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

Transcription

1 Report on Comments F2006 Copyright, NFPA NFPA 12 Report of the Committee on Mary P. Hunstad, US Department of the Navy, DC [E] (Alt. to Douglas J. Barylski) Gaseous Fire Extinguishing Systems Giuliano Indovino, North American Fire Guardian Technology, Incorporated, Italy [M] Jeffrey L. Harrington, Chair (Alt. to Maurizio Barbuzzi) Harrington Group, Incorporated, GA [SE] Robert Kasiski, FM Approvals/FM Global, RI [I] (Alt. to Robert C. Merritt) Richard A. Malady, Fire Fighter Sales & Service Company, PA [IM] (Alt. to Norbert W. Makowka) Ivan M. Nibur, Global Risk Consultants Corporation, KY [SE] (Alt. to Paul F. Helweg, Jr.) Steven W. Rhodes, US Social Security Administration, MD [U] (Alt. to Matthew T. Gustafson) James M. Rucci, Harrington Group, Incorporated, GA [SE] (Alt. to Jeffrey L. Harrington) John M. Schuster, 3M Company, MN [M] (Alt. to Paul E. Rivers) Len D. Seebaluck, Firetrace International, AZ [M] (Alt. to William A. Eckholm) Margaret A. Sheppard, US Environmental Protection Agency, DC [E] (Alt. to Bella A. Maranion) John C. Spalding, Healey Fire Protection, Incorporated, MI [IM] (Alt. to Robert H. Kelly) George Unger, Underwriters Laboratories of Canada, Canada [RT] (Alt. to George E. Laverick) Ronald C. Adcock, Marsh USA Incorporated, AZ [I] Maurizio Barbuzzi, North American Fire Guardian Technology, Incorporated, Italy [M] Douglas J. Barylski, US Department of the Navy, DC [E] John E. Dellogono, Liberty Mutual Property, MA [I] Rep. Property Casualty Insurers Association of America Todd A. Dillon, GE Insurance Solutions, OH [I] William A. Eckholm, Firetrace International, AZ [M] Dale R. Edlbeck, Ansul Incorporated, WI [M] Don A. Enslow, BP Exploration (Alaska), AK [U] William A. Froh, US Department of Energy, DC [U] Matthew T. Gustafson, US Social Security Administration, MD [U] Howard S. Hammel, DuPont Fluoroproducts, DE [M] Christopher P. Hanauska, Hughes Associates, Incorporated, MD [SE] Paul F. Helweg, Jr., Global Risk Consultants Corporation, RI [SE] Robert H. Kelly, Fire Defense Equipment Company Incorporated, MI [IM] Rep. Fire Suppression Systems Association James L. Kidd, The Hiller Companies, MA [IM] George E. Laverick, Underwriters Laboratories Incorporated, IL [RT] Norbert W. Makowka, National Association of Fire Equipment Distributors, IL [IM] Bella A. Maranion, US Environmental Protection Agency, DC [E] Robert C. Merritt, FM Global, MA [I] Robert G. Richard, Honeywell, Incorporated, NY [M] Paul E. Rivers, 3M Fire Protection, MN [M] Patrick W. Schoening, General Motors Corporation, MI [U] Joseph A. Senecal, Kidde-Fenwal, Incorporated, MA [M] Clifford R. Sinopoli, II, Exelon Corporation, PA [U] Rep. Edison Electric Institute Louise C. Speitel, US Federal Aviation Administration, NJ [E] Brad T. Stilwell, Fike Corporation, MO [M] Al Thornton, Chemtura, TX [M] Klaus Wahle, US Coast Guard, DC [E] () Fred K. Walker, US Department of the Air Force, FL [E] Robert T. Wickham, Wickham Associates, NH [SE] Thomas J. Wysocki, Guardian Services, Incorporated, IL [SE] Jiann C. Yang, US National Institute of Standards & Technology, MD [RT] Nonvoting Rudolf Klitte, Ginge-Kerr Danmark A/S, Denmark [M] Ingeborg Schlosser, VdS Schadenverhuetung, Germany [I] Fernando Vigara, APICI, Spain [SE] Staff Liaison: Mark T. Conroy Committee Scope: This Committee shall have primary responsibility for documents on the installation, maintenance, and use of carbon dioxide systems for fire protection. This Committee shall also have primary responsibility for documents on fixed fire extinguishing systems utilizing bromotrifluoromethane and other similar halogenated extinguishing agents, covering the installation, maintenance, and use of systems. This Committee shall also have primary responsibility for documents on alternative protection options to Halon 1301 and 1211 fire extinguishing systems. It shall not deal with design, installation, operation, testing, and maintenance of systems employing dry chemical, wet chemical, foam, aerosols, or water as the primary extinguishing media. Alternates Philip B. Atteberry, Chemtura, IL [M] (Alt. to Al Thornton) Charles O. Bauroth, Liberty Mutual Property, MA [I] (Alt. to John E. Dellogono) Kenneth V. Blanchard, DuPont Fluoroproducts, DE [M] (Alt. to Howard S. Hammel) Philip J. DiNenno, Hughes Associates, Incorporated, MD [SE] (Alt. to Christopher P. Hanauska) Randall Eberly, US Coast Guard, DC [E] (Alt. to Klaus Wahle) Raymond N. Hansen, US Department of the Air Force, FL [E] (Alt. to Fred K. Walker) Mark E. Herzog, The Hiller Companies, AL [IM] (Alt. to James L. Kidd) William Matt Hogan, Duke Power Company, SC [U] (Alt. to Clifford R. Sinopoli, II) Daniel J. Hubert, Kidde/Chemetron Fire Systems, IL [M] (Alt. to Joseph A. Senecal) This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. This portion of the Technical Committee Report of the Committee on Gaseous Fire Extinguishing Systems is presented for adoption. This Report on Comments was prepared by the Technical Committee on Gaseous Fire Extinguishing Systems, and documents its action on the comments received on its Report on Proposals on NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2000 edition, as published in the Report on Proposals for the 2006 Fall Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Gaseous Fire Extinguishing Systems, which consists of 33 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 12-1

2 Report on Comments F2006 Copyright, NFPA NFPA Log #4 Final Action: Reject (4.1) Submitter: Thomas J. Wysocki, Guardian Services, Inc. Comment on Proposal No: 12-9 Recommendation: Delete proposed text from the ROP and revert to existing text for Section 4.1 from NFPA 12, 2005 edition. Substantiation: The new wording provides very detailed restrictions on the use of total flood carbon dioxide systems in normally occupied spaces. The wording, however, leaves no room for engineering analysis and judgment which is crucial to successful application of fire extinguishing agents. The current language in NFPA 12, 2005 edition paragraph 4.12 gives similar guidance for best use of carbon dioxide in total flooding applications while leaving room for engineering judgment. It should remain unchanged. The proposed wording in 12-9 (Log #CP1) could effectively eliminate carbon dioxide in most every flammable liquids hazard which could be considered normally occupied including most large shipboard machinery spaces where CO 2 is the international standard for fire protection. In shipboard application this is particularly onerous since proven extinguishing effectiveness is extremely critical - one cannot call for a fire department to extinguish a blaze that is not controlled by the shipboard extinguishing system. Also space and weight restrictions are part and parcel of shipboard application - new vessels may be designed in some cases to allocate more space to fire suppression systems but on existing vessels space constraints will exist. I agree that CO 2 total flooding systems should not generally be used in typical normally occupied spaces when acceptable alternatives are available. I do not agree that the NFPA standard on carbon dioxide should regulate the use of carbon dioxide in normally occupied spaces without allowance for engineering judgment as CP1 proposes to do. Such regulation, if it can be proven to be in the best interest of public safety, should be left to government regulators - who will be in a position to do detailed cost/benefit and risk/benefit analyses to justify such regulation. FATALITIES RESULTING FROM COMMON ACTIVITIES One Year Accident Statistics 1 for the USA Fatalities Cause 42,900 Vehicle accident (auto, etc.) 14,200 Falls 3,900 Exposure to smoke, fire, flames 734 Fall out of bed or chair 456 Accidental strangulation in bed by bed clothes 439 Fall from ladder or scaffold 116 Animal riding 57 Contact with hot tap water 35 Vehicular airbag activation 2 8 Asphyxiation by nitrogen purge gas 3 Less than 1 Discharge of carbon dioxide fire extinguishing systems 4 1 From National Safety Council 2001 data with exceptions as noted 2 National Highway Transportation Safety Administration data 3 U.S. Chemical Safety and Hazard Investigation Board data from 1992 to 2002, average per year 4 EPA report Carbon Dioxide as a Fire Suppressant: Examining the Risks, North American average 1948 through 1998 Carbon dioxide has been successfully and safely used since To eliminate its use for broad classes of applications without adequate supporting data is not supportive of good safety practices. The burden of proof for restriction of a long standing, successfully used technology should be placed on those desiring to establish such restriction. In the politically charged debate on this issue, data supporting 12-9 (Log #CP1 s) effective ban on the use of carbon dioxide in certain total flood application has not been provided. Risk/benefit and cost/benefit have not been considered. The view forwarded in support of banning carbon dioxide in certain applications has eschewed consideration of risk/benefit and cost/benefit. But consider the following risk and benefit factors. RISKS Risks of carbon dioxide have been well known, even before the first carbon dioxide total flood system was installed in There is risk in every human activity - we weigh risks versus benefits continually in our lives. The tables on the next pages show fatalities caused by everyday activities compared to carbon dioxide fire system discharge: The everyday activities listed in the table are continued virtually without question. Why? Because the benefits of continuing them are considered to justify the known risks. Why are not safer means of obtaining these benefits employed? For example, why do people continue to drive passenger cars of standard manufacture rather than armored tanks? Admittedly an armored vehicle would give more protection in an accident than a standard passenger car - but cost/benefit considerations prompt society to continue using passenger cars as a primary means of transportation in many developed countries including the Untied States in spite of nearly 43,000 deaths due to vehicle accidents per year. Or what about falls from chairs or beds - over 700 deaths per year? Could these not be reduced if all beds were required by law to have guard rails and people were required by law to use them? Each of the above activities could be legislated to be done more safely - but risk/benefit and cost/benefit obviate consideration of such legislation. Risk/benefit and cost/benefit are an integral part of engineering and everyday life. Yet, no risk/benefit or cost/benefit analysis has been presented in support of further restricting use of carbon dioxide by code or standard and totally prohibiting the exercise of engineering judgment in determining the most suitable agent for given hazards. The data presented in the EPA s substantiation for their proposal shows the following for carbon dioxide systems of all types (total flooding, local application, etc.) used in North America where NFPA Standards are prevalent: Data extracted from the EPA report: Carbon Dioxide as a Fire Suppressant: Examining the Risks U.S. Environmental Protection Agency Office of Air and Radiation Stratospheric Protection Division February 2000 The data does not support even a partial ban on the use of carbon dioxide systems in total flood applications. Indeed if one were to rely on this data in support of this proposal, one would conclude that use of carbon dioxide in normally occupied spaces offers less risk than its use in normally unoccupied spaces and neither use is unreasonably risky. BENEFITS For those who may be less familiar with the benefits of carbon dioxide fire protection, some of the benefits are listed below: Carbon dioxide - clean, dry, no-residue, naturally occurring substance, electrically nonconductive gas. Effective for a wide range of hazards: flammable liquids and gases, solid surface fire, deep seated fires,fire in high voltage energized electrical equipment. No secondary damage to equipment - No agent decomposition North America: Yeas 1948 through 1998: Fatalities involving CO 2 per EPA report Type of Occupancy Incidents Frequency of Total Fatalities in 51 years Yearly Average Incidents Not Normally Occupied 19 1 per 2.7 yrs incidents 0.43 fatalities Unknown Occupancy 12 1 per 4.25 yrs incidents 0.29 fatalities Normally Occupied 5 1 per 10.2 yrs incidents 0.1 fatalities Total for 51 years Note incidents 0.84 fatalities Note 1: Five of the 43 deaths occurred during fires and it is uncertain whether the carbon dioxide discharge or the fire caused these fatalities. 12-2

3 Report on Comments F2006 Copyright, NFPA NFPA 12 Nearly 100 years of field experience with this agent - Proven MAKOWKA, N.: Carbon Dioxide should not be used in most normally technology occupied spaces however; there can be circumstances where carbon Readily available world wide at reasonable cost dioxide is the best agent for the hazard. The action on Committee Proposal The bench mark against which other extinguishing agents 12-9 (Log #CP1) removes the ability of a fire protection professional for effectiveness is measured internationally choosing carbon dioxide extinguishing systems when it could be the most Multiple means of application (total flood, local application, hand hose effective agent for a special application. line) to meet a wide variety of industrial and marine hazards. The current standard mandates that before a carbon dioxide system is A single agent source may be used to protect hazards containing installed in a normally occupied space, the designer must document for the various and varying fuels requiring various means of application. authority having jurisdiction that carbon dioxide is the most appropriate Can be piped long distances to readily protect large hazards extinguisher agent. Suitable for extreme temperature conditions from Arctic to Tropics Section 4.4, Specifications, Plans, and Approvals require that all aspects Well over 90 percent of fires fought with carbon dioxide fire of specifying, design and installation be approved by the AHJ. The extinguishing systems are totally extinguished without need for manual committee action removes this authority from the AHJ and limits the fire fire fighting (for example, the North American aluminum industry reported protection professional in their choice of extinguishing agents 7,745 fires successfully extinguished between with a 99.3 SCHOENING, P.: Do not agree with Committee Action due to the percent success ratio) reasons stated in the substantiation provided by the submitter. CO 2 is NOT a halon alternative nor is it a clean agent per NFPA WYSOCKI, T.: The submitter of Comment 12-1 (Log #4) proposed to leave Section 4.1 of NFPA 12 as it currently exists in the 2005 edition. Each year CO 2 extinguishes without incident more fires than all other The text of Section 4.1 was the subject of considerable thought, discussion gaseous agents combined. and study by the very experienced group of experts in the application RISK VS BENEFIT of carbon dioxide systems which comprised the technical committee Fatalities to both civilians and fire fighters due to exposure to smoke, fire responsible for NFPA 12 edition It provides excellent guidance for and flame take a huge toll each year in North America. Some 3,900 died in the rare, but possible, instances where carbon dioxide will be the best the USA during 2001 due to fire. Additional statistics are readily available choice for a normally occupied space - requiring careful justification by from the NFPA. the design professional on a case by case basis with the check and final In the marine environment, uncontrolled fire is particularly devastating. assent of the authority having jurisdiction. An average of 176 deaths on large ships occurs each year due to fire. 5 This proposed change to the standard (CP1) ignores 75 years of safe and The high risk of loss of life and livelihood from fire must be weighed successful application of carbon dioxide as a fire extinguishing agent as against the low risk of accidental discharge causing injury or death. Risk well as the work of the carbon dioxide experts who formulated 4.1 of Management NFPA edition. Further please note the following: Data provided indicates the risk due to use of carbon dioxide in normally The proposed committee action ignores the substantial and welldocumented technical substantiation provided by the submitter of occupied spaces (typically industrial or shipboard spaces) are very small - and exceptionally well managed. Data does not justify the detailed Comment 12-1 (Log regulation proposed in 12-9 (Log #CP1). The committee statement for rejecting Comment 12-1 (Log #4) and a Questions number of similar comments is The substantiation of the submitter did If total flood carbon dioxide systems are judged to be so dangerous to not provide new persuasive information on the topic. This committee life that the alternatives must be used in new systems intended to protect statement does not address technically even a single point made by the normally occupied spaces, why is it not likewise required that all existing submitters. total flood carbon dioxide systems protecting normally occupied spaces be Committee Proposal 12-9 (Log #CP1) is not supported by technical replaced with alternatives on a retroactive basis? On the other hand, if the substantiation in either the ROP or in the committee substantiation for existing systems may remain provided they are retrofitted with specified rejecting Comment 12-1 (Log safety features, why are not new systems permitted so long as they are As it stands, Committee Proposal 12-9 (Log #CP1) is both technically installed with the specified safety features? flawed and incomplete. Safety professionals worldwide understand that their job is to seek 1. For example, no technical justification has been presented for setting sensible management of risks, not a risk-free society. 6 I ask that the firesafety professionals on the GFE technical committee apply this basic dioxide in normally occupied spaces ( ). voltages > 400 as a line of demarcation for potential use of carbon principle in a consistent manner. Manage risk in order to gain benefit 2. Further, Committee Proposal 12-9 (Log #CP1) is incomplete in that rather than eliminating both risk and benefit. The existing verbiage in ROP states New total flooding carbon dioxide systems shall be NFPA 12 Edition 2005 section 4.1 provides better guidance for application permitted to be installed in normally occupied enclosures in marine engine of carbon dioxide than the wording proposed in the ROP -- leave section rooms where it is determined that an inerting concentration is required and 4.1 unchanged from the 2005 edition and reject the changes proposed in the inerting concentration required using alternate gaseous agents results in 12-9 (Log #CP1). a concentration above the LOAEL or the oxygen concentration is less than 8 percent. (add a foot print limit here). The technical committee failed 5 3,526 people died in shipboard fires in 20 years ( ) Source: to develop the important considerations for space requirements for the Emergency Disaster Management, Inc. various gaseous agents, space requirements which were recognized during 6 Health and Safety Commission Annual Report, Bill Callaghan, the ROP process as essential for determining the viability of fire protection Chairman, Great Britain HSC, 2005 methods for marine application. Comments 12-1 through 12-4 should be accepted and the upcoming Committee Statement: The substantiation of the submitter did not revision of NFPA 12 published with the current wording for 4.1. provide new persuasive information on the topic. Explanation of Abstention: MERRITT, R.: I m returning the subject ballot on behalf of FM Global Ballot Results: Affirmative: 24 Negative: 5 Abstain: 2 voting Affirmative with Exception(s). I am abstaining on the Committee Action for Comment Nos through 12-5 for the reasons as stated below for all of these comments. KELLY, R.: The wording as proposed in Committee Proposal 12-9 (Log FM Global has chosen to abstain on comments 12-1 through We #CP1) limits the capability to provide the best fire protection/suppression are not in a position to evaluate the life safety concerns surrounding the solution for some types of hazards. The existing wording adequately use of CO 2 as a fire protection system. However, we feel it is important places the responsibility and liability on the distributor/installer company to note that CO 2 has been an effective fire suppression agent both in and specifically on the designer of said system. This indicates that any North America and throughout the world. When used correctly, it has engineer/designer who chooses a carbon dioxide system would have to do significantly reduced the consequences of fire events in high hazard some serious research and consideration before making this occupancies. Although there are other gaseous agents now available, recommendation. He would also have to obtain the approval of the none provide all the fire protection benefits of CO 2 and many create authority having jurisdiction. other unacceptable consequences when used in occupancies that have KIDD, J.: I agree with Tom Wysocki that the 12-9 (Log #CP1) is too the potential for severe flammable liquid fires. We feel the position put restrictive. Mr. Wysocki has presented a very good argument with factual forward by Tom Wysocki in Comment 12-1 (Log #4) is clear, logical data to support his position. The existing text for Section 4.1 from NFPA and supports the continued use of CO 2 with proper hazard evaluation and 12, 2005 should remain as is. suitable safeguards as recommended in NFPA 12. The present wording adequately places the responsibility and liability on WAHLE, K.: These committee actions, if adopted, would create the distributor/installer company and specifically on the designer of said a conflict with current U.S. Coast Guard regulations that permit the system. This indicates that any engineer/designer who chooses a carbon installation of CO 2 systems in occupied machinery spaces. dioxide system would have to do some serious research and consideration The matter is currently under Coast Guard review with a view toward before making this recommendation. He would also have to obtain the eventual prohibition of the installation of new CO 2 systems in occupied approval of the authority having jurisdiction. spaces. 12-3

4 Report on Comments F2006 Copyright, NFPA NFPA 12 Committee Statement: The substantiation of the submitter did not 12-2 Log #1 Final Action: Reject provide new persuasive information on the topic. (4.1 through ) Submitter: Ingeborg Schlosser, VdS Schadenverhutung Comment on Proposal No: 12-9 Recommendation: Reject the proposal. Substantiation: From the view of Vds Schadenverhutung there are technical and organization options to operate carbon dioxide systems. In normally occupied enclosures with a very high level of safety for persons. Ballot Results: Affirmative: 24 Negative: 5 Abstain: 2 KELLY, R.: See my Explanation of Negative for Comment 12-1 (Log KIDD, J.: See my Explanation of Negative on Comment 12-1 (Log MAKOWKA, N.: See reasoning for Comment 12-1 (Log The use of CO 2 in occupied areas should not be limited in general. It SCHOENING, P.: Do not agree with Committee Action due to the should be decided case by case taking into account the measures provided reasons stated in the substantiation provided by the submitter. for personal safety. Committee Statement: The substantiation of the submitter did not provide new persuasive information on the topic. Ballot Results: Affirmative: 24 Negative: 5 Abstain: 2 WYSOCKI, T.: See my Explanation of Negative for Comment 12-1 (Log Explanation of Abstention: MERRITT, R.: See my Explanation of Abstain on Comment 12-1 (Log WAHLE, K.: See my Explanation for Abstention for Comment 12-1 (Log KELLY, R.: See my Explanation of Negative for Comment 12-1 (Log KIDD, J.: See my Explanation of Negative on Comment 12-1 (Log MAKOWKA, N.: See reasoning for Comment 12-1 (Log SCHOENING, P.: Do not agree with Committee Action due to the reasons stated in the substantiation provided by the submitter. WYSOCKI, T.: See my Explanation of Negative for Comment 12-1 (Log Explanation of Abstention: MERRITT, R.: See my Explanation of Abstain on Comment 12-1 (Log WAHLE, K.: See my Explanation for Abstention for Comment 12-1 (Log 12-3 Log #5 Final Action: Reject (4.1 through ) Submitter: Karl Heinz Stahl, Din German Standards Institute for Normung e.v. Comment on Proposal No: 12-9 Recommendation: Reject the proposal. Substantiation: CEN/TC 191/WG 6 wishes to point out that there are technical and organizational options to operate carbon dioxide systems is normally occupied enclosures with a very high level of safety for persons. The use of CO 2 in occupied areas should not be limited in general. It should be decided case by case taking into account the measures provided for personal safety. Committee Statement: The substantiation of the submitter did not provide new persuasive information on the topic. Ballot Results: Affirmative: 24 Negative: 5 Abstain: 2 KELLY, R.: See my Explanation of Negative for Comment 12-1 (Log KIDD, J.: See my Explanation of Negative on Comment 12-1 (Log MAKOWKA, N.: See reasoning for Comment 12-1 (Log SCHOENING, P.: Do not agree with Committee Action due to the reasons stated in the substantiation provided by the submitter. WYSOCKI, T.: See my Explanation of Negative for Comment 12-1 (Log Explanation of Abstention: MERRITT, R.: See my Explanation of Abstain on Comment 12-1 (Log WAHLE, K.: See my Explanation for Abstention for Comment 12-1 (Log 12-4 Log #7 Final Action: Reject (4.1 through ) Submitter: Wolfram Krause, Bundesverband Technischer Brandschulz e.v. Comment on Proposal No: 12-9 Recommendation: Reject the proposal. Substantiation: From the view of the Bundesverband Technischer Brandschulz ev there are technical and organizational options to operate carbon dioxide systems in normally occupied enclosures with a very high level of safety for persons. The use of CO 2 in occupied areas should not be limited in general. It should be decided case by case taking into account the measures provided for personal safety Log #6 Final Action: Reject ( ) Submitter: Douglas J. Barylski, Naval Sea Systems Command Comment on Proposal No: 12-9 Recommendation: Revise to read as follows: New total flooding carbon dioxide systems shall be permitted to be installed in marine cargo holds where it is determined that using alternate gaseous agents results in a concentration above the LOAEL or the oxygen concentration is less than 8 percent, and no alternative systems using nongaseous agents are acceptable for protection of all hazards. Substantiation: Alternative fire extinguishing systems, such as water sprinklers, can adequate protect some marine cargo holds. Committee Statement: Total flooding carbon dioxide systems are currently permitted for this application by the standard. The US Coast Guard does not permit other types of systems for this application. Ballot Results: Affirmative: 28 Negative: 2 Abstain: 1 BARYLSKI, D.: The committee statement is incorrect. The committee states The Coast Guard does not permit other types of systems for this application. This is a false statement, as in fact the Coast Guard does permit other systems. Sprinkling was permitted in USNS LEWIS AND CLASS (T-AKE 1) for its cargo holds, in lieu of carbon dioxide. FROH, W.: I do not agree with the committee action on this comment. I think that accepting Comment 12.5 (Log #6) would ensure a similar level of personnel safety exists for all normally occupied enclosures, including marine cargo holds. The committee agreed to restrictions for other types of normally occupied enclosures, and I think marine cargo holds should not be treated any differently. The committee statement accompanying the action to reject Comment 12-5 (Log #6) does not provide a persuasive argument for rejection, in my opinion. For these reasons, I am voting negative on the committee action to reject comment number 12-5 (Log #6). Explanation of Abstention: MERRITT, R.: See my Explanation of Abstain on Comment 12-1 (Log 12-6 Log #8 Final Action: Accept in Principle ( ) Submitter: Norbert W. Makowka, Nat l Assn. of Fire Equipment Distributors Comment on Proposal No: Recommendation: Accept original proposal as submitted: In a lowpressure system the tank shutoff valve shall not be considered as a lockout valve. Substantiation: The lockout valve is required as a life safety device used to prevent the unwanted discharge of carbon dioxide. For this safety device to be utilized it is essential that it be convenient to the hazard and not affect other hazards that may be protected from the same storage unit. Section requires that a lock-out shall be provided on all systems except where dimensional constraints prevent personnel from entering the protected space. And that the system shall be locked out: when persons not familiar with the systems and their operation are present in a protected space or when persons are present in locations where discharge of the system will endanger them, and they will be unable to proceed to a safe location within the time-delay period for the system. The vast majority of low-pressure carbon dioxide systems protect multiple hazards from a single storage unit. It is not realistic to assume that an end user would shut off fire protection to all of the hazards

5 Report on Comments F2006 Copyright, NFPA NFPA 12 associated with that storage unit because one hazard needed to be locked SENECAL, J.: 1. These devices have been in use and unsupervised out. Printing press operations (see Annex B.4), power plants, metalprocessing facilities (machining centers, heat-treating, etc.) engine test CO 2 for many years (approx 50). I am unaware of any complaints about a system failing to operate due to a defective pneumatic line in a heat cells, and metal rolling mills are examples of facilities that have multiple actuated detection system. hazards protected from a single storage unit. 2. As the original submitter of the underlying proposal indicated, these Low-pressure carbon dioxide systems are seldom located close to the detectors are most commonly used on marine systems or at sites without a hazards they protect. Additionally, low-pressure storage units are often dependable power supply. located outdoors and a substantial distance from the hazard. Should we 3. I am unaware how long the current requirement has been in the expect someone would travel hundreds of feet and climb on top of a standard. As long as the requirement has been in the standard, AHJs must storage unit to reach the tank shut-off every time the hazard needed to be have been waiving this requirement since HAD system pneumatic lines locked out? have not had supervision capability. The lockout valve needs to be located close to the hazard to be effective Comment on Affirmative: or we are defeating the purpose of having a lockout valve as a life safety FROH, W.: The substantiation provided for Comment 12-8 (Log #10) device. includes the following statement: The exemption to the various safety Committee Meeting Action: Accept in Principle requirements allowed by the AIP has no restrictions other than the end user Revise text to read as follows: does not want to run electrical wiring in a hazard. However, the original In a low-pressure system the tank shutoff valve shall not be proposal from the ROP meeting provided cases (within the substantiation) considered as a lockout valve, except as permitted by in which automatic detection and actuation are provided by means other Where a single low pressure storage tank supplies single or than through wires. multiple systems protecting hazards that are interrelated, and when none of the hazards require protection if the equipment being protected is shut down, the storage tank shut-off valve shall be permitted to be used as a lock-out valve for the entire system. Add inside the parenthetical of ROP Proposal (Log #49). Committee Statement: The additional text allows a reasonable use of the storage tank shut-off valve as a lock-out valve. Ballot Results: Affirmative: Log #9 Final Action: Reject ( ) Submitter: Norbert W. Makowka, Nat l Assn. of Fire Equipment Distributors Comment on Proposal No: Recommendation: Delete changes from committee action on Proposal Substantiation: See substantiation for comment regarding Proposal Committee Statement: See committee action on Comment 12-6 (Log #8). Ballot Results: Affirmative: Log #10 Final Action: Accept (4.5.5) Submitter: Norbert W. Makowka, Nat l Assn. of Fire Equipment Distributors Comment on Proposal No: Recommendation: Delete changes from committee action on Proposal and return to the language in the current standard. Substantiation: The revision incorporated by the committee s AIP eliminates decades of committee work to make carbon dioxide systems safer and more reliable. The exemption to the various safety requirements allowed by the AIP has no restrictions other than the end user does not want to run electrical wiring in a hazard. Small hazardous materials storage cabinets are currently protected by pre-engineered systems and therefore the requirements of this standard do not necessarily apply. Committee Meeting Action: Accept Ballot Results: Affirmative: 29 Negative: 2 ECKHOLM, W.: I have voted to reject the new committee action on Comment 12-8 (Log #10). The Technical Committee discussed the proposed new wording for NFPA A specific committee action was taken to develop new wording that more appropriately addresses this topic. The committee action passed overwhelmingly. We believe the committee action allows for special situations where a full blown, electrical control system is not needed or possible. By mandating such requirements under all circumstances, it places an undue financial burden on users who wish to protect remote or other areas where power may not be present. We therefore respectfully suggest that Comment 12-8 (Log #10) be rejected and the wording as proposed by the committee be kept for the standard Log #2 Final Action: Reject (4.5.6 (New) ) Submitter: Shane M. Clary, Bay Alarm Co., Inc. Comment on Proposal No: 12-6 Recommendation: Add new text to read: Alarms. Audible and visual warning alarms shall be provided installed in accordance with NFPA 72 with the following purposes: (Strike out provided and insert installed in accordance with NFPA 72. ) Substantiation: The purpose of these audible and visual appliances is to provide warning of a discharge to occupants of the space. These appliances need to be installed in accordance with NFPA 72 so that the proper mounting heights and circuit integrity is maintained. Committee Statement: NFPA 72 covers all types of installations. It could be problematic to comply with certain portions of NFPA 72 for some carbon dioxide system installations. For example the mounting height requirements would not be applicable for certain hazard installations. Ballot Results: Affirmative: 30 Negative: 1 GUSTAFSON, M.: I agree with Comment 12-9 (Log #9) made by Mr. Clary suggesting that alarms should comply with NFPA 72, National Fire Alarm Code. Paragraph of NFPA 2001, 2005 edition, requires alarms to comply with NFPA 72. NFPA 12 and NFPA 2001 should be consistent on this matter Log #3 Final Action: Reject (A ) Submitter: Shane M. Clary, Bay Alarm Co., Inc. Comment on Proposal No: Recommendation: Revise as follows: A Supplemental Vvisible appliances are not required to comply with the mounting heights and light pulse characteristics of NFPA 72 so that rotating beacons or other visible appliances are permitted to be used. Visible throughout the space includes the reflection of the light being visible on surfaces complies with this requirement. Substantiation: The purpose of these audible and visual appliances is to provide a warning of a discharge to occupants of the space. This includes the hearing impaired. The light characteristics requirements of strobes found in NFPA 72 is meant to comply with the requirements of the Americans with Disabilities Act. The proposed Annex gives misleading direction, and is contrary to the requirements of NFPA 72. The proposed annex seems to remove provisions for the alerting of the hearing impaired that may be in the space when the alarm occurs. The revised text allows for these types of notification appliances to be installed as supplemental appliances. Committee Statement: See committee action on Comment 12-9 (Log #2). Also there are functional differences between the way you address evacuation alarms for suppression systems versus notification devices per NFPA 72. Ballot Results: Affirmative:

6 FORM FOR FILING NOTICE OF INTENT TO MAKE A MOTION (NITMAM) AT AN ASSOCIATION TECHNICAL MEETING 2006 FALL REVISION CYCLE FINAL DATE FOR RECEIPT OF NITMAM: 5:00 pm EST, October 20, 2006 If you have questions about filling out or filing the NITMAM, please contact the Codes and Standards Administration at FOR OFFICE USE ONLY Log #: For further information on the Codes- and Standards-Making Process, see the NFPA website ( Date Rec'd: Date Name Tel. No. Company or Affiliation Address Street Address City State Zip 1. (a) NFPA Document (include Number and Title) (b) Proposal or Comment Number (c) Section/Paragraph 2. Motion to be made. Please check one: (See also 4-6 of the Regulations Governing Committee Projects) (a) Proposal _(1) Accept. (3) Accept as modified by the TC. (2) Accept an Identifiable Part.* (4) Accept an Identifiable Part as modified by TC.* (b) Comment (1) Accept. (2) Accept an Identifiable Part.* (3) Accept as modified by the TC. (4) Accept an Identifiable Part as modified by TC.* (5) Reject (6) Reject an Identifiable Part.* (c) Return Technical Committee Report for Further Study (1) Return entire Report. (2) Return a portion of a Report in the form of a proposal and related comment(s). (3) Return a portion of a Report in the form of identifiable part(s) of a proposal and related comments (s). (Identify the specific portion of the proposal and the related comments below)* * Clearly identify the Identifiable Part(s) indicated above (use separate sheet if required). 3. I am entitled to make this motion in accordance with of the Regulations Governing Committee Projects, as follows: (check (a), (b), or (c). (a) This motion may be made by the original submitter or their designated representative, and I am the (if you check (a) indicate one of the following): I am the Original submitter, or I am the submitter s designated representative (attach written authorization signed by the original submitter), or I am an Organizational Member delegate permitted to represent the submitter on behalf of the Organization Member in accordance with (c). (b) This motion may be made by a Technical Committee Member and I am a Member of the responsible Technical Committee. (c) This motion may be made by anyone. (Form continued on next page)

7 NITMAM form (continued) 4. Comments or Clarification (optional): This NITMAM will be reviewed by a Motions Committee. In addition to determining whether your Amending Motion is proper, the Committee may take other actions as described in 2.3 of the Technical Meeting Convention Rules as follows: Restating and Grouping of Motions. Upon request or on its own initiative, and in consultation with the mover(s), the Motions Committee may: (a) restate an Amending Motion to facilitate the making of a proper motion or to clarify the intent of the mover; and (b) group Amending Motions that are dependent on one another into a single Amending Motion. Dependent motions are motions that the mover(s) wish to be considered by the assembly and voted on as single up or down package. In addition to the foregoing, the Motions Committee may take such other actions or make such other recommendations as will facilitate the fair and efficient consideration of amending. The NFPA Staff may contact you to clarify your motion or to consult on the permitted actions in 2.3. If you have any comments, suggestions, or requests of the Motions Committee as it reviews your NITMAM and considers actions permitted in 2.3, please provide them below. (Use additional sheet if necessary): Name (please print): Signature (Required) (Note: This NITMAM will be reviewed, and if proper, your Amending Motion will be certified in accordance with the Technical Meeting Convention Rules and posted on the NFPA website by November 17, Documents that have Certified Amending Motions will be considered at the June 2007 Annual Meeting Technical Committee Report. In order to have your Certified Amending Motion considered at that meeting, you must appear, sign in, and make the motion as prescribed in the Convention Rules). PLEASE USE A SEPARATE NITMAM FORM FOR EACH AMENDING MOTION YOU WISH TO MAKE, Mail to: Secretary, Standards Council, National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA Fax: (617)

8 Sequence of Events Leading to Issuance of an NFPA Committee Document Step 1 Call for Proposals Proposed new Document or new edition of an existing Document is entered into one of two yearly revision cycles, and a Call for Proposals is published. Step 2 Report on Proposals (ROP) Committee meets to act on Proposals, to develop its own Proposals, and to prepare its Report. Committee votes by written ballot on Proposals. If two-thirds approve, Report goes forward. Lacking two-thirds approval, Report returns to Committee. Step 3 Report on Proposals (ROP) is published for public review and comment. Report on Comments (ROC) Committee meets to act on Public Comments to develop its own Comments, and to prepare its report. Committee votes by written ballot on Comments. If two-thirds approve, Reports goes forward. Lacking two-thirds approval, Report returns to Committee. Step 4 Report on Comments (ROC) is published for public review. Technical Report Session Notices of intent to make a motion are filed, are reviewed, and valid motions are certified for presentation at the Technical Report Session. ( Consent Documents that have no certified motions bypass the Technical Report Session and proceed to the Standards Council for issuance.) NFPA membership meets each June at the Annual Meeting Technical Report Session and acts on Technical Committee Reports (ROP and ROC) for Documents with certified amending motions. Step 5 Committee(s) vote on any amendments to Report approved at NFPA Annual Membership Meeting. Standards Council Issuance Notification of intent to file an appeal to the Standards Council on Association action must be filed within 20 days of the NFPA Annual Membership Meeting. Standards Council decides, based on all evidence, whether or not to issue Document or to take other action, including hearing any appeals. I

9 The Technical Report Session of the NFPA Annual Meeting The process of public input and review does not end with the publication of the ROP and ROC. Following the completion of the Proposal and Comment periods, there is yet a further opportunity for debate and discussion through the Technical Report Sessions that take place at the NFPA Annual Meeting. The Technical Report Session provides an opportunity for the final Technical Committee Report (i.e., the ROP and ROC) on each proposed new or revised code or standard to be presented to the NFPA membership for the debate and consideration of motions to amend the Report. The specific rules for the types of motions that can be made and who can make them are set forth in NFPA s rules which should always be consulted by those wishing to bring an issue before the membership at a Technical Report Session. The following presents some of the main features of how a Report is handled. What Amending Motions are Allowed. The Technical Committee Reports contain many Proposals and Comments that the Technical Committee has rejected or revised in whole or in part. Actions of the Technical Committee published in the ROP may also eventually be rejected or revised by the Technical Committee during the development of its ROC. The motions allowed by NFPA rules provide the opportunity to propose amendments to the text of a proposed code or standard based on these published Proposals, Comments and Committee actions. Thus, the list of allowable motions include motions to accept Proposals and Comments in whole or in part as submitted or as modified by a Technical Committee action. Motions are also available to reject an accepted Comment in whole or part. In addition, Motions can be made to return an entire Technical Committee Report or a portion of the Report to the Technical Committee for further study. The NFPA Annual Meeting, also known as the World SafetyConference and Exposition, takes place in June of each year. A second Fall membership meeting was discontinued in 2004, so the NFPA Technical Report Session now runs once each yearat the Annual Meeting in June. Who Can Make Amending Motions. Those authorized to make these motions is also regulated by NFPA rules. In many cases, the maker of the motion is limited by NFPA rules to the original submitter of the Proposal or Comment or his or her duly authorized representative. In other cases, such as a Motion to Reject an accepted Comment, or to Return a Technical Committee Report or a portion of a Technical Committee Report for Further Study, anyone can make these motions. For a complete explanation, NFPA rules should be consulted. The filing of a Notice of Intent to Make a Motion. Before making an allowable motion at a Technical Report Session, the intended maker of the motion must file, in advance of the session, and within the published deadline, a Notice of Intent to Make a Motion. A Motions Committee appointed by the Standards Council then reviews all notices and certifies all amending motions that are proper. The Motions Committee can also, in consultation with the makers of the motions, clarify the intent of the motions and, in certain circumstances, combine motions that are dependent on each other together so that they can be made in one single motion. A Motions Committee report is then made available in advance of the meeting listing all certified motions. Only these Certified Amending Motions, together with certain allowable Follow-Up Motions (that is, motions that have become necessary as a result of previous successful amending motions) will be allowed at the Technical Report Session. Consent Documents. Often there are codes and standards up for consideration by the membership that will be non-controversial and no proper Notices of Intent to Make a Motion will be filed. These Consent Documents will bypass the Technical Report Session and head straight to the Standards Council for issuance. The remaining Documents are then forwarded to the Technical Report Session for consideration of the NFPA membership. Important Note: The filing of a Notice of Intent to Make a Motion is a new requirement that takes effect beginning with those Documents scheduled for the Fall 2005 revision cycle that reports to the June 2006 Annual Meeting Technical Report Session. The filing of a Notice of Intent to Make a Motion will not, therefore, be required in order to make a motion at the June 2005 Annual Meeting Technical Report Session. For updates on the transition to the new Notice requirement and related new rules effective for the Fall 2005 revision cycle and the June 2006 Annual Meeting, check the NFPA website. II

10 Action on Motions at the Technical Report Session. In order to actually make a Certified Amending Motion at the Technical Report Session, the maker of the motion must sign in at least an hour before the session begins. In this way a final list of motions can be set in advance of the session. At the session, each proposed Document up for consideration is presented by a motion to adopt the Technical Committee Report on the Document. Following each such motion, the presiding officer in charge of the session opens the floor to motions on the Document from the final list of Certified Amending Motions followed by any permissible Follow-Up Motions. Debate and voting on each motion proceeds in accordance with NFPA rules. NFPA membership is not required in order to make or speak to a motion, but voting is limited to NFPA members who have joined at least 180 days prior to the session and have registered for the meeting. At the close of debate on each motion, voting takes place, and the motion requires a majority vote to carry. In order to amend a Technical Committee Report, successful amending motions must be confirmed by the responsible Technical Committee, which conducts a written ballot on all successful amending motions following the meeting and prior to the Document being forwarded to the Standards Council for issuance. Standards Council Issuance One of the primary responsibilities of the NFPA Standards Council, as the overseer of the NFPA codes and standards development process, is to act as the official issuer of all NFPA codes and standards. When it convenes to issue NFPA documents it also hears any appeals related to the Document. Appeals are an important part of assuring that all NFPA rules have been followed and that due process and fairness have been upheld throughout the codes and standards development process. The Council considers appeals both in writing and through the conduct of hearings at which all interested parties can participate. It decides appeals based on the entire record of the process as well as all submissions on the appeal. After deciding all appeals related to a Document before it, the Council, if appropriate, proceeds to issue the Document as an official NFPA code or standard. Subject only to limited review by the NFPA Board of Directors, the Decision of the Standards Council is final, and the new NFPA code or standard becomes effective twenty days after Standards Council issuance. The illustration on page 9 provides an overview of the entire process, which takes approximately two full years to complete. III