This portion of the Technical Committee Report of the Committee on Portable Fire Extinguishers is presented for adoption.

Transcription

1 Report of the Committee on Portable Fire Extinguishers David J. Burkhart, Chair Code Consultants, Inc., MO [SE] James C. Elenbaas, Jr., Michigan Dept. of Consumer & Industry Services, MI [E] Richard J. Fairclough, Brooks Equipment Company, Inc., NC [M] Fred B. Goodnight, Amerex Corporation, AL [M] Rep. Compressed Gas Association Ernest E. Horvath, Reliable Fire Equipment, IL [IM] Rep. National Association of Fire Equipment Distributors Inc. Robert Kasiski, Factory Mutual Research Corporation, RI [I] Emil W. Misichko, Underwriters Laboratories Inc., IL [RT] Gary A. Nadolny, Tyco Suppression Systems, WI [M] Rep. Fire Equipment Manufacturers Association J. R. Nerat, Badger Fire Protection/Williams Holdings, MI [M] Rep. NFPA Industrial Fire Protection Section James A. Oldham, Duke Power Company, NC [U] Rep. Edison Elecric Institute Richard R. Osman, Schirmer Engineering Corporation, IL [SE] Joseph E. Parkany, Nuclear Service Organization, DE [I] John E. Reiter, PG&E National Energy Group, MD [U] Robert J. Ross, City of Middletown Fire Department, CT [E] George Unger, Underwriters Laboratories of Canada, Canada [RT] Klaus Wahle, U.S. Coast Guard Headquarters, DC [E] Committee Scope: This Committee shall have primary responsibility for documents on the installation, maintenance and use of portable fire extinguishers and equipment. Does not apply to permanently installed fire extinguishing systems even though portions of those systems are portable, such as hose and nozzles which may be attached to a fixed supply of extinguishing agent. 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. This portion of the Technical Committee Report of the Committee on Portable Fire Extinguishers is presented for adoption. This Report on Comments was prepared by the Technical Committee on Portable Fire Extinguishers, and documents its action on the comments received on its Report on Proposals on NFPA 10, Standard for Portable Fire Extinguishers, 1998 edition, as published in the Report on Proposals for the 2002 May Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Portable Fire Extinguishers, which consists of 16 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Alternates Warren D. Bonisch, Schirmer Engineering Corporation, TX [SE] (Alt. to R. R. Osman) Randall Eberly, U.S. Coast Guard Headquarters, DC [E] (Alt. to K. Wahle) Rod Getz, Getz Fire Equipment, IL [M] (Alt. to E. E. Horvath) Michael J. Laderoute, MJL Associates, Inc., VA [M] (Alt. to G. P. Nadolny) Mike Larabel, CFPS, CFI, Alticor, Inc., MI [M] (Alt. to J. R. Nerat) Byron J. Sarago, Detroit Edison Company, MI [U] (Alt. to J. A. Oldham) Peter M. Shank, Nuclear Service Organization, DE [I] (Alt. to J. E. Parkany) David C. Smith, Factory Mutual Research Corporation, MA [I] (Alt. to R. Kasiski) James J. Urban, Underwriters Laboratories Inc., IL [RT] (Alt. to E. W. Misichko) Staff Liaison: Mark T. Conroy 274

2 (Log #21) 10-1-(Entire Document) : Reject RECOMMENDATION: Return the standard to the NFPA 10 Committee. The safety concerns resulting from the proposals accepted by the committee are significant. The changes required are extensive and need time for thorough consideration. SUBSTANTIATION: I believe the NFPA 10 document is not meant to be a marketing tool for the advantage of equipment sales. Its purpose of being a life safety and fire protection guide and requirement for portable fire extinguisher users seems to be lost in many proposals accepted by the NFPA 10 Committee. COMMITTEE STATEMENT: The committee acted on all of the comments received and felt that the issues were resolved through these actions. The committee disagrees with the submitter s substantiation. (Log #2) 10-2-(1-3) : Accept in Principle SUBMITTER: Fred Goodnight, Amerex Corp. COMMENT ON PROPOSAL NO:10-3 RECOMMENDATION: Delete all definitions except the preferred definition. Also, there is a conflict in definition of class C fires (preferred) versus that in log CP#3. I believe CP3 is the correct definition. Do not agree with preferred definition of inspection - it should reference extinguisher since this standard deals with extinguishers. SUBSTANTIATION: Only one definition should be included. Extra definitions will only confuse the end user. Adopt the preferred definitions from the NFPA Glossary of Terms for the following terms: ANSI (preferred) 1 American National Standards Institute. DOT. (preferred) 57 U.S. Department of Transportation. Dry Chemical A mixture of finely divided solid particles, usually sodium bicarbonate-, potassium bicarbonate-, or ammonium phosphate-based with added particulate material supplemented by special treatment to provide resistance to packing, and moisture absorption (caking), and to promote proper flow characteristics. Extinguisher Inspection A quick check that a fire extinguisher is available and is in operating condition. It is intended to give reasonable assurance that the fire extinguisher is fully charged. This is done by verifying that it is in its designated place, that it has not been actuated or tampered with, and that there is no obvious physical damage or condition to prevent its operation. Extinguisher Service Pressure The normal operating pressure as indicated on the nameplate or cylinder of a fire extinguisher. Wet Chemical Wet chemicals include, but are not limited to, solutions of water and potassium acetate, potassium carbonate, potassium citrate, or any combinations thereof. COMMITTEE STATEMENT: Deleted extra definitions. (Log #22) 10-3-(1-3) : Reject COMMENT ON PROPOSAL NO:10-5 RECOMMENDATION: Revise text to read as follows: Class C Fires: Fires that involve energized electrical equipment where a very low electrical conductivity level of the extinguishing media is of importance. (When electrical equipment is de-energized, fire extinguishers for Class A or Class B fires can be used safely. SUBSTANTIATION: I believe this is another attempt to remove the traditional electrically nonconductive Class C agent (media) references and requirements from NFPA 10. That requirement should remain and proper references to it should be contained in the standard. If you users of fire extinguishers want to continue to have a Class C electrically nonconductive category of extinguishers, you had better let the NFPA 10 Committee know. See Comments on Proposals and for more information. COMMITTEE STATEMENT: The definitions should only define the term. The proposed text provides additional criteria which would be inappropriate for a definition. (Log #64) 10-4-(1-3) : Reject 3 RECOMMENDATION: Reject previously accepted proposal which states: Add a definition for Water Mist Extinguishers to read as follows: Water Mist Extinguishers. A water type portable fire extinguisher containing distilled water and employing a nozzle that discharges the agent in a fine spray. SUBSTANTIATION: The substantiation for the original proposal indicated: Water mist extinguishers have been available in the marketplace for several years to meet special hazard requirements. Adding a new definition would recognize their availability. The above substantiation is in fact true; water mist extinguishers have been available in the market place for several years. However, this original proposal and others are clearly a case of developing and marketing a product that is in conflict with NFPA 10 and then attempting to modify NFPA 10 to fit the product. NFPA 10 Section states that portable fire extinguishers used to comply with this standard shall be listed and labeled and meet or exceed all the requirements of one of the fire test standards and one of the appropriate performance standards. It is important to reemphasize the words of NFPA 10, Section MEET OR EXCEED ALL THE REQUIREMENTS...AP- PROPRIATE PERFORMANCE STANDARD. The label on a water mist extinguisher indicates the extinguisher has been listed and labeled to Fire Test Standards ANSI/UL 711 and Performance Standards ANSI/UL 626 and rated as Class A and Class C. However, after consultation with the manufacturer of the water mist extinguisher, the manufacturer indicated that the water mist extinguishers were in fact tested and listed to Performance Standard UL 8 and not UL 626. This is in conflict to the placard on the water mist extinguisher, which indicates that the extinguisher is tested to ANSI/UL 626. UL 8 is the performance test standard for foam fire extinguishers. The scope of UL 8 indicates that the test standard is limited to portable foam-type fire extinguishers. Water mist extinguishers do not contain any of the features, characteristics, components, and materials necessary to be tested and labeled under this standard. UL 8 is in fact the wrong performance test standard for water mist extinguishers. Water mist extinguishers are Water Type extinguishers. The basic difference between a traditional water extinguisher and the water mist extinguisher is simply the discharge wand and nozzle. Essentially every other component is identical to a traditional water extinguisher. Therefore, to comply with NFPA 10, water type extinguishers should be tested to the Performance Standard, UL 626. This is further supported in the Scope of UL 626. In addition, Section 1.5 of UL 626 states a product whose features, characteristics, components, materials, or systems conflict with specific requirements or provisions of this standard does not comply with this standard. There are two basic provisions of 626 which water mist extinguishers do not comply with. First and foremost is Section 26.1 which states...shall discharge a stream a horizontal distance of not less than 30 feet and maintain this range for at least 40 seconds. Water mist extinguishers do not meet this criteria. Their effective discharge range is between 8-12 feet. In addition, Section 18.3 of UL 626 states When a hose is hanging vertically, the tip of the nozzle shall clear any plane surface on which the extinguisher is placed by at least 1/2 inch but not more than 2 1/2 inches. The hoses on water mist extinguishers do not meet this criteria. With respect to the Class C rating, water mist extinguishers should have not tested and granted a Class C Listing. NFPA 10, at that time, required extinguishing agents for Class C to be nonconductive. Water, even distilled water, is highly conductive. The test criteria in UL fire test standard 711 is not an agent conductivity test, it is simply a test that assures the safety of the operator while the agent is being discharged. It does not test the conductivity of the agent. This conductivity issue is and has been addressed in numerous other proposals and comments. Water mist extinguishers were developed, inappropriately tested and mislabeled, and marketed when they clearly do not meet the requirements of NFPA 10 or the appropriate UL test standards. The marketing of water mist extinguishers has violated the integrity of the NFPA, NFPA 10 Committee, Underwriters Laboratory, and eroded public trust. Therefore, due to the fact that water mist extinguishers were inappropriately tested to the wrong performance test standard as required by NFPA 10, Section and the fact that they are mislabeled, they should not be recognized in any NFPA document. COMMITTEE STATEMENT: Water mist extinguishers exist and the committee feels that there is a need for a definition. (Log #66) 275

3 10-5-(1-3) : Reject COMMENT ON PROPOSAL NO:10-5 RECOMMENDATION: Reject. Section 1-3 Class C Fires to revise text: Proposal to remove the where electrical nonconductivity of the media is of importance. (When electrical equipment is de-energized, fire extinguishers for Class A or Class B fires can be used safely.) SUBSTANTIATION: One of the main hazards with an electrical fire is that the equipment is energized. Non conductivity of the media is very important to protect the operator and fire fighters in the event pooling of the agent occurs. While it is recognized that everything (even sand) is conductive then exposed to a great enough voltage, dry chemical, carbon dioxide, and halongenated agents will not create or leave behind the pooling hazard that water-based agents such as water mist. In addition to eliminating the important information that Class A and B fires can be used if the equipment is de-energized, this change also provides the opportunity for technologies such as water mist to be used for Class C applications. The risk of misinformation of this type is that the person may survive the fire but be electrocuted in the process. As another concern, this change in definition will confuse and mislead the public. If this passes, anyone previously trained on extinguisher use will have the misconception that the Class C agent will not create a hazard to personnel. This misunderstand could potentially cause someone their life. Finally, this change would be inconsistent with federal law as outlined in the OSHA requirements. COMMITTEE STATEMENT: See Committee Statement on Comment 10-3 (Log #22). (Log #67) 10-6-(1-3) : Reject 3 RECOMMENDATION: Reject. Add new text to create a separate definition for Water Mist rather than include it within the definition of Water Type Fire Extinguisher. SUBSTANTIATION: a. There are no significant differences between the water mist technology and fire extinguishers such as the AFFF. From a hardware standpoint, only the nozzle design is different. For the extinguishing media, an attempt has been made to distinguish distilled water from water. There is, however, no appreciable different in the fire fighting capability of the unit. In fact, the military allows the definition of water mist to include sea water although potable water is preferred. b. In looking at the users of the NFPA, care must be taken to understand the audience. For comprehension of the text, it is a mistake to establish a precedence whereby every hardware model and extinguishing media combination is defined rather than grouped into logical categories. c. This is a thinly veiled attempt to distinguish water mist from water type extinguishers in order to justify their use on energized electrical applications. COMMITTEE STATEMENT: See Committee Statement on Comment 10-4 (Log #64). (Log #68) 10-7-(1-3) : Reject 4 RECOMMENDATION: Reject. Add new text to create a separate definition for Wetting Agent rather than include it within the definition of Water Type Fire Extinguisher. SUBSTANTIATION: There are no significant differences between a wetting agent and water-based extinguishing media. In looking at the users of the NFPA, care must be taken to understand the audience. For comprehension of the text, it is a mistake to establish a precedence whereby every hardware model and extinguishing media combination is defined rather than grouped into logical categories. COMMITTEE STATEMENT: Wetting agent is a term used in the standard. 276 (Log #56) 10-8-(1-4.1 and 1-4.2) : Accept in Part 5 RECOMMENDATION: The revised wording and relocation to the Annex should be returned to the original wording and location. SUBSTANTIATION: The committee proposal is in appropriate and eliminates enforcement authority. The information in and is important information and germane to the end user. In addition, the deletion of the requirement in Item c Agent must be a nonconductor of electricity is in violation of Federal law. COMMITTEE ACTION:Accept in Part Revise Item C to read as follows: (c) Class C rating. No fire test. Agent must be a nonconductor of electricity. COMMITTEE STATEMENT: The text contains no requirement, therefore the committee feels that the information is more appropriate in the annex Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #69) 10-9-(1-4.1 and 1-4.2) : Accept in Part 5 RECOMMENDATION: Reject and modify text. Eliminate the requirement of Agent must be a non-conductor in the description of Class C rating and move the explanation into the Annex section of the standard. SUBSTANTIATION: The electrocution risk of water type extinguishers which may pass the Underwriter Laboratories Class C test is very great, especially with units as large as 2-1/2 gallon used on 440V transformers. In an industrial setting, given the proximity of extinguishers, more than one may be used on a fire. The requirement of the agent to be a non-conductor is imperative to eliminating this risk. This requirement is so critical to the standard, it cannot be moved to the Annex whereby it is unenforceable. COMMITTEE ACTION:Accept in Part COMMITTEE STATEMENT: See Committee Statement on Comment 10-8 (Log #56) Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #91) (1-4.1 and 1-4.2) : Accept in Principle SUBMITTER: J. R. Nerat, Badger Fire Protection/Rep. NFPA Industrial Section 5 RECOMMENDATION: Revise text to read as follows: (c) Class C Rating. No Fire Test. Special tests for nonconductivity of extinguishing media as it is being discharged. Agent must be a nonconductor of electricity. SUBSTANTIATION: NFPA-10 needs to remain consistent with other fire code class C fire extinguisher references and maintain its nonconductive agent requirement within the body of the standard. Operator life safety concerns should not be reduced or limited to test conditions that only evaluate operator electrocution potential back through the agent discharge stream. Before advocating novice fire extinguisher operators use water based extinguishing agents

4 on energized electrical class C hazards, proper testing must also address any safety hazards associated with water based agent fallout and pooling. COMMITTEE STATEMENT: See Committee Statement on Comment 10-8 (Log #56) Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #25) (1-4.2) : Accept in Principle 7 RECOMMENDATION: This proposal includes renumbering paragraph and the following revisions (b)6 Wet chemical agents, water, water based agents, and halogenated agents shall be tested in accordance with ASTM D , Standard Test Methods for Electrical Conductivity and Resistivity of Water. Fire extinguishers containing any of these agents which have a conductivity higher than one microsiemen shall not be rated Class C. WARNING: Wet chemical agents...on them. (Comment; Include warning without change). SUBSTANTIATION: I agree with the proposer s intent and substantiation; however, paragraph has been moved to a non-mandatory section of NFPA 10. Adding it to paragraph 1-4.3(b)6 will make compliance mandatory. NFPA 10 has no restrictions on where portable Class C rated extinguishers are used on electrically energized equipment. Since 1926 and before, Class C listed fire extinguishers have contained agents with conductivities of less than 1 microsiemen. Wet chemical has a conductivity of 464,000 microsiemens and will bring housings, handles and tabletop puddles up to full line voltage when injected into ungrounded energized electrical equipment. Persons touching such equipment can be seriously injured or killed. Standard electrical conductivity tests with 1 cubic centimeter. Samples of agent with 100 volts applied show that: 1. All previous Class C agents produce a current of less than.0001 amperes; 2. Wet chemical produces a current of 46.4 amperes. Usually fatal shock current levels for humans (.065 to.100 amperes). I believe NFPA 10 has a duty to warn its users of the potential after use shock hazards of extinguishers rated Class K:C. Accept this comment and restore the safe, valuable, essentially nonconductive Class C agent category to the users. COMMITTEE STATEMENT: See Committee Comment for (Log #CC1). AFFIRMATIVE: 15 ABSTENTION: 1 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #70) (1-4.2) : Accept in Principle 7 RECOMMENDATION: Reconsider rejected log and revise text. Reference a standard test ASTM D Standard Test Method for Electrical Conductivity for Resistivity of Water to establish those extinguishers which should carry a Class C Rating. SUBSTANTIATION: This is an established industry standard which can be utilized to eliminate the electrocution potential in pooling scenarios for Class C extinguishers. The current Underwriters Laboratory test method does not sufficiently address the operator safety beyond the discharge stream. COMMITTEE STATEMENT: See Committee Comment for (Log #CC1) The first sentence states that the agent for a Class C rating shall not be a conductor of electricity. Then the third sentence permits the agent to be conductive to 1 microsiemen/cm. The first sentence implies that the agent needs to have a conductivity of 0.0 microsiemen/cm, which is contrary to the 1.0 microsiemen/cm conductivity threshold defined in the third sentence. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=O.5 calculated value) was chosen as the threshold. There is no technical reason for doubling the calculated value for the conductivity threshold requirement, which permits a higher acceptable shock hazard. Likewise, there is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and not intended for measuring the conductivity of the dry chemical. It would be more appropriate to use 240 volts, or for industrial applications, 440 volts. 1. The definition for a Class C rating, 1-4.2, states that the agent shall not be a conductor of electricity. Then the third sentence of permits the agent to be conductive to 1 microsiemen/cm. To imply that the agent has a conductivity of 0.0 microsiemen/cm and then define acceptable conductivity as 1.0 microsiemen/cm using an ASTM test method for flowing water is a contradiction. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=0.5 calculated value) was chosen as the threshold. There is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and is not intended for measuring the conductivity of the dry chemical. The voltage which should be used is more appropriately 240 volts, or for industrial applications, 440 volts (550 volts in Canada). Referring to published Control Unit Standards, the maximum acceptable current for shock hazard testing is 809 milliamperes. Using these numbers, the acceptable level of conductivity would change drastically. A further inconsistency lies in the doubling of the calculated value to be the threshold requirement. If 0.5 microsiemen/cm is calculated as the maximum threshold value, twice that value is technically unsound, and would appear to condone a higher acceptable shock hazard. (Log #71) (1-4.2) : Accept in Principle in Part 9 RECOMMENDATION: Reject and revise text. Accept in Principle eliminating the requirement that the agent must be a nonconductor of electricity in the definition of Class C rating. SUBSTANTIATION: The electrocution risk of water type extinguishers which may pass the Underwriter Laboratories Class C test is very great, especially with units as large as 2-1/2 gallon used on 440V transformers. In an industrial setting, given the proximity of extinguishers, more than one may be used on a fire. The requirement of the agent to be a non-conductor is imperative to eliminating this risk. in Part COMMITTEE STATEMENT: See Committee Statement on Comment 10-8 (Log #56) Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #65)

5 10-14-(1-4.2 (New) ) : Accept in Principle 7 RECOMMENDATION: Accept Original proposal (with the following changes), which states: Revise text to read as follows: (c) Class C Rating. No fire test. Agent must be a nonconductor of electricity. (For wet chemical water based agents see ) Wet chemical agents In addition to successfully meeting the requirements of UL 711, water based agents shall be tested in accordance with ASTM D , Standard Test Methods for Electrical Conductivity and Resistivity of Water. Fire extinguishers containing wet chemical water based agents which have a conductivity higher than one 1.5 microsiemen shall not be rated Class C. WARNING: Wet chemical agents are strong conductors of electricity. Turn off the power to the electrical appliances before using a wet chemical Class K rated fire extinguisher on them. SUBSTANTIATION: The committee response to the original proposal indicated that the committee was not able to reach agreement on appropriate test criteria for the extinguishing agent. The above mentioned test and below mentioned criteria is a Nationally recognized standard test and is grounded in true science. The threshold of 1.5 microsiemen is referenced in ASTM D as the maximum conductivity for reagents. The basis here is that when water is higher than 1.5 microsiemen, it s properties are changed significantly enough to be considered conductive. In the interest of public safety, we must preserve the long-standing tradition that Class C agents are nonconductive and safe for use on energized electrical equipment not only while being discharged but also after the agent has been discharged. With the addition of wet chemical and water mist fire extinguishing agents having a Class C rating the current paragraph 1-4.2(c), NFPA 10, 1998 edition, needs clarification of the existing thirty five year old, Class C rating for the agent to be nonconductive. There is no specific test in the Performance Standards cited in paragraph of NFPA 10, 1998 edition which addresses this issue. Resolution: The addition of ASTM D , Standard Test Methods for Electrical Conductivity and Resistivity of Water, a standardized test method, and a threshold value of 1.5 microsiemen, will clarify the requirement for the extinguishing agent to be nonconductive, as required in paragraph 1-4.2(c) of the NFPA 10, 1998 edition. This will correct a problem that was overlooked during a regular revision cycle by providing consistency for testing of the wet chemical and water mist extinguishing agents, with the other extinguishing agents. The performance requirement is equivalent to Section 50.4, Dielectric Strength Test, in ANSI/UL 299 as cited in paragraph of NFPA 10, 1998 edition. It will fulfill a void in the Performance Standards for wet chemical as specified in paragraph of NFPA 10, 1998 edition. It will also return to the public a benefit that would rectify a continuing dangerous life safety situation from a recognized hazard. COMMITTEE STATEMENT: See Commitee Comment for (Log #CC1) The first sentence states that the agent for a Class C rating shall not be a conductor of electricity. Then the third sentence permits the agent to be conductive to 1 microsiemen/cm. The first sentence implies that the agent needs to have a conductivity of 0.0 microsiemen/cm, which is contrary to the 1.0 microsiemen/cm conductivity threshold defined in the third sentence. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=O.5 calculated value) was chosen as the threshold. There is no technical reason for doubling the calculated value for the conductivity threshold requirement, which permits a higher acceptable shock hazard. Likewise, there is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and not intended for measuring the conductivity of the dry chemical. It would be more appropriate to use 240 volts, or for industrial applications, 440 volts. 1. The definition for a Class C rating, 1-4.2, states that the agent shall not be a conductor of electricity. Then the third sentence of permits the agent to be conductive to 1 microsiemen/cm. To imply that the agent has a conductivity of 0.0 microsiemen/cm and then define acceptable conductivity as 1.0 microsiemen/cm using an ASTM test method for flowing water is a contradiction. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=0.5 calculated value) was chosen as the threshold. There is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and is not intended for measuring the conductivity of the dry chemical. The voltage which should be used is more 278 appropriately 240 volts, or for industrial applications, 440 volts (550 volts in Canada). Referring to published Control Unit Standards, the maximum acceptable current for shock hazard testing is 809 milliamperes. Using these numbers, the acceptable level of conductivity would change drastically. A further inconsistency lies in the doubling of the calculated value to be the threshold requirement. If 0.5 microsiemen/cm is calculated as the maximum threshold value, twice that value is technically unsound, and would appear to condone a higher acceptable shock hazard. (Log #19) (1-4.2(c)) : Accept in Principle SUBMITTER: Mike Larabel, CFPS, CFI, Alticor Inc./Rep. Industrial Fire Protection Section 5 RECOMMENDATION: Leave current wording in effect. SUBSTANTIATION: Extinguishers rated for electrical fires should utilize an extinguishing agent that is nonconductive. Water based agents are extremely conductive and should not be allowed to be rated for class C extinguishers. COMMITTEE STATEMENT: See Committee Statement on Comment 10-8 (Log #56) Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #23) (1-4.2(c)) : Accept in Principle 5 RECOMMENDATION: Revise text to read as follows: Class C Rating. No fire test. Agent must be a nonconductor of electricity as required by paragraph 1-4.3(b)6. Note: This recommended comment wording refers directly to paragraph 1-4.2(c) in NFPA 10, (Explanation; see comment by P. Huston on proposal 10-17, paragraph 1-4.2). SUBSTANTIATION: The proposed change removes the traditional electrical nonconductivity characteristic of Class C rated agents as shown in the 1998 NFPA 10 Standard. I believe highly conductive agent wet chemical Class K; C rated extinguishers and conductive water mist are in violation of the requirements of NFPA 10, Approve the comment and the low safe conductivity Class C category of extinguishers will remain available to the users. Also, see Comment by P. Huston on paragraph for more information. COMMITTEE STATEMENT: See Committee Statement on Comment 10-8 (Log #56) Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) permits agents to be conductive to 1.0 microsiemen/cm. 1. Class C rating. No fire test. Agent must be a nonconductor of electricity. Since UL 711 has always evaluated the Class C rating for fire extinguishers while the agent is being discharged from the extinguisher, this statement needs to be included. Furthermore, the proposal for (Log #CC1) is permitting agents to be conductive. (Log #8)

6 10-17-(1-4.2(e)) : Accept in Part SUBMITTER: Fred Goodnight, Amerex Corp. 5 RECOMMENDATION: Revise text to read as follows: (e) class K rating. Special tests on cooking appliances using combustible cooking media (vegetable or animal oils and fats). Wet chemical extinguishers manufactured after Jan. 1, 2002 should not be listed and labeled with a class C rating. SUBSTANTIATION: First sentence was inadvertently left out of ROP proposal. Also, second sentence revised to acknowledge that there are many class K extinguishers in existence with class C ratings. An agreement by FEMA members will assure that after Jan. 1, 2002 that no new class K extinguishers will be manufactured with a class C rating. COMMITTEE ACTION:Accept in Part Replace (e) with the following: (e) Class K rating. Special tests on cooking appliances using combustible cooking media (vegetable or animal oils and fats). COMMITTEE STATEMENT: The committee felt that it would be more appropriate to refer to the special tests in a generic way rather than in a negative way. (Log #32) (1-4.4) : Accept in Principle Delete the exception and add the following new paragraph: Fire extinguishers manufactured prior to January 1, 1986 shall not be required to comply with paragraph (Log #CC1) (Para 1-4.4) : Accept SUBMITTER: Technical Committee on Portable Fire Extinguishers, 5 RECOMMENDATION: Revise as follows: Extinguishers listed for the Class C rating shall not contain an agent that is a conductor of electricity. In addition to successfully meeting the requirements of UL 711, water based agents shall be tested in accordance with Comparison Values Extinguishing Agent Halon 1211 Manufacturer of Agent Either ICI America or Great Lakes Chemicals Conductivity Microsiemen/cm, (µs/cm) ASTM D , Standard Test for Electrical Conductivity and Resistivity of a Flowing High Purity Water Sample. Fire extinguishers containing water based agents which have a conductivity higher than 1.00 microsiemens/cm at 25C (77F) shall be considered a conductor of electricity and therefore shall not be rated Class C. This requirement applies only to water based extinguishers manufactured after August 15, SUBSTANTIATION: Recommendation For Conductivity Value For Water Based Fire Extinguishing Agent. The value for conductivity has been derived from the inverse of resistivity as determined from the voltage and current values according to Ohm s law. [1] G = I (amps)/ E (volts) G = Conductivity I = Current E = Voltage In order to solve for conductivity the following values were chosen: E = Voltage = 5000 Vac This voltage was chosen based upon the correlating value for dry chemical extinguishing agents as specified in ANSI/UL 299, Section 48, Extinguishing Agents, paragraph I = Current =2.6 milliamps = 4 miliamps x 0.65 = Beginning of reflex action for a female adult reference Table 1, P39 Naval Research Laboratory report 6475, published May 25, Solving for Conductivity: G = I/ E = / 5000 = 0.5 x 10-6 S/cm =0.5 microsiemen /cm Based upon this analysis it is proposed a maximum of 1.00 microsiemen / 25 C (77 F). It is proposed this value to be determined based upon ASTM D , Standard Test Method for Electrical Coductivity and Resistivity of a Flowing High Purity Water Sample. This method is proposed based upon the recommendation from Mr. David Gray, Thorton Inc, member of the ASTM D1125 Committee, for determining conductivity values below 10 microsiemens/cm. See ComparisonValues Table Below REFERENCES 1. Eutech Instruments Web Page, Tech Tips Introduction to Conductivity, October 31, American Pacific Corp. , Subject: Halon / Halotron I Conductivities, Jeff Gibson, October 31, Dupont , Subject: Resistivity, Greg Rubin, October 9, Systems Design Manual, A.1.16 Electrical Properties, Imperial Chemical Industries Limited, Mond Division, Document GC/1158/1857/3Ed/13/374, pp 9, Physical Chemistry, Some Applications of Conductance Measurements, Gordon M. Barrow, Second Edition, p TPS Pty Ltd. Web Page, Conductivity Measurements, August 3, E. H. Bolander et al., Use of Seawater for Fighting Electrical Fires, Hughes Associates, May 25, 1989, p. 6, Santa Clara Valley Water District Web Page, Drinking Water Test Method µs/cm at ñ10 C (14 F) *ASTM D1125, Method A Source of Data American Pacific [2] ICI America µs/cm Unknown ICI Americas[4] Halotron I American Pacific µs/cm at -10 C (14 F) *ASTM D1125, Method A HFC-236 (FE-36) American Pacific [2] Dupont µs/cm s ASTM Dupont [3] Absolute Pure Water Theoretical µs/cm at 25 C (77 F) N/A [5, 6, 1] Distilled Water Unknown 1 µs/cm at 25 C (77 F) Conductivity Meter TPS Pty Ltd [6] *ASTM D , Standard Test Method for Electrical Conductivity and Resistivity of Water, Method A ñ Minor adjustments due to low boiling point, and vapor pressure of extinguishing agents. s ASTM , Standard Test Method for Dissipation Factor (or Power Factor) and Relative Permittivity (Dielectric Constant) of Electrical Insulating Liquids ñ The results from this test method were presented as resistivity. The results were converted by calculation to conductivity. The data from this source was presented as resistivity. The results were converted by calculation to conductivity. 279

7 Laboratory/SCVWD Laboratory Water Quality Reports, September COMMITTEE ACTION:Accept The first sentence states that the agent for a Class C rating shall not be a conductor of electricity. Then the third sentence permits the agent to be conductive to 1 microsiemen/cm. The first sentence implies that the agent needs to have a conductivity of 0.0 microsiemen/cm, which is contrary to the 1.0 microsiemen/cm conductivity threshold defined in the third sentence. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=O.5 calculated value) was chosen as the threshold. There is no technical reason for doubling the calculated value for the conductivity threshold requirement, which permits a higher acceptable shock hazard. Likewise, there is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and not intended for measuring the conductivity of the dry chemical. It would be more appropriate to use 240 volts, or for industrial applications, 440 volts. 1. The definition for a Class C rating, 1-4.2, states that the agent shall not be a conductor of electricity. Then the third sentence of permits the agent to be conductive to 1 microsiemen/cm. To imply that the agent has a conductivity of 0.0 microsiemen/cm and then define acceptable conductivity as 1.0 microsiemen/cm using an ASTM test method for flowing water is a contradiction. and E=5000 volts (UL min. dielectric voltage withstand strength for dry chemical). Based upon these values used in the calculation, G=0.5 calculated value) was chosen as the threshold. There is no substantiation for using the 5000 volt value other than being referenced in UL 299. The 5000 volts is a dielectric breakdown voltage and is not intended for measuring the conductivity of the dry chemical. The voltage which should be used is more appropriately 240 volts, or for industrial applications, 440 volts (550 volts in Canada). Referring to published Control Unit Standards, the maximum acceptable current for shock hazard testing is 809 milliamperes. Using these numbers, the acceptable level of conductivity would change drastically. A further inconsistency lies in the doubling of the calculated value to be the threshold requirement. If 0.5 microsiemen/cm is calculated as the maximum threshold value, twice that value is technically unsound, and would appear to condone a higher acceptable shock hazard. (Log #33) (1-4.5) : Accept in Principle Delete the two exceptions and add the following two paragraphs: Fire extinguishers manufactured prior to January 1, 1989 shall not be required to comply with paragraph Certification organizations accredited by the Standards Council of Canada shall not be required to comply with paragraph (Log #34) (1-6.1) : Accept in Principle Delete the exception and add the following new paragraph: Fire extinguishers classified for use on Class C, Class D, or Class K hazards shall not be required to have a number preceding the classification letter. exceptions 280 (Log #58) (1-6.4(g)) : Reject COMMENT ON PROPOSAL NO:10-23 RECOMMENDATION: Reject Proposal. SUBSTANTIATION: Carbon dioxide fire extinguishers with metal horns are still widely used for the protection of Class B fires and should not be arbitrarily determined by the committee as obsolete. This is simply a marketing ploy. COMMITTEE STATEMENT: These extinguishers, if still in service, are past their useful life. Calling for removal of these units will avoid confusion and necessary statements in the standard that refer to using carbon dioxide extinguishers on Class C fires except if equipped with a metal horn. (Log #90) (1-6.7) : Accept in Principle SUBMITTER: Michael Kluczynski, New Dimension Industries COMMENT ON PROPOSAL NO:10-27 RECOMMENDATION: Revise text to read as follows: Portable fire extinguishers other than wheeled extinguishers types shall be securely installed on the hanger or on/in a listed bracket approved for such purpose or in the bracket supplied by the extinguisher manufacturer or placed in cabinets or wall recesses. The hangar bracket shall be securely and properly anchored to the mounting surface in accordance with the manufacturer s instructions. Portable fire extinguishers with a gross weight of 12 pounds or less shall be installed in strap-type brackets unless they are placed in cabinets or wall recesses. Wheeled type fire extinguishers shall be located in a designated location. SUBSTANTIATION: By limiting hanger(s)/bracket(s) to the use of those supplied only by the extinguisher manufacturer it creates exclusion of other forms of Listed or Classified brackets, hangers or devices that have been tested and found to perform equal to or to a greater degree than the OEM device. Revise text as follows: Portable fire extinguishers other than wheeled extinguishers shall be securely installed on the hanger, or in the bracket supplied by the extinguisher manufacturer, or in a listed bracket approved for such purpose, or placed in cabinets or wall recesses. Wheeled fire extinguishers shall be located in a designated location. COMMITTEE STATEMENT: The committee agreed that a listed bracket approved for the purpose would satisfy the need. (Log #24) ( ) : Reject COMMENT ON PROPOSAL NO:10-32 RECOMMENDATION: This comment deletes proposed text and returns the text to the requirement shown in the NFPA 10, 1998 Standard as follows: Fire Extinguishers for protecting Class A hazards shall be selected from the following: (a) Water type, (b) Halogenated agent type (for halon-agent type fire extinguishers, see 2-1-1). (c) Multipurpose dry chemical type, (d) Wet chemical type. SUBSTANTIATION: That extinguishers must be specifically listed and labeled for use on classes of fires is required by paragraph Proposal for paragraph has no real information value to the user. I believe it is part of an effort to eliminate the present authority of the NFPA 10 Committee to review and evaluate and understand new models of extinguishers and agents and their applications before integrating them into the standard. See Proposals 10-32, 10-33, For agreement with this comment see Proposals 10-35, 10-36, 10-37, and if you have time, COMMITTEE STATEMENT: More appropriate as annex. AFFIRMATIVE: 15 NEGATIVE: 1 EXPLANATION OF NEGATIVE:

8 WAHLE: The selection of specific types of extinguishers for particular class of hazards provides important guidance to the public. The Committee s proposal to replace the selection of extinguishers with a statement that extinguishers must be listed for a particular hazard rather than identifying suitable extinguisher types does not provide the needed information. It shifts the NFPA s function to educate the public to the listing laboratories. (Log #26) ( ) : Reject COMMENT ON PROPOSAL NO:10-33 RECOMMENDATION: This comment deletes the proposed text and returns the text to the requirement shown in the NFPA standard as follows: Fire extinguishers for the protection of Class B hazards shall be selected from the following: (a) Aqueous film-forming foam (AFFF) (b) Film-forming fluoroprotein foam (FFFP) (c) Carbon dioxide (d) Dry chemical type (e) Halogenated agent type (for halon agent-type fire extinguishers, see 2.1.1). SUBSTANTIATION: That extinguishers must be specifically listed and labeled for use on classes of fires is required by paragraph Proposal has no real information value to the user. I believe it is part of an effort to eliminate the present authority of the NFPA 10 Committee to review and evaluate and understand new models of extinguishers and agents and their applications before integrating them into the standard. See proposals 10-32, 10-33, and For agreement with this comment see proposals 10-35, 10-36, 10-37, and if you have time, COMMITTEE STATEMENT: More appropriate as annex. AFFIRMATIVE: 15 NEGATIVE: 1 EXPLANATION OF NEGATIVE: WAHLE: The selection of specific types of extinguishers for particular class of hazards provides important guidance to the public. The Committee s proposal to replace the selection of extinguishers with a statement that extinguishers must be listed for a particular hazard rather than identifying suitable extinguisher types does not provide the needed information. It shifts the NFPA s function to educate the public to the listing laboratories ( ) : Reject SUBMITTER: Mike Larabel, CFPS, CFI, Alticor Inc./Rep. Industrial Fire Protection Section COMMENT ON PROPOSAL NO:10-39 RECOMMENDATION: Proposal (Log #CP5) intends to delete the note attached to Section apparently as a result of the proposed addition to 1-6.4(g) which obsolete carbon dioxide extinguishers with metal horns. The current note should remain in place but the wording should be changed as follows: NOTE: Carbon dioxide Fire extinguishers equipped with metal horns discharge devices are not considered safe for use on fires in energized electrical equipment and, therefore, are not classified for use on Class C hazards. SUBSTANTIATION: Eliminating this note will open the door for use of fire extinguishers with metal wands and other metal discharge devices. Even though carbon dioxide extinguishers with metal horns have become obsolete, there are a number of other extinguishers that utilize metal discharge devices. Any type of extinguisher that uses a metal discharge device around energized electrical equipment poses a serious electrocution hazard to the operator and should not be permitted. COMMITTEE STATEMENT: Cartridge operated dry chemical extinguishers have metal discharge devices and are appropriate for Class C hazards. (Log #57) ( ) : Reject COMMENT ON PROPOSAL NO:10-39 RECOMMENDATION: Reject Proposal. SUBSTANTIATION: Carbon dioxide fire extinguishers with metal horns are still widely used for the protection of Class B fires. This note is important for the end user of this standard. COMMITTEE STATEMENT: See Committee Statement for Comment (Log #51). (Log #28) ( ) : Reject COMMENT ON PROPOSAL NO:10-34 RECOMMENDATION: This comment deletes the proposed text and the 1998 Standard text and returns it generally to the text of NFPA 10, 1994 as follows: Fire extinguishers for the protection of Class C hazards shall be selected from the following: (a) Carbon dioxide, (b) Dry chemical type, (c) Halogenated agent type (for halon agent-type fire extinguishers see 2.1.1). SUBSTANTIATION: Paragraph requires extinguishers must be listed and labeled. The existing and proposed paragraph has no informational value to the users of the NFPA 10 Standard. Paragraph as shown in NFPA 10, 1998, was turned down by a majority of the committee, turned down at the Fall Convention; but, through an appeal to the NFPA Standards Council, was put into the 1998 Standard. I believe the present wording is part of an effort to require the NFPA 10 Committee to automatically accept any new agent or extinguisher design into the standard that is listed and labeled by UL. I believe the NFPA 10 Committee needs to have a check and balance authority to protect the interests of the users of extinguishers. See comment by Paul Huston on Proposal 10-17, paragraph and Proposals 10-35, 10-36, 10-37, and COMMITTEE STATEMENT: The committee is relying on the listing process to identify extinguishers for use on Class C hazards. AFFIRMATIVE: 15 NEGATIVE: 1 EXPLANATION OF NEGATIVE: WAHLE: The selection of specific types of extinguishers for particular class of hazards provides important guidance to the public. The Committee s proposal to replace the selection of extinguishers with a statement that extinguishers must be listed for a particular hazard rather than identifying suitable extinguisher types does not provide the needed information. It shifts the NFPA s function to educate the public to the listing laboratories. (Log #51) 281 (Log #72) ( ) : Reject COMMENT ON PROPOSAL NO:10-35 RECOMMENDATION: Reconsider rejected log and revise text. Only identify safe extinguishers to be used on Class C fires as halogenated agent, carbon dioxide, and dry chemicals. These extinguishers do not create a secondary hazard to the operator. SUBSTANTIATION: It is imperative to eliminate the risk of electrocution due to pooling of agent after discharge in a Class C fire. The Underwriters Laboratories Class C test does not address the electrocution risk. The proposal specifically eliminates recommendation of using water mist and wet chemical technologies in Class C applications. COMMITTEE STATEMENT: See Committee Statement for Comment (Log #28) AFFIRMATIVE: 15 NEGATIVE: 1 EXPLANATION OF NEGATIVE: WAHLE: The selection of specific types of extinguishers for particular class of hazards provides important guidance to the public. The Committee s proposal to replace the selection of extinguishers with a statement that extinguishers must be listed for a particular hazard rather than identifying suitable extinguisher types does not provide the needed information. It shifts the NFPA s function to educate the public to the listing laboratories. (Log #84) ( ) : Reject COMMENT ON PROPOSAL NO:10-38 RECOMMENDATION: Reconsider rejected log. Only identify safe extinguishers to be used on Class C fires as halogenated agent, carbon dioxide, and dry chemicals. SUBSTANTIATION: It is imperative to eliminate the risk of electrocution due to pooling of agent after discharge in a Class C fire. The Underwriters Laboratories Class C test does not address the electrocution risk. The proposal specifically eliminates recommendation of using water mist and wet chemical technologies in Class C applications.