Report on Proposals Copyright, NFPA NFPA 505 Report of the Committee on

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1 Report of the Committee on Staff Liaison: James D. Lake Industrial Trucks Joseph John Dahlstrom, Chair UK and Associates, IL [SE] Lewis C. Barbe, World Safety Organization, MN [SE] Denise Beach, National Propane Gas Association, DC [IM] Rep. National Propane Gas Association John K. Bouchard, Palmer & Cay, Inc., MA [I] Bryan S. Bower, Buckeye Fire Equipment, NC [M] Rep. Fire Equipment Manufacturersʼ Association John M. Jacovetty, Ford Motor Company, MI [M] Patrick J. Kapust, US Department of Labor, DC [E] John M. Mertens, Fyrsafe Engineering, Inc., IL [U] Harry Ruetschlin, Underwriters Laboratories Inc., IL [RT] Brian N. Tyrer, Pyroban Limited, England [SE] Kenneth R. Van Hook, Mitsubishi Caterpillar Forklift America Inc., TX [M] Rep. Industrial Truck Association David B. Wechsler, The Dow Chemical Company, TX [U] Rep. American Chemistry Council Alternates Committee Scope: This Committee shall have primary responsibility for documents on the safe use, maintenance, and operation of industrial trucks and other material-handling equipment to minimize fire hazards. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. The Report of the Technical Committee on Industrial Trucks is presented for adoption. This Report was prepared by the Technical Committee on Industrial Trucks and proposes for adoption, amendment to NFPA 505, Fire Safety Standard for Powered Industrial Trucks Including Type Designations, Areas of Use, Conversions, Maintenance, and Operation, 2002 edition. NFPA is published in Volume 8 of the 2003 National Fire Codes and in separate pamphlet form. This Report has been submitted to letter ballot of the Technical Committee on Industrial Trucks, which consists of 13 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. William H. Gray, Underwriters Laboratories Inc., IL [RT] (Alt. to Harry Ruetschlin) Jerry L. Harpin, FM Global, MA [I] (Voting Alt. to FM Rep.) Michael J. Laderoute, MJL Associates, Inc., VA [M] (Alt. to Bryan S. Bower) William J. Montwieler, Industrial Truck Association, DC [M] (Alt. to Kenneth R. Van Hook) Matthew Frank Ukleja, UK and Associates, IL [SE] (Alt. to Joseph John Dahlstrom) 505-1

2 505-1 Log #3 Final Action: Reject ( Entire Document ) Submitter: Karin Rountree, Roseanne Gullo, Ampco Safety Tools Recommendation: Anywhere ignition sources are a concern, please include as a requirement: Non-Sparking Tools are required where hazardous, combustible or flammable gases, liquids, dusts, or residues are present. Substantiation: Ordinary hand tools are usually made of steel and if struck, scraped, or dropped, can cause sparks which can be disastrous in an explosive environment. Non-Sparking Tools eliminate this hazard, however, standards regarding their application are incomplete, inconsistent and in some cases inaccurate. We feel prevention is one of the most effective means of ensuring safety. If we can prevent an accident and save someoneʼs life and business, if we can implement standards and codes to educate and inform before an accident happens, then we should make the necessary standards and codes to solve the problem. The standards and recommended practices developed by NFPA are designed to improve overall safety and protection of property and personnel. Implementing a Non-Sparking Tools requirement wherever an ignition source is concern would reduce the risk of fire and explosion where hazardous conditions are present. Non-Sparking Tools are recommended by Safety Engineers and Insurance Companies and meet OSHA and EPA requirements where hazardous, combustible or flammable gases, liquids, dusts and residues are present. Non-Sparking Tools should be used when storing, processing and handling hazardous materials as well as maintenance and repair operations within hazardous environments. All it takes is just one spark to cause an explosion. Committee Meeting Action: Reject Committee Statement: Paragraph does not permit repairs in Class I, II and III locations. Therefore a requirement for nonsparking tools is not necessary. BARBE: I vote no as the chairman promised to give my paper on necessary changes consideration. To date no response from anyone. KAPUST: I abstain from voting per OSHA policy Log #1 Final Action: Reject ( 4.2 ) Submitter: Robert Zuiderveld, Servolift/Sichelschmidt Recommendation: To avoid public safety from being jeopardized, I propose to no longer allow the use of EE rated forklift equipment in Class 1, Division 2, groups B, C and D explosion hazardous areas. EE trucks comply with the forklift code, UL 583, not necessarily to the electrical code as stated in NEC 505. Substantiation: EE rated equipment complies with the forklift codes UL 583. However in addition it should be mandatory for EE equipment to be certified according to UL 1604 before allowing its use in Class 1, Division 2, Groups B, C and D explosion hazardous areas. The term non sparking is improperly used since EE trucks come with the standard carbon (sparking) forks, a E-rated, not-locking battery connectors and regular battery cables. Allowing the current design EE equipment, without a UL 1604 certification in Class 1, Division 2, Groups B, C and D explosion hazardous areas is a grave disregard for public safety. Committee Meeting Action: Reject Committee Statement: Under both NFPA 497 and 505 the definition of a Class I Division 2 location anticipates an atmosphere which is only hazardous under abnormal circumstances. If the location has known releases of hazardous material, it becomes by definition a Class I Division 1 location warranting the removal of the vehicle. The Scope of UL 1604 specifically states that battery powered portable equipment need not comply with this requirement (1604). UL 1604 is intended to apply to permanently installed equipment for use in Class 1 Division 2 locations. Paragraph of NFPA 505 addresses the issue raised by this proposal. Comment on Affirmative: WECHSLER: The National Electrical Code in Article 500 presents the requirements for electrical and electronic equipment and wiring for all voltages in Class I, Divisions 1 and 2; Class II, Divisions 1 and 2; and Class III, Divisions 1 and 2 locations where fire or explosion hazards may exist due to flammable gases or vapors, flammable liquids, combustible dust, or ignitable fibers or flyings. Additionally the NEC defines Class I, Division 2 as a condition in which an atmosphere may be hazardous due to the presence of ignitable concentrations during abnormal conditions, but within a context in which it also requires that electrical equipment used in such a location must be suitable of operating during this abnormal condition. So for instance, Article 500 does not permit the use of general electrical equipment that is arcing or sparking or has an elevated surface temperature in excess of the specific autoignition temperature for those materials being used, under normal conditions of operation. Thus while a product standard, such as UL 1604, may state otherwise, this does not change the requirements of using electrical equipment within an electrically classified location as defined in Article 500 of the NEC. Further compliance with such a product standard would merely reinforce the condition that the equipment would not be tested/verified as being suitable per the NEC. Therefore the submitter is quite correct in some of his substantiation. However, the proposed recommendation does not agree with the NFPA style manual and for this reason the proposal must be rejected. However, it is also unfortunate that currently NFPA 505 in section does very little to clarify to users or inspectors the requirement details that equipment used within a hazardous (classified) location must comply with Article 500.8A(1) of the NEC, as being identified as being suitable. An example of a more correct proposal recommendation format might be as follows: Recommendation: In Table 4.2 under the Column Electric-Powered EE, replace K with NA for Class I, Division 2, Groups A, B, C, and replace A with NA for Class I, Division 2, Group D Log #2 Final Action: Reject ( 4.2 ) Submitter: Robert Zuiderveld, Servolift/Sichelschmidt Recommendation: Add text to read as follows: Allow Eex, Zone 2 EIC tested and certified equipment for the use in Class 1, Division 2, Groups B, C and D explosion hazardous areas. Substantiation: The IEC requirements for the use of electrical equipment in Class 1, Division 2, Groups B, C and D explosion hazardous areas exceed the requirements set forth for EE lift trucks. The extra protection features on the Eex, Zone 2 forklift equipment will enhance safety in the workplace and it will offer corporate America a wider variety of equipment that can be used safely in Class 1, Division 2, Groups B, C and D explosion hazardous areas. Committee Meeting Action: Reject Committee Statement: The concept is not incorrect and NFPA 505 allows the use of EX trucks in Class 1 Division 2 Groups B & C. The reference to a truck that is specifically tested and certified in Class 1 Division 2 Groups B, C & D could be permitted with approval of the authority having jurisdiction under NFPA 505. In addition the references to IEC and Eex industrial trucks may be accepted in the equivalency provisions in Section 1.4 of NFPA 505. Furthermore specifically states that documentation shall be submitted to the AHJ which is consistent with Log #4 Final Action: Reject ( 4.2 ) Submitter: David Wechsler, The Dow Chemical Company / Rep. American Chemistry Council Recommendation: Replace all section 4.2, including Table 4.2, with this revised wording: Section 4.2 replace Table 4.2 and the entire existing 4.2 text with the following, again with the expressed purpose of providing specific information for user understanding and application with respect to the use of industrial trucks: 4.2 Specific Areas of Use Any of the Type Designated Units as presented in Normative Annex A shall be permitted to be used in any unclassified or general-purpose outdoor location, subject to Site and/or Plant requirements/restrictions. The following would be the contents of the new Normative Annex A: [Ed-normative is an accepted term used in global standards that means it is mandatory and not just an informational reference] Normative Annex A- Type Designations of Lift/Industrial Trucks Type Designation D - A diesel-powered unit that has minimum acceptable safeguards against inherent fire hazards.

3 Type Designation DS - A diesel-powered unit meeting all the requirements of Type Designated EX truck shall be permitted to be used in Class I, a Type D unit which is provided with additional safeguards to the exhaust, fuel, Division 1, Group D locations, subject to Site and/or Plant requirements/ and electric systems. restrictions. Type Designation DY - A diesel-powered unit meeting all the requirements Power-operated industrial trucks shall not be used in locations that of a Type DS unit in which additionally any electric equipment is completely contain Group E combustible metallic dusts including aluminum, magnesium, enclosed and equipped with and their commercial alloys, or other combustible dusts whose particle size, temperature-limitation features. abrasiveness, and conductivity present similar hazards in the use of electrical Type Designation E - An electrically powered unit that has minimum equipment, unless such industrial truck(s) have been identified for such use. acceptable safeguards against inherent fire and electrical shock hazards. (Note See NFPA 70, Article 500 for definition of identified ) Type Designation ES - An electrically powered unit meeting all the Certified or listed truck units shall be permitted to be used in requirements of a Type E unit that is provided with additional safeguards to the accordance with the prescribed listing or certification, subject to Site and Plant electrical system to prevent emission of hazardous sparks and to limit surface requirements. For example, MIAG types that are certified as Ex de IIB T4 temperatures. may be used in Zone 1 or Zone 2, Group IIB electrically classified locations, Type Designation EE - An electrically powered unit that, in addition to subject to Site and/or Plant requirements/restrictions. meeting all the requirements for Type E and ES units has its electric motors Any of the Type Designated Units/trucks shall be permitted to be used and all other electric equipment completely enclosed. in any hazardous (classified) location, subject to additional Site and/or Plant Type Designation EX - An electrically powered unit, that differs from the requirements/restrictions when the area of use is tested initially and routinely Types E, ES and EE units in that the electric fittings and equipment are so monitored and found to be free of concentrations of flammable gases, vapors, designed, constructed, and assembled that the unit is rated for use in Class I, combustible gases, combustible liquids, or combustible dusts, and the use of Division 1, Group D and Class II, Division 1, Group G locations as defined in the designated truck is done under an administrative control, such as a safe/hot/ NFPA 70, National Electrical Code. work permit. Type Designation G - A gasoline-powered (G) unit that has minimum Converted Industrial Trucks. acceptable safeguards against inherent fire hazards Power-operated industrial trucks for ordinary (unclassified) locations Type Designation G/CN - A unit that operates on either gasoline or shall be permitted to be converted to an alternate fuel in accordance with the compressed natural gas (CN) that has minimum acceptable safeguards against requirements in Chapter 6. inherent fire hazards The conversion of trucks approved for, or that conform to, the Type Designation G/LP - A unit that operates on either gasoline or liquefied requirements for hazardous locations shall be in accordance with the petroleum gas (LP) and that has minimum acceptable safeguards against requirements of UL 558, Standard for Safety Industrial Trucks, Internal inherent fire hazards. Combustion Engine-Powered, and shall be certified by a nationally recognized Type Designation GS - A gasoline-powered unit that, in addition to meeting testing laboratory (NRTL). all the requirements for Type G units, is provided with additional safeguards to Power-operated industrial trucks that previously have been approved the exhaust, fuel, and electric systems. for, or that conform to, the requirements for Type CN, Type G, Type LP, Type Type Designation GS/CNS - A unit that operates on either gasoline or G/CN, or Type G/LP shall not be converted to a type designation for use in compressed natural gas and, in addition to meeting all the requirements for hazardous (classified) locations, such as conversion of LP to LPS, G to GS, and Type G/CN units, is provided with additional safeguards to the exhaust, fuel, CN to CNS. and electric systems. Substantiation: Section 4.2 Specific Area of Use is anything but specific. Type Designation GS/LPS. A unit that operates on either gasoline or liquefied It provides for judgements from the authority having jurisdiction and others petroleum gas and, in addition to meeting all the requirements for the Type to make decisions regarding the use of vehicles that have designated markings G/LP units, is provided with additional safeguards to the exhaust, fuel, and when the markings seemingly do not align with listed for use in a hazardous electric systems. (classified) location. Type Designation LP - A liquefied petroleum gas LP-Gas-powered unit that Committee Meeting Action: Reject has minimum acceptable safeguards against inherent fire hazards. Committee Statement: There are no Normative Annexes in NFPA standards. Type Designations LPS - An LP-Gas-powered unit that, in addition to meeting NFPA Annexes are intended to be nonmandatory. These requirements the requirements for Type LP units, is provided with additional safeguards to therefore must be maintained in the body of the standard. the exhaust, fuel, and electric systems Type Designated Units - DS, DY, ES, EE, EX, GS, GS/LPS, GS/CNS, and LPS shall be permitted to be used, subject to additional Site and/or Plant a) outdoor Class I, Division 2, Group D locations b) outdoor Class I, Division 2, Group B, or Group C locations in which the WECHSLER: chemicals used within the area have autoignition temperatures (AIT) greater Judging from the Panel comment, it seems that the Panel completely missed than 175 C (347 F) (for Committee consideration/information only and the issues addressed by this proposal. The focus was not on the location of the should not appear in the printed text-the point established is the autoignition identified types of trucks. This was only a first step and was offered to make temperature of cheap paper). the text less wordy. However, action to Accept in Principle, and place this c) indoor Class I, Division 2, Group D locations equipped with continuous opening text within the body of the document would have easily solved this problem by modifying the proposed as follows: d) indoor Class I, Division 2, Group B, or Group C locations in which the Any of the Type Designated Units as presented in 3.3 above shall be chemicals used within the area have autoignition temperatures (AIT) greater permitted to be used in any unclassified or general-purpose outdoor location, than 175 C (347 F) and in which the location is equipped with continuous subject to Site and/or Plant requirements/restrictions. The main focus of this proposal was to address issues associated with hazardous (classified) locations which are defined by the National Electrical Code, e) indoor or outdoor locations used for the storage of flammable or combustible liquids in sealed containers, or liquefied or compressed gases in and addressed in more detail in NFPA 497 and 499, and the somewhat random containers (no dispensing). way these terms and equipment requirements are tossed about in NFPA 505. f) in Class II, Division 2, Group F or Group G locations. This proposal takes a frontal, practical approach in permitting the use of the g) in Class III, Division 2 locations. industrial truck to be contingent upon the userʼs defined hazardous (classified) h) in Unclassified or general purpose locations. location assessment, by applying the NFPA 505 scope/material to the industrial truck and allowing other NFPA documents, such as the NEC Article 500, Type Designated Units - DS, DY, ES, EE, EX, GS, GS/LPS, GS/CNS, and LPS shall be permitted to be used, subject to additional Site and/or Plant NFPA 497 and NFPA 499 to address and resolve hazardous (classified) location issues. This proposal also eliminates problematic areas in which the user or a) outdoor Zone 2, Group IIA locations inspector is provided with conflicting information or asked to make judgments b) outdoor Zone 2, Group IIB or Group IIC locations in which the chemicals without having the needed criteria provided for resolution. used within the area have autoignition temperatures (AIT) greater than 175 C The heart of permitted uses of Industrial Trucks within the NFPA 505 document is Table 4.2. From the perspective of the user this table is an excellent (347 F) (point established is the autoignition temperature of cheap paper). c) indoor Zone 2, Group IIA locations equipped with continuous mechanical reference as it clearly covers all the hazardous (classified) location areas. If one eliminates the NA and the J and K footnotes from the table, the guidance d) indoor Zone 2, Group IIB, or Group IIC locations in which the chemicals to the user results in the following five basic recommendations: used within the area have autoignition temperatures (AIT) greater than 175 1) All trucks may be used in unclassified (the NEC revised term for nonclassified ), C (347 F) and in which the location is equipped with continuous mechanical 2) Any Type _S or _X may be used in Class III, Division 2 locations, e) indoor or outdoor locations used for the storage of flammable or 3) Only Types DY, DX, EE and EX may be used in Class I, Division 2, Group combustible liquids in sealed containers or liquefied or compressed gases in D; Class II, Division 2, Group F, and Class III, Division 1 locations. containers. 4) Only Types DX and EX may be used in Class I, Division 2 Group D; Class f) in Zone 22 locations in which the chemicals used within the area have II, Division 1, Group F and G; (There is a proposal to reconsider this aspect as autoignition temperatures (AIT) greater than 175 C (347 F). well), and g) in Unclassified or general purpose locations

4 5) Only Types DX and EX may be used in Class I, Division 1, Group D locations. Yet within NFPA 505, section 4.2 there exist a number of NFPA 505 defined hazardous (classified) occupancies such as section 4.2.3, which is simply an interpreted sample of the defined Class I, Division 2, but with Group D materials; or section which reflect areas as being typical, Class II, Division 1 locations with Group G materials. So if the table can clearly define for the given hazardous (classified) location or area what trucks are appropriate, why does NFPA 505 in section 4.2 need to have the numerous amplified mandated lists of hazardous (classified) location occupancies which in fact may not be correct for all users or their operating conditions? It does not and should not. From the NFPA 505 scope statement the user may understand that poweroperated industrial trucks are those fork trucks, tractors, platform lift trucks, motorized hand trucks, and other specialized industrial trucks powered by electric motors or internal combustion engines. More simply the user may understand that power-operated industrial trucks are those defined within Article 3.3. However, power-operated industrial trucks do not include compressed air-operated or nonflammable compressed gas-operated industrial trucks, farm vehicles, or automotive vehicles for highway use. So, if NFPA 505 truly meant that power-operated trucks, which for the reason stated above are the only trucks addressed within NFPA 505, and these are not permitted to be used in Class I, Division 1, Groups A, B, or C locations. Yet if they are not permitted why are these locations shown in the table and additionally why are the types addressed by the footnote designation NA? One reason we might offer is these are included just for completeness, but as can be seen, this is one example of user confusion presented in NFPA 505. The footnote designation NA is used not only in Class I, Division 1 Group A, B and C, but profusely used throughout the Table. NA is indicated as meaning Type truck not authorized in location described. From the userʼs or inspectorʼs perspective the question is who or whom is the authorizer for the use? Is the authorizer the AHJ or is authorizer another term for approved? Again from the user perspective, there are real needs for using equipment that is not otherwise listed, certified, or approved within an identified hazardous (classified) location. An example of this is the need to use a cutting torch or a welder within a hazardous (classified) location. Within the many industries that have hazardous (classified) locations, these needs or applications are conducted by use of an administrative control, such as a safe or hot work permit. Aspects of these permits require that the area be monitored for concentrations of the presence of a flammable gas and/or vapor and for work to be immediately stopped and all equipment de-energized upon detection of the flammable concentration. Some many suggest that use of these administrative controls/ permits are quite acceptable for Division 2 locations, because the flammable material will only be present during abnormal operations. But they may argue that permits are not acceptable for Division 1 locations because by definition in a Class I, Division 1 location the flammable material would likely be present during normal operations and there may be also personal exposure issues. It is suggested that this is a user issue and not an issue that NFPA 505 should be further involved with. NFPA 505 already confronts this issue with permission to use Types DX and EX within Class I, Division 1, Group D locations. In a similar way, if the atmosphere is determined to have no flammable concentrations, then permission to use the truck with controls should be provided. This is the concept that has been included in this proposal as new item and one reason why the wording of existing paragraph was revised significantly by that of the new paragraphs suggested in Section 4.2. There are two other footnotes to Table 4.2 that further contribute to vagueness and use of this table, as well as conflict with the existing texts in section 4.2. These are footnotes J and K defined respectively as follows: J =Type truck authorized for location described with approval of the authority having jurisdiction K =Type truck authorized to be determined by the authority having jurisdiction Having been involved with codes and standards writing, I am very positive that the NFPA 505 writers, back some time ago, really choose these words with a very deliberate purpose of mind. However, the fine aspect of the difference in these footnotes has been lost over time with the result that to most users, these statements are indistinguishable, nebulous and do not impart a solid recommended action. Further despite the appearance otherwise, condition K should be considered more rigorous a condition to be met than that of J. To remedy this entire condition, changes to the text, as indicated for instance in the new paragraph 4.2.2, have been recommended that contain clear specific language and performance criteria. Lastly, the entire subject of determining hazardous (classified) locations has and continues to be addressed by numerous books written to improve upon the basic guidance presented in NFPA 497 and 499 documents. It seems both odd and somewhat unreasonable that NFPA 505 should wish to tackle this subject or attempt to compete with these other NFPA documents by defining what Class I, Class II and Class III, Division 1, Division 2 and Unclassified locations are. NFPA 505 should stick to the documents scope and provide needed recommendations to address the fact that designated types of trucks do not, as a general rule, align with listed certified or approved NFPA 70 Article 500 hazardous (classified) location apparatus. NFPA 505 should not be telling users as for example, in the current statement that Class I, Division 1, Group D SHALL include the following 10 items, when in fact, they may not at all IN FACT be that. Again, NFPA 497 provides excellent guidance on how to determine not only the Class, Division and Group, but also the extents or the boundary distances beyond the potential source. Attempts by NFPA 505 to circumvent this defined hazardous (classified) location criteria by asking users or other authorities to apply concepts based upon fire and loss experience or explosion history fall significantly short of the needed assessment and are woefully poor as a means of determining how close the suitability of equipment safeguards matches with the NEC designated protection techniques. It was all these issues that these proposed revisions address and clarify. With this as the basis for this proposal, notice how the first revised item simply addresses the locations of use and additionally provides the users with a sound criteria for determining how to use certain types of trucks: Type Designated Units DS, DY, ES, EE, EX, GS, GS/LPS, GS/CNS, and LPS shall be permitted to be used, subject to additional Site and/or Plant a) outdoor Class I, Division 2, Group D locations b) outdoor Class I, Division 2, Group B, or Group C locations in which the chemicals used within the area have autoignition temperatures (AIT) greater than 175 C (347 F) c) indoor Class I, Division 2, Group D locations equipped with continuous d) indoor Class I, Division 2, Group B, or Group C locations in which the chemicals used within the area have autoignition temperatures (AIT) greater than 175 C (347 F) and in which the location is equipped with continuous e) indoor or outdoor locations used for the storage of flammable or combustible liquids in sealed containers, or liquified or compressed gases in containers ( no dispensing). f) in Class II, Division 2, Group F or Group G locations. g) in Class III, Division 2 locations. h) in Unclassified or general purpose locations. A companion paragraph, was added to address Zones which are now recognized by the NEC Type Designated Units DS, DY, ES, EE, EX, GS, GS/LPS, GS/CNS, and LPS shall be permitted to be used, subject to additional Site and/or Plant a) outdoor Zone 2, Group IIA locations b) outdoor Zone 2, Group IIB or Group IIC locations in which the chemicals used within the area have autoignition temperatures (AIT) greater than 175 C (347 F) ( point established is the autoignition temperature of cheap paper). c) indoor Zone 2, Group IIA locations equipped with continuous mechanical d) indoor Zone 2, Group IIB, or Group IIC locations in which the chemicals used within the area have autoignition temperatures (AIT) greater than 175 C (347 F) and in which the location is equipped with continuous mechanical e) indoor or outdoor locations used for the storage of flammable or combustible liquids in sealed containers or liquified or compressed gases in containers. f) in Zone 22 locations in which the chemicals used within the area have autoignition temperatures (AIT) greater than 175 C (347 F). g) in Unclassified or general purpose locations. To address the only hazardous (classified) location listed trucks there is paragraph, Type Designated DX and EX trucks shall be permitted to be used in Class I, Division 1, Group D locations, subject to Site and/or Plant requirements/restrictions. To address changes within the NEC regarding combustible dusts and the nature of what is an appropriately designed truck to operate in such environments, the NEC term of identified is used in revised paragraph Power-operated industrial trucks shall not be used in locations that contain Group E combustible metallic dusts including aluminum, magnesium, and their commercial alloys, or other combustible dusts whose particle size, abrasiveness, and conductivity present similar hazards in the use of electrical equipment, unless such industrial truck(s) have been identified for such use. (FPN:See NFPA 70, Article 500 for definition of identified ) To also address the use of IEC listed trucks, new paragraph was developed Certified or listed truck units shall be permitted to be used in accordance with the prescribed listing or certification, subject to Site and Plant requirements. For example, MIAG types that are certified as Ex de IIb T4 may be used in Zone 1 or Zone 2, Group IIB electrically classified locations, subject to Site and/or Plant requirements/restrictions. As was mentioned above, to permit the use of any truck under an administrative control, paragraph was introduced Any of the Type Designated Units/trucks shall be permitted to be used in any hazardous (classified) location, subject to additional Site and/or Plant requirements/restrictions when the area of use is tested initially and routinely monitored and found to be free of concentrations of flammable gases, vapors, combustible gases, combustible liquids, or combustible dusts, and the use of the designated truck is done under an administrative control, such as a safe/hot/ work permit.

5 No changes were suggested to the converted truck section (section ) which would follow as a renumbered section. Everything else under the current 4.2 would be deleted as it has been addressed by the above statements through the appropriate application of the criteria for hazardous (classified) locations in NFPA 70, 497 and Log #CP2 Final Action: Accept ( Exception ) Recommendation: Change the Exception to to a new paragraph and revise language as follows As an alternative, the authority having jurisdiction shall be permitted to conduct a survey of the fire and explosion hazards related to the truck and the specific area of use to determine if a Type DX or Type EX truck is permitted to be used. Substantiation: An editorial change to change the exception into positive code language per NFPA Manual of Style. WECHSLER: Prior to the Panel action, the section appeared as follows: Class II, Division 1, Group E Power-operated industrial trucks shall not be used in locations that contain Group E combustible metallic dusts including aluminum, magnesium, and their commercial alloys, or other combustible dusts whose particle size, abrasiveness, and conductivity present similar hazards in the use of electrical equipment. Exception: An approved power-operated industrial truck designated as Type DX or Type EX shall be permitted to be used in such locations, subject to special investigation of the truck and the specific area of use by the authority having jurisdiction In atmospheres where the dust of magnesium, aluminum, or aluminum bronze can be present, truck fuses, switches, motor controllers, and circuit breakers shall have enclosures that are specifically approved for such locations. Following the proposed actions, the exception to became , but nothing is mentioned about the current The revised begins with the text As an alternative This makes no sense; an alternative to what? It is highly suggested that the Panel action be revised as follows: Renumber , , delete the exception under , and as its replacement create a new as follows: As an alternative to an approved Type DX or type EX power-operated industrial truck. It was the Panel action to modify the wording of the exception. With this revised wording the suggested rewrite might result in the following: As an alternative to the authority having jurisdiction shall be permitted to conduct a survey of the fire and explosion hazards related to the truck and the specific area of use to determine if a Type DX or Type EX truck is permitted to be used. However of more importance, the initial requirement of being subject to special investigation of the truck is meaningless since there are no criteria for the assessment. Additionally, if the truck were found to be deficient in design, it is very likely that any modifications made would violate the original approval provided with the Type DX or EX designations. Lastly, the specific area of use should already have been addressed by the hazardous (classified) location determination and thus the requirement to seek a second investigation by the authority having jurisdiction of the hazards related to the specific area of use seems pointless. The revised wording offers little improvement. For example, an authority having jurisdiction does not need to be given authority or permission by NFPA 505. A survey is not an assessment, and a survey of fire and explosion hazards related to the truck and the specific area again is not tied to any criteria and certainly does not correlate the strict equipment design requirements of equipment used in a hazardous (classified) location. Lastly, if 505-4, Log #4 is accepted in principle, this item becomes a non issue Log #5 Final Action: Accept ( ) Submitter: G.C. Slawson, Liskow & Lewis / Rep. ICBA, North American Product Safety & Regulatory Committees Recommendation: Revise text to read as follows: (1) Carbon black, charcoal, coal, and coke dusts that have more than 8 percent total volatile material (same rest method) (and that are present in quantities sufficient to produce explosive or ignitable mixtures). Substantiation: The standard should relate to a demonstrated hazardous condition, such as where the listed materials are present in sufficient amounts (such as above the lower explosive limit, LEL) to pose an ignition or explosion risk. For carbon black, this change does not affect workplace safety. Carbon black does not present an ignition or explosion hazard related to forklift operations. Testing has demonstrated that ignition of carbon black products is extremely difficult. Laboratory tests were unable to ignite carbon black mixtures at every level that could be associated with industrial truck operations. See 2003 analysis. In addition, explosive atmospheres are unlikely to ever exist at carbon black manufacturing facilities. The lower explosive limit of carbon black is 50 grams per cubic meter, in contrast with measured workplace air levels that are less than 3.5 milligram per cubic meter PEL. Also, there have been no reported carbon black dust explosions in the industry. The ICBA proposes changes in the language of NFPA-505 Section to clarify that the restrictions are to be based on the presence of a demonstrated workplace hazard. The NFPA develops standard such as NFPA 505 to minimize the risk of fire hazards. NFPA 505 refers to and defines approved conditions for industrial trucks classified with the various designations of the Underwriters Laboratories, Inc., ( UL, e.g. D, DY, EX, etc). These UL truck designations specifically relate to fire and explosion hazards, as stated in Section A of the current NFPA 505 standard. The proposal by the ICBA is to clarify Section by adding language expressly stating that the restrictions requiring the use of EX industrial trucks are based on the actual presence of ignitable or explosive atmospheres. This aligns Section with the numerous other NFPA 505 sections that refer to atmospheres containing the potentially ignitable or explosive materials in quantities sufficient to produce ignitable or explosive atmospheres. Absent this clarification, Section may incorrectly be read broadly to impose restrictions to EX industrial trucks with no consideration as to whether a hazard is present and where no ignition or explosion hazard is likely. The current wording can be read to impose this restriction on any location where even a minute amount or even a single particle of carbon black is present. For example, a loading dock with a copy machine using carbon black based toner or a neighbor to a carbon black or tire manufacturing facility would be restricted to EX trucks. This restriction would apply without any evaluation of the hazardous nature of the workplace atmosphere, simply because some carbon black may be present. The ICBA does not believe this broad reading is the intent of the NFPA in formulating reasonable hazard-based standards for fire protection. Further, such a broad reading ignores the variability in the ignition/explosion characteristics among the carbon-containing materials (carbon black, coal and coke) in Section Specifically, testing has demonstrated that carbon black is in fact difficult to ignite. First, the heat present in the carbon black production process is sufficient to remove volatile organic constituents. Second, the ignition energy for carbon black is great and the Lower Explosive Limit (LEL) is very high. In the 1998 study of carbon black performed on behalf of the ICBA, the LEL was found to be 50 grams per cubic meter. Technical reports on carbon lack ignitability are also available. By comparison with the other carbon materials listed in Section , the energy needed for ignition of carbon black is 2-3 orders of magnitude greater than that or coke or coal dust. The hazard that may be posed by carbon black is not equivalent to that posed by coal, with which it is combined in the current standard. Thus, the ICBA suggests in its proposal to relate the EX truck restriction to the hazard actually posed by the relevant materials in specific workplace conditions. As further demonstration of the low ignition/explosion hazard posed by carbon black, no carbon black dust explosions have been reported at ICBA member carbon black manufacturing facilities. For these reasons, the ICBA proposes this modification and clarification of the Section standard to reflect the need to consider and evaluate the hazards posed by the referenced materials and not their mere presence in any amount whatsoever. Note: Supporting material is available for review at NFPA Headquarters. WECHSLER: It is not appropriate for the 505 committee to redefine the NEC/NFPA 497/NFPA499 definitions for Class, Division and Group. This should be extracted material and not applied as the proposer recommends. This is the definition for Class II, Division 1 - (1) Class II, Division 1. A Class II, Division 1 location is a location (1) In which combustible dust is in the air under normal operating conditions in quantities sufficient to produce explosive or ignitible mixtures, or (2) Where mechanical failure or abnormal operation of machinery or equipment might cause such explosive or ignitible mixtures to be produced, and might also provide a source of ignition through simultaneous failure of electric equipment, through operation of protection devices, or from other causes, or (3) In which combustible dusts of an electrically conductive nature may be present in hazardous quantities.

6 The definition for Group F is Group F. Atmospheres containing combustible carbonaceous dusts that have more than 8 percent total entrapped volatiles (see ASTM D , Standard Test Method for Volatile Material in the Log #CP9 ( ) Final Action: Accept Analysis Sample for Coal and Coke, for coal and coke dusts) or that have been sensitized by other materials so that they present an explosion hazard. Coal, carbon black, charcoal, and coke dusts are examples of carbonaceous dusts. [NFPA 499, 1-3] Therefore if the Panel wishes to accept the recommendation offered by proposer, the entire section should be replaced by the following: Class II, Division 1, Group F Approved power-operated industrial trucks designated as Type DX or Type EX shall be permitted to be used in Class II, Division 1, Group F, hazardous (classified) location. Lastly, if 505-4, Log #4 is accepted in principle, this item becomes a non issue. Recommendation: Renumber as and revise as follows: When a conversion kit is installed, all original identification of approval or listing and type designation shall not be removed and the plate specified in 6.1.4(3) shall be installed. in lieu thereof. Renumber current as Substantiation: Clarifies committee intent that the original and conversion nameplates must be visible and adjacent to one another Log #CP1 Final Action: Accept ( , , , ) Recommendation: Move to the Annex for and place an asterisk on Move to the Annex for and place an asterisk on Add and to the Annex for Substantiation: These lists are informational and not intended to be all inclusive, therefore it is more appropriate that they be placed in the Annex of the standard Log #CP3 Final Action: Accept ( ) Recommendation: Revise as follows: Industrial trucks designated as Type E that have been used previously in the locations described in 4.2.9, other than in manufacturing or processing, shall be permitted to be continued in use with the approval of the authority having jurisdiction. Substantiation: An editorial change to change the exception into positive code language per NFPA Manual of Style Log #CP4 Final Action: Accept ( 5.3 ) Recommendation: Delete 5.3. Substantiation: Redundant requirement, see also CP5 for committee actions on revision of the requirements for truck marking Log #CP6 Final Action: Accept ( ) Recommendation: Revise as follows: Removable LP-Gas containers shall not be exchanged near, and LP- Gas-powered vehicles shall not be parked near, sources of heat or open flame or similar sources of ignition or near open pits, underground entrances, elevator shafts, or other similar areas unless ventilated in accordance with NFPA 30. Exception: This requirement shall not apply to open pits, underground entrances, elevator shafts, or similar areas that are adequately ventilated to prevent accumulations of LP-Gas. Substantiation: Editorial revision to remove the exception and unenforceable language. WECHSLER: Since an LP gas powered vehicle produces heat, under most cases the new requirements of would prevent changing the gas container on that vehicle. Additionally the proposed wording of exchanged near and parked near introduces vague unenforceable requirements/ language Log #CP7 Final Action: Accept ( ) Recommendation: Revise by deleting the word substantial. Substantiation: Editorial change to remove unenforceable language Log #CP5 Final Action: Accept ( 8.4 ) Recommendation: Change the title of 8.4 and renumber the paragraphs as follows: 8.4 Marking and Labeling Types CNS, DS, DY, DX, ES, EE, EX, GS, LPS, GS/CNS, and GS/LPS Industrial Trucks Proper equipment shall be used in classified areas for the safety and protection of employees and property Approved trucks that are listed by a testing laboratory for use in such areas shall be clearly identified To facilitate identification by operators and supervisory personnel, a uniform system of marking as described in and shall be used

7 Durable markers indicating the type designation of trucks used in classified areas shall be applied to each side of the vehicle in a visible but protected location Log #CP8 ( 8.6 ) Final Action: Accept The markers shall be distinctive in shape as shown in Figure FIGURE Markers Used to Identify Type of Industrial Truck. [Existing (no change)] The markers for Types LPS, GS, DS, ES, CNS, GS/LPS, and GS/ CNS shall be 4-in. (102-mm) squares The width of markers for other type designations shall be 5 in. (127 mm) The markers shall consist of black borders and lettering on a yellow background Marking of Areas of Use Entrances to classified areas where industrial trucks are to be used shall be posted with durable markers as shown in Figure FIGURE Building Sign for Posting at Entrance to Hazardous Areas. [ExistingFigure (no change)] The minimum width of the sign shall be 11 in. (279 mm) The minimum height of the sign shall be 16 in. (406 mm) The word Caution shall be printed on the sign in yellow letters on a black background The body of the sign shall consist of black letters on a yellow background A marker(s) identical to that used on the side of the truck shall be installed on the sign. (See Figure ) Substantiation: Editorial revision of the section to clarify and separate the requirements for marking the vehicles and marking the building locations. Recommendation: Revise 8.6 as follows: There shall be a written operating procedure plan and operator training relevant to the location of use and type of truck Add a new: (5)(c) fire emergency procedures (6) hazardous location classifications and markings (7) industrial truck designations and markings Substantiation: Provide a requirement for complete training consistent with the requirements of NFPA 505. WECHSLER: While the revision to helps to further focus and correlate the needed operator training with the location, use and type of truck, I do not see that the three suggested new items offered under procedures, as truck procedures. Truck procedures are those directly related to the truck. There are many other items that an operator must be aware of- one is use of proper personal protection equipment, like seat belts, hard hats, proper clothing and shoes, etc. Another is being alert to conditions around the truck, changes in the ground level and surface, etc. Likewise there are all types of emergency conditions that may occur within a manufacturing facility. Fire is only one and may be the least impact for the truck operator. The need for hazardous location training would be part of the overall training if such conditions were applicable to that operation or use. If a facility has only one type of truck why must training be given on all types/designations/markings? I do feel that the wording of could be improved as follows: There shall be a written operating procedure plan and operator training relevant to the location, use, and type of truck. (strike of and add two commas) 505-7