeck, Tyco Fire & Security/Ansul, WI [M] Don A. Enslow, BP Exploration (Alaska), AK [U] William A. Froh, US Department of Energy, DC [U] Matthew T. Gustafson, US Social Security Administration, MD [U] Howard S. Hammel, DuPont Fluoroproducts, DE [M] Robert H. Kelly, Fire Defense Equipment Company Incorporated, MI [IM] Rep. Fire Suppression Systems Association George E. Laverick, Underwriters Laboratories Incorporated, IL [RT] Norbert W. Makowka, National Association of Fire Equipment Distributors, IL [IM] Bella A. Maranion, US Environmental Protection Agency, DC [E] Robert C. Merritt, FM Global, MA [I] Robert G. Richard, Honeywell, Incorporated, NY [M] Paul E. Rivers, 3M Fire Protection, MN [M] Patrick W. Schoening, General Motors Corporation, MI [U] Joseph A. Senecal, Kidde-Fenwal, Incorporated, MA [M] Clifford R. Sinopoli, II, Exelon Corporation, PA [U] Rep. Edison Electric Institute Louise C. Speitel, US Federal Aviation Administration, NJ [E] Brad T. Stilwell, Fike Corporation, MO [M] Al Thornton, Chemtura, TX [M] Klaus Wahle, US Coast Guard, DC [E] () Fred K. Walker, US Department of the Air Force, FL [E] Robert T. Wickham, Wickham Associates, NH [SE] Rep. Halon Alternatives Research Corporation Thomas J. Wysocki, Guardian Services, Incorporated, IL [SE] Jiann C. Yang, US National Institute of Standards & Technology, MD [RT] Alternates Philip B. Atteberry, Chemtura, IL [M] (Alt. to Al Thornton) Kenneth V. Blanchard, DuPont Fluoroproducts, DE [M] (Alt. to Howard S. Hammel) Charles O. Bauroth, Liberty Mutual Property, MA [I] (Voting Alt. to PCIAA Rep.) Randall Eberly, US Coast Guard, DC [E] (Alt. to Klaus Wahle) Steven A. Giovagnoli, GE Insurance Solutions, IL [I] (Alt. to Todd A. Dillon) Raymond N. Hansen, US Department of the Air Force, FL [E] (Alt. to Fred K. Walker) William Matt Hogan, Duke Power Company, SC [U] (Alt. to Clifford R. Sinopoli, II) Daniel J. Hubert, Kidde/Chemetron Fire Systems, IL [M] (Alt. to Joseph A. Senecal) Mary P. Hunstad, US Department of the Navy, DC [E] (Alt. to Douglas J. Barylski) Giuliano Indovino, North American Fire Guardian Technology, Incorporated, Italy [M] (Alt. to Maurizio Barbuzzi) Robert Kasiski, FM Approvals/FM Global, RI [I] (Alt. to Robert C. Merritt) Richard A. Malady, Fire Fighter Sales & Service Company, PA [IM] (Alt. to Norbert W. Makowka) Earl D. Neargarth, Fike Corporation, MO [M] (Alt. to Brad T. Stilwell) Ivan M. Nibur, Global Risk Consultants Corporation, KY [SE] (Voting Alt. to GRC Corp. Rep.) Steven W. Rhodes, US Social Security Administration, MD [U] (Alt. tomatthew T. Gustafson) James M. Rucci, Harrington Group, Incorporated, GA [SE] (Alt. to Jeffrey L. Harrington) John M. Schuster, 3M Company, MN [M] (Alt. to Paul E. Rivers) Len D. Seebaluck, Firetrace International, AZ [M] (Alt. to William A. Eckholm) Margaret A. Sheppard, US Environmental Protection Agency, DC [E] (Alt. to Bella A. Maranion) John C. Spalding, Healey Fire Protection, Incorporated, MI [IM] (Alt. to Robert H. Kelly) 12-1 Rudolf Klitte, Ginge-Kerr Danmark A/S, Denmark [M] Ingeborg Schlosser, VdS Schadenverhutung, Germany [I] Fernando Vigara, Fernando Vigara & Asociados, Spain [SE] Staff Liaison: Mark T. Conroy Committee Scope: This Committee shall have primary responsibility for documents on the installation, maintenance, and use of carbon dioxide systems for fire protection. This Committee shall also have primary responsibility for documents on fixed fire extinguishing systems utilizing bromotrifluoromethane and other similar halogenated extinguishing agents, covering the installation, maintenance, and use of systems. This Committee shall also have primary responsibility for documents on alternative protection options to Halon 1301 and 1211 fire extinguishing systems. It shall not deal with design, installation, operation, testing, and maintenance of systems employing dry chemical, wet chemical, foam, aerosols, or water as the primary extinguishing media. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. The Technical Committee on Gaseous Fire Extinguishing Systems is presenting three Reports for adoption, as follows: Report I: The Committee proposes for adoption, amendments to NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2000 edition. NFPA 12 is published in Volume 1 of the 2004/2005 National Fire Codes and in separate pamphlet form. NFPA 12 has been submitted to letter ballot of the Technical Committee on Gaseous Fire Extinguishing Systems, which consists of 32 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Report II: The Technical Committee proposes for adoption, amendments to NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 2004 edition. NFPA 12A is published in Volume 1 of the 2004/2005 National Fire Codes and in separate pamphlet form. This Report has been submitted to letter ballot of the Technical Committee on Gaseous Fire Extinguishing Systems, which consists of 32 voting members; of whom 31voted affirmatively, and 1 ballot was not returned (T. Dillon). Report III: The Technical Committee proposes for adoption, amendments to NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2004 edition. NFPA 2001 is published in Volume 12 of the 2004/2005 National Fire Codes and in separate pamphlet form. This Report has been submitted to letter ballot of the Technical Committee on Gaseous Fire Extinguishing Systems, which consists of 32 voting members; of whom 27 voted affirmatively, 5 negatively after circulation of negative ballots (M. Barbuzzi, D. Edlbeck, H. Hammel, B. Stillwell, T. Wysocki). Mr. M. Barbuzzi voted negatively stating: Comment on Log #5: The standard makes no reference to the commercial evaluation criteria with regards to applicability and acceptability. Mr. D. Edlbeck voted negatively stating: Log #16: Testing done to UL test parameters does not indicate a substantial increase in extinguishing time of Class A fires when the discharge time is extended to 120 seconds. Detection and control systems used with Clean Agent systems are designed to suppress a fire in its incipient stage, long before it achieves a high burning rate that would allow increased damage caused by any longer extinguishing times associated with a 120 second discharge time. The USCG currently allows the 120 second discharge time for 85 percent of the design concentration as verified by the UL listing. The Marine chapter of this standard allows the 120 second discharge time based on the USCG listing. The benefits to the customer for the extended discharge outweigh any slight increase in extinguishing times.

2 Mr. H. Hammel voted negatively stating: 1. There are a number of Accepted or Accepted in Principle proposals that if incorporated into the standard will cause a significant change in system design and will impact currently installed systems. There are no data or substantiation to support these changes. To the contrary, there are years of installed systems that indicate the current accepted practice achieves the necessary margin of safety in the design of Clean Agent Systems. 2. a) There is an effort to incorporate parts of an ISO standard that is still in the draft stage into NFPA This ISO standard utilizes Class A fire tests that are much larger than UL 2166/UL2127 and is based on visual interpretation only. There is very limited data for results from the ISO fire test. The reproducibility and consistency of this procedure is yet to be confirmed. In fact there was a wide difference in MEC data for the same agent depending if the system was super pressurized to 360 psig vs. 600 psig. UL standards have been used for many years. There is a proven margin of safety for systems based on the Class A fire test used in UL standards. b) Placing the Class A full-scale test data from the ISO method is not appropriate. Listing this data will only cause confusion. The hardware (especially nozzles) can effect the MEC and should be run for each hardware type, as is required by UL. If data is to place in NFPA 2001, it should be based on UL methodology. c) The current heptane cup burner data in NFPA is from the most current test method, current Annex B. It was determined form multiple tests from multiple sources. The ISO cup burner data is from one set of data from one source. Data derived from a different standard should not be included in NFPA Mr. B. Stilwell voted negatively stating: Log #18 Disagree with Committee Action. Log #11 and #21 Disagree with Committee Action. Mr. T. Wysocki voted negatively stating: After consideration of comments accompanying negative ballots of Edlbeck, Stillwell, Hammel and Barbuzzi, I vote negative on this document for the following reasons: There is insufficient technical justification for the proposed changes to design concentration requirements. On the other hand, there is justification for extension of the discharge time for Class A fire suppression using inert gases and this extension was rejected. The proposed document is inconsistent in its handling of the various competing agents. There is nothing of extreme urgency requiring immediate change in NFPA 2001 that justifies going forward with an ROP which is replete with such inconsistent handling of competing agents. 12-2

3 12-1 Log #46 Final Action: Accept in Principle (1.3.5) Submitter: Patrick W. Schoening, General Motors Recommendation: Revise the paragraph as follows: The upgrade for signage shall be completed by August 7, Substantiation: Due to the size and complexity of large total flood systems, the time necessary for engineering and installation must be timed with complex production processes that have limited downtimes to accomplish the necessary revisions. Further, the availability of the parts to accomplish the revisions on such a large scale throughout the country is questionable for the time frame given. While it is agreed that the necessary changes in predischarge alarms and time delays is warranted, the time frame given by the standard for this action is inappropriate. Revise the paragraph as follows: The upgrades shall be completed by December 31, Committee Statement: The committee feels that a TIA should be developed to provide a reasonable date for all companies to comply with these requirements. This change would be in concert with that proposed TIA and would provide a reasonable time frame for compliance. Ballot Results: Affirmative: 31 Negative: 1 HAMMEL, H.: Proposal 12-1 is in conflict with TIA Log No The committee approved this TIA for both Technical Merit and for Emergency Nature. Proposal 12-1 would delay the implementation of the TIA for 3 years. The emergency nature for the TIA was a Potentially Life Threatening Hazard. It is unreasonable to delay the change for 3 years after the committee found it to be an immediate hazard Log #21 Final Action: Accept (3.3.5 Normally Occupied, Normally Unoccupied, Occupiable, Unoccupiable) Recommendation: Modify the following definitions in the body of the text as they are presently and replace with the following: Normally Occupied Enclosure or Space. An enclosure or space where, under normal circumstances, one or more persons are present under normal circumstances * Normally Unoccupied Enclosure or Space. An area enclosure or space not normally occupied by people but could be entered by one or more persons occasionally for brief periods Occupiable Enclosure or Space. See 3.3.6, Normally Occupied. An enclosure or space which has dimensions and physical characteristics such that it could be entered by a person Unoccupiable Enclosure or Space. An enclosure or space, that cannot be occupied due to dimensional or other physical constraints which has dimensions and physical characteristics such that it could not be entered by a person. Substantiation: The modifications to these important definitions more clearly define a space s capacity for human occupancy or need for people to be present Log #2 Final Action: Accept in Principle (3.3.7 Occupiable) Submitter: Robert T. Wickham, Wickham Associates Occupiable. See Normally Occupied. An area or space which is normally unoccupied but without dimensional or other physical constraints that would serve to prevent personnel from entering or occupying. Substantiation: The current definition which equates occupiable with normally occupied is incorrect. The proposed definition more accurately describes occupiable. Committee Statement: See Committee Action on 12-2 (Log #21) Log #10 Final Action: Accept in Principle (3.3.7 Occupiable) Submitter: Matthew T. Gustafson, Social Security Administration Occupiable. See 3.3.5, Normally Occupied Occupiable. See Miriam-Webster s Collegiate Dictionary Substantiation: Normally occupied spaces are subset of all occupiable spaces but the current definition lumps them together creating confusion and making 12-3 some sections of the code, such as paragraph , unenforceable. Committee Statement: See Committee Action on 12-2 (Log #21) Log #43 Final Action: Accept in Principle (3.3.7 Occupiable) Submitter: Dale R. Edlbeck, Tyco Fire & Security/Ansul Recommendation: Revise the definition to read as follows: Occupiable. See 3.3.5, Normally Occupied. An enclosure with dimensions that allow it to be entered by a person. Substantiation: The new verbiage more accurately identifies the intent of the definition. Committee Statement: See Committee Action on 12-2 (Log #21) Log #22 Final Action: Accept in Principle (3.4.2 Space) Recommendation: Space should be numbered with various spaces as , , etc. as follows: Marine Systems. Systems installed on ships, barges, offshore platforms, motorboats, and pleasure craft Space Cargo Space. A space for the carriage or storage of items or products that are transported by the vessel Electrical Equipment Space. A space containing electrical propulsion, power generating, or power distribution equipment Machinery Space. A space that contains mechanical equipment for handling, pumping, or transferring flammable or combustible liquids as a fuel Vehicle Space. A space that is designed for the carriage of automobiles or other self-propelled vehicles. Substantiation: Editorial renumbering. The Space definition is a subparagraph of Marine Systems. Change to read as follows: Marine system spaces. Committee Statement: These definitions only apply to marine systems, so this is a technical clarification of the terms being used Log #3 Final Action: Accept in Principle in Part (4.1) Submitter: Robert T. Wickham, Wickham Associates 4.1.1* Carbon dioxide total flooding fire-extinguishing systems shall not be installed in normally occupied enclosures except as permitted in through New Installations. Total flooding carbon dioxide systems shall be permitted to be installed in normally occupied enclosures where there are no suitable fire extinguishing agents that can be used to provide an equivalent level of fire protection to that of carbon dioxide If it is determined that carbon dioxide is to be used for a given application, the designer/installer shall provide supporting documentation to the authority having jurisdiction to verify that carbon dioxide is the most appropriate fire suppression agent for the application Marine Applications. Manually operated total flooding marine systems shall be permitted to be installed in normally occupied enclosures equipped with the following: (1) System lock out valves specified in (2) Pneumatic predischarge alarms and pneumatic time delays specified in (3) Two independent, manually operated system discharge control valves to actuate the carbon dioxide system as specified in Existing Systems. Existing total flooding carbon dioxide systems shall be permitted in normally occupied enclosures equipped with system lock out valves, pneumatic predischarge alarms, and pneumatic time delays specified in Substantiation: The current paragraph 4.1, and its following subparagraphs were incorporated in NFPA 12 in the 2005 edition in response to a proposal and several comments seeking an unconditional prohibition of the use of carbon dioxide total flooding systems in normally occupied spaces. The text of the initial proposal suggested Carbon dioxide total flooding systems shall not be used in normally occupied areas. While the first sentence of appears responsive to the initial proposal and comments ( Carbon dioxide total flooding fire-extinguishing systems shall

4 not be installed in normally occupied enclosures... ) the concluding text of that sentence (... except as permitted in through ) in essence makes the requirement unenforceable. Specifically, paragraphs through should be deleted for the following reasons: 1. Paragraph and are objectionable from the standpoint they provide a carte blanche for the incorporation of total flooding systems in normally occupied spaces based on the opinion of a single designer. During the discussions of this subject in the previous NFPA 12 technical committee and from the responses to the EPA s notice of data availability (see epa.gov/edkpub/do/edkstaffcollectiondetailviewbyid?collectionld=oar ) not one single example has been put forward by anyone identifying a total flooding hazard in a normally occupied space where carbon dioxide stands as only the solution from a technical standpoint when taking into consideration all the alternatives to carbon dioxide. Thus these paragraphs would seem to be useful only for (1) designers unskilled and unaware of alternatives or (2) designers determined to use carbon dioxide irrespective of the alternatives. 2. Paragraph is objectionable from the standpoint that marine carbon dioxide total flooding systems in normally occupied spaces, equipped with all the safety devices enumerated, still have the poorest safety record with the greatest amount of injuries and fatalities associated with carbon dioxide systems. (See and for further information). On that basis alone, of all market applications for total flooding carbon dioxide systems used in normally occupied spaces that might be considered for an exemption from a prohibition, marine systems should be the very last. 3. Paragraph is objectionable due to the implication that existing systems can be made safe with the addition of lock-out valves, pneumatic predischarge alarms, and pneumatic time delays. Systems without these added devices are considered by some to be more dangerous but this paragraph suggests that less dangerous is equivalent to made safe. This is not the case. The devices called for in this paragraph have been mandatory in marine systems for over 50 years and that sector still has the poorest safety record of all with the greatest amount of injuries and fatalities associated with carbon dioxide systems. Instead of providing the dubious guidance offered by this paragraph, it would be more useful for the users of the standard to make their own decisions about existing total flooding carbon dioxide systems in normally occupied spaces taking into consideration both the guidance on new systems and the retroactivity guidance offered in paragraph 1.3 ( 1.3 Retroactivity. The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection from the hazards addressed in this standard at the time the standard was issued. [emphasis added]) in Part Committee Statement: See Committee Action on 12-9 (Log #CP1). Ballot Results: Affirmative: 28 Negative: 3 Abstain: 1 MAKOWKA, N.: I wish to change my vote to negative for the reasons stated by Mr. Schoening. SCHOENING, P.: Do not agree with the APP vote since it references Proposal 12-9, (Log #CP1). Do not agree with 12-9 (Log #CP1) per the reasons stated under Proposal 12-9 (Log #CP1)below. WYSOCKI, T.: The current language in NFPA 12 paragraph 4.12 gives guidance for best use of carbon dioxide in total flooding applications. The proposed wording in CP1 would effectively eliminate carbon dioxide in nearly every flammable liquids hazard which might be considered normally occupied. For flammable liquids hazards, carbon dioxide has been successfully and safely used since To eliminate it s use without adequate supporting data is not supportive of good safety practices. The burden of proof for restriction of a long standing, successfully used technology should be placed on those desiring to establish such restriction. In the politically charged debate on this issue, data supporting CP1 s effective ban on the use of carbon dioxide in certain total flood applications has not been provided. The data presented in the EPA s substantiation for their proposal shows the following for carbon dioxide systems of all types (total flooding, local application, etc.) used in North America where NFPA Standards are prevalent: North America: Years 1948 through 1998: Fatalities involving CO 2 per EPA report Type Of Occupancy Incidents Frequency of incidents Total Fatalities Yearly Average Not Normally Occupied Unknown Occupancy Normally Occupied Totals for 51 years discharge or the fire caused these fatalities. Data extracted from the EPA report: Carbon Dioxide as a Fire Suppressant: Examining the Risks in 51 years 19 1 per 2.7 yrs incidents 12 1 per 4.25 yrs 5 1 per 10.2 yrs 12-4 U.S. Environmental Protection Agency Office of Air and Radiation Stratospheric Protection Division February 2000 The data does not support even a partial ban on the use of carbon dioxide systems in total flood applications. No risk/benefit or cost/benefit analysis has been submitted which would support further restriction on the use of carbon dioxide. The burden of proof should remain with those who wish to ban carbon dioxide, one of the most versatile and most proven gaseous fire extinguishing agents in history. Explanation of Abstention: WAHLE, K.: These proposals would create a conflict with current U.S. Coast Guard regulations that permit the installation of CO 2 systems in occupied machinery spaces. The matter is currently under review with a view toward eventual prohibition of the installation of new CO 2 systems on occupied spaces Log #9 Final Action: Accept in Principle in Part (4.1) Submitter: Bella A. Maranion, US Environmental Protection Agency 4.1 Restrictions for Normally Occupied Enclosures * Carbon dioxide total flooding fire-extinguishing systems shall not be installed in normally occupied enclosures except as permitted in through New Installations. Total flooding carbon dioxide systems shall be permit ted to be installed in normally occupied enclosures where there are no suitable fire-extinguishing agents that can be used to provide an equivalent level of fire protection to that of carbon dioxide If it is determined that carbon dioxide is be used for a given application, the designer/installer shall provide supporting documentation to the authority having jurisdiction to verify that carbon dioxide is the most appropriate fire suppression agent for the application Marine Applications. Manually operated total flooding marine systems shall be permitted to be installed in normally occupied enclosures equipped with the following: (1) System lock-out valves specified in (2) Pneumatic predischarge alarms and pneumatic time delays specified in (3) Two independent, manually operated system discharge control valves to actuate the carbon dioxide system as specified in Existing Systems. Existing total flooding carbon dioxide systems shall be permitted in normally occupied enclosures equipped with system lock-out valves, pneumatic predischarge alarms, and pneumatic time delays specified in Substantiation: Paragraph 4.1 and its following subparagraphs were incorporated in NFPA 12 in the 2005 edition in response to a proposal and several comments seeking a prohibition of the use of carbon dioxide total flooding systems in normally occupied spaces. The original proposal requested adoption of the following language Carbon dioxide total flooding systems shall not be used in normally occupied areas into the revised standard. While the revised standard adopted the sentence Carbon dioxide total flooding systems shall not be installed in normally occupied enclosures, the exception language that concludes that sentence and including paragraphs 4.1.2, , 4.1.3, and 4.1.4, burden the original text with exception language making the provision unenforceable. This proposal is to delete the specified exception language. EPA has expressed concern with the safe use of carbon dioxide total flooding fire extinguishing systems since its initial listing as an acceptable alternative technology to ozone-depleting halons (see co2/co2report.pdf ) fatalities incidents 0.29 fatalities incidents 0.1 fatalities Note incidents 0.84 fatalities Note 1: Five of the 43 deaths occurred during fires and it is uncertain whether the carbon dioxide

5 Recent information (see pdf) about the growth in use of carbon dioxide systems, particularly in marine installations, and continuing reports of injuries or deaths related to the use of these systems has prompted EPA to review these and other information on carbon dioxide systems to determine whether its listing should be changed to prohibit use in normally occupied spaces, consistent with other agent listings where design concentration and potential exposure pose significant risks (see nid=oar ). The U.S. EPA has been working with the carbon dioxide technical committee over the past two years trying to address the conflicts between the safety requirements of NFPA 12, NFPA 12A and NFPA 2001 dealing with carbon dioxide, halon 1301 and clean agent fire extinguishing systems respectively. Both NFPA 12A and NFPA 2001 specifically prohibit the use of the extinguishing agents covered by those standards in concentrations unsafe for human exposure in total flooding systems in normally occupied spaces. EPA has supported the approach taken in NFPA 12A and 2001 and more recently the draft NFPA 2010 standard with regard to personnel safety and is concerned with the inconsistent and inadequate personnel safety requirements in NFPA 12. NFPA 12, for carbon dioxide systems, allows the use of that agent in normally occupied spaces at concentrations four times that which is considered lethal. EPA first brought these concerns to the NFPA 12 Technical Committee in late 2003 in the belief that NFPA should lead on this safety issue. Over two years efforts to work within NFPA s consensus standards making process yielded a significant shift in the Technical Committee s deliberations with an accept in principle of the original proposal and EPA s comment to add to the standard the sentence carbon dioxide total flooding systems should not be used in normally occupied areas ; however, the ROC language accepted at the Association Membership meeting burdened the original text with exception language making the provision unenforceable. On January 12, 2005, EPA made an appeal to the Standards Council to return the exception language resulting in an unconditional prohibition to the use of carbon dioxide total flooding fire extinguishing systems in normally occupied areas. Although the January 14, 2005, Standards Council Decision (see NFPA 12 F04 Comment 12-19a Appeal Final Decision ) denied the appeal, the decision referred further consideration of the issues raised by the appeal to the new Technical Committee for Gaseous Fire Extinguishing Systems as indicated below (emphasis added): Although the appellant and others make serious arguments and raise important concerns, it is not for the Council to evaluate and weigh the technical merits of the various positions. This does not mean that consideration of the issues raised by the appeal should end. Rather, the Council has, through previous actions, which it now reaffirms, directed that the Technical Committees that deal with gaseous extinguishing agents be reorganized into a single Technical Committee. The Council believes that such a committee is in the best position to address the technical and safety issues raised by gaseous extinguishing agents, including carbon dioxide, and to do so in a manner that achieves harmony and consistency in the approach to the various agents and technologies. The Council believes that this new committee is the appropriate place to review and continue consideration of the issues raised by the appeal. The basis for that appeal are presented below as further substantiation for this proposal to delete the exception language in NFPA 12 paragraph and following subparagraphs 4.1.2, , 4.1.3, and These include the following: 1) Arguments already evident in ROP and ROC documents 2) Technical Committee activity not reflected in the ROP and ROC 3) Technical Meeting activity influencing the outcome of the motion at the Association Meeting, and 4) Consequences of failure to adopt proposal. 1) First, arguments already evident in NFPA 12 ROP and ROC documents (see ) including: Important and multifaceted role of CO2 in fire protection is recognized CO2 inherently dangerous at intended use concentrations A record exists of injuries and death since 1973 Increasing use, particularly in ships, likely to lead to increased casualty rate Safer alternative gaseous agents available, some with weight and space advantages Inconsistent personnel safety requirements of gaseous agent total flooding systems 2) Next, regarding Technical Committee activity not reflected in the ROP and ROC: Technical Committee went through a significant reversal of original, unanimous opposition to original proposal At a special meeting of the TC scheduled the day before the membership vote, EPA informed the TC that it viewed the accept in principle with the exception language as a disguised rejection and would submit a motion to reject exception language EPA motion supported by members of TC including at least 3 manufacturers and 1 association 3) Next, Technical Meeting activity influencing the outcome of the motion: Motion to call vote was made and passed before several others could speak 12-5 in favor of the motion; additional speakers would have been helpful to demonstrate motion had solid and growing support Chair Rucci s comment on the motion failed to convey the significant shift in the Technical Committee s deliberations; specifically, the results of the ROC balloting of 16-1 to accept the ROC back in August 2004 did not accurately reflect the case in the weeks or month leading up to the vote and certainly not the case as revealed at the Special TC meeting the day before the vote. Undecided members were knowingly presented with an out-of-date assessment that failed to disclose the changes in views on the final ROC up until the day before the membership vote. 4) Finally, regarding consequences of Committee s failure to adopt the proposal: Incidences of injuries and death likely to continue unless use of carbon dioxide total flooding fire extinguishing systems in normally occupied spaces is prohibited, without exceptions, in normally occupied spaces by NFPA or another authority Failure to act could be used as an example of a failure of the consensus standards making process to adequately protect the public and to advocate for the worker or private citizen who may be exposed to these systems, oftentimes unknowingly, and whose interests may not be represented on the Committee or perhaps even in the association itself Failure to fulfill the objectives of the new combined committee to address the technical and safety issues raised by gaseous extinguishing agents, including carbon dioxide, and to do so in a manner that achieves harmony and consistency in the approach to the various agents and technologies. In the development of personnel safety requirements for NFPA 2001 and NFPA 2010, EPA has worked productively as a member of the relevant technical committees to ensure consistent, scientifically based safety requirements between the NFPA standards and EPA regulations. EPA strongly supports the consensus standards making process and prefers to see organizations like NFPA take the lead in developing standards to directly address matters of public safety with the design, installation, and use of fire protection products and systems. NFPA s highly respected process for developing and updating voluntary standards for fire safety, its legions of volunteer technical experts from around the globe, and its standards that are followed worldwide make the case that NFPA should also lead on this important issue of safety. NFPA and this technical committee would simply be carrying out its mission to disseminate information on fire and life safety, advocating for consistent, scientifically based consensus codes and standards, and ensuring public safety. in Part Committee Statement: See Committee Action on 12-9 (Log #CP1). Ballot Results: Affirmative: 28 Negative: 3 Abstain: 1 MAKOWKA, N.: I wish to change my vote to negative for the reasons stated by Mr. Schoening. SCHOENING, P.: See My Explanation of Negative on 12-7 (Log #3). WYSOCKI, T.: See My Explanation of Negative on 12-7 (Log #3). Explanation of Abstention: WAHLE, K.: See My Explanation of Abstention on 12-7 (Log #9) Log #CP1 Final Action: Accept (4.1 through ) Submitter: Technical Committee on Gaseous Fire Extinguishing Systems Recommendation: Revise 4.1 to read as follows: 4.1 Restrictions for Normally Occupied Enclosures New total flooding carbon dioxide systems shall not be installed in normally occupied enclosures except as permitted in , , , or New total flooding carbon dioxide systems shall be permitted to be installed in normally occupied enclosures where it is determined that an inerting concentration is required and the inerting concentration required using alternate gaseous agents results in a concentration above the LOAEL or the oxygen concentration is less than 8% New total flooding carbon dioxide systems shall be permitted to be installed in normally occupied enclosures for fires involving energized electrical equipment >400 volts and grouped electrical cables where no gaseous alternative agent has been successfully tested New total flooding carbon dioxide systems shall be permitted to be installed in normally occupied enclosures where design methods and/or hardware for unencloseable openings or extended discharge are not available for other gaseous agents New total flooding carbon dioxide systems shall be permitted to be installed in marine cargo holds New total flooding carbon dioxide systems shall be permitted to be installed in normally occupied enclosures in marine engine rooms where it is determined that an inerting concentration is required and the inerting concentration required using alternate gaseous agents results in a concentration above the LOAEL or the oxygen concentration is less than 8%. (add a foot print limit here). (delete existing through 4.1.3) (renumber existing as 4.1.2) Substantiation: These provisions provide reasonable requirements for best

6 essential use of carbon dioxide in normally occupied enclosures. They also resolve in part concerns related to a blanket prohibition on all new total flooding systems for normally occupied enclosures. Ballot Results: Affirmative: 28 Negative: 3 Abstain: 1 MAKOWKA, N.: I wish to change my vote to negative for the reasons stated by Mr. Schoening. SCHOENING, P.: Do not agree with the Accept vote to 12-9 (Log #CP1). Do not agree with the blanket ban (with exception of marine cargo holds and engine rooms) for all new total flooding systems for normally occupied enclosures. Do support the various precautions (inspections, signage, discharge testing, system lock-out valves, pneumatic pre-discharge alarms and pneumatic time delays) per existing sections 4.1.4, 4.3, and However, question the need to attempt to exclude a proven effective extinguishing agent in use for a variety of hazards without an appropriate cost-benefit analysis. WYSOCKI, T.: See My Explanation of Negative on 12-7 (Log #3). Explanation of Abstention: WAHLE, K.: See My Explanation of Abstention on 12-7 (Log #9) Log #45 Final Action: Reject (4.1.2 and ) Submitter: Patrick W. Schoening, General Motors Recommendation: Revise as follows: New Installations. Total flooding carbon dioxide fire-extinguishing systems shall be permitted to be installed in normally occupied enclosures in accordance with the provisions specified in Delete and renumber succeeding paragraphs as required. Substantiation: and as written are too general assumes many things to be suitable without sufficient justification for eliminating carbon dioxide. The standard already specifies various precautions to be in place by the presence of 4.1.4, 4.3, and With those items addressed, why the need to attempt to exclude one of the most effective extinguishing agents in use for a variety of hazards without an appropriate cost benefit analysis? Accepting the action previously stated makes unnecessary; the paragraph becomes redundant. Committee Meeting Action: Reject Committee Statement: The committee s position for new installations of total flooding applications in normally occupied enclosures is that they should not be permitted unless there are no technically feasible alternatives. Ballot Results: Affirmative: 30 Negative: 2 MAKOWKA, N.: I wish to change my vote to negative for the reasons stated by Mr. Schoening. SCHOENING, P.: Do not agree with the Reject vote. Agree with submitter s substantiation Log #23 Final Action: Accept ( ) Recommendation: Revise the wording as follows: For all new system installations, the The safety sign format... Substantiation: The intent is for all systems to be subject to the safety sign format, not just new systems Log #41 Final Action: Accept ( ) Submitter: Hendrik T. Lammertink, Kidde Fenwal Inc. Recommendation: Revise text to read as follows: For all new system installations, the safety sign format, color, letter style of signal words, message panel lettering, lettering size, and the safety provisions of symbols shall be in accordance with MNBV/ ANSI Z535, Standard for Environmental and Facility Safety Signs. Substantiation: The acronym MNBV is not relevant. The ANSI Z535 Committee on Safety Signs created subcommittees for the development of five standards, including: ANSI Z535.1, Safety Color Code ANSI Z535.2, Environmental and Facility Safety Signs ANSI Z535.3, Criteria for Safety Symbols ANSI Z535.4, Product Safety Signs and Labels ANSI Z535.5, Accident Prevention Tags The Z535.2 standard seems the most appropriate one for the development of signs in accordance with NFPA 12 in reference to word message letter height and minimum safe viewing distances. As stated in these standards, Z535.2 and 12-6 Z535.4 are intentionally similar; each address different physical and visual requirements. Note: Supporting material is available for review at NFPA Headquarters Log #38 Final Action: Accept (Figure , , , , and ) Submitter: Hendrik T. Lammertink, Kidde Fenwal Inc. Recommendation: The signal word CAUTION should be replaced by WARNING for all signs. The message wording should be left alignment. Substantiation: As the words...can cause injury or death... appear in all signs the signal word of the sign should be consistent for all signs. The left alignment of message wording aids in readability, in accordance with ANSI Z535.2, paragraph B Note: Supporting material is available for review at NFPA Headquarters Log #24 Final Action: Accept in Principle (Figure ) Recommendation: Change Signal Word on this sign from CAUTION to WARNING. Substantiation: In accordance with ANSI Z535.4, the signal word definition for: CAUTION indicates a potentially hazardous situation which, if not avoided, may result in minor or moderate injury. WARNING indicates a potentially hazardous situation, if not avoided, could result in death or serious injury. The latter applies to a space where carbon dioxide can collect. Committee Statement: See Committe Action on (Log #38) Log #25 Final Action: Accept ( ) Recommendation: Revise text to read as follows: For existing system installations that have existing signs that differ from those required by but which meet the requirements of , the existing signage shall be considered to be acceptable if the facility has an effective a signage training program in place covering all suppression systemrelated signage, with all personnel with access to the protected space either trained on the signage or accompanied when in the protected space at all times by a person who has received the intended required training. New installations in facilities covered by this paragraph shall be equipped with the same type signage as used in existing system signage in the facility. All signs within the facility shall have the same style and format. Substantiation: The current wording of does not provide for consistency in signage where new system installations are added to facilities with existing systems where existing signs meet the requirements of but do not follow the ANSI Z535, Standard for Environmental and Facility Safety Signs, criteria specified in Multiple formats for warning signs within a given facility can lead to confusion on the part of personnel. Consistency of warning signage facilitates training of personnel in recognition of potential hazards and suitable response thereto Log #26 Final Action: Accept in Principle (4.3.3 and 4.5.6) Recommendation: Rewrite and consolidate subject paragraphs dealing with alarms Rewrite existing text as follows (deleted sentences will be moved to various places within 4.5.6): Evacuation Procedures All persons who can at any time enter a space protected by carbon dioxide shall be warned of the hazards involved and provided with safe evacuation procedures. (See ) * Visual and audible devices shall be located at the entrance to each occupiable space protected by a carbon dioxide system and at the entrance to each space where carbon dioxide could migrate, creating a hazard to personnel. Provisions shall be made to prohibit entry of unprotected personnel to spaces made unsafe by a carbon dioxide discharge until the space is ventilated and

7 appropriate tests of the atmosphere have verified that it is safe for unprotected persons to enter. Persons who are not properly trained in the use of and equipped with self-contained breathing apparatus (SCBA) shall not remain in spaces where the concentration exceeds 4 percent Provide audible and visual alarms per The visual alarms required by shall be permitted to serve this purpose if they are left operating until the space is ventilated and the safety of the atmosphere for entry by unprotected persons has been verified The operation of electrically operated warning devices shall be continued after agent discharge until positive action has been taken regarding the alarm and prevention of exposure of personnel to hazardous concentrations The predischarge warning signal shall provide a time delay to allow for evacuation under worst case conditions, except as noted in Dry runs shall be made to determine the minimum time needed for persons to evacuate the hazard area, allowing time to identify the warning signal Audible and visual predischarge signals shall be provided, except as noted in Rewrite as follows: Alarms. Audible and visual warning alarms shall be provided for the following purposes: 1. To alert personnel not to enter a space because the atmosphere in the space may be hazardous due to the presence of a high concentration of carbon dioxide. 2. To provide personnel opportunity to evacuate spaces which could be made unsafe by the discharge of a carbon dioxide system Pre-Discharge alarm and Time Delay. A pneumatic predischarge alarm and pneumatic time delay and visual predischarge alarm shall be provided for the following enclosures: (1) Normally occupied and occupiable enclosures protected by total flooding systems (2) Normally occupied and occupiable enclosure where the discharge from a Local Application system will expose personnel to hazardous concentrations of carbon dioxide Exception: For occupiable hazard areas where the provision of a time delay could result in unacceptable risk to personnel or unacceptable damage to critical pieces of equipment, time delays need not be provided. Provision shall be made to ensure that the carbon dioxide system is locked out at any time that personnel are present in the protected area or space The predischarge alarms, when required, shall be located within the enclosure The predischarge time delay shall provide a time delay for purpose for predischarge alarm of sufficient duration to allow evacuation of personnel from areas within the spaces most remote from the exists Dry runs shall be made to determine the minimum time needed for persons to evacuate the hazard area, allowing time to identify the warning signal. (from 4.3.3) Audible signal appliances shall either have sound levels in accordance with the following sections or acoustic characteristics n accordance with NFPA , Narrow Band Tone Signaling for Exceeding Masked Thresholds Audible predischarge alarms shall be at least 15 db above ambient noise level or 5 db above maximum sound level, whichever is greater, measured 5 ft (1.5 m) above the floor of the occupiable area Audible signal appliances shall have a sound level not more than 120 db at the minimum hearing distance from the audible appliance The predischarge alarm shall have minimum decibel rating of 90 dba at 10 ft (3 m) Visual and audible alarms shall be located outside each entrance to (1) Normally occupied and occupiable space protected by a total flooding carbon dioxide system (2) Normally occupied and occupiable enclosures where the discharge from a Local Application system will expose personnel to hazardous concentrations of carbon dioxide (3) Normally occupied and occupiable spaces where carbon dioxide could migrate, creating a hazard to personnel. (rewrite from 4.3.3) These alarms shall begin operation prior to or at the start of the discharge * These alarms shall continue to operate after agent discharge until (1) other positive action has been taken to prevent entry of personnel to the space containing an atmosphere made unsafe by the carbon dioxide discharge. (2) or the space is ventilated and the safety of the atmosphere for entry by unprotected persons has been verified. (from 4.4.3) Move material to Annex: A All total flood hazards will be made unsafe for entry of unprotected personnel until such spaces are ventilated of carbon dioxide. Spaces containing equipment protected by local application systems could become unsafe, particularly if the protected equipment occupies a sizable portion of the volume of the room containing the equipment. Pits, cellars, and rooms adjacent to the protected hazard, especially those at lower elevations, can be made unsafe by migration of the discharged carbon dioxide. Oil of wintergreen is a common and recommended odorizer added to the discharging carbon dioxide to produce a distinctive odor that warns of the presence of carbon dioxide gas. Other odorizers that are specially appropriate for specific locations can also be used, but, if there is no specific reason to use 12-7 an odorizer other than oil of wintergreen, oil of wintergreen should be used. Olfactory indicators could be inappropriate for applications such as cleanrooms, food processing, aluminum rolling mills, and telecommunications facilities since they could adversely affect the process or equipment. Provisions to help prevent entry of persons into areas made unsafe by the discharge of carbon dioxide may include one or more of the following: (1) Addition of a distinctive odor to the discharging carbon dioxide, the detection of which serves as an indication to persons that carbon dioxide gases present (Personnel should be trained to recognize the odor and evacuate spaces wherein the odor is detected.) (2) Provision of automatic alarms at the entry to and within such spaces, which alarms are activated by carbon dioxide detectors or oxygen detectors (3) Establishment and enforcement of confined space entry procedures for such areas (moved from body of standard) Substantiation: To clarify the requirements for system alarms and consolidate requirements for alarms into a single section of the standard. Presently, the user must reference several sections to find all the requirements for system alarms. 1. Accept the recommended text and reword the exception to read as follows: Time delays shall be permitted to be eliminated for occupiable hazard areas where the provision of a time delay will result in unacceptable risk to personnel or unacceptable damage to critical pieces of equipment Where time delays are omitted, provision shall be made to ensure that the carbon dioxide system is locked out at any time that personnel are present in the protected area or space. 2. Renumber the submitted text accordingly to accommodate the renumbered exception above. 3. Change annex numbering for A to A Change the word visual to visible throughout the document. Committee Statement: Editorially changes were made to the submitted text. Comment on Affirmative: GUSTAFSON, M.: I agree with reorganizing the requirements applicable to pre-discharge alarms in order to make the standard clearer. However, I do not agree with new section allowing pre-discharge alarms and time delays to be omitted in favor of property protection. The committee was shown a video of a fire and immediate CO2 discharge in a rolling machine as evidence that pre-discharge alarms are not needed. However, the protected equipment was in an open space and personnel were able to easily walk away from the hazard. The CO2 discharge was not in a total flood enclosure with restricted or circuitous means of egress. The committee is remiss in not providing guidance to users of the standard helping users determine under what circumstances predischarge alarms can safely be omitted. As currently proposed, pre-discharge alarms and time delays are nothing more than a recommendation and are not required by the standard Log #44 Final Action: Accept in Principle ( ) Submitter: Dale R. Edlbeck, Karen Holcik, Tyco Fire & Security/Ansul Recommendation: Move that portion of beginning with Provisions shall be made to prohibit entry of unprotected personnel... to a new Change to Renumber the remaining paragraphs. Revise the wording in new to read: Provisions shall be made to prohibit entry of unprotected personnel to spaces where carbon dioxide will not dissipate immediately after the discharge and that can be made unsafe by a carbon dioxide discharge... Substantiation: This proposal qualifies the requirements for extended warning devices to spaces that can maintain a concentration of carbon dioxide. It removes the possibility that the requirements of the new paragraph may be applied to a local application system where the agent cannot collect in hazardous concentrations. Committee Statement: See Committee Action on (Log #26) Log #11 Final Action: Accept in Principle ( ) Submitter: Matthew T. Gustafson, Social Security Administration Audible and visual pre discharge signals shall be provided, except as noted in Audible and visual pre-discharge signals shall be provided for all automatic systems and all manual systems except as noted in Audible and visual signals shall be provided throughout the protected space such that audible and visual alerting characteristics are not less effective than those required by NFPA 72 for public mode evacuation. Substantiation: The current requirement is not clear. Paragraph implies that visual and audible signals located outside the protected space would fulfill the requirements of The current document does not