Continental breakfast will be provided each morning at 7:30 am. Lunch provided on Day One.

Transcription

1 TECHNICAL COMMITTEE ON FINISHING PROCESSES Pre-First Draft (F2017) Meeting Agenda March 24-25, am-5 pm EDT Hilton Carillon Park Saint Petersburg, Florida Continental breakfast will be provided each morning at 7:30 am. Lunch provided on Day One. 1. Call to Order-Committee Chair, Tom Euson. 2. Introduction of Attendees and Update of Committee Roster. (Attachment 1) 3. Approval of Minutes of Last Meeting. (Attachment 2) 4. Report of Staff Liaison-Status of NFPA edition. 5. Task Group Reports. a) Sprinkler Systems for Duct and Stack Protection-Tom George. b) Clarification of Terms Continuous Spraying and Spray Booth/Room-Geoff Raifsnider c) Chapter 8 Task Group-TBA d) Recirculation/Filtration Task Group-Geoff Raifsnider e) Chapter 18 Task Group-John McKnight 6. Other Possible Issues to be Addressed During Next Revision. (Attachments 3) a. Review of FIs and Ballot Comments b. Other Recirculation Issues c. Reference language to Figures 6.4 (c) and (d) d. Review of 9.5 in NFPA 33 and 9.9 in NFPA 34 e. Removal of additional exceptions-chapter 6 f. Clarification of how applies to robot sleeves g. Clarification of application to open containers h. Redo of in NFPA 34 for consistency i. Protection requirements for No Spray areas in the booth j. Diagrams in 33 Chapter 6 k. Change MEC C.2.1 to 30 g/m3 l. Air exhaust from mixing rooms m (1) application n. Smoke detection o. Discussion on listed Electrostatic applicators p. Questions from Jeff Bennett q. Discussion about powder fire frequency

2 7. New Business. a) Submitting input on Membrane Enclosures for Airplane Hangars NFPA 409 b) Data initiative NFPA 8. Formation of Additional Task Groups. 9 Schedule First Draft Meeting. 10. Adjournment.

3 Address List No Phone Finishing Processes 02/19/2015 Nancy Pearce Thomas G. Euson Chair 3S Incorporated 8686 Southwest Parkway Harrison, IN : Matthew M. Euson IM 1/1/1988 Geoffrey A. Raifsnider Secretary Global Finishing Solutions Norway Road Osseo, WI M 8/5/2009 Shane A. Adams Rancho Cucamonga Fire Protection District Civic Center Drive Rancho Cucamonga, CA E 08/09/2012 William C. Anderson Approved Fire Protection Company, Inc North Burdick Street Kalamazoo, MI National Association of Fire Equipment Distributors IM 7/20/2000 Donald W. Ankele UL LLC 333 Pfingsten Road Northbrook, IL : Michael A. Slowinske RT 1/14/2005 John D. Bloomgren Infinity Precision Systems, LLC 7850 Park Drive Chanhassen, MN : Mark W. Roeber M 4/1/1993 Mark A. Bowman XL Global Asset Protection Services Chevington Drive Pickerington, OH : Jeffrey A. Spiesz I 10/28/2008 Amy Brown FM Global 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA : John A. LeBlanc I 8/5/2009 Dean Doherty General Motors Company Mount Road, Mailcode PO Box 9040 Warren, MI NFPA Industrial Fire Protection Section : James M. Sute U 1/16/2003 Luc Durand Saskatoon Fire Department Prevention and Investigation Division 125 Idylwyld Drive South Saskatoon, SK S7M 1L4 Canada E 10/23/2013 Robert J. Feldkamp Nordson Corporation 300 Nordson Drive Amherst, OH : Edward L. Jones M 7/24/1997 Paul B. Gentry Zurich Services Corporation Risk Engineering 1047 Waldron Road La Vergne, TN : James W. Taylor I 10/4/2001 1

4 Address List No Phone Finishing Processes 02/19/2015 Nancy Pearce Thomas B. George Tokio Marine Management, Inc. 800 East Colorado Boulevard Pasadena, CA : Mark C. Rascio I 1/15/2004 John Gokey Tyco Fire Protection Products One Stanton Street Marinette, WI : Jeffrey A. Breighner M 7/1/1993 James S. Gustin Travelers Companies, Inc. Risk Control PO Box Charlotte, NC I 3/1/2011 Brian K. Haynack Sherwin-Williams Company 101 Prospect Ave. NW, Midland Bldg. 400 Cleveland, OH American Industrial Hygiene Association M 7/26/2007 Bryant C. Jeffrey DuPont/Axalta Coating Systems Route 141 & Henry Clay Building E308, Room 215 Wilmington, DE : Richard J. Hild M 10/23/2013 Anton Jensen, Jr. Liberty Mutual Insurance Company Bella Vista Parkway, Suite 210 Warrenville, IL : Skip Donnell I 03/03/2014 Steven D. Jensen 3M Company 915 Adams Street, SE Hutchinson, MN U 4/1/1995 Guy L. Jones, Jr. Amerex Corporation 7595 Gadsden Highway PO Box 81 Trussville, AL Fire Equipment Manufacturers' Association : William Vegso M 03/05/2012 Martin J. Korecky AkzoNobel Powder Coatings 150 Columbia Street Reading, PA : Thomas Flannery M 3/15/2007 John McKnight National Marine Manufacturers Association 650 Massachusetts Avenue, Suite 520 Washington, DC Society of the Plastics Industry, Inc. U 4/1/1996 Lowell Miles U 1/1/1986 Miles Fiberglass & Composites 8855 SE Otty Road Portland, OR American Composites Manufacturers Association Douglas A. Rivord Graco, Inc. PO Box 1441 Minneapolis, MN : Mike Thies M 01/18/2001 Don Scarbrough 550 Randall Road Elyria, OH SE 1/1/1972 2

5 Address List No Phone Finishing Processes 02/19/2015 Nancy Pearce Barry Thomas BECCA Inc Cobb International Blvd. Kennesaw, GA : John S. Jurasic M 1/1/1996 Mike Thies Voting GEMA USA, Inc West 54th Street Indianapolis, IN : Douglas A. Rivord Voting Alt. to Graco Rep. M 10/23/2013 Jeffrey A. Breighner Tyco/SimplexGrinnell 705 Digital Drive, Suite N Linthicum, MD : John Gokey M 8/5/2009 Skip Donnell Liberty Mutual Insurance Company 3350 Carly Lane Indianapolis, IN : Anton Jensen, Jr. I 03/03/2014 Matthew M. Euson 3S Incorporated 8686 Southwest Parkway Harrison, IN : Thomas G. Euson IM 10/28/2008 Thomas Flannery AkzoNobel Powder Coatings Wakefield Place Fishers, IN : Martin J. Korecky M 03/03/2014 Richard J. Hild Axalta Coating Systems 1003 Bogart Circle Bel Air, MD : Bryant C. Jeffrey M 10/23/2013 Edward L. Jones Nordson Corporation 300 Nordson Drive, M/S 42 Amherst, OH : Robert J. Feldkamp M 7/26/2007 John S. Jurasic Spray Tech Enclosures 1427 Noth Linden Avenue Rialto, CA : Barry Thomas M 1/18/2001 John A. LeBlanc FM Global 1151 Boston-Providence Turnpike PO Box 9102 Norwood, MA : Amy Brown I 8/5/2009 Mark C. Rascio Tokio Marine Management, Inc Tinkerton Court Mint Hill, NC : Thomas B. George I 08/11/2014 Mark W. Roeber Infinity Precision Systems, LLC 7850 Park Drive Chanhassen, MN : John D. Bloomgren M 08/11/2014 Michael A. Slowinske UL LLC 333 Pfingsten Road Northbrook, IL : Donald W. Ankele RT 7/22/1999 Jeffrey A. Spiesz XL Global Asset Protection Services Goulders Green Bay Village, OH : Mark A. Bowman I 07/29/2013 3

6 Address List No Phone Finishing Processes 02/19/2015 Nancy Pearce James M. Sute General Motors Company Parkwood Lane Brownstown Township, MI NFPA Industrial Fire Protection Section : Dean Doherty M 07/29/2013 James W. Taylor Zurich Services Corporation 545 Saddle Lane Cookeville, TN : Paul B. Gentry I 3/4/2009 William Vegso Buckeye Fire Equipment Company 110 Kings Road Kings Mountain, NC Fire Equipment Manufacturers' Association : Guy L. Jones, Jr. M 3/15/2007 Matthew I. Chibbaro Nonvoting Member US Department of Labor Occupational Safety & Health Administration 200 Constitution Ave. NW, Room N3609 Washington, DC : 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 : Matthew I. Chibbaro E 3/4/2009 Nancy Pearce Staff Liaison National Fire Protection Association 1 Batterymarch Park Quincy, MA /11/2012 4

7 I. ATTENDANCE TECHNICAL COMMITTEE ON FINISHING PROCESSES MINUTES OF SECOND DRAFT MEETING Drury Inn and Suites, Riverwalk San Antonio, TX March 4-6, 2014 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. (Rep Natl Assoc. of Fire Equipment)* Donald Ankele, Underwriters Laboratories Inc. John Bloomgren, Infinity Precision, Inc. Mark Bowman, XL Global Asset Protection Services Amy Brown, FM Global Luc Durand, Saskatoon Fire Department Robert Feldkamp, Nordson Corporation Paul Gentry, Zurich Services Corporation Thomas George, Tokio Marine Management, Inc. James Gustin, Travelers Insurance Company Richard Hild, DuPont/Axalta Coating Systems** Bryant Jeffrey, DuPont/Axalta Coating Systems Steven Jensen, 3M Company Guy Jones, Amerex Corporation 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 James Sute, General Motors (Rep NFPA Industrial Protection Section)** Barry Thomas, BECCA Incorporated Mike Thies, GEMA USA Inc ** Nancy Pearce, NFPA Staff Liaison * Second day conference call ** s GUESTS: Tom Flannery - Azko Nobel Mark Rascio - Tokio Marine Jason Blanco - Berg Steel Pipe Jim Pakkala - Durr Systems Jim Parks - Lauderdale Marine Ryan Watt - Duroair Systems Kelly Rankin - Duroair Systems Bill Koffel - Koffel Associates FAA Meeting Minutes.doc

8 II. MINUTES 1. The meeting was called to order by Technical Committee Chair Tom Euson at 8:00 AM on Tuesday, March 4, Attendees introduced themselves. The Technical Committee roster was corrected as necessary. 3. The Minutes of the last meeting (January 29, 2014 Conference Call/Adobe Connect Meeting) were unanimously approved as submitted. 4. Technical Committee Chair Tom Euson reviewed the meeting agenda. 5. NFPA Staff Liaison Nancy Pearce reviewed the important dates for the current revision cycle and presented on Second Draft Meeting Process. 6. The following Task Group reports were given on Day 1 of the meeting. a) Water Supply Requirements-Tom George b) Powder Coating-Marty Korecky c) Dry Scrubber/New Technologies-Tom Euson 7. John McKnight provided a report of the Membrane Enclosure Task Group on Day 2 of the meeting. Bill Koffel, representing Lauderdale Marine, presented his public comment related to membrane enclosures and the committee asked questions about the proposed changes to Chapter 18. Ryan Watt and Kelly Rankin of Duroair made suggestions and answered questions about their public inputs related to the membrane enclosures. After discussion the Committee created a Second Revision to Chapter 18 that included the use of membrane enclosures inside buildings. 8. The Committee completed review of 58 Public Comments on NFPA 33 with 73 Second Revisions. The Committee completed review of 10 Public Comments on NFPA 34 with 19 Second Revisions. Revisions were based on task group reports and recommendations as well as public inputs. 9. Proposed changes to figures in both NFPA 33 and NFPA 34 were reviewed and accepted. Nancy will work with artist to revise changes and will review changes with Geoff and Tom to confirm that artwork is correct before submitting the second revisions along with the second draft. 10. Task Groups were formed for the following items for the next revision cycle: Sprinkler systems protecting ducts and stacks (33:9.4.6). Task Group: Thomas George (Chair), Amy Brown, John LeBlanc Correlating TG with CMP14 (Article 516). Task Group: Don Ankele (Chair), Geoff Raifsnider Clarification of Continuous in Chapter 9. Task Group: Geoff Raifsnider (Chair), Bryant Jeffrey, Thomas George Chapter 8 Review. Task Group: Amy Brown (Chair), Geoff Raifsnider Recirculation. Task Group: Geoff Raifsnider (Chair), Jim Sute 11. The Chair asked Nancy to check on the next revision of NFPA 33 and 34 and indicated that he would prefer not to wait too long between meetings in order to keep the document on track for revision. The next meeting will likely be scheduled in The Technical Committee meeting adjourned at 12:00 PM on March 6, Respectfully submitted, Geoff Raifsnider Secretary, NFPA Technical Committee on Finishing Processes FAA Meeting Minutes.doc

9 Questions for Next Revision Cycle NFPA 33/34 a) Review FIs and Review Ballot comments Second Draft (see separate documents) b) Advisory Service Question-Recirculation type spray booths require most of the air returned to the booth and a small portion of air exhausted to a thermal oxidizer (or to atmosphere). In a fire alarm condition, is the exhaust volume maintained at the same rate? If the exhaust volume needs to change, where is it stated in NFPA 33? (Without anything else to go by, I d have to say that the standard requires ventilation to be maintained at whatever velocity, flow-rate and flow conditions it would have under normal operation. Perhaps the TC should discuss whether the system should go to full exhaust. That s probably what 33 SHOULD require.) See pdf Recirc. Air c) NFPA 34-Figure 6.4 (c) and (d). Definition of confined to process. No descriptive language for the diagrams in the document, only in the title. d) Work on wording in 9.5 in NFPA 33 and 9.9 in NFPA 34 to clarify? e) Remove Exceptions in Chapter 6 NFPA 33 and Chapter 5 of NFPA 34. f) Section as it applies to robot sleeves. May need to clarify in annex. g) clarify that it applies only to OPEN containers. Right now says open containers, supply containers, etc. h) Need to redo Figure in NFPA 34 to be consistent with other artwork that has been revised. i) From Tom Euson-Protection requirements for exhaust ducts from no spray areas in the booth area, such as flash-off tunnels, quiet zones, etc. What is our position if there are vapors present, but no particulates? This question is coming up more often as some booth manufacturers and end-users are redefining what we have traditionally thought of as part of the booth. For instance, the flashoff tunnel between the last spray zone and the oven was generally considered part of the booth. Now, more and more, we see the 3 bubble around the end of the spray zone classified as Class I, Division 2 with the rest of the flash-off tunnel unclassified. If this is the case, and no protection is provided in this area, should the ducts from this area be protected? j) Steve G The diagram in looks like only the number was changed to 3 feet at the open face, not the drawing itself at the upper and right sketches. The 3 foot lines at the conveyor

10 opening are clearly not the same distance are those at the face. This should be fixed as a minor editorial correction prior to publication. And in neither the the drawing nor the text, as it has been for some time apparently without major issue, is explicit about the entire booth interior being Division 1. The ceiling level plan view could be interpreted to mean that the Div 2 area extends into the booth. The language in is more explicit. I recommend this be addressed in the next edition. Geoff-On the attached figure I tried to mark up the discrepancies he mentioned. (See PDF) As far as the second comment, the figure may be confusing and we should revisit in the next cycle. However, 6.5 addresses areas "adjacent to or connected to spray areas", so technically all the figures in 6.5 should only be showing those areas adjacent or connected (not in) the spray area/booth and we could skip shading for Class I, Div 1. Chapter 6.4 covers the electrical area classification in spray areas/booths. The figures have grown to show both the requirements of 6.4 and 6.5. Bottom line, if we can clean up at this point in the process then I think we should should wait until next cycle. TOM-I agree that the diagram needs a littler work. I concur with Steve and Geoff s comments about the 3 distance not consistent on the diagram. A closer look has the 3 bubble on the 3D/isometric view offset to the left. This should be corrected also. Geoff s marked up diagram (attached) has the CID1 area shown also. The new diagram should also. On 6.5.4, I thought we shaded the interior of the booth. Does the final copy not reflect this? k) Need to change C.2.1 MEC should now be 30g/m3 not 15 g/m3 to match that in text in Chapter 15. l) Advisory Service Question. Section 7.4 specifically states that air exhausted from "liquid spray areas" shall be ducted to the outside of the building. Q1: Does air exhausted from mix rooms have to comply with 7.4? My guess is that while we do not specify in NFPA 33 that dedicated exhaust to outside is required the answer is/should be YES. NFPA 30 has the following * Exhaust ventilation discharge shall be to a safe location outside the building. (Liquid spray area was probably to distinguish from powder spray.) m) From Bob B -There is an issue with NFPA 33, 9.8.2(1) that we need to discuss, based on an advisory service question I handled. We need to clarify or explain in an annex that this section applies in addition to the basic fire protection requirement mandated by 9.1. In handing this, I forgot some of the subtleties involved in this and had to backtrack on my answer. n) Smoke detection in spray booths see Tom Euson (saved as msg)

11 Advisory Service Question-I have a general contractor who has installed smoke detectors in the make-up air units in other parts of a building (per NFPA 90A), who is asking if there should be smoke detectors in the make-up air unit for a paint booth. The components of the fire detection and protection system are not typically in our scope of supply. NFPA 33 does not reference 90A. Have you or the committee had any discussion regarding smoke detection in the supply from the make-up air unit? Or needing to comply with NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems? Tom s Response-I had never heard of using smoke detectors in a booth before last week. A consulting engineer from NYC said that an AHJ somewhere was requiring the smoke detectors in the booth exhaust. At BMW, they are using something they call B to B for the air. It stands for Building to Booth. They are taking some of the building exhaust air and using it for part of the booth air supply. There was an issue of a smoke detector in the building exhaust before the air got to the booth. I don t know what was done as it wasn t in our scope. This air is going to a manual zone then cascaded to an automated zone then cascaded to the flash-off before the oven. All of this is to decrease the amount of air that has to be heated. This is something we need to address in our next cycle. What % LFL should we specify with the air going to 3 different places? o) Don Scarbrough- The changes to allow unlisted equipment were instituted at a meeting of the committee in Savannah seventeen years ago at the plaintive request of the automotive companies, two of which (Ford and Chrysler) were then under citation by federal OSHA for noncompliance with the then existing requirement for listing of all electrostatic equipment. They all expressed support for the requirement, but stated they could not be brought into compliance overnight. The bargain struck was to the effect that, if the committee would make changes to NFPA 33 allowing use of unlisted equipment with several additional safeguards, and sustain this allowance for one revision cycle of the standard, they would bring all automotive plants into compliance by installation of listed equipment during that cycle, and would support reinstatement of the requirement for listing of all electrostatic equipment effective with adoption of the next edition of NFPA 33. Generous time has been allowed for them to refit with listed equipment, and I think it is time to hold the automotives to the agreement. p) Questions from Jeff Bennett Conductive Gloves for Manual Electrostatic Painting Operations If painters are wearing ESD shoes, why are conductive gloves required? Because of the excessive charge generated by the spray gun? Non-Sparking Tools Although non-sparking tools are no longer required by NFPA 30 and NFPA 33, is it in TEMA's best interest to state that non-sparking tools are not required? Cellophane Bags for Sprinkler Head Protection Is it possible to find bags that are true "cellophane", or will all bags have some polyethylene be in any cellophane bags? What is the practical limit of polyethylene in a "cellophane" bag beyond which the bag will be considered not acceptable?

12 Open Containers in Flammable Liquid Storage Cabinets Safety Cans, Safety Lids and Drums with Pumps in Flammable Liquid Storage Cabinets Grounding of Containers within Flammable Liquid Storage Cabinets Grounding of Flammable Liquid Storage Cabinets Grounding of Metal Parts During Repair Should open containers be allowed in flammable liquid storage lockers? Should open containers with approved lids be allowed in flammable liquid storage cabinets? Should containers placed within flammable liquid storage cabinets be grounded? Are flammable liquid storage cabinets required to be grounded? Is it required (and/or best practice) to ground all parts being repaired to their fixture or a known good ground? Does it matter how much surface area is being repaired? An example of this would be a painted tailgate being prepped on a padded fixture. If a repair is made on that type of fixture, is there a consideration for the amount of material to be applied? Grounding of Vehicles in Repair After Final Assembly Is it necessary to ground vehicles which are rolling on rubber tires which are in the process of final repair? Static Dissipating Covers for Robots and Booth Side Walls Are static-dissipating covers required for robots and other equipment located within spray zones? If the cover is manufactured with material that meets with the requirements of NFPA 99, will it also meet the requirements of NFPA 33? Grounding Manual Electrostatic Guns through Power Cable and Compressed Air Line? Combining Rags Saturated with Both Solvent Base and Waterbase Materials. Will a typical electrostatic spray gun be affected if the compressed air line is grounded (via a spiral type ground cable molded into the compressed air line)? Is there a documented risk when combining rags which have been used for cleaning of different types of liquids (e.g. waterbase and solvent base paint materials)?

13 Are fiberglass grates acceptable for installation in a paint booth? Is there a distinction between liquid and powder? Is a flash-off area (outside the 3-foot bubble) considered to be unclassified even though solvent vapors may be present during this process? Are combustible liquids liquids to be treated differently than flammable liquids with respect to their electrical classification? Fiberglass grates have been observed inside spray rooms. Although the electrical definition in NFPA 33 suggests that this is unclassified, it would be helpful to know if this is the real intent. Do the electrical areas of classification for flammable liquids apply to combustible liquids, too? q) Tom-Need discussion about perception that powder fires may be increasing in frequency? Task Groups: 1) Sprinkler Systems for Protection of Ducts and Stacks Task Group a needs to look at large ducts and water supply issues. Coordinate with NFPA 13. 2) Coordination of NEC 3) Review of Flammable Comb liquids requirements in Chapter 8 a. Look at 8.2 and 8.3 MAQs for Flammable/combustible liquids. Quantities are different for mixing rooms etc. 4) Clarification of Continuous versus Automatic Spraying 5) Recirculation Task Group a needs to look at large ducts and water supply issues. Coordinate with NFPA 13. b. Air intake filters that are a part of a wall or ceiling assembly shall be labeled listed as Class 1 or Class 2, in accordance with ANSI/UL 900, Standard for Air Filter Units. 6) Membrane Enclosures Task Group a. Are we ok with partial membrane enclosures or does the entire piece need to be enclosed? Question if the membrane can seal to the deck and then people work above and below the deck. Do we need to specify in that not only can no one be INSIDE the enclosure but also should not be ON TOP OF the piece/deck etc.

14 Formal Interpretation NFPA 33 Spray Application Using Flammable or Combustible Materials 2011 Edition Reference: Chapters 4 through 8, Chapter 10 F.I Question 1: Chapters 4 and 5 of NFPA 33 provide requirements for the design, location and construction of spray booths and spray rooms. a) Will compliance with these requirements assure that a spray booth or spray room will provide adequate protection against health hazards from toxic materials? b) Will compliance with these requirements assure that a spray booth or spray room will meet the Clean Air Act standards for exhaust emissions? Question 2: In Chapter 6 of NFPA 33, certain areas within or adjacent to spray finishing areas are designated as hazardous locations, i.e., Class I or II, Division 1 or 2. Does this designation indicate the extent to which worker health hazards from toxic material may be present? Question 3: In Chapter 7 of NFPA 33, the concentration of flammable materials in a spray booth or room ventilation exhaust stream is required to be maintained below 25 percent of the LFL a) Will compliance with these sections also assure that concentrations of toxic material will be kept at a safe level, i.e., below the Threshold Limit Values? b) Will the Standard allow for the concentration to be raised above 25 percent of the LFL in order to meet environmental compliance requirements limiting the amount of material that may be discharged from an exhaust stack? Question 4: Chapter 8 of NFPA 33 provides requirements for the storage and handling of flammable and combustible liquids necessary to prevent fire and explosion. Will compliance with the Standard also assure that worker exposure to toxic materials will be kept at a safe level, i.e. - below the Threshold Limit Values? (Continued)

15 Question 5: Chapter 10 of NFPA 33 provides requirements for maintenance in a spray area. These requirements include disposal techniques for overspray collectors; residue scrapings and rags or waste material; storage of contaminated clothing; and the prompt removal of contaminated materials and residues. a) Will compliance with these requirements assure that all necessary steps have been taken to prevent worker exposure to harmful concentrations of toxic materials? b) Do the requirements include those steps needed to assure compliance with RCRA rules for hazardous waste disposal? Issue Edition: 1985 Reference: Chapters 4 through 8, Chapter 10 Date: September 1987 Reissued to correct error: January 2002 Copyright 2010 All Rights Reserved NATIONAL FIRE PROTECTION ASSOCIATION

16 Formal Interpretation NFPA 33 Spray Application Using Flammable or Combustible Materials 2011 Edition Reference: Chapter 9 F.I. No.: Question No. 1: Does Section 9.1 require some type of fire protection for spray areas, as defined in Chapter 3 of NFPA 33? Answer: Yes. Question No. 2: If the answer to Question No. 1 is Yes, does Section 9.1 specify the type of system that must be used? Question No. 3: If the building in which the spray application is located is not protected by automatic sprinklers, does Chapter 9 require that the spray area be protected by an automatic sprinkler system? Question No. 4: If the answer to Question No. 3 is No, does Chapter 9 allow an alternative fire protection system? Answer: Yes. Issue Edition: 1995 Reference: Chapter 9 Issue Date: August 3, 1999 Effective Date: August 23, 1999 Reissued to correct error: January 2002 Copyright 2010 All Rights Reserved NATIONAL FIRE PROTECTION ASSOCIATION

17 Formal Interpretation NFPA 33 Spray Application Using Flammable or Combustible Materials 2011 Edition Reference: 9.1, Appendix A.9.1 through A.9.7 F.I Question 1: Does Section 9.1 of NFPA 33 mean that paint spray rooms or booths are required to be sprinklered or be equipped with another type fire extinguisher system where sprinkler protection is not available? Answer: Yes. Question 2: In Appendix A.9.1 through A.9.7 of NFPA 33, does the use of the word should instead of the word shall imply that fire extinguishing systems are not required in all paint spray rooms and booths? Question 3: Are manufactured, pre-fab(ricated) and portable paint spray booths, which are not equipped with built-in fire extinguishing systems, yet advertised as meeting UL, BOCA, NFPA, and OSHA standards, exempt from the requirements for sprinkler protection or an approved fire extinguishing system, as required by Section 9.1 of NFPA 33? Question 4: Do the requirements of NFPA 33, specifically (those of) sprinkler protection or an approved fire extinguishing system, apply to a paint spray room or booth that has been constructed outside and separated from the main body shop premises? Answer: Yes. Issue Edition: 1985 Reference: Chapter 9, Appendix A.9.1 through A.9.7 Date: May 1987 Reissued to correct error: January 2002 Copyright 2010 All Rights Reserved NATIONAL FIRE PROTECTION ASSOCIATION

18 Ballot Comments NFPA Doug Rivord Delete the word "temporary" Geoff Raifsnider This 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". It is not necessary to include "natural or mechanical means" in the definition. The requirement to be "natural" or to be "mechanical" is addressed in the enforceable language in the body of the standard. NFPA 34 Public Comment No. 9 is a better fit. (Same in NFPA 34 see below) 4.3 Thomas George While we reference the definition for Basement in NFPA 101 within the Committee Statement, this will be lost in the published standard. The NFPA 101 definition for Basement should be added to NFPA 33 during the next cycle. Amy Brown Conducting spray painting operations in a basement is inherently unsafe. The original wording expresses clearly this intent. C.2.1 Bob Feldkamp c.2.1 has an error, 15 MEC should be 30 MEC. However, the rest of SR53 is correct. This number can be corrected with a TIA. Geoff Raifsnider The MEC value to be used is 30 g/m3 when the manufacturer's information is not available. This was inadvertently changed to 15 g/m3. The enforceable language in Chapter 15 states the MEC requirements correctly. Ballot Comments NFPA 34 NFPA 34 Geoff Raifsnider This 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". It is not necessary to include "natural or mechanical means" in the definition. The requirement to be "natural" or to be "mechanical" is addressed in the enforceable language in the body of the standard. Public Comment No. 9 is a better fit for this document.

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