TECHNICAL COMMITTEE ON FINISHING PROCESSES Second Draft Meeting Agenda March 4-6, 2014 Drury In and Suites, Riverwalk San Antonio, TX

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1 TECHNICAL COMMITTEE ON FINISHING PROCESSES Second Draft Meeting Agenda March 4-6, 2014 Drury In and Suites, Riverwalk San Antonio, TX Note-Breakfast served in lobby each morning. Lunch will be provided on day one. Day One 8:00AM-5:00 PM 1. Welcome and Introduction. Tom Euson, Chair. 2. Roll Call and Introduction of New Committee Members. 3. Approval of Meeting Minutes from Pre-SD meeting (attached). 4. Staff updates-nancy Pearce a) Committee membership update. (attached) b) Fall 2014 revision cycle schedule. (attached) c) New Process Presentation-Second Draft Meeting 5. Task Group Reports and Second Revisions a) Water Supply Requirements-Tom George b) Powder Coating-Marty Korecky c) Dry Scrubber/New Technologies-Geoff Raifsnider/Tom Euson d) Artwork in NFPA 33/34-Geoff Raifsnider/Tom Euson 6. Review of Public Comments NFPA 33 and NFPA 34. (attached) Day Two 8:00AM-12:00 PM Review of Public Comments NFPA 33 and NFPA 34 (continued) Lunch 12:00-1:00 Day Two 1:00 PM -5:00 PM 7. Task Group Report Indoor Membrane Enclosures-John McKnight 8. Presentations from Guests-Indoor Membrane Enclosures and Public Comments a) Greg Cahanin, Cahanin Fire & Code Consulting b) Bill Koffel, Koffel Associates representing Lauderdale Marine c) Jim Parks, Lauderdale Marine d) Ryan Watt, Duroair Questions from Committee to Guests

2 Day Three 8:00AM -12:00PM 9. Completion of Outstanding Public Comments and Other Committee Work. 10. Other Business 11. Adjournment.

3 TECHNICAL COMMITTEE ON FINISHING PROCESSES Pre-SD MINUTES Conference Call/Adobe Connect Meeting January 29, :00-11:00 AM EDT Attendees: Thomas Euson, 3S Incorporated, Chair Geoffrey Raifsnider, Global Finishing Solutions, Secretary Shane Adams, Rancho Cucamonga Fire Protection District William Anderson, Approved Fire Protection Company, Inc. Donald Ankele, Underwriters Laboratories Inc. Amy Brown, FM Global Dean Doherty, General Motors North America Luc Durand, Saskatoon Fire Department Robert Feldkamp, Nordson Corporation Thomas George, Tokio Marine Management, Inc. John Gokey, Tyco Fire Suppression & Building Products James Gustin, Travelers Insurance Company Bryant Jeffrey, DuPont/Axalta Coating Systems Richard Hild, DuPont/Axalta Coating Systems * Steven Jensen, 3M company Martin Korecky, Rohm and Haas Company John LeBlanc, FM Global* John McKnight, National Marine Manufacturers Association (Rep. Society of the Plastics Industry) Lowell Miles, Miles Fiberglass & Composites (Rep. American Composites Manufacturers Association) Douglas Rivord, Graco Incorporated Mike Thies, GEMA USA Inc * *Alternates Nancy Pearce, NFPA Staff Liaison Bob Bennedetti, NFPA Staff 1. Welcome and Introduction. Tom Euson, Chair. Tom Euson welcomed the committee and indicated that the primary purpose of the meeting was to review the task group work related to indoor membrane enclosures. 2. Introduction of New Committee Members and Role. Attendance was taken. 3. Approval of Meeting Minutes from FD meeting. Minutes of previous meetings for First Draft were approved. 4. Summary of Public Comments Received. Nancy indicated that public comments had been sent previously for Committee member review. Tom and Nancy had reviewed the comments previously and did not note the need for any additional task groups. All committee members were reminded to review the comments in preparation for the meeting. The comments will be sent out again with the agenda. 5. Task Group Work to be Done-Updates. a) Water Supply Requirements-Tom George indicated that the task group had met several times and it appears that annex material will be developed to assist in the estimation of water demands in small versus more complicated booths with several types of fire protection systems. He indicated that the task group was not

4 able to complete work on calculation of demands in exhaust ducts and that he suggested asking NFPA 13 be to assist with this task for the next revision cycle. b) Powder Coating-Marty Korecky indicated that the task group had developed annex material for Chapter 15 and that it would include MECs for powders that had been tested. c) Dry Scrubber/New Technologies-Geoff Raifsnider did not have an update but indicated that the task group would be meeting soon. d) Artwork in NFPA 33/34-Tom Euson, Geoff Raifsnider will review the options for new artwork in NFPA 33 and NFPA 34. Steven Jensen volunteered to assist in reviewing the artwork for NFPA 34. e) Indoor Membrane Enclosures-John McKnight explained that the task group had met and after discussion decided that public comment # 62 on Indoor Membrane Enclosures best reflected what the task group would recommend. Public comment # 62 included the use of an FM approved material that the NFPA 13 committee put forth for consideration as a committee input at their first draft meeting. Since the NFPA 13 revision is out of synch with the NFPA 33 revision by about 6 months, the NFPA 33 committee cannot be sure that the material in question will be allowed in NFPA 13 until after the NFPA 13 second draft meeting and ballot. Nancy explained that any change in the NFPA 33 standard that impacted sprinklers would have to be submitted to the NFPA 13 sprinkler task group for review since it was not clear whether or not the use of a membrane enclosure is currently allowed in NFPA 13. Before the task group asked the sprinkler committee to review the public comment, they wanted to discuss the issue with the full committee to determine if there was general agreement that this was a change worthy of consideration. If the full committee clearly did not wish to proceed, then it would make no sense to ask the Sprinkler committee to review the proposal. After discussion, the committee voted 11/7 in favor of asking the sprinkler task group for their opinion. Once an opinion is rendered, the NFPA 33/34 committee can decide how to proceed at the second draft meeting. Nancy will submit the public comment to the task group immediately and ask for a review and opinion prior to the March meeting. 6. Second Draft Meeting Logistics. Nancy reminded the group that the cutoff date for making reservations at the NFPA discounted rate for the upcoming Second Draft Meeting is February 10 th. Anyone who is planning to attend should also contact Joanne Goyette to RSVP to the meeting. 7. Other Business. a) Don Ankele reminded the committee that NFPA 70 will be going back into cycle with public input closing dates coming up in November A task group will need to be formed once again. b) Advisory Service Question. A question was received asking if recirculation ducts used for the purpose of drying, curing only would need to be sprinklered. There was general consensus in the group that this was not the intent and that the definition of spray area that included recirculation ducts would not include recirculation ducts for drying, curing only. This would be contingent upon the duct being free and clear of debris and buildup. The committee may need to clarify this in future revisions. 8. Adjournment. The meeting adjourned at 11:45 AM.

5 Address List No Phone Finishing Processes 02/14/2014 Nancy Pearce Thomas G. Euson Chair 3S Incorporated 8686 Southwest Parkway Harrison, IN Alternate: Matthew M. Euson IM 1/1/1988 Geoffrey A. Raifsnider Secretary Global Finishing Solutions Norway Road Osseo, WI Alternate: John S. Vonasek M 8/5/2009 Shane A. Adams Principal Rancho Cucamonga Fire Protection District Civic Center Drive Rancho Cucamonga, CA E 08/09/2012 William C. Anderson Principal Approved Fire Protection Company, Inc North Burdick Street Kalamazoo, MI National Association of Fire Equipment Distributors IM 7/20/2000 Donald W. Ankele Principal UL LLC 333 Pfingsten Road Northbrook, IL Alternate: Michael A. Slowinske RT 1/14/2005 John D. Bloomgren Principal Infinity Precision, LLC 7850 Park Drive Chanhassen, MN M 4/1/1993 Mark A. Bowman Principal XL Global Asset Protection Services Chevington Drive Pickerington, OH Alternate: Jeffrey A. Spiesz I 10/28/2008 Amy Brown Principal FM Global 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA Alternate: John A. LeBlanc I 8/5/2009 Larry B. Cox Principal Structurlite Composites Consultants 122 Wilshire Drive Hebron, OH SE 11/2/2006 Dean Doherty Principal General Motors North America Mount Road, Mailcode PO Box 9040 Warren, MI NFPA Industrial Fire Protection Section Alternate: James M. Sute U 1/16/2003 Luc Durand Principal Saskatoon Fire Department Prevention and Investigation Division 125 Idylwyld Drive South Saskatoon, SK S7M 1L4 Canada E 10/23/2013 Robert J. Feldkamp Principal Nordson Corporation 300 Nordson Drive Amherst, OH Alternate: Edward L. Jones M 7/24/1997 1

6 Address List No Phone Finishing Processes 02/14/2014 Nancy Pearce Paul B. Gentry Principal Zurich Services Corporation Risk Engineering 1047 Waldron Road La Vergne, TN Alternate: James W. Taylor I 10/4/2001 Thomas B. George Principal Tokio Marine Management, Inc. 800 East Colorado Boulevard Pasadena, CA Alternate: Dennis P. Mason I 1/15/2004 John Gokey Principal Tyco Fire Protection Products One Stanton Street Marinette, WI Alternate: Jeffrey A. Breighner M 7/1/1993 Steven J. Gunsel Principal SGTechnologies, LLC 944 Southport Drive Medina, OH SE 1/1/1992 James S. Gustin Principal Travelers Companies, Inc. Risk Control PO Box Charlotte, NC I 3/1/2011 Brian K. Haynack Principal Sherwin-Williams Company 101 Prospect Ave. NW, Midland Bldg. 400 Cleveland, OH American Industrial Hygiene Association M 7/26/2007 Bryant C. Jeffrey Principal DuPont/Axalta Coating Systems Route 141 & Henry Clay Building E308, Room 215 Wilmington, DE Alternate: Richard J. Hild M 10/23/2013 Steven D. Jensen Principal 3M Company 915 Adams Street, SE Hutchinson, MN Alternate: David J. Schutt U 4/1/1995 Guy L. Jones, Jr. Principal Amerex Corporation 7595 Gadsden Highway PO Box 81 Trussville, AL Fire Equipment Manufacturers' Association Alternate: William Vegso M 03/05/2012 Martin J. Korecky Principal AkzoNobel Powder Coatings 150 Columbia Street Reading, PA M 3/15/2007 John McKnight Principal National Marine Manufacturers Association 444 North Capitol Street NW, Suite 645 Washington, DC Society of the Plastics Industry, Inc. U 4/1/1996 Lowell Miles Principal Miles Fiberglass & Composites 8855 SE Otty Road Portland, OR American Composites Manufacturers Association U 1/1/1986 2

7 Address List No Phone Finishing Processes 02/14/2014 Nancy Pearce G. Randall Nance Principal Automated Fire Systems, Inc. PO Box Charlotte, NC IM 1/1/1990 Douglas A. Rivord Principal Graco, Inc. PO Box 1441 Minneapolis, MN Alternate: Mike Thies M 1/18/2001 Don Scarbrough Principal 550 Randall Road Elyria, OH SE 1/1/1972 Barry Thomas Principal BECCA Inc Cobb International Blvd. Kennesaw, GA M 1/1/1996 Jeffrey A. Breighner Alternate Tyco/SimplexGrinnell 705 Digital Drive, Suite N Linthicum, MD Principal: John Gokey M 8/5/2009 Matthew M. Euson Alternate 3S Incorporated 8686 Southwest Parkway Harrison, IN Principal: Thomas G. Euson IM 10/28/2008 Richard J. Hild Alternate DuPont/Axalta Coating Systems 1003 Bogart Circle Bel Air, MD Principal: Bryant C. Jeffrey M 10/23/2013 Edward L. Jones Alternate Nordson Corporation 300 Nordson Drive, M/S 44 Amherst, OH Principal: Robert J. Feldkamp M 7/26/2007 John A. LeBlanc Alternate FM Global 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA Principal: Amy Brown I 8/5/2009 Dennis P. Mason Alternate AEGIS Insurance Services Loss Control Division 4797 Jackson Street Trenton, MI Principal: Thomas B. George I 7/17/1998 David J. Schutt Alternate 3M Company Design and Engineering Solutions 3M Center, Building W-25 St. Paul, MN Principal: Steven D. Jensen U 8/9/2011 Michael A. Slowinske Alternate UL LLC 333 Pfingsten Road Northbrook, IL Principal: Donald W. Ankele RT 7/22/1999 Jeffrey A. Spiesz Alternate XL Global Asset Protection Services Goulders Green Bay Village, OH Principal: Mark A. Bowman I 07/29/2013 James M. Sute Alternate General Motors Parkwood Lane Brownstown Township, MI NFPA Industrial Fire Protection Section Principal: Dean Doherty M 07/29/2013 3

8 Address List No Phone Finishing Processes 02/14/2014 Nancy Pearce James W. Taylor Alternate Zurich Services Corporation 545 Saddle Lane Cookeville, TN Principal: Paul B. Gentry I 3/4/2009 Mike Thies Alternate GEMA USA, Inc West 54th Street Indianapolis, IN Principal: Douglas A. Rivord M 10/23/2013 William Vegso Alternate Buckeye Fire Equipment Company 110 Kings Road Kings Mountain, NC Fire Equipment Manufacturers' Association Principal: Guy L. Jones, Jr. M 3/15/2007 John S. Vonasek Alternate Global Finishing Soluitions Norway Road Osseo, WI Principal: Geoffrey A. Raifsnider M 10/29/2012 Matthew I. Chibbaro Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Alternate: William R. Hamilton E 4/15/2004 William R. Hamilton Alt. to Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC Principal: Matthew I. Chibbaro E 3/4/2009 Nancy Pearce Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA /11/2012 4

9 2014 FALL REVISION CYCLE *Public Input Dates may vary according to standards and schedules for Revision Cycles may change. Please check the NFPA Website for the most up to date information on Public Input Closing Dates and schedules at (i.e. and click on the Next Edition tab. Process Stage Process Step Dates for TC Dates for TC with CC Public Input Closing Date* 1/4/2013 1/4/2013 Final Date for TC First Draft Meeting 6/14/2013 3/15/2013 Public Input Posting of First Draft and TC Ballot 8/2/2013 4/26/2013 Stage Final date for Receipt of TC First Draft ballot 8/23/2013 5/17/2013 (First Draft) Final date for Receipt of TC First Draft ballot recirc 8/30/2013 5/24/2013 Posting of First Draft for CC Meeting 5/31/2013 Final date for CC First Draft Meeting 7/21/2013 Posting of First Draft and CC Ballot 8/2/2013 Final date for Receipt of CC First Draft ballot 8/23/2013 Final date for Receipt of CC First Draft ballot recirc 8/30/2013 Post First Draft Report for Public Comment 9/6/2013 9/6/2013 Public Comment Closing Date for Paper Submittal* 10/11/ /11/2013 Public Comment Closing Date for Online Submittal (e PC)* 11/15/ /15/2013 Final Date to Publish Notice of Consent Standards (Standards that 11/29/ /29/2013 received no Comments) Appeal Closing Date for Consent Standards (Standards that received 12/13/ /13/2013 no Comments) Final date for TC Second Draft Meeting 5/2/2014 1/24/2014 Comment Posting of Second Draft and TC Ballot 6/13/2014 3/7/2014 Stage Final date for Receipt of TC Second Draft ballot 7/7/2014 3/28/2014 (Second Final date for receipt of TC Second Draft ballot recirc 7/14/2014 4/4/2014 Draft) Posting of Second Draft for CC Meeting 4/11/2014 Final date for CC Second Draft Meeting 5/23/2014 Posting of Second Draft for CC Ballot 6/13/2014 Final date for Receipt of CC Second Draft ballot 7/3/2014 Final date for Receipt of CC Second Draft ballot recirc 7/11/2014 Post Second Draft Report for NITMAM Review 7/18/2014 7/18/2014 Tech Session Notice of Intent to Make a Motion (NITMAM) Closing Date 8/22/2014 8/22/2014 Preparation Posting of Certified Amending Motions (CAMs) and Consent 10/17/ /17/2014 Standards (& Issuance) Appeal Closing Date for Consent Standards 11/1/ /1/2014 SC Issuance Date for Consent Standards 11/11/ /11/2014 Tech Session Association Meeting for Standards with CAMs 6/22 25/2015 6/22 25/2015 Appeals and Appeal Closing Date for Standards with CAMs 7/15/2015 7/15/2015 Issuance SC Issuance Date for Standards with CAMs 8/20/2015 8/20/2015 Approved October 18, 2011 _ Revised March 7, 2013

10 of 64 2/14/2014 1:10 PM Public Comment No. 39-NFPA [ Global Input ] For Chapter 18, replace "spray paint area" with "spray area". "Spray area" is the term that is used throughout the document. This change is for consistency. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Thu Nov 14 22:37:31 EST 2013

11 of 64 2/14/2014 1:10 PM Public Comment No. 63-NFPA [ Global Input ] Suggested re-wording and comments have been provided below to the proposed wording for Chapter 18, to cover indoor membrane enclosures. Changes are in bold and italicized This additional material would be added to the First Revision 13, new Chapter 18, to cover indoor membrane enclosures Temporary membrane enclosures for spray painting boats in marina s shall be permitted to be installed in buildings provided all of the requirements of this chapter are complied with in design, installation, and conduct of spray paint operations within the enclosure Only shrink wrap material passing NFPA 701 Test 2 requirements shall be used for spray painting boats in marina buildings. The importance of the material is that it meets the requirements of NFPA 701 Test Method * Buildings in which temporary membrane enclosures are installed shall have a minimum of 25% of the exterior walls open and unobstructed Buildings in which temporary membrane enclosures are installed that do not have a minimum of 25% of the exterior walls open and unobstructed must exhaust the VOC gases to the exterior of the building through code compliant venting and meeting the venting requirements of chapter 7. In the marine industry it is common to have a building with 25% of the exterior wall open however in many other facilities this will not be the case. The intent is to exhaust gases out of the building in the same manner as other exhaust systems listed in NFPA 33. The will keep the LFL below the required minimum and protect workers from harmful gases released into the shop environment. A The openness requirement serves two purposes. First it helps to insure that any flammable vapors released as a part of spray painting are readily diluted while reducing the possibility of concentrations of flammable vapors in the building. Second, the openness requirement gives better access to responding firefighters in the event of a fire emergency. My concern with this wording is that flammable vapors should not be exhausted into an interior environment of any kind unless meeting the requirements of chapter 7.5. Flammable vapors should be exhausted as per the requirements of chapter 7 from the building Buildings in which temporary membrane enclosures are installed shall be provided with Automatic Sprinkler Systems in accordance with Section The automatic sprinkler system shall be designed for Extra Hazard (Group 2) occupancies, as defined in NFPA 13, Standard for the installation of Sprinkler Systems As per chapter , Pre-engineered extinguishing systems shall not be used for fire protection unless specifically listed for use in temporary membrane enclosures. The proposed changes are designed to incorporate industries including and beyond the marine industry. The changes are designed to improve the safety to operators and protection of the building. Submitter Full Name: RYAN WATT Organization: DUROAIR TECHNOLOGIES INC

12 of 64 2/14/2014 1:10 PM Submittal Date: Fri Nov 15 16:30:35 EST 2013

13 of 64 2/14/2014 1:10 PM Public Comment No. 64-NFPA [ Global Input ] Incorporate the indoor use of membrane enclosures for marinas into Chapter 18. As advocates for boatyards and boat builders in the marine industry for 70 years, The American Boat Builders and Repairers Association is very aware of the use of temporary membrane enclosures both in boatyeards indoors and outdoors. In our observation, professional use of this spray-painting method includes use of necessary precautions accounting for safety and environmental conditions. Submitter Full Name: Gordon Connell Organization: ABBRA Submittal Date: Mon Nov 18 12:41:25 EST 2013

14 of 64 2/14/2014 1:10 PM Public Comment No. 65-NFPA [ Global Input ] Incorporate the indoor use of membrane enclosures for marinas into Chapter 18. Spray painting in the marine industry is vital to the survival of repair and fabricating facilities throughout the country. This procedure has been performed for many years and membrane enclosures have been an intrigal part of the process to facilitate an acceptal finish. It is a containment source for smaller facilities and protection of the environment and air quality. Submitter Full Name: Wayne Morrison Organization: Shelter Island Boatyard Submittal Date: Mon Nov 18 12:46:05 EST 2013

15 of 64 2/14/2014 1:10 PM Public Comment No. 66-NFPA [ Global Input ] Incorporate the indoor use of membrane enclosures for marinas into Chapter 18. Paint spray applications and containment enclosures are vital to our business. As an owner of a family run small business, customers demands are high for quality. In order for us to compete with out of area body or warehouse type facilities, we must provide a high quality finish with regards to invigorus safety and protection for the survival of our establishment. Submitter Full Name: Jose Gonzalez Organization: Jag Yacht Painting Inc. Submittal Date: Mon Nov 18 13:01:15 EST 2013

16 of 64 2/14/2014 1:10 PM Public Comment No. 67-NFPA [ Global Input ] Incorporate the indoor use of membrane enclosures for marinas into Chapter 18. The use of membrane enclosures is important to this industry by allowing us to provide acceptable dust free finishes. On top of that, they allow us to reduce the release of overspray and contamination into the surrounding environment. For many years their use has reduced impact on air quality and environment. Submitter Full Name: Eduardo Hernandez Organization: Hernandez Yacht Refinishing Submittal Date: Mon Nov 18 13:09:04 EST 2013

17 of 64 2/14/2014 1:10 PM Public Comment No. 68-NFPA [ Global Input ] Incorporate the indoor use of membrane enclosures for marinas into Chapter 18. Spray operations are vital to business in Ft. Lauderdale and the membranes are temproary and can be utilized indoors and outdoors. We are the yachting capital and would not want business to go elsewhere. Submitter Full Name: Brett Osceola Organization: Lulu Marina & Associates Submittal Date: Mon Nov 18 13:38:49 EST 2013

18 of 64 2/14/2014 1:10 PM Public Comment No. 9-NFPA [ Global Input ] See attached file Additional Proposed Changes File Name Description Approved CI_14-NFPA_ _1_.docx Comment to committee Input 14-NFPA The concept of allowing spray operation inside of buildings in unsprinklered enclosures would significantly increase the risk of fire to the building, occupants, and fire fighters. Related Item Committee Input No. 14-NFPA [Global Input] Submitter Full Name: Roland Asp Organization: National Fire Sprinkler Association Submittal Date: Fri Nov 08 13:22:24 EST 2013

19 Comment to Committee Input 14 NFPA Identification of Submitter: Roland Asp, National Fire Sprinkler Association. Identification of NFPA Standard: NFPA Identification of paragraph: proposed sections , , , A , , Comments on CI No. 14 NFPA : This CI is exploring the possibility of expanding the first revision to create a new chapter 18, which will be applicable to temporary membrane enclosure in the outdoor environment, and allowing this practice in an indoor setting. The National Fire Sprinkler System is speaking against this proposed allowance and does not believe that it is good practice to allow spray painting, in unsprinklered temporary enclosures within buildings. As stated in this CI, the committee is soliciting public comments on allowing spray painting in temporary shrink wrap enclosures within a building. The challenge is to mitigate the potential for fire and not to increase the fire risk to the building where these temporary enclosures are located. Some of the proposed safeguards that have been proposed are to require the enclosure to be constructed of shrinkwrap material passing NFPA 701 Test 2, The building in which these enclosures are located must have the exterior walls at least 25% open in order to prevent vapor build up and allow fire department access and finally, the building must be equipped with an automatic sprinkler system designed for Extra Hazard (Group 2). The installation standards have long based effective fire protection on the principle of applying water or another extinguishing agent to the fire at the early stages so that the fire does not propagate to a size that may overwhelm the sprinkler system. The key is to control or suppress the fire when it is still of a manageable size. An unsprinklered enclosure by its very nature will make this accepted fire protection methodology difficult if not impossible to achieve. The enclosure will delay the heat from a fire from activating the ceiling sprinklers, and once activated, the discharge from these sprinklers will be obstructed from reaching the fire hazard. The risk is that a fire in this unsprinklered space, which may be filled with flammable vapors, will grow to the extent that it will not be able to be contained by the ceiling sprinkler system even one designed to Ordinary Hazard Group 2 densities. The you tube video of the fire demonstration in these enclosures does not rise to the standards of fire testing and may not be used to demonstrate that these unsprinklered temporary enclosures are safe on the inside of buildings. This demonstration did however raise several concerns: The fire (wooden crib) was relatively small and not indicative of a potential fire in spray painting application which would include significant flammable vapors in an enclosed space. Although the fire did burn through the shrink wrap enclosure directly over the fire, the hole in the enclosure above the active fire would certainly not allow an unimpeded discharge of water to reach the fire and is a significant obstruction to sprinkler discharge. Further the enclosure would delay the heat from activating the ceiling sprinklers. All these factors taken together indicate that the practice of allowing spray operations, inside buildings in unsprinklered enclosures is not acceptable and would significantly increase the risk of fire to the building, occupants, and fire fighters.

20 0 of 64 2/14/2014 1:10 PM Public Comment No. 15-NFPA [ New Section after 3.3 ] TITLE OF NEW CONTENT 3.3.XX Hybrid water mist fire protection system. An extinguishing system that introduces both inert gas and water as an extinguishing media such that the oxygen concentration is between 12.5% and 16% at extinguishment. I have included water mist and hybrid fire protection systems to be allowed to be used as protection options in this standard. I have included the definition of a hybrid system since there is not an NFPA definition of this type of system. The committee resolved my public input stating that "NFPA 33 does not define other suppression systems. The definition is the responsibility of the committee for the applicable standard." The problem is the definition of a hybrid system is not covered by another NFPA standard. At the July 2013 Standards Council meeting, the Council rejected the request for the creation of a new standard covering hybrid extinguishing. NFPA 750 is the document most applicable to these types of systems, but the TC has yet to define them. Because of this, a definition of these types of systems in this document is appropriate. Submitter Full Name: Peter Thomas Organization: Victaulic Company Submittal Date: Tue Nov 12 10:52:53 EST 2013

21 1 of 64 2/14/2014 1:10 PM Public Comment No. 6-NFPA [ Section No ] Competent Person. One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. [56: 2012] This is definition of Competent Person from the Glossary of Terms is used by the most documents. NFPA 56 is the primary source document for this definition so an extract to NFPA 56 should be added. Related Item First Revision No. 47-NFPA [New Section after 3.3.4] Submitter Full Name: Susan Desrocher Organization: Freelance Editor Affilliation: Member of the Glossary of Terms Technical Advisory Committee Submittal Date: Thu Nov 07 10:03:19 EST 2013

22 Public Comment No. 10-NFPA [ Section No ] Limited Combustible. A building construction material not complying with the definition of noncombustible material that, in the form in which it is used, has a potential heat value not exceeding 8140 kj/kg ( 3500 Btu/lb), where tested in accordance with NFPA 259, Standard Test Method for Potential Heat of Building Materials, and complies with (a) or (b): (a) materials having a structural base of noncombustible material, with a surfacing not exceeding a thickness of 3 mm ( 1 8 in. ) that has a flame spread index not greater than 50; and (b) materials, in the form and thickness used, other than as described in (a), having neither a flame spread index greater than 25 nor evidence of continued progressive combustion and of such composition that surfaces that would be exposed by cutting through the material on any plane would have neither a flame spread index greater than 25 nor evidence of continued progressive combustion. (Materials subject to increase in combustibility or flame spread index beyond the limits herein established through the effects of age, moisture, or other atmospheric condition shall be considered combustible.. (See ) This makes NFPA 33 consistent with other NFPA documents (including NFPA 101 and 5000) in placing the requirements for noncombustible material and limited combustible material in the body of the document. The language is extracted from NFPA The proposed new sections are included in separate comments. This comment is made on behalf of the NFPA Glossary Committee on Terminology. Submitter Full Name: Marcelo Hirschler Organization: GBH International Affilliation: NFPA GOT Submittal Date: Sun Nov 10 12:46:19 EST of 64 2/14/2014 1:10 PM

23 3 of 64 2/14/2014 1:10 PM Public Comment No. 11-NFPA [ Section No ] Noncombustible Material. A material that, in the form in which it is used and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat. Materials that are reported as passing ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 C, are considered noncombustible materials. [ 220, 2012] (see 5.1.2) This makes NFPA 33 consistent with other NFPA documents (including NFPA 101 and 5000) in placing the requirements for noncombustible material and limited combustible material in the body of the document. The new section 5.1 is being proposed in an alternate comment. This comment is made on behalf of the NFPA Glossary Committee on Terminology. Related Public Comments for This Document Related Comment Public Comment No. 10-NFPA [Section No ] Relationship Submitter Full Name: Marcelo Hirschler Organization: GBH International Affilliation: NFPA GOT Submittal Date: Sun Nov 10 12:51:41 EST 2013

24 4 of 64 2/14/2014 1:10 PM Public Comment No. 7-NFPA [ New Section after ] Replace the new definition of Ventilation with a generic one from the glossary of terms Ventilation. The changing of air within a compartment by natural or mechanical means. As a representative of the GOT Committee, I can report that the GOT committee is against this change as it is written. The GOT Committee's work has been to create general and consistent definitions of the same term throughout the NFPA system of documents. The definition of Ventilation as used in NFPA 33 (before and after its ROP revision) is unique. The glossary of terms presently has too many definitions of Ventilation. In keeping with the goals of the GOT Committee as dictated by the Standards Council, the definition as proposed by this commenter is the most generic definition in the glossary, which is used by 4 documents (1925, 302, 402, 69). The specifics of the definition as proposed by NFPA 33 could be put in the annex material in order to use the generic definition. Related Item First Revision No. 59-NFPA [Section No ] Submitter Full Name: Susan Desrocher Organization: Freelance Editor Affilliation: Member of the Glossary of Terms Technical Advisory Committee Submittal Date: Thu Nov 07 10:09:08 EST 2013

25 5 of 64 2/14/2014 1:10 PM Public Comment No. 23-NFPA [ Section No ] Ventilation. The natural or powered movement of conditioned or unconditioned air that is sufficient to prevent the accumulation of vapor to air concentrations greater than 25 percent of the lower flammable limit to or from any space. The first revision change does not fit well with how "Ventilation" is used throughout the document. There are many instances where ventilation is preceded with "mechanical", "positive pressure", and "positive mechanical". The requirement for 25% of the LFL is removed from the definition and allows the term to be used for both ventilation of flammable vapor areas and combustible dust areas. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Wed Nov 13 20:53:09 EST 2013

26 Public Comment No. 8-NFPA [ Section No ] Vessel. Any watercraft or Every description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water, including special-purpose floating structures not primarily designed for or used as a means of transportation on water. [306: 2014] As a representative of the GOT Committee, I can report that the GOT committee is against this change as it is written. The GOT Committee's work has been to create general and consistent definitions of the same term throughout the NFPA system of documents. Adding this definition creates another unique definition in the glossary of terms. There is already a definition of Vessel used by NFPA 306; this definition should extract from 306. Related Item First Revision No. 48-NFPA [New Section after ] Submitter Full Name: Susan Desrocher Organization: Freelance Editor Affilliation: Member of the Glossary of Terms Technical Advisory Committee Submittal Date: Thu Nov 07 10:16:04 EST of 64 2/14/2014 1:10 PM

27 7 of 64 2/14/2014 1:10 PM Public Comment No. 14-NFPA [ Section No ] Limited Finishing Workstation. An apparatus that is capable of confining the vapors, mists, residues, dusts, or deposits that are generated by a spray application process and that meets the requirements of Section 14.3, but does not meet the requirements of a spray booth or spray room, as herein defined. A Limited finishing workstations meet the requirements of Section 14.3 of this standard. Definitions are not supposed to contain requirements. This public comment is submitted on behalf of the Glossary Committee on Terminology. Submitter Full Name: Marcelo Hirschler Organization: GBH International Affilliation: NFPA GOT Submittal Date: Sun Nov 10 13:18:41 EST 2013

28 Public Comment No. 24-NFPA [ Section No. 4.3 ] 4.3 * Locations Below Grade Basements. Spray booths, rooms, and areas shall not be located below the surrounding grade level in cases where flammable vapors are heavier (denser) than air Spray application operations conducted from pits to paint the underside of a workpiece shall be permitted in a basement unless all the following requirements are met: (1) A means of egress is provided that meets the requirements of Chapter (2) An access means is provided for emergency response personnel. The use of the term "Basement" better captures the location where it may be more hazardous to perform spray application processes. From NFPA 101, Basement: Any story of a building wholly or partly below grade plane that is not considered the first story above grade plane. The ventilation requirements of Chapter 7.2 address the hazards of vapors that may be heavier than air within a spray area. The new language addresses the egress and accessibility concerns. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Wed Nov 13 21:13:15 EST of 64 2/14/2014 1:10 PM

29 9 of 64 2/14/2014 1:10 PM Public Comment No. 12-NFPA [ Chapter 5 ] Chapter 5 Construction and Design of Spray Areas, Spray Rooms, and Spray Booths 5.1 Terminology * Noncombustible Material [NFPA 5000; 2015] A material that complies with any one of the following shall be considered a noncombustible material: (1)*The material, in the form in which it is used, and under the conditions anticipated, will not ignite, burn, support combustion, or release flammable vapors when subjected to fire or heat (2) The material is reported as passing ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 Degrees C (3) The material is reported as complying with the pass/fail criteria of ASTM E 136 when tested in accordance with the test method and procedure in ASTM E 2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shaped Airflow Stabilizer, at 750 Degrees C Where the term limited-combustible is used in this Code, it shall also include the term noncombustible * Limited-Combustible Material. A material shall be considered a limited-combustible material where both of the following conditions of 5.1.2(1), and 5.1.2(2), and the conditions of either or are met [NFPA 5000; 2015]: (1) The material does not comply with the requirements for a noncombustible material in accordance with (2) The material, in the form in which it is used, exhibits a potential heat value not exceeding 3500 Btu/lb (8141 kj/kg), when tested in accordance with NFPA 259, Standard Test Method for Potential Heat of Building Materials The material shall have a structural base of noncombustible material with a surfacing not exceeding a thickness of 1 8 in. (3.2 mm) where the surfacing exhibits a flame spread index not greater than 50 when tested in accordance with ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials The material shall be composed of materials that in the form and thickness used, neither exhibit a flame spread index greater than 25 nor evidence of continued progressive combustion when tested in accordance with ASTM E 84 or ANSI/UL 723 and are of such composition that all surfaces that would be exposed by cutting through the material on any plane would neither exhibit a flame spread index greater than 25 nor exhibit evidence of continued progressive combustion when tested in accordance with ASTM E 84 or ANSI/UL Where the term limited-combustible is used in this Practice, it shall also include the term noncombustible. A The provisions of do not require inherently noncombustible materials to be tested in order to be classified as noncombustible materials. [NFPA 5000; 2015] A (1) Examples of such materials include steel, concrete, masonry and glass. [NFPA 5000; 2015] A Material subject to increase in combustibility or flame spread index beyond the limits herein established through the effects of age, moisture, or other atmospheric condition is considered combustible. (See NFPA 259, Standard Test Method for Potential Heat of Building Materials, and NFPA 220, Standard on Types of Building Construction.) [NFPA 5000; 2015] 5.2 * Walls and Ceilings. Walls, doors, and ceilings that intersect or enclose a spray area shall be constructed of noncombustible or limited-combustible materials or assemblies and shall be securely and rigidly mounted or fastened. The interior surfaces of the spray area shall be smooth, designed and installed to prevent pockets that can trap residues, and designed to facilitate ventilation and cleaning.

30 Air intake filters that are a part of a wall or ceiling assembly shall be listed as Class 1 or Class 2, in accordance with ANSI/UL 900, Standard for Air Filter Units The floor of the spray area shall be constructed of noncombustible material, limited-combustible material, or combustible material that is completely covered by noncombustible material Aluminum shall not be used for structural support members or the walls or ceiling of a spray booth or spray room enclosure. Aluminum also shall not be used for ventilation ductwork associated with a spray booth or spray room. Aluminum shall be permitted to be used for interior components, such as platforms, spray apparatus components, and other ancillary devices If walls or ceiling assemblies are constructed of sheet metal, single-skin assemblies shall be no thinner than 1.2 mm ( in.), and each sheet of double-skin assemblies shall be no thinner than 0.9 mm ( in.) Structural sections of spray booths shall be permitted to be sealed with a caulk or sealant to minimize air leakage Spray rooms shall be constructed of and separated from surrounding areas of the building by construction assemblies that have a fire resistance rating of 1 hour * Enclosed spray booths and spray rooms shall be provided with means of egress that meet the requirements of NFPA 101, Life Safety Code Spray booths that are used exclusively for powder coating shall meet the requirements of Chapter 15. They shall be permitted to be constructed of fire-retardant combustible materials where approved by the authority having jurisdiction Listed spray booth assemblies that are constructed of other materials shall be permitted Spray application operations and processes that involve the use of finishing materials containing nitrocellulose shall be confined to water-wash spray booths as defined in this standard unless otherwise specified in Spray application of finishing materials containing nitrocellulose shall be permitted in a dry-type spray booth provided that residue is removed from all baffle plates at least daily and all filters are changed at least daily Conveyor Openings. Conveyor openings that are necessary for transporting or moving work into and out of the spray area shall be as small as practical * Separation from Other Operations. Spray booths shall be separated from other operations by a minimum distance of 915 mm (3 ft) or by a partition, wall, or floor/ceiling assembly having a minimum fire resistance rating of 1 hour. Multiple connected spray booths shall not be considered as other operations except as provided for in Section Spray booths shall be installed so that all parts of the booth are readily accessible for cleaning A clear space of not less than 915 mm (3 ft) shall be maintained on all sides and above the spray booth. This clear space shall be kept free of any storage or combustible construction This requirement shall not prohibit locating a spray booth closer than 915 mm (3 ft) to or directly against an interior partition, wall, or floor/ceiling assembly that has a fire resistance rating of not less than 1 hour, provided the spray booth can be maintained and cleaned. 0 of 64 2/14/2014 1:10 PM

31 This requirement shall not prohibit locating a spray booth closer than 915 mm (3 ft) to an exterior wall or a roof assembly, provided the wall or roof is constructed of noncombustible material and provided the spray booth can be maintained and cleaned Illumination and Observation Panels Panels for luminaires or observation shall be of heat-treated glass, laminated glass, wired glass, or hammered-wired glass and shall be sealed to confine vapors, mists, residues, dusts, and deposits to the spray area Listed spray booth assemblies that have observation panels constructed of other materials shall be permitted Panels for luminaires shall be separated from the fixture to prevent the surface temperature of the panel from exceeding 93 C (200 F) The panel frame and method of attachment shall be designed to not fail under fire exposure before the observation panel fails Observation panels for spray booths that are used exclusively for powder coating processes shall be permitted to be constructed of fire-resistant combustible materials Ventilation. Spray areas that are equipped with ventilation distribution or baffle plates or with dry overspray collection filters shall meet the requirements of through Distribution plates or baffles shall be constructed of noncombustible materials and shall be readily removable or accessible for cleaning on both sides Filters shall not be used when applying materials known to be highly susceptible to spontaneous heating or spontaneous ignition Supports and holders for filters shall be constructed of noncombustible materials Overspray collection filters shall be readily removable or accessible for cleaning or replacement Filters shall not be alternately used for different types of coating materials if the combination of the materials might result in spontaneous heating or ignition. (See also Section 10.9.) Also add: ASTM E 136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 Degrees C (2012) and ASTM E 2652, Standard Test Method for Behavior of Materials in a Tube Furnace with a Cone-shaped Airflow Stabilizer, at 750 Degrees C (2012), ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials and NFPA 259, into section 2 on referenced standards. Also add: NFPA 220 and NFPA 259 into the annex on referenced standards. Also add NFPA 5000 into the section on standards used for extracts. This is the companion public comment to the comments on the definitions of limited combustible and non combustible. This makes NFPA 33 consistent with other NFPA documents (including NFPA 101 and 5000) in placing the requirements for noncombustible material and limited combustible material in the body of the document. This comment is made on behalf of the NFPA Glossary Committee on Terminology. Related Public Comments for This Document 1 of 64 2/14/2014 1:10 PM

32 2 of 64 2/14/2014 1:10 PM Related Comment Public Comment No. 10-NFPA [Section No ] Public Comment No. 11-NFPA [Section No ] Public Comment No. 13-NFPA [Sections A.5.1, A.5.1.7, A.5.3] Relationship Submitter Full Name: Marcelo Hirschler Organization: GBH International Affilliation: NFPA GOT Submittal Date: Sun Nov 10 12:53:59 EST 2013

33 3 of 64 2/14/2014 1:10 PM Public Comment No. 17-NFPA [ Section No ] * Enclosed spray booths and spray rooms shall be provided with means of egress that meet the applicable requirements of Chapter 40 of NFPA 101, Life Safety Code. The occupancy classification of paint spray booths or rooms that meet the requirements of NFPA 33 should be General Industrial and the hazard of contents considered Ordinary. Means of egress should meet the applicable sections of NFPA 101 Chapter 40. Chapter 40 is the starting point within NFPA 101 and then directs users to other relevant Chapters. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Wed Nov 13 09:46:56 EST 2013

34 4 of 64 2/14/2014 1:10 PM Public Comment No. 1-NFPA [ New Section after ] The interior surfaces, including walls, ceiling and floors, shall be permitted to have combustible coverings per and Provide reference to maintenance section regarding interior surfaces. Submitter Full Name: Kelly Nicolello Organization: Western Regional Fire Code Dev Submittal Date: Tue Sep 24 19:29:19 EDT 2013

35 5 of 64 2/14/2014 1:10 PM Public Comment No. 3-NFPA [ Section No ] * Open flames, spark-producing equipment or processes, and equipment whose exposed surfaces exceed the autoignition temperature of the material being sprayed shall not be located in a spray area or in any surrounding area that is classified as Division 2, Zone 2, or Zone 22. Exception: This This requirement shall not apply to drying, curing, or fusing apparatus covered by Chapter 13. Exception to moved to section to conform to the NFPA Manual of Style. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 14:51:56 EDT 2013

36 6 of 64 2/14/2014 1:10 PM Public Comment No. 26-NFPA [ Section No ] Mixing rooms shall meet all of the following requirements: (1) The mixing room Mixing rooms shall meet the construction requirements of Section 5.1. (2) The aggregate area of the one or more mixing room rooms shall not exceed 14 m 2 (150 ft 2 ) in a single control area. (3) The mixing room Mixing rooms shall be designed to contain a spill of the contents in the room. (4) The mixing room used for mixing and dispensing operations Mixing rooms shall be provided with continuous mechanical ventilation capable of providing air movement of not less than 0.3 m 3 /min per square meter of floor area (1 ft 3 /min/ft 2 ) or 4 m 3 /min (150 ft 3 /min), whichever is greater. The ventilation system shall be in operation at all times. (5) The mixing Mixing room air make-up systems system and exhaust system shall remain functioning during any fire alarm condition in accordance with Section 9.3. (6) Dispensing and mixing Mixing rooms shall be classified, for purposes of electrical area classification, the same as enclosed spray booths, in accordance with (7) The mixing room Mixing rooms shall be provided with an approved automatic fire protection system that meets all applicable requirements of Chapter 9. (8) The mixing room Mixing rooms shall be provided with portable fire extinguishers located in accordance with NFPA 10, Standard for Portable Fire Extinguishers. The revised language addresses the practice of installing multiple mixing rooms to increase the storage capacity within a single control area beyond the limits implied by a single mix room and spray booth and to avoid having to comply with NFPA 30 construction for mix rooms over 150 sq ft. Additional changes clean up the wording for consistency. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Wed Nov 13 21:55:02 EST 2013

37 7 of 64 2/14/2014 1:10 PM Public Comment No. 60-NFPA [ Section No ] The automatic fire protection system shall be permitted to be, and shall be installed in accordance with, any of the following: (1) An automatic water sprinkler system that meets all applicable requirements of NFPA 13, Standard for the Installation of Sprinkler Systems (2) An automatic foam water sprinkler system that meets all applicable requirements of NFPA 16, Standard for the Installation of Foam-Water Sprinkler and Foam-Water Spray Systems (3) A carbon dioxide extinguishing system that meets all applicable requirements of NFPA 12, Standard on Carbon Dioxide Extinguishing Systems (4) A dry chemical extinguishing system that meets all applicable requirements of NFPA 17, Standard for Dry Chemical Extinguishing Systems (5) A gaseous agent extinguishing system that meets all applicable requirements of NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems (6) A water mist or hybrid water mist fire protection system that meets the applicable requirements of NFPA 750, Standard on Water Mist Fire Protection Systems New testing and Listings on water mist and hybrid water mist systems are continually taking place. These systems are perfectly acceptable for many applications including small mix rooms, large automotive refinish booths, dipping and coating operations. Either new Listings could be obtained or existing Listings for machine space applications can be utilized if acceptable to the AHJ. Water mist and hybrid systems are not only acceptable for many of these applications, they may be preferred due to the large clean-up operations that would be associated with some other types of extinguishing systems. By not including water mist and hybrid water mist extinguishing systems in the list of acceptable systems it may discourage their use by the assumption they are not allowed or are unsuitable. Including water mist and hybrid systems in the list can also encourage further testing and Listings by manufacturers. Submitter Full Name: Peter Thomas Organization: Victaulic Company Submittal Date: Fri Nov 15 11:39:19 EST 2013

38 Public Comment No. 27-NFPA [ Section No. 9.2 ] 9.2 Continuous Automated Spray Application Operations For continuous automated spray application operations, activation of the automatic fire protection system shall automatically accomplish all of the following: (1) Activate a local alarm in the vicinity of the spraying operation (2) Transmit an alarm signal to the facility's fire alarm system, if such a system is provided (3) Shut down the coating material delivery system (4) Shut down all spray application operations (5) Stop any conveyors into and out of the spray area For continuous automated spray application operations, the additional requirements of Section 9.7, for automated powder application equipment, or Section 9.8, for automated liquid electrostatic spray application equipment, whichever is applicable, shall also apply Emergency Shutdown. For continuous automated spray application operations, one or more manual emergency system shutdown stations shall be installed to serve each spray area. When activated, the stations shall accomplish at least the functions listed in (1) and (3) through (5). At least one such station shall be within ready access of operating personnel. If access to this station is likely to involve exposure to danger, an additional station shall be located adjacent to an exit from the area. Continuous has been replaced with automated to address the confusion over the term "continuous". Automated implies unattended, such as reciprocator and robot application equipment, and is consistent with the language used for electrostatic and powder sections. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Wed Nov 13 22:05:27 EST of 64 2/14/2014 1:10 PM

39 9 of 64 2/14/2014 1:10 PM Public Comment No. 61-NFPA [ Section No ] Automated liquid electrostatic spray application equipment that is unlisted shall be protected further by the following: (1) In addition to meeting the requirements in 9.8.1, the optical flame detection system shall also activate one of the following over each zone in which fire has been detected: (a) An open head deluge system designed to discharge a minimum density of 24.4 mm/min (0.6 gpm/ft 2 ) (b) A carbon dioxide extinguishing system (c) A dry chemical extinguishing system (d) A gaseous agent extinguishing system (e) A water mist or hybrid water mist fire protection system (2) Manual activation stations shall be installed. At least one such station shall be within ready access of operating personnel. If access to this station is likely to involve exposure to danger, an additional station shall be located adjacent to an exit from the area. These devices shall activate the fire protection system as specified in 9.8.2(1) and accomplish the requirements of and (2). (3) A wet pipe sprinkler system shall also be provided throughout the spray booth. This system shall meet all the applicable requirements of NFPA 13, Standard for the Installation of Sprinkler Systems for Extra Hazard (Group 2) occupancies. (4) Automatic electrostatic equipment enclosures inside the booth systems shall be protected with an approved automatic fire protection system. Activation of this system shall automatically accomplish the requirements of and (2). The same substantiation as my Public Comment No. 60. New testing and Listings on water mist and hybrid water mist systems are continually evolving. These systems are perfectly acceptable for many applications and may actually be preferred because of clean up operations that result in the operation of some other system types. By not including water mist and hybrid water mist extinguishing systems in this list of acceptable systems may discourage their use by the assumption they are not allowed or are unsuitable. Including water mist and hybrid water mist systems in the list can encourage further testing and Listing by manufacturers. Submitter Full Name: Peter Thomas Organization: Victaulic Company Submittal Date: Fri Nov 15 12:18:48 EST 2013

40 0 of 64 2/14/2014 1:10 PM Public Comment No. 21-NFPA [ Chapter 18 [Title Only] ] Spray Application Operations in Membrane Enclosures Revise Chapter 18 to address only Paint Spraying Using Marina Membrane Enclosures changing workpiece to vessel after all comments are addressed for this chapter. The Committee improperly opened the door to any type of temporary membrane enclosure without fully understanding what would be placed in the membrane enclosure, what portable enclosures exist that do and no established safety performance record for membrane enclosures in a non-marine environment. Temporary membrane enclosures for spray painting of marine vessels has been an established practice for well over a decade inside the United States and internationally without a single instance where a fire occurred inside of a membrane enclosure during spray painting or any other operation. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Affilliation: None Submittal Date: Wed Nov 13 17:39:21 EST 2013

41 1 of 64 2/14/2014 1:10 PM Public Comment No. 44-NFPA [ Section No ] Spray application operations and processes within the enclosure shall only be permitted for the workpiece for which the enclosure was erected. Spray application operations for parts removed from the workpiece shall be conducted in accordance with the other provisions of applicable NFPA 33 provisions. The proposed changes better express the intent of the scope statement with regard to the temporary nature of these enclosures and the reasoning that the Chapter 18 provisions are applied as being equal to existing permanent booths covered in NFPA 33. Related Public Comments for This Document Related Comment Public Comment No. 43-NFPA [Section No. A ] Relationship Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:24:34 EST 2013

42 2 of 64 2/14/2014 1:10 PM Public Comment No. 31-NFPA [ New Section after ] Inner Membrane Material Where there is an interior disposal membrane, the membrane must meet the requirements of NFPA 701 test method 2. The inner membrane is to be changed after every spray operation which could include multiple coats for a single workpiece. Inner membrane is to be attached to the interior metal structure in order to create a smooth and continuous surface. This inner lining serves the purpose of capturing overspray by creating a smooth and continuous wall on the inside of the enclosure. This in turn eliminates buildup of overspray on the metal structure and exterior membrane. Submitter Full Name: RYAN WATT Organization: DUROAIR TECHNOLOGIES INC Submittal Date: Thu Nov 14 19:14:49 EST 2013

43 3 of 64 2/14/2014 1:10 PM Public Comment No. 30-NFPA [ Section No ] Membrane material Any contaminated membrane material or membrane material with overspray build up shall not be reused for any other spray application operations. It is believed that a disposable inner membrane lining rated to NFPA 701 is a safer approach. This will provide a smooth and continuous inner surface which will protect the metal structure and exterior membrane from overspray build up and potential fire hazard. Submitter Full Name: RYAN WATT Organization: DUROAIR TECHNOLOGIES INC Submittal Date: Thu Nov 14 19:08:48 EST 2013

44 4 of 64 2/14/2014 1:10 PM Public Comment No. 45-NFPA [ Section No ] * Operations conducted within the enclosure other than spray applications shall meet the fire and safety requirements for those operations and are not addressed in this standard. These operations shall not take place while the spray application operation is in progress Hot work shall be in compliance with Chapter 10. Because of the size of marine vessels that began this new chapter is such that they cannot be moved, sanding and repairing of the vessel with the attendant advantage of controlling environmental conditions on the site is often performed while the enclosure is erected and not as a part of or during spray painting on the vessel. The clarifications in are intended to more clearly state NFPA 33 does not apply and the annex now better emphasizes the changes. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:27:21 EST 2013

45 5 of 64 2/14/2014 1:10 PM Public Comment No. 42-NFPA [ New Section after 18.3 ] Incorporate the language into the new Chapter 18 for Membrane Enclosures. Spray painting in the marine industry in temporary enclosures has been performed indoors and outdoors for decades without a single fire event. The requirements for sprinkler protection as required for the storage of boats as a part of the use of membrane enclosures will provide a level of safety that exceeds the NFPA 33 requirements for dry chemical suppression systems alone. The material used for membrane enclosures in the marine environment in and of itself will not hinder the movement of heat to the ceiling of buildings or the activation of fire sprinklers to extinguish any possible fires from spray painting. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:18:30 EST 2013

46 6 of 64 2/14/2014 1:10 PM Public Comment No. 47-NFPA [ New Section after 18.3 ] Outdoor temporary membrane enclosures and a 5-foot zone outside the enclosure, as stipulated in Section , shall be separated from permanent structures by a minimum of 15 feet or exposure protection shall be provided to all for separations of less than 15 feet The AHJ shall review and accept exposure protection designs and installations where membrane enclosures of less than 15 feet are desired prior to the installation of the membrane enclosure Temporary membrane enclosures shall be permitted to be installed in buildings provided all of the requirements of this chapter are complied with in design, installation, and conduct of spray paint operations within the enclosure * Buildings in which temporary membrane enclosures are installed shall have a minimum of 25% of the exterior walls open and unobstructed Buildings in which temporary membrane enclosures are installed shall be provided with Automatic Sprinkler Systems in accordance with Section The automatic sprinkler system shall be designed for Extra Hazard (Group 2) occupancies, as defined in NFPA 13, Standard for the installation of Sprinkler Systems adds an allowance to reduce the distance from the building with the presence of exposure protection of an acceptable type that could be considered. An acceptable type might be a water spray or deluge system on the exterior of the building operating either automatically or manually. Rather than dictate NFPA 13 provisions for the unknown workpiece in this standard it is better to allow for such protection and then clarify in the new that the AHJ has to approve of such a change. Exposure protection for buildings is well accepted for other applications and should be here as well. Section 3.2 and its subsections is a proposed use of enclosures in buildings with a minimum fire sprinkler classification consistent with the storage provisions for marine vessels. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:31:14 EST 2013

47 7 of 64 2/14/2014 1:10 PM Public Comment No. 49-NFPA [ New Section after 18.3 ] Temporary membrane enclosures for spray painting boats in marina s shall be permitted to be installed in buildings provided all of the requirements of this chapter are complied with in design, installation, and conduct of spray paint operations within the enclosure Only shrink wrap material passing NFPA 701 Test 2 requirements shall be used for spray painting boats in marina buildings * Buildings in which temporary membrane enclosures are installed shall have a minimum of 25% of the exterior walls open and unobstructed Buildings in which temporary membrane enclosures are installed shall be provided with Automatic Sprinkler Systems in accordance with Section The automatic sprinkler system shall be designed for Extra Hazard (Group 2) occupancies, as defined in NFPA 13, Standard for the installation of Sprinkler Systems. A valid concern raised in the discussions of the testing of membrane materials was what about other materials besides shrink wrap material? Section 18.6 says you can use any material that passes the NFPA 701, Test 2 requirements. The simple answer is we don t know how those materials will react in a fire or with fire sprinklers. THEREFORE I am rewording the proposed text for marina use only for consideration. Marinas around the world have been spray painting in these membrane enclosures for well over a decade without a single fire while spray painting in and out of buildings. This standard chapter will add more checks and balances to a painting system that could readily be labeled as being inherently safe and made safer by the publication of this standard. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:36:11 EST 2013

48 8 of 64 2/14/2014 1:10 PM Public Comment No. 62-NFPA [ New Section after 18.3 ] Temporary membrane enclosures for spray painting boats in marina s shall be permitted to be installed in buildings provided all of the requirements of this chapter are complied with in design, installation, and conduct of spray paint operations within the enclosure * The membrane material shall be listed for installation beneath sprinklers and in installed to meet the requirements of Section of NFPA 13. A There are membrane materials that have been investigated as a ceiling material in accordance with UL Subject 723S, Outline of Investigation for Drop-Out Ceilings Installed Beneath Automatic Sprinklers or as FM Class Number 4651, Plastic Suspended Ceiling Panels. Such membrane materials are designed such that the activation of the sprinkler and the ability of the sprinkler discharge to reach the hazard being protected are not adversely impacted * Buildings in which temporary membrane enclosures are installed shall have a minimum of 25% of the exterior walls open and unobstructed. A The openness requirement serves two purposes. First it helps to insure that any flammable vapors released as a part of spray painting are readily diluted while reducing the possibility of concentrations of flammable vapors in the building. Second, the openness requirement gives better access to responding firefighters in the event of a fire emergency Buildings in which temporary membrane enclosures are installed shall be provided with Automatic Sprinkler Systems in accordance with Section The automatic sprinkler system shall be designed for Extra Hazard (Group 2) occupancies, as defined in NFPA 13, Standard for the installation of Sprinkler Systems. With the exception of and A , the language is consistent with CI No. 14. The reference to NFPA 701 is not required since one of the requirements of complying with UL 723 is to be tested in accordance with UL 723, which is generally considered equivalent to ASTM E84. The actual permitted flame spread index and smoke developed index would be as permitted by the applicable building code, NFPA 101, or fire code. At least one membrane product has been evaluated by UL using UL Subject 723S and is currently listed as being suitable for being installed beneath sprinklers. The listed membrane product contains seams that will fail during a fire and as such, does not impact the ability of the water to reach the hazard being protected. The reference to Section of NFPA 13 brings in the following requirements: Drop-Out Ceilings Drop-out ceilings shall be permitted to be installed beneath sprinklers where ceilings are listed for that service and are installed in accordance with their listing Drop-out ceilings shall not be installed below quick-response or extended coverage sprinklers unless specifically listed for that application Drop-out ceilings shall not be considered ceilings within the context of this standard * Piping installed above drop-out ceilings shall not be considered concealed piping * Sprinklers shall not be installed beneath drop-out ceilings. The drop-out ceiling panels referenced by Section of NFPA 13 are evaluated by the same UL or FM documents as contained in the proposed A A Committee Input to revise Section to specifically reference ceiling materials such as the membrane materials permitted by this Public Comment was developed by the Technical Committee on Sprinkler System Discharge Criteria. It is anticipated that the Committee Input will be further evaluated during the Public Comment period based upon the Public Comments received.

49 9 of 64 2/14/2014 1:10 PM Submitter Full Name: William Koffel Organization: Koffel Associates, Inc. Affilliation: Lauderdale Marine Center Submittal Date: Fri Nov 15 12:49:20 EST 2013

50 0 of 64 2/14/2014 1:10 PM Public Comment No. 51-NFPA [ Section No ] If a marine vessel or other workpiece is being sprayed within the membrane enclosure and has living quarters and other habitable areas, they shall not be occupied during spray operations. Some workpieces will not have living quarters but this clarification makes certain a mechanic is not working on an engine in a locomotive while spray painting is going on in the enclosure. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:42:55 EST 2013

51 1 of 64 2/14/2014 1:10 PM Public Comment No. 38-NFPA [ Section No [Excluding any Sub-Sections] ] The spray paint area shall consist of the interior of the temporary membrane enclosure and a 1.5 m (5 ft) zone outside of the enclosure. Clarifies what is the spray area. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Thu Nov 14 22:33:29 EST 2013

52 2 of 64 2/14/2014 1:10 PM Public Comment No. 52-NFPA [ Section No ] Membrane enclosures shall be permitted to be used for activities other than spray painting. Other uses of the membrane enclosure shall comply with applicable codes or standards. This is a repeat of Both are not needed. If this is the better location then in the alternative delete Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:43:51 EST 2013

53 3 of 64 2/14/2014 1:10 PM Public Comment No. 53-NFPA [ Section No ] Hot work adjacent to designated spray painting operations in membrane enclosures shall be performed only when authorized by the competent person to minimize the possibility of ignition of adjacent Competent Person designated for spray painting operations. The original language is confusing and in conflict with alternative wording is offered here. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:44:40 EST 2013

54 4 of 64 2/14/2014 1:10 PM Public Comment No. 54-NFPA [ Section No ] Membrane enclosures without active spray painting tasks shall have power cords and lighting rated for outdoor use. Ordinary portable electrical tools and equipment can be used in these areas when spray painting is not being performed. This better clarifies further and its annex note with specific intent to the use of power tools. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:45:28 EST 2013

55 Public Comment No. 55-NFPA [ Section No ] Electrical wiring and utilization equipment used in membrane enclosures during spray painting shall comply with Chapter 6 except as amended below The spray area shall consist of the area within the temporary membrane enclosure, and shall be considered a Class I, Division 1 area. A 1.5 m (5 ft) zone outside of the temporary membrane enclosure shall be considered Class I, Division 2. See Figure Figure Electrical Classifications for Outdoor Membrane Enclosures. Utilization and used are the near synonyms. Submitter Full Name: Gregory Cahanin Organization: Cahanin Fire & Code Consulting Submittal Date: Fri Nov 15 09:46:20 EST of 64 2/14/2014 1:10 PM

56 6 of 64 2/14/2014 1:10 PM Public Comment No. 37-NFPA [ Section No ] The spray area shall consist of the area within the temporary membrane enclosure, and shall be considered a Class I, Division 1 area. A 1.5 m (5 ft) zone outside of the temporary membrane enclosure shall be considered Class I, Division 2. See Figure Figure Electrical Classifications for Outdoor Membrane Enclosures. The artwork in this section implies that this chapter is only for the marine industry. It is recommended that generic artwork similar to the artwork in Chapter 6 is used. Submitter Full Name: RYAN WATT Organization: DUROAIR TECHNOLOGIES INC Submittal Date: Thu Nov 14 20:05:14 EST 2013

57 7 of 64 2/14/2014 1:10 PM Public Comment No. 40-NFPA [ Section No ] The spray area shall consist of the area within the temporary membrane enclosure, and shall and a 1.5 m (5 ft) zone outside the enclosure. This area shall be considered a Class I, Division 1 area. A 1 The area 1.5 m (5 ft) zone outside to 3 m (10 ft) outside of the temporary membrane enclosure shall be considered Class I, Division 2. See Figure Figure Electrical Classifications for Outdoor Membrane Enclosures. This change is consistent with the language in regarding what is a spray area. Spray areas are Class I, Division 1 areas. Either update the figure to match the language or remove the figure. Submitter Full Name: Geoffrey Raifsnider Organization: Global Finishing Solutions Submittal Date: Thu Nov 14 22:39:53 EST 2013