{ ohn E. Cieslik, CSA, Ford Motor Co., MI [U]

Transcription

1 Report of the Committee on Finishing Processes Edward Watson, Chair Zurich American, GA [I] W. H. White, Secretar 3 White Consulting Services, OH [SE] Richard A. Bannister, R. S. Finishing Systems, ON, Canada [IM] Constance Bayne, Liberty Mutual Insurance Co., OH [I] Rep. The Alliance of American Insurers John Bloomgren, Forward Technology Industries, Inc., MN [M] { ohn E. Cieslik, CSA, Ford Motor Co., MI [U] aul H. Dobson, Factory Mutual Research Corp., MA [I] Thomas G. Euson, 3S, Inc., OH [IM] John Gokey, Ansul Inc./Tyco, Wl [M] Rep. Fire Equipment Mfrs. Assn. Steven J. Gunsel, Marsh, Inc., OH [I] Steven D. Jensen, 3M Company, MN [U] John Katunar, IIl, HSB Industrial Risk Insurers, MI [I] Rich Kimbrough, Kimbrough Fire Extinguisher Co., Inc~, TX [IM] Rep. Nat'l Assn. of Fire Equipment Distributors Inc. Wilh'am G. Kullman, Graco Inc., MN [M] {~ hn C. Larson, DuPont Automotive, PA[M] ichael Loan, Nordson Corp., OH [M] John McKnight, Nat'l Marine Mfrs. Assn., DC [U] Rep. Society of the Plastics Industry Inc. Kerry L. McManama, Underwriters Laboratories Inc~, IL [RT] Lowell Miles, Miles Fiberglass & Plastics, OR [U] Rep. Composite Fabricators Assn. Gregory M. Murin, Travelers Insurance, CT [I] G. Randall Nance, Automated Fire Systems, Inc., NC JIM] Allen Pirro, Intertek Testing Services, NY [RT] Gerald J. Rosicky, General Motors Corp., MI [U] Rep. NFPA Industrial Fire Protection Section Don 1L Searbrough, Elyria, OH [SE] James Shea, Kidde-Fenwal, Inc., MA [M] Rep. Fire Suppression Systems Assn. Barry Thomas, Team Blowtherm, GA [M] Larry L. Utterback, ITW Ransburg, IN [M] Alternates Ronald J. Beauchamp, Underwriters Laboratories Inc., IL [RT] (Alt. to K. I.. McManama) Bob Feldkamp, Nordson Corp., OH [M] (Alt. to M. Loan) Erling L. Horn, ITW Binks, CA [M] (Alt. to L. L. Utterback) John 1L Johnson, Royal Insurance, NC [I] (Voting Alt. to American Insurance Services Group) Jane I. Lataille, HSB Industrial Risk Insurers, CT [I] (Alt. to J. Katunar) Yamln Ma, Graco Inc., MN [M] (Air. to W. S. Kullman) Donald E. Major, Factory Mutual Research Corp., MA [I] (Alt. to P. H. Dobson) Dennis P. Mason, Marsh, Inc., MI [I] (Alt. to S.J. Gunsel) Kenneth J. Pilat, Liberty Mutual Insurance Co., ALM Services, Inc.~" FL [I] (Alt. to C. Bayne) John Schweitzer, Composite Fabricators Assn., MI [U] (Alt. to L. Miles) Nonvoting Robert B. Bell, U.S. Occupational Safety & Health Admin., DC [E] Patrick H. Franzen, Patrick H. Franzen & Assoc., OR [SE] (Member Emeritus) Terence P. Smith, U.S. Occupational Safety & Health Admin., DC [ (Alt. to R. B. Bell) Staff Liaison: Robert P. Benedettl Committee Scope: This Committee shall have primary responsibility for documents on safeguarding against the fire and explosion hazards associated with spray application processes, di. p ing. processes,. coating. rocesses,. and other. similar rocesses,,nc~ding glass fiber/resin tpabr, caaon processes, except F2r certain dipping processes that are within the scope of the Committee on Ovens and Furnaces. 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 classifwations is found at the front of this book. The Technical Committee on Finishing Processes is presenting two Reports for adoption, as follows: Report h The Technical Committee proposes for adoption amendments to NFPA , Standard for Spray Application Using Flammable or Combustible Materials. NFPA is published in Volume 2 of the 1999 National Fire Codes and in separate pamphlet form. NFPA 33 has been submitted to letter ballot of the Technical Committee on Finishing Processes, which consists of 28 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. Report II: The Technical Committeeproposes for adoption amendments to NFPA , Standardfor Dipping andcoating Processes Using Flammable or Combustible Liquids. NFPA $ is published in Volume 2 of the 1999 National Fire Codes and in separate pamphlet form. NFPA 34 has been submitted to letter ballot of the Technical Committee on Finishing Processes, which consists of 28 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report. 169

2 NFPA 33 m MAY 2000 ROP NFPA $$ (Log #CP22) (1-1.1(d), 1-1.2(c), 1-2.1): Accept SUBMITTER~ Technical Committee on Finishing Processes I RECOMMENDATION: Revise 1-1.1(d) to read: "other means of atomized application." Revise 1-1.2(c) to read: "other means of fiuidized application." Revise by deleting the word "reasonable." (Log #CP13) (1-1.3 (New)): Accept SUBMITTER- Technical Committee on Finishing Processes I RECOMMENDATION: Add a new Subsection to read: "This standard shall also apply to spray application of water-borne, waterbased, and water-reducible materials that contain flammable or combustible liquids or that produce combustible deposits or residues." Renumber subsequent paragraphs accordingly. SUBSTANTIATION: This new addition to the scope clarifies applicability of NFPA 33 to the subject coatings. (Log #CP14) (1-1.5 Exception): Accept I RECOMMENDATION: Delete the exception. SUBSTANTIATION: This correlates with the addition of new Subsection (Log #19) (1-1.7): Reject SUBMITTER: Charles Van Rickley, Rhinolinings U.S.A. RECOMMENDATION: Add new text to Chapter 1 as follows: This standard shall not apply to the spray application of plural-component urethane materials that are composed of Class III-B materials only, and are not used with organic peroxide catalysts or flammable solvents. SUBSTANTIATION: Sprayable coating materials and spray processes have been developed, and are in wide use, that consist of two or more Class III-B materials, and utilize no organic peroxide catalysts or flammable solvents. The components of these products are mixed at the spray nozzle, and use low air pressure for delivery to the substrate. These processes present a lower hazard than the presently exempted Automobile Undercoating. Although it appears that this standard is not intended to regulate this type of enforcement confusion among Authority Having risdiction's requires dais process to be addressed. COMMITTEE STATEMENT: The issue is already addressed by The Technical Committee's proposed changes to Chapter 12. (Log #10) (1-6 Batch (New)): Reject SUBMITTEI~ W. H. White, Perrysburg, OH RECOMMENDATION: Batch as used in is defined as: "The quantity of material prepared or required for one operation or the quantity produced at one operation." SUBSTANTIATION: The committee felt that Batch should be defined. COMMITTEE STATEMENT: The Technical Committee feels that the dictionary definition is adequate. (Log #CP23) (1-6 Definitions): Accept RECOMMENDATION: In Section 1-6, replace the definitions of "Labeled" and "Listed" with the standard NFPA definitions. In Section 1-6, replace the definition of "Liquid" with the following: "Liquid. x Any material that has a fluidity greater than that of 300 penetration asphalt when tested il~ accordance with ASTM D5, Test for Penetration for Bituminous Materials. Flammable Liquid. Any liquid that has a closed-cup flash point below 10 F (37 C), as determined by the test procedures and i apparatus set forth in Flammable liquids shall be classified i as Class 1 as follows: Class I Liquid. Any liquid that has a closed-cup flash point below 10 F (37 C) and a Reid vapor pressure not exceeding 40 psia ( mm Hg) at 100ooF (37~C), as determined by ASTM D323, Standard Method of Test for Vapor Pressure of Petroleum Products (Reid Method). Class 1 liquids shall be further classified as follows: Class IA liquids shall include those liquids that have flash points below 73 F (22.8 C) and boiling points below 100 F (37.8 C). Class IB liquids shall include those liquids that have flash points below 73 F (22.8 C) and boiling points at or above 100 F (37.8 C). Class IC liquids shall include those liquids that have flash points at or above73 F (22.8 C), but below 100 F (37.8 C). Combustible Liquid. A combustible liquid shall be defined as any liquid that has a closed-cup flash point at or above 100 F (37.8 C), as determined by the test procedures and apparatus set forth in Combustible liquids shall be classified as Class II or Class III as follows: Class II Liquid. Any liquid that has a flash point at or above 10O F (37.8 C) and below 140 F (60 C). Class IliA. Any liquid that has a flash point at or above 140 F (60 C), but below 200 F (93 C). Class IIIB. Any liquid that has a flash point at or above 200 F (93 C). (NFPA 30, & 1-7.3)" In Section 1-6, add a new definition to read as follows: "Readily Accessible. Capable of being removed or exposed without damaging the equipment or system or the building structure or finish, or not permanently enclosed." In Section 1-6, Spray Booth: delete the word "considered." In Section 1-6, add a new definition to read as follows: "Ventilation. x As specified in this code, movement of air that is provided for the prevention of fire and explosion. It is considered adequate if it is sufficient to prevent accumulation of significant quantities of vapor-air mixtures in concentrations over one-fourth of the lower flammable limit." (NFPA 30, 1-6) nature. They accomplish the following objectives: Replacement of Incorporation of standard NFPA definitions. Incorporation of definitions extracted from NFPA 30, Flammable and Combustible Liquids Code, related to classification of flammable and combustible liquids. Add new definitions for "ventilation," extracted from NFPA 30, and "readily accessible." 170

3 NFPA MAY 2000 ROP COMMENT ON AFFIRMATIVE: ROSICKY: Typos under flammable liquid (10 F should be 100 F) and Class I liquid (10 F should be 100 F and should be 100 ). (Log #34) (1-6 Equipment (New)): Accept in Principle SUBMITTER: Barry Thomas, Team Blowtherm RECOMMENDATION: Add the following definition: Equipment - Any pre-engineered sheet metal design that is erected within a building is considered to be equipment. SUBSTANTIATION: In some cases, jurisdictions have argued over who is responsible and what codes have precedence over spray booths. For the spray booth manufacturers of pre-engineered sheet metal, we would consider them as "equipment." COMMITTEE ACTION: Accept in Principle. Revise the definition of "Spray Booth" to read: "A power-ventilated enclosure for a spray application operation or process, that confines and limits the escape of the material being sprayed, including vapors, mists, dusts, and residues that are produced by the spraying operation and conducts or directs these materials to an exhaust system. Spray booths are manufactured in a variety of forms,.including automotive refinishing, downdraft, open-face, traveling, tunnel, and updraft booths. This definition is not intended to limit the term 'spray booth' to any particular design. The entire spray booth ~s part of the spray area. A spray booth is not a spray room." COMMITTEE STATEMENT: The changes made by the Technical Committee better accomplish the submitter's objectives. (Log #CP20) (1-6 Flash-Off Area): Accept RECOMMENDATION: Add a new definition to read as follows: Flash-Off Area. An open or enclosed area located after a spray application process where vapors are released due to exposure to ambient air or a heated atmosphere. SUBSTANTIATION: This definition is needed for proper understanding of new Section SUBSTANTIATION: This definition establishes a new term to apply to those enclosures that do not meet the definition of a limited finishing workstation, spray booth or spray room. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: (Log #CPS) (1-6 Spray Area) : Accept RECOMMENDATION: Revise the definition of Spray Area to read as follows: Spray Area.* Any area in which dangerous quantities of flammable or combustible vapors, mists, residues, dusts, or deposits are present due to the operation of a spray process. It can be either enclosed or unenclosed and includes: (a) Any area in the direct path of a spray application process; and (b) The interior of any exhaust plenum and any exhaust duct leading from the spray process; and (c) The interior of any limited finishing work station, spray booth or spray room, as herein defined. SUBSTANTIATION: This revised definition is necessary, to extend the scope of NFPA 33 to limited finishing workstations. (Log #CP6) (1-6 Spray Area, Unenclosed (New)): Accept I RECOMMENDATION: Add the following new definition: Spray Area, Unenclosed. Any spray area that is not confined by a limited finishing workstation, spray booth, or spray room, as herein defined. SUBSTANTIATION: This definition distinguishes an unenclosed spray area from what the Technical Committee considers to be enclosed spray areas. COMMITTEEACTION: Accept. 28 (Log #CP3) (1-6 Limited Finishing Workstation (New)): Accept RECOMMENDATION: Add the following new definition: Limited Finishing Workstation. An apparatus that is capable of confining the vapors, mists, residues, dusts, or deposits that are generated by a spray application process and that meets the requirements of Section 12-3, but does not meet the requirements of a spray booth or spray room, as herein defined. SUBSTANTIATION: This definition establishes a new term to apply to those enclosures that do not meet the definition of spray booth or spray room, but are not totally unenclosed spray areas. (Log #CP4) $3-10- (1-6 Preparation Workstation (New)): Accept RECOMMENDATION: Add the following new definition: Preparation Workstation. An enclosed, partially enclosed, or unenclosed power-ventilated apparatus that is used to control the dusts and residues generated by surface preparation activities, such as sanding. A preparation workstation is not a limited finishing workstation, spray booth or spray room, as herein defined. (Log #32) (3-1): Accept in Principle SUBMITTER: GeraldJ. Rosicky, IFPS RECOMMENDATION: For the fourth paragraph of Section 3-1, revise the existing sentence "Aluminum shall not be used." to the following: "Aluminum shall not be used for structural suonort members, the booth or room enclosure, and its associated ventilation ductwork. Aluminum may be used for interior comoonents of the booth such platforms, spray apparatus comt)onents, and other ancillary SUBSTANTIATION: Aluminum has long been recognized as a metal that loses its tensile strength under higher heat conditions as compared to steel, as well as having a low melting point [1220 F (660 C)]. I have provided two figures from the NFPA Fire Protection Handbook (18th edition) which details the tensile differences in these two materials at elevated temperatures. These are from pages and concerning metals. At 700 degrees F, aluminum has a tensile strength of only about 4500 psi, whereas steel at the same temperature has tensile strength of 50,000 psi. As a result, if aluminum is used for the supporting members, the booth or room enclosure or its ductwork, there will be structural failure at relatively low elevated temperatures. However, the use of aluminum in the interior would not affect structural stability. Note: Sttppordng material is available for review at NFPA Headquarters. COMMITTEE ACTION: Accept in Principle. 171

4 NFPA MAY 2000 ROP COMMITTEE STATEMENT: This issue has been addressed by Proposal (Log #CP15). (Log #CP15) (3-1): Accept RECOMMENDATION: Replace the fourth paragraph of Section 3-1 with the following text: "Aluminum shall not be used for structural support members or the walls or ceiling of a spray booth or spray room enclosure. Aluminum shall also not be used for ventilation ductwork associated with a spray booth or spray room. Aluminum shall be permitted to be used for interior components, such as platforms, spray apparatus components, and other ancillary devices." SUBSTANTIATION: The Technical Committee recognizes that aluminum loses structural strength at relatively low temperatures and has a low melting point (1220 F or 660 C). At 700 F, aluminum has a tensile strength of only 4500 psi, whereas steel has a tensile strength of 50,000 psi at the same temperature. Thus, if aluminum is used for supporting members, the walls or ceiling, or the ductwork, there will be structural failure at relatively low temperatures should a fire occur. However, use of aluminum components inside the booth would not affect structural integrity of the booth or room. (Log #CP24) (3-1, 3-1.2, 3-1.5, 3-3.2): Accept RECOMMENDATION: Revise the second sentence of Section 3-1 to read: "The interior surfaces of the spray area shall be smooth and shall be designed and installed to prevent pockets that can trap residues, and designed to facilitate ventilation and cleaning." Revise Subsection to read: "Structural sections of spray booths shall be permitted to be sealed with a caulk or sealant to minimize air leakage." Revise Subsection by deleting the word "suitable." Revise Subsection by deledng the word "adequately" in both Exceptions. (Log #CP25) (4-3.2(b), 4-3.5, 4-7): Accept SUBMrFrER: Technical Committee on Finishing Processes RECOMMENDATION: Revise the second sentence of Subsection (b) by replacing the word "properly" with the words "as designed." Revise the first sentence of Subsection to read: "Where spray application equipment and supply containers are located in an area that is venulated at a rate that is sufficient to I maintain the concentration of ignitable vapors in the area at or! below 25 percent of the lower flammable limit,..." Revise Section 4-7 by deleting the word ~readily" in the Exception. COMMITI'EE ACTION: Accept. ( Log #11 ) (4-3.5 and (New)): Accept in Part SUBMITTER: W. H. White, Perrysburg, OH RECOMMENDATION: Revise as follows: Place a comma after the word "equipment" in the first line and add the words "spray gun cleaners" before the words "and supply." Add new section as follows: 8-7.$ Spray gun cleaners using flammable or combustible solvents shall conform to the requirements of Chapter 4, Section SUBSTANTIATION: Spray gun cleaners are widely used in maintenance operations and did not address this equipment. COMMITTEE ACTION: Accept in Part. Accept only the revision to Subsection COMMITTEESTATEMENT: The Technical Committee feels that the change to Subsection is sufficient to meet the intent of the submitter. The change to Subsection is redundant. (Log #30) (4-4.3): Accept SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Light fixtures that are an integral part of the walls or ceiling of a spray area shall be permitted to be separated from the spray area by glass panels that are an integral part of the fixture. Such fixtures shall be listed for use in Class I, Division 2 or Class II, Division 2 locations, whichever is applicable, and also shall be s~ml~,e listecl for accumulations of deposits of combustible residues. Such fixtures shall be permitted to be serviced from inside the sprayarem (See Figure ) SUBSTANTIATION: This change reflects changes to NFPA 70, Chapter 5, temperature ranges now included in the listing (5-2): Reject (Log #8) SUBMI'ITEFa W. H. White, Perrysburg, OH RECOMMENDATION: Add the following to 5.2 after the words confining in the fourth line: "...and removing combustible residues, dusts, and deposits from the point of application and in the direction of the filtration system." SUBSTANTIATION: The word controlling without modifiers does give the authority having jurisdiction adequate guidance. COMMITTEE STATEMENT: The Technical Committee recognizes that this requirement is too onerous and, in fact, cannot be accomplished. The existing performance criteria are sufficient. (Log #CP16) (5-2.2): Accept SUBM1TTER: Technical Committee on Finishing Processes RECOMMENDATION: Correct spelling of the word "powder" and change the reference to Section SUBSTANTIATION: Correction of errors. NUMBER OF COMMITFEE MF.2dBERS ELIGIBLE TO VOTE:

5 NFPA MAY 2000 ROP (Log #CP26) (5-6, ): Accept RECOMMENDATION: Revise Section 5-6, Exception No. 1, by replacing the words "are not likely to" with the words "will not. ~ Revise Section 5-6, Exception No. 2, by replacing the words "shall be unlikely to" with the words "will not" in 1tern (a) and by deleting the parenthetical in (c). Revise Subsection by deleting the word "proper." (Log #25) (5-8): Reject SUBMITTER: western Regional Fire Code Dev. Committee RECOMMENDATION: Revise 5-8 to read: 5-8* Support of Exhaust Ducts. Exhaust ducts shall be supported to prevent collapse under fire conditions and be of non-combustible construction. Aluminum shall not be used. SUBSTANTIATION: The supports for the duct should be capable of supporting the duct m the event of a fire. The supports should be of non-combustible construction and not be permitted to be made of aluminum or other low melting point metals. COMMITTEE STATEMENT: This issue is addressed by NFPA 91, which is referenced by Chapter 5 of NFPA 33. (Log #26) (5-8.1): Reject SUBMITTER= Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Duct supports shall be designed to carry the weight of the duct system itself, plus the anticipated weight of any residues, ff sprinkler protection is provided inside the duct system, then the duct supports also shallbe designed to carry the anticipated weight of any accumulation of sprinkler discharge or an approved drainage system shall be nrovided. SUBS'rANTIATION: Tlais permits the ducts to not support the anticipated weight of the sprinkler discharge if an approved drainage system is provided. Provides and alternative design method. COMMITTEE STATEMENT: This issue is addressed by NFPA 91, which is referenced by Chapter 5 of NFPA 33. (Log #27) (5-8.4): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Exhaust ducts shall not use ~ building walls, floors, ceilings, or roofs as component parts. SUBSTANTIATION: Better clarifies that structural members should not be used as parts of the exhaust duct systems. COMMITTEE STATEMENT: This issue is addressed by NFPA 91, which is referenced by Chapter 5 of NFPA 33. (Log #'28) (5-9): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise 5-9 to read: 5-9 Exhaust Duct Cross Section. Exhaust ducts shall be permitted to be round, rectangular, or any other suitable shape. They shall be provided with doors, panels, or other means Of ~ufficient size. location and number to facilitate inspection, maintenance, cleaning, and access to fire protection devices. SUBSTANTIATION: Better clarifies that the opening must be of sufficient size, location and number to adequately perform the work. COMMrrTEE STATEMENT: This issue is addressed by NFPA 91, which is referenced bzchapter 5 of NFPA 33. (Log #33) ( ): Accept in Principle SUBMITTER: Barry Thomas, Team Blowtherm RECOMMENDATION: Revise text to read as follows: "Where the combined quantifies of liquids located in a spray area and in the mixing room do not exceed 120 gal (454 L)f SUBSTANTIATION: Current equipment utilized in mix rooms including mixing stations, gun cleaners, solvent recyclers, and general solvent for clean-up quickly surpass the 60 gal level. 120 gad is a more reasonable quantity for today's technology and conditions. COMMITTEE ACTION: Accept in Principle. COMMITTEE STATF_aMENT: This issue has been addressed by the Technical Committee's proposed revision of Section 6-3. AFFIRMATIVE: 24 NEGATIVE: 2 EXPLANATION OF NEGATIVE: ROSICKY: The revisions as discussed at the Dallas meeting are not included in the ballot. SHEAz Revise quantity from current 60 gallon capacity to 120 gallons. The revision was based solely on convenience. No consideration was given to increased load of fire hazard within the 9oray area. MMENT ON AFFIRMATIVE: KATUNAR: There was considerable discussion at last committee meeting, but the proposed revisions to Section 6-3 are not included with the minutes or this ballot. (Log #CP27) ( , , 6-4.1, 6-4.3, 6-4.6, 6-5.1, 6-5.3): Accept [ RECOMMENDATION: Revise Subsection to read: "The room shall be provided with continuous mechanical ventilation [ capable of providing not less than 1 c m of air movement per ft ~ of floor area (0.3 m /min/m ) or 150 cfm (4 m /rain), whichever is I greater. The ventilation system shall be operating at all times that the spray area is in use." Revise Subsection to read: "Portable fire extinguishers shall be provided and located in accordance with NFPA 10, Standard for Portable Extinguishers." Revise Subsection by deleting the second sentence. Revise Subsection by deleting the word '~eriodically." Revise Subsection by deleting the words appropriate to the ser~ce." Revise Subsection to read: "Liquids shall be transported by means of closed containers, approved safety cans, approved portable tanks, or shall be transferred by means of a piping system. Open containers shall not be used for moving or storing liquids." Revise Subsection by deleting the words "properly designed." NUMBER OF COIVlMI'I~I'EE MEMBERS ELIGIBLE TO VOTE:

6 NFPA 33 m MAY 2000 ROP (Log #29) (6-4.2): Reject SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: 6-4.2* Piping systems within the spray area shall be of steel or material having comparable heat and physical resistance where possible. Where tubing or hose is used, a ~ shut-off valve shall be provided on the st-eel- pipe at the connection. SUBSTANTIATION: Clarifies that the valve should be metal installed on the piping before the tubing or hose. By deleting the word steel it would require that a valve be installed when comparable materials are used. COMMITTEE STATEMENT: This issue is addressed in Chapter 3 of NFPA 30, which is referenced as a mandatory code in of NFPA 33. (Log #CP1) (6-5.5 Exception (New)): Accept RECOMMENDATION: Add an exception to Subsection to read: "Exception: The following need not meet this requirement. (a) pressure containers less than 6 in. in diameter; (b) pressure containers that operate at less than 15 psig; (c) siphon-type spray cups." SUBSTANTIATION: The devices specified in this exception have been used extensively in the industry with no unusual hazards. They are not covered under the ASME Boiler and Pressure Vessel Code and it is reasonable to allow their continued use, without having to comply with the Code. (Log #17) (%1.3 Exception No. 3 (New)): Reject SUBMITTER: Peter Hohnquist, ATR Industries, Inc. RECOMMENDATION: Add the following Exception: Exception No. 3: In a totally enclosed spray booth with a fire extinguishing system and a directly connected air make-up system. SUBSTANTIATION: While the intent of not interlocking the Air Make-up and spray area exhaust system with the fire alarm/extingmshing system is to keep the fire moving into the containment area of an open front, open top, or open side (i.e., conveyer design) spray booth or spray area, this is not, in our estimation, appropriate for a fully enclosed spray booth. A fully enclosed spray booth can provide containment in a fire condition especially when fire dampers are utilized in both the supply and exhaust ducts and the ventilation system (make-up air fan and exhaust air fan) is cut-out through an interlock, upon a fire alarm or fire condition. Furthermore, utilizing low leak open/close dampers on both the supply and exhaust side will further enhance the fire containment and the flow of air to the fire is virtually eliminated. In addition, the interlock/shut down system eliminates another serious condition of extreme positive or negative air pressure within the enclosed booth structure, in the event that only half of the ventilation system is rendered inoperable due to the fire condition. Many spray booth designs would not be able to sustain the extreme pressurization and would either "explode" or "implode" from the extreme pressure, thereby opening up the fire condition to the surrounding area. It is our firm belief that the safest approach when dealing with a fully enclosed spray booth is to utilize interlocks to shut down both thesupply and exhaust air fans, close both supply and exhaust dampers, utilize fire dampers, and through this containment, render the fire condition too "lean" to burn and allow the extinguishing system to do its job. COMMITTEE STATEMENT: Spray booth fires generate an enormous amount of smoke very rapidly and this smoke will quickly move to surrounding areas if not exhausted. This would severely impair the ability of personnel to evacuate and of fire fighters to effect rescue and fire control. ff enclosed, the possibility of backdraft exists. NOT RETURNED: 2 Bannlster, Johnson (Log #15) (7-2.5): Reject SUBMITrER: Bruce Verhei, Kent, WA RECOMMENDATION: Revise text as follows: "7-2.5 Sprinklers protecting spray areas shall be protected against overspray residue so that they will operate quickly in event of fire. If covered, polyethylene vr zc!!op~rme bags having a thickness of (0.051 mm)... ~... v-r".... ~,~ shall be used. Coverings shall be..." SUBSTANTIATION: 1. Paper bags in a flash fire tend to burn away before sprinkler heads operate, taking more time. Polyethylene bags melt to head allowing faster heat transfer and quicker operation of head. 2. Two mil polyethylene sandwich bags are widely avail'able and inexpensive. 3. Overspray on poly bags is more obvious than on paper. 4. Proposal is cost neutral. COMMITTEE STATEMENT: Testing indicates that both cellophane and thin paper bags are acceptable. (Log #16) (%2.6 (New)): Reject SUBMITTER: Bruce Verhei, Kent, WA RECOMMENDATION: Add new text as follows: Listed quick response sprinklers shall be used. SUBSTANTIATION: 1. Spray booth fires are rapid in build up and usually open all heads in booth, plenum, and duct. If all heads are going to open, it makes sense for them to operate as fast as possible. 2. Quick response heads are coming down in price as usage goes up. Cost in an eight head installation would be about $ COMMITI'EE ACTION: Reject. COMMITTEE STATEMENT: It is the Technical Committee's opinion that the nature of a spray booth fire is such that standard links will operate quickly enough. (Log #CP28) (7-4): Accept SUBM1TTER: Technical Committee on Finishing Processes RECOMMENDATION: Revise Secdon 7-4 to read: "Portable fire extinguishers shall be provided and located in accordance with NFPA 10, Standard for Portable Extinguishers." NUMBER OF COMMITrEE MEMBERS ELIGIBLE TO VOTE:

7 NFPA MAY 2000 ROP COMMENT ON AFFIRMATIVE: SHEA: Revise to reference NFPA 10 pamphlet. Include to read: "...in accordance with NFPA pamphlet 10, Standard for Portable Fire Extinguishers, for Extra High Hazards. Substantiation: Hazards involved with spray applications typically involve high levels of fire loading beyond the typical occupancy. Further, fires which occur in these hazards spread rapidly. The fact that a stand alone standard exists for these hazards demonstrates that they should be considered "High" in nature. (Log #CP18) (8-1.1): Accept RECOMMENDATION: Revise to read as follows: 8-1.1" Spray application operations shall not be conducted outside of predetermined spray areas, _....~... ~'h~+l,7:?i ffdff? ifi'-'. -imination... of confusing:... text. '" (Log #CP7) (8-1.2 (New)): Accept I RECOMMENDATION: Add a new Subsection to read as follows: Inspection of extinguishing systems shall be conducted to ensure that the performance of the extinguishing system components will not be affected by overspray and residues. SUBSTANTIATION: Extinguishing systems have specific maintenance that must be conducted semi-annually to ensure performance of the system and which do not pertain dlrecfly to any components that might be affected by overspray and residues from sprayint~ operations. Examples are: weighing cylinders, checking exfingutshing agent, etc. The intent of this new language is not to require more frequent maintenance, but to ensure the performance of components that are exposed to overspray and residues. AFFIRMATWE: 26 COMMENT ON AFFIRMATIVE: BAYNE: During the next cycle, we should include information on what the appropriate time table should be for the inspection - semi-annual, annual or more frequently. SHEA: Add subsection to read "lr~spection of extinguishing systems shall be conducted to ensure that the performance of the extinguishing system components will not be affected by overspray and residues." Add: "...by a trained person who has undergone the instructions necessary to perform the maintenance and recharge service reliably and has the applicable manufacturer's listed installation and maintenance manual and service bulletins." Substantiation: Remains consistent with NFPA 17. (Log #CP29) (8-4.2, 8-5, 8-7.1, 8-7.2, 8-11): Accept RECOMMENDATION: Revise the second sentence of Section 8-1 by deleting the word "proper " Revise the first sentence of Section 8-3 to read: "High pressure hose lines that convey flammable or combustible coating material in "airless" spray application operations shall be inspected frequently and shall be repaired or replaced, as necessary." Revise Subsection by deledng the word "safe." Revise the second sentence of Section 8-5 by deleting the word "properly." Revise the Exception to Subsection to read: "Solvents having flash points not less than those used in spray operations shall be permitted to be used for cleaning spray nozzles and auxiliary equipment." Revtse Subsection to read: "Cleaning operations using flammable or combustible solvents shall be conducted inside spray areas with ventilating equipment operating or in other adequately ventilated locations that meet the requirements of Subsection 4-3.5)' Revise the first sentence of Section 8-11 by replacing the word "similar" with the word "other." Revise the second sentence of Section 8-11 by deleting the word "proper." (Log #CP$0) (9-1, 9-3.2, 9-3.3, 9-3.4, 9-5.1, 9-3.7, 9-4.1): Accept RECOMMENDATION: Revise the first sentence of Section 9-1 by deleting the word "similar." Revise the first sentence of Subsection to read: "Electrodes and electrostatic atomizing heads shall be insulated from ground." Revise the first sentence of Subsection by deleting the word "properly." Revise the second sentence of Subsection by deleting the word "suitable." Revise the last sentence of Subsection to read: "This requirement shall also apply to any personnel that might enter the spray area " Revise Subsection by deleting the word "adequate." Revise Subsection by deleting the word "adequate." Revise the first sentence of Subsection to read: "Conveyors, hangers, and application equipment shall be arranged so that a minimum separation of at least twice the sparking distance is maintained between the workpiece or material being sprayed and the electrodes, electrostatic atomizing heads, or charged conductors." COMMITTEE ACTION: Accept (Log #22) (9-5): Reject SUBMITTER: Don R. Scarbrough, Elyria, OH RECOMMENDATION: Restore unequivocal language to require that "All electrostatic equipment shall be listed." SUBSTANTIATION: The five largest loss fires in spray painting facilities (two at G.M. Lordstown, two at Ford Lorain, one at G.M. Wilmington) were all ignited by pinhole failures of the paint feed tube. Countless other fires have resulted from the same problem Provisions of current listing procedures require structure that eliminates this ignition hazard along with other features that are attended by proven ignition hazards. Permitting further use of unlisted apparatus further propagates these unwarranted risks to life and property. COMMITTEE STATEMENT: The Commitee Action on Proposal (Log #24) addresses this issue. 175

8 NFPA 33 ~ (Log #6) (9-5.2): Accept in Principle SUBMITTER: Erling L. Horn, Binks Mfg. Company RECOMMENDATION: Revise to read as follows: Spray equipment installed after July 2, 1999, shall be listed. SUBSTANTIATION: We request this amendment for the following reasons. The published date of July 1, 1996 is less than 10 months away. Binks Manufacturing Company and Sanles Electrostatic, Inc. have had meetings and discussions with three (3) listing firms prior to the request for a TIA. We (Binks and Sames) find there is not a protocol published to test incentive equipment covered by our standard. Factory Mutual has a draft standard; however, this test protocol will not be ready for publication and public distribution in time to allow manufacturers to submit equipment for test and approval. Factory Mutual appears to be the sole testing source for listing incentive electrostatic equipment. Factory Mutual indicated to us that all prior listed equipment will have to be re-examined under the light of the new standard when the standard is published. It is not possible for all suppliers to be listed by July 1, 1996, since Factory Mutual may be the only testing source. Binks Manufacturing Company and Sames Electrostatic, Inc. find these circumstances have resulted in an adverse impact on our ability to market our equipment to existing and future customers. We believe that other electrostatic equipment manufacturers have similar concerns with respect to the listing date requirements. We believe Factory Mutual cannot accomplish all the work required to list all of Binks and Sames equipment and other equipment suppliers by July 1, COMMITTEE ACTION: Accept in Principle. Replace the existing Section 9-5 with the following: "9-5 Listing and Approval of Equipment. Spray equipment shall be listed. Exception: Spray equipment that was installed prior to December 31, 1997 shall be listed or approved." COMMITTEE STATEMENT: The action on this proposal incorporates Tentative Interim Amendment 95-1 made to the 1995 edition of NFPA 33. (Log #24) (9-5.2 Exception No. 2 (New)): Accept SUBMITTER: J.J. Mroczka, Ford Motor Co. RECOMMENDATION: Add Exception No. 2 to to read as follows: Exception No. 2: This requirement shall not apply to automatic electrostatic spray equipment where all of the following additional fire protection is provided: (a) The flame detection system shall use optical flame detectors. In addition to the requirements in 7-6(b), the optical flame detection system shall also activate an open head deluge system designed to discharge a minimum density of 0.6 gpm/sq ft (24.4 mm/min) over each affected automated zone. (b) Manual deluge activation stations shall be installed at each personnel entrance to an automated electrostatic spray zone. These devices shall activate the open head deluge system for die "affected antomated zone and accomplish the requirements in 7-6(b). (c) A wet pipe sprinkler system shall also be provided throughout the spray booth. This system shall meet all the applicable requirements of NFPA 13, Standard for the Installation of Sprinkler Systems, for Extra Hazard (Group 2) occupancies. (d) The automated zone open head deluge systems and spray booth wet pipe sprinkler system shall be supplied by separate or dual fed water supply piping. (e) Automatic electrostatic equipment enclosures containing paint delivery systems shall be protected with an approved automatic fire suppression system. Activation of this system shall automatically accomplish the requirements of 7-6(b). SUBSTANTIATION: This protection scheme outlined above has been used throughout the world for over 10 years. In locations where these systems have been installed, there have been no significant fire losses attributed to electrostatic paint spray operations. Fire loss history has proven that the highest probability for fire in an automatic (i.e., electrostatic) paint operation is during non operating periods, when the listed equipment does not provide protection. The fire systems will provide protection. MAY 2000 ROP The objective for requiring and using listed automatic electrostatic paint spray equipment is to reduce the risk to life or property. The protection scheme outlined in the exception provides equivalent protection to life and greater protection to property. Change second sentence of (a) to read: "In addition to the requirements in " COMMITTEE STATEMENT: The minor change is made to delete a confusing and inaccurate reference to AFFIRMATIVE: 25 NEGATIVE: 1 EXPLANATION OF NEGATIVE: DOBSON: The request for Listing exemption does not provide adequate substantiation. The statement is made that "the highest probability of fires in an automatic (i.e., electrostatic) paint operation is during non operatingperiods." The highest frequency of fires in electrostatic spray paint fires reported to Factory Mutual has been during painting operations, ff the statement was correct there would be no difference in hazard between conventional and electrostatic spray equipment. At least one of the major protection systems may not be operating when the operators are in the booth. Flame detection systems and the water spray systems they operate may be bypassed due to concern for accidental operation. Manually operated systems are frequently not operated in the event of a rapid developing, high heat release rate fire. This is due to the concern the operator has in getting out of the fire area. The objective of Listing is to prevent fires. The protection contained in the exemption will not prevent fires and therefore will not offer "equivalent protection to life and greater protection to property." (Log #CP31) ( , , ): Accept SUBMrrTER: Technical Committee on Finishing Processes RECOMMENDATION: Revise Section 10-1 by deleting the word "similar." Revise Section 10-3 to read: "Hand-held electrostatic spray apparatus and devices shall be listed. The high voltage circuits shall be designed so that they cannot produce a spark that is capable of igniting the most hazardous vapor-air mixture or powder-air mixture likely to be encountered and so that they cannot result in an ignition hazard upon coming in contact with a grounded object under all normal operating conditions." Revise Subsection by deleting the word "adequate." Revise the last sentence of Subsection to read: "This requirement shall also apply to any personnel that might enter the area." Revise Subsection by deleting the words "regularly" and "adequate." (Log #CP19) (10-5.2): Accept SUBM1TTER: Technical Committee on Finishing Processes RECOMMENDATION: Revise to read: All electrically conductive objects in the spray area, except those objects required by the process to be at high voltage, shall be electrically connected to ground with a resistance of not more than 1 megohm. This requirement shall apply to containers of coating material, wash cans, guards, hose connectors, brackets, and an~, other electrically conductive objects or devices in the area. This requirement also shall apply to any personnel that m:.~.. ~.~ in enter the area. SUBSTANTIATION: Clarification. 176

9 NFPA 33 m MAY 2000 ROP (Log #7) ( and ): Accept in Part SUBMITTER: W. H. White, Perrysburg, OH RECOMMENDATION: Revise to change the last line to read: "...and the requirements of NFPA 86 as well as the requirements of Sections through " Change to read: "Spraying apparatus, drying apparatus and the ventilating system shall be equipped with interlocks arranged so that the spraying apparatus cannot be operated when drying apparatus is in operation or while portable radiant drying apparatus is in the spray area. SUBSTANTIATION: The Committee vote on the Formal Interpretation on was barely within the limit and these changes should make it clear that 33 does state that compliance with 86 is required. COMMITTEE ACTION: Accept in Part. Accept the proposed text, but in the revision proposed for , delete the phrase "or while portable radiant drying apparatus is in the spray area." Text will now read as follows: "Spraying apparatus, drying apparatus and the ventilating system shall be equipped with interlocks arranged so that the spraying apparatus cannot be operated when drying apparatus is in operation." COMMITTEE STATEMENT: The Technical Committee agrees with this Proposal, but feels that the deleted text is redundant to the preceding language and can be deleted. (Log #12) ( Exception (New)): Accept in Principle SUBMITTER: Larry T. Medler, General Motors - Paint Engr. RECOMMENDATION: Add exception to Paragraph as follows: Exception: Unlisted portable electric infrared heaters shall be permitted on swing arms and/or rail mechanisms provided all of the following conditions have been met: (a) All electrical controls for the infrared heater are placed outside the spray booth. (b) All electrical receptacles and terminal boxes shall be Class 1, Group D, Division 1. (c) During spraying operations the infrared heater head shall be placed in the designated overspray-free area. The spray booths fresh make-up air shall pass through this overspray-free area before going to the actual spray area. (d) An interlock shall be provided to ensure that the heater head is placed in the designated area before any spraying operations may begin. (e) The infrared heater shall not contain any structure cavities which could trap solvent vapors. (f) The painting operation is limited by using only hand held cup (gravity feed or suction feed) spray guns and with the total volume of paint used in an eight hour period to less than one gallon. SUBSTANTIATION: Portable infrared heaters used in spray booths today require the same interlocks and operations as any permanently mounted infrared unit referred to in NFPA 33. This change will clarify the situation of using portable infrared heaters which are mounted (not fixed and unique in the booth) on rails or arms for the operator ergonomics. Currendy no portable electrical infrared heaters are listed per die NFPA 33 requirement and none of the listing agencies have any standards for listing portable electric infrared heaters. COMMITTEE ACTION: Accept in Principle. Reverse the order of Paragraphs and Add new and to read as follows: Radiant drying, curing, or fusion apparatus that is permanently attached to the structure of a spray booth mad is movable, but is suitable only for use in an ordinary hazard (general purpose) location, i.e. is not suitable for a hazardous (classified) location as defined in NFPA 70, National Electrical Code@, shall be permitted to be used provided that: (a) the apparatus can be moved into a pressurized enclosure that meets the requirements for Type X Pressurizing, as specified in NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, and (b) the means of storage is arranged so that solid particulate residues cannot accumulate on any horizontal surface, and (c) interlocks are provided to both prevent the use of the spray application equipment unless.the drying, curing, or fusion apparatus has been moved into the pressurized enclosure and the enclosure has been purged and pressurized in accordance with NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, and to prevent the actuation of the drying, curing, or fusion apparatus when it is located in the enclosure Radiant drying, curing, or fusion apparatus that is permanently attached to the structure of a spray booth and is pendant-mounted or employs the use of a track or similar system, but is suitable only for use in an ordinary hazard (general purpose) location, i.e. is not suitable for a hazardous (classified) location as defined in NFPA 70, National Electrical Code@, shall be permitted to be used provided that all requirements of have been met. In addition, pendant-mounted apparatus shall" be arranged to allow the apparatus, its power cord, and its pendant mount system to be moved into a pressurized enclosure that meets the requirements for Type X Pressurizing, as specified in NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment. Track-mounted systems shall also meet the reqmrements for Type X Pressurizing, as specified in NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment. Renumberexisting and to and COMMITTEE STATEMENT: This proposal provides necessary design criteria to safely allow the use of drying apparatus that is not suitable for hazardous locations in the spray area itself. The Technical Committee's proposed language addresses all of the concerns of the submitter. (Log #CP32) ( , 11-5): Accept I RECOMMENDATION: Revise Subsection by deleting the word "suitable." Revise Section 11-5 to read: "Fusion apparatus shall be ventilated at a rate that is sufficient to maintain the concentration of ignitable vapors in the area at or below 25 percent of the lower flammable limit." (Log #CP21) (11-4): Accept RECOMMENDATION: Add a new Section 11-4 to read: 11-4 Flash-Off Areas The electrical area classification extending into a flash-off area shall meet the requirements for openings specified in Flash-offareas that are heated above ambient temperatures to accelerate release of vapors shall meet the requirements of NFPA 86, Standard for Ovens and Furnaces Open or enclosed, unheated flash-off areas shall be ventilated in accordance with Section Open flash-off areas shall be protected in accordance with the requirements of the occupancy in which they are located Enclosed flash-off areas shall be provided with an approved automatic fire protection system. Renumber current Section 11-4 as 11-6 and relocated accordingly. 177

10 NFPA MAY 2000 ROP SUBSTANTIATION: Currently, NFPA :3:3 lacks any guidance at all on proper treatment of flash-off areas. This addition corrects the deficiency. (Log #18) (Chapter 12): Reject SUBMITTER: Marvin L. Vannier, Faxmetals RECOMMENDATION: Revise text as follows: Chapter 12-1 Miscellaneous operations Spray undercoating of vehicles in garages, conducted in areas having adequate natural or mechanical ventilation, shall be exempt from the requirements of this standard pertaining to spray application operations, where: (a) undercoating materials not more hazardous than kerosene (as classified by Underwriters Laboratories Inc.) in respect to fire hazard rating are used; or (b) undercoating materials using only solvents having a flash point in excess of 100 F (37.8 C) are used; and (c) no open flames are within 20 ft (6100mm) while such operations are conducted Spray undercoating operations that do not meet the requirements of shall meet all applicable requirements of. this standard pertaining to spray application operations Preparation Workstations If spray finishing operations are performed at a preparation workstation, the preparation workstation sfiall be considered an unenclosed spray area and shall meet all requirements of an unenclosed spray area. Exception: A preparation workstation that is designed and operated in accordance with Section 12-3 or 12-4 shall be considered a limited finishing workstation and not an unenclosed spray area Limited Finishing Workstation. A limited finishing workstation shall be designed and operated to meet all the requirements of through or all requirements of The limited finishing workstation shall be constructed to have: (a) a dedicated make-up air supply and air supply plenum; (b) curtains or partitions that are noncombustible, limited combustible, or that meet the requirements of test method 2 of NFPA 701; (c) a dedicated mechanical exhaust and filtration system The amount of material sprayed in a limited finishing workstation shall not exceed 1 gal (3.8L) in any eight-hour period :3 The limited finishing workstation shall meet all applicable requirements of this chapter and all applicable requirements of Chapters 2 through 8 and Chapter Curtains or partitions shall be fully closed during spray application operations. 12-:3.5 The area inside the curtains or partitions shall be considered a Class I Division I, as defined in NFPA 70, National Electrical Code* A Class I, Division 2 or Class II, Division 2 area shall extend horizontally and vertically beyond the volume enclosed by the outside surface of the curtains or partitions as follows: (a) five ft (1525 ram) horizontally and :3 ft (915 mm) vertically, if the spray application equipment is interlocked with the exhaust ventilation system. [See Figure 12-:3.5 (a) ] (b) ten ft (:3050 ram) horizontally and :3 ft (915 mm) vertically, if the spray application equipment is not interlocked with the exhaust ventilation system. [See Figure (b)] The limited finishing workstation used for spray finishing shall not be used for operations that are capable of producing sparks or particles of hot metal or for operations involving open flames or electrical utilization equipment capable of producing sparks or particles of hot metal. 12-:3.7 Drying, curing, or fusion equipment that is permanently attached to a limited finishing workstation and cannot he moved from the classified area defined in shall be listed for the " location in which it is installed and shall be listed for exposure to flammable or combustible vapors, mists, dusts, residues, or deposits. It shall be interlocked with the spray application equipment so that spray operations cannot be conducted while the drying, curing, or fusion equipment is energized. 12-:3.8 Drying, curing, or fusion equipment that is permanently attached to a limited finishing workstation and can be moved out of the classified area defined in 12-:3.5 shall be listed for its intended use, shall be moved out of the classified area whenever spray application operations are being conducted, and shall be interlocked with the spray application equipment so that spray operations cannot be conducted while the drying, curing, or fusion equipment is within the classified area~ The source of electrical power shall be permanently connected to the equipment and shall comply with Sections Portable spot drying, curing or fusion equipment shall be permitted to be used in a limited finishing workstataon, provided that it is not located within the classified area defined in when spray application operations are being conducted A limited finishing workstation which has an air recirculation and purification system shall be capable of meeting all of the following conditions: (1) The work area shall be completely enclosed during any spray application operation and the enclosed area shall not exceed 1,000 cubic ft. (2) The workstation shall have curtains or partitions that are noncombustible, limited combustible, or that meet the requirements of test method 2 of NFPA 701. (3) The workstation shall be equipped with a fully automated listed fire suppression system. (4) The surface area sprayed in the enclosed area at any one time shall be less than 9 square ft. (5) The amount of material sprayed in the enclosed area shall not exceed 1/4 gal (0.95 L) in any elght-hour period. (6) No nitrocellulose-based finishing material shall be sprayed in the enclosed area. (7) A HVLP gun must be used in any spray application operation performed in the enclosed area. (8) The workstation shall be able to bring the air contained in the enclosed area to acceptable OSHA and EPA standards within 20 minutes after cessation of a spray application operation by use of a filtration system that removes particulates and substances that contain various volatile organic chemicals that create vapors. (9) The source of electrical power to the workstation shall be permanently connected to the workstation and all of the workstation's electrical wiring and utilization equipment that is located in the enclosed area shall comply with Chapter 4 of NFPA 33. (10) No equipment or apparatus shall be used in the enclosed area during any spray application operation that produces sparks electrical or otherwise, particles of hot metal or open flames. (11). No spray application operation shall be conducted while drying, curing, or fusion equipment is energized within 20 (6100 mm) ft of the enclosed area. SUBSTANTIATION: Recently, a task group was set up to study NFPA 33 as concerns the automotive refinishing industry and the use of "prep stations" for spray painting of automobiles. The task force unfortunately, only dealt with fixed prep stations and did not consider mobile units or anything involving air recirculation. After the task force made its proposal and recommendations, they passed a TIA which was then passed along to the Standards Committee. The Standards Committee met and heard a lot of evidence and facts that had not been presented to the task group on this issue. It appears that there needs to be two sets of definitions such that one set deals with a fixed limited finishing workstation and the other that deals with a mobile or recirculation workstation. The problem becomes one of application out in the "real world" that cannot be addressed by a strictly adhered to a one dimensional set of rules that only pertains to fixed prep stations that exhaust to the outside and intake from the outside. This was the same problem that the task group faced. There has been tremendous advancements made in the spray painting industry in the last ten years that make it safer than ever, such as: 1. The automotive paint companies have greatly changed the mixture of the paint product and the solvent content, so that there is less "thinners" in the product to be sprayed. This means that there will be less vapors from the solvents to mix with the air during a spray operation and less chance of ignition. 2. The development of HVLP guns for spraying the product which allows the user to apply more of the paint product to the surface and less over spray in the air. This also means less solvents are released in the air during a spray operation, and if the solvent concentrations in the air are less, there is less chance of ignition. Again, this means less danger of fire. 3. The automotive industry has seen a rise in small spot jobs and therefore less of a need to put each and every job into full size paint booth. This has necessitated the industry's need to look at 178

11 NFPA MAY 2000 ROP how to best do small jobs as rapidly as they can and not tie up expensive full size paint booths with a small job. 4. There have been great advancements in the technology with filters mad the filter industry. They are advancing so rapidly that not even all of the filter manufacturers can keep up with the new types of multilayered, chemically treated filters which can remove just about anything by one pass through the filter. Activated carbon filters laminated with potassium catch things that 10 years ago no filter could remove. 5. The Environmental Protection Agency has had a major impact on direct discharge vapors into the atmosphere. This means that there has to be a certain amount of filtering and collection of particulates and vapors that cannot just be puked out into the atmosphere. Therefore, even the full size paint booths have to collect a certain amount of contaminants in their filters and on their walls and in their vents that can no longer just be vented outside. 6. Lastly, there have appeared many uses that unfortunately cannot be easily categorized and make use of full size paint booths no matter how the regulations are written. For them, compliance is impossible. A few examples of these uses are as follows: (a) Remodeling of a shop area at a shopping mall. This is where one tenant at the mall moves out and the landlord wants to remodel the area for the next tenant. When the landlord starts his remodeling, they generally put up plastic sheets to protect the rest of the mall from the dust and fumes as the remodeling project proceeds. Unfortunately, it is impossible to bring a full size paint booth to the area or to take the area to the full size paint booth. Some of these people have taken a recirculation and purification system into the area and while doing the remodeling, let it run by collecting the contaminants in the air and captured the vapors so that they are not released into the rest of the mall area. (b) There are some isolated job sites where small parts need to be painted or prepped and it is unfeasible to move the small parts great distances to accomplish this. An example of this is dam sites and other operations where space is at a premium and the distance to the surface or to adequate locale to paint is unfeasible. Obviously, regulations cannot conceive of every problem that will arise in our society where a full size~aaint booth or fixed preparation workstation will work. There needs to be a balance or tradeoff in the rules and regulations so that society can progress at a reasonable pace without jeopardizing safety by fire or explosion. The task group that looked at "preparations workstationsunfortunately did not see any way that recirculation units could fit into their definitions or feasibilities. I think that if real tests were performed to show the likelihood of fire or loss of life or property in a controlled recirculatlon area as we have set them forth in the proposed 12-4, the risk would be minuscule. There is no reason to pass a regulation like that proposed by the task group, that is an overkill for such a small danger. When you consider the volume of air movement in a recirculation unit, the amount of spray, material used in the given length of time, the rate of evaporation of the particular solvent and the use of the filtration system, recirculation workstations can be safe and can help towards alleviating the problem of "open area spraying". As you can see from our proposal, Sections 12-1 through are pretty much the changes that the task group had proposed. We have merely added Chapter 12-4 to cover recirculation units and all those workstations that involve spray finishing operations to be performed on small areas or spot areas. Recirculation units do not, nor should they ever, replace the use of a full size paint booth. Recirculation units are the answer to some problems that exist in the "real world." We need recirculation units, but they do have to be defined and some limits placed upon their use. We hope that you will consider putting our suggested 12-4 into the new NFPA 33 Edition. We thank you for your time and consideration. COMMITTEE STATEMENT: The Technical Committee has developed new Sections 12-2 and 12-3 to address these units. The Committee's proposed language is more technically valid in light of testing done prior to the development of the text. In addition, the Committee notes that recirculation is already addressed in Section 5-5. Also, while carbon indeed absorbs vapors, it releases those vapors slowly, so exposure can still occur. NOT RETURNED: 2 Bannlster, Johnson (Log #CP8) (12): Accept RECOMMENDATION: Change ~e dfle of Chapter 12 to read "Miscellaneous Spray Operations.' SUBSTANTIATION: Right now, Chapter 12 addresses only one type of spray process and exempts that process from the requirements of NFPA 33. However, there are other processes that should be covered to a limited degree by NFPA 33 and Chapter 12 is the appropriate place to do so. AFFIRMAT WE: 26 (Log #CP9) (12-1): Accept RECOMMENDATION: Revise Section 12-1 to read as follows: 12-1 Vehicle Undercoating and Body Lining Spray undercoating or spray body lining of vehicles that is conducted in an area that has adequate natural or mechanical ventilation shall be exempt from the provisions of this standard, if all of the requirements of through are met: There shall be no open flames or spark-producing equipment within 20 ft (6100 ram) of the spray operation while the spray operation is being conducted There shall be no drying, curing, or fusion apparatus in use within 20 ft (6100 mm) of the spray operation while the spray operation is being conducted Any solvent used for cleaning procedures shall have a flash point not less than 100 F (37.8 C) The coating or lining materials used: (a) shall be no more hazardous than UL Class 30-40, when tested in accordance with UL $40, Test for Comparative Flammability of Liquids; or (b) shall not contain any solvent or component that has a flash point below 100 F (37.8 C); or (c) shall consist only of Class IIIB liquids and shall not include any organic peroxide catalyst. Renumber 12-2 to SUBSTANTIATION: These changes are being proposed to extend the exemption from the requirements of the standard that now exists for automobile undercoating to automobile and truck body lining processes that are no more hazardous than undercoating. After reviewing information on several lining processes, as resented by industry representatives, the Technical Committee on ~ inishing Processes has concluded that body lining and undercoating processes are of equal nature and hazard and the exemption should logically apply to both. (Log #20) (12-1 and 12-2): Reject SUBMIXTER: Charles Van Rickley, Rhinolinings U.S.A. RECOMMENDATION: Revise and add text to Chapter 12 as follows: Chapter 12 Automobile Undercoating "~ C:ra~cz Annlied Polyurethane Plural-Comnonent Coatings General The application of-~pray undercoating of... L:,^. :... and snrav annlied Polyurethane nluralcomnonent coatings in buildings, conducted in areas having adequate natural or mechanical ventilation, shall be exempt from the requirements of this standard pertaining to spray coating operations, where: (a) (remains the same); or (b) (remains the same); am#or (c) Spray ~pplied polyurethane plural-comoonent coatines using only Class III-B materials and utilizinv no organic oeroxide Catalysts or flammable solvents are used: and e~ (remains the same) 179

12 NFPA MAY 2000 ROP 12-2 Non-complying Undercoating or Spray Applied Coatin~ Operations. Spray applied undercoating 9r spray applied polyrurethane coating operations that do not meet the requirements of Section 12-1 shall meet all applicable requirements of this standard pertaining to spray finishing operations. SUBSTANTIATION: Sprayable coating materials and spray processes have been developed, and are in wide use, that consist of two or more Class III-B materials, and utilize no organic peroxide catalysts or flammable solvents. The components of these products are mixed at the spray nozzle, and use low air pressure for delivery to the substrate. These processes present a lower hazard than the presently exempted Automobile Undercoating. Although it appears that this standard is not intended to regulate this type of process, enforcement confusion among authorities having Jurisdiction's requires this process to be addressed. COMMITTEE STATEMENT: This proposal is too product specific. Other systems are available and are being used that are of equal safety. The Technical Committee's proposed amendments to the Chapter 12 adequately address the issue. NUMBER OF COMMrI'TEE MEMBERS ELIGIBLE TO VOTE: 28 (Log #23) (12-1.2): Reject SUBMITTER: Claudio Burtin, Burtin Polyurethanes, Inc. RECOMMENDATION: Line-X spray-in bedliners should be added in next to "undercoatings" as exempt. SUBSTANTIATION: Spray-in truck bedliners should be exempt from Chapter 12 of NFPA 33. A spray-in bedliner has a flash point in excess of 100 degrees with no question, and it contains no solvents. The undercoating materials are much less hazardous than kerosene. I have provided copies of Material Safety Data Sheets concerning spray-in bedliners. Note: Supporting material is available for review at NFPA Headquarters. COMMITTEE STATEMENT: The proposal is too product specific. 7qUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 28 (Log #CP11) (12-3 (New)): Accept RECOMMENDATION: Add the following new Section 12-3: 12-3 Limited Finishing Workstations. A limited finishing workstation shall be designed and operated in accordance with the requirements of 12-$.1 through A limited finishing workstation shall be designed and constructed to have: (a) a dedicated make-up air supply and air supply plenum; and (b) curtains or partitions that are noncombustible or limited combustible, as defined in NFPA 220, or that can successfully pass Test Method 2 of NFPA 701; and (c) a dedicated mechanical exhaust and filtration system; and (d) an approved automatic extinguishing system that meets the requirements of Chapter The amount of material sprayed in a limited finishing workstation shall not exceed I gal (3.8 L) in any eight-hour period The limited finishing workstation shall meet all applicable requirements of Chapters 2 through 8 and Chapter 16 of this standard Curtains or partitions shall be fully closed during any spray application operations The area inside the curtains or partitions shall be considered a Class l, Division 1 or Class II, Division 1 hazardous (classified) location, as defined by NFPA 70, National Electrical Code. A Class I, Division 2 or Class II, Division 2 hazardous (classified) location shall extend horizontally and vertically beyond the volume enclosed by the outside surface of the curtains or partitions as follows: (a) Five ft (1525 ram) horizontally and $ ft (915 mm) vertically, if the spray application equipment is interlocked with the exhaust ventilation system. [See Figure (a).] Dedicated mechanical exhaust system - ~ ~------'-~'~, Dedicated make-up /q~_,,p'*~,.,,~ "~.. air supply system, "...A ~ "~-." Air supply,,'7"..16,,~ %.. J[[~ ~,.. plenum 'J.tt'~"~'-'~. I.t~lU~"~ "-'.-./ L, ;~: II P~'-."~F-~J~ /~.-'... Curtains (Log #CP10) (12-2 (New)): Accept RECOMMENDATION: Add the following new Section 12-2: 12-2 Preparation Workstations. If spray finishing operations are performed at or in a preparation workstation, the preparation workstation shall be considered an unenclosed spray area and shall meet all requirements of an unenclosed spray arem Exception: A preparation workstation that is designed and operated in accordance with Section 12-B shall be considered a limited finishing workstation and not an unenclosed spray arem SUBSTANTIATION: This new section provides guidance for application of the requirements of NFPA 33 to work stations that are intended for surface preparation only, but are sometimes used for minor spraying. Since these units are not designed in accordance with the requirements for enclosed spray areas, they must be considered unenclosed spray areas, if used for such activities. %1 s J I / -. = ",% " Extent of Class I, ". = / Division 2 area "-,L...~ F'~ure (a) (b) Ten ft (3050 mm) horizontally and 3 ft (915 mm) vertically, if the spray application equipment is not interlocked with the exhaust ventilation system. [See Figure (b).],,I I 180

13 Dedicated mechanical exhaust system NFPA MAY ", ~, -. Dedtcated make-up Ii r~ _~---~. "'. air supply system / ",~-- [ ~lll[.~/ ~" "X~a"". "-. plenum, -... ><..!, ',.^.~"~ ( ('~'~.~'{"~ 3~',} l]-t'"curtains,',t j "',"~( ) ] bk'~/ (t ~i-p~ I1,/ I """.! loft s Extent of Class I, -..- Division 2 area -. I/ Figure 12-S.5(b) For the purposes of this subsection, "interlocked" shall mean that the spray application equipment cannot be operated unless the exhaust ventilation system is operating and functioning properly and spray application is automatically stopped if the exhaust ventilation system fails Any limited finishing workstation used for spra)' application operations shall not be used for any operatmn that is capable of producing sparks or particles of hot metal or for operations that involve open flames or electrical utilization equipment capable of producing sparks or particles of hot metal Drying, curing, or fusion apparatus that is permanently attached to a limited finishing workstation and cannot be removed from the hazardous (classified) location defined in shall be listed for the location in which it is installed and shall be listed for exposure to flammable or combustible vapors, mists, dusts, residues, and deposits. The apparatus shall be interlocked with the spray application equipment so that spray operations cannot be conducted while the drying, curing, or fusion apparatus is energized Drying, curing, or fusion apparatus that is permanently attached to a limited finishing workstation, but can be moved out of the hazardous (classified) location defined in , shall be listed for its intended use, shall be moved out of the hazardous (classified) location whenever spray application operations are being conducted, and shall be interlocked with the spray application equipment so that spray operations cannot be conducted while the drying, curing, or fusion apparatus is within the hazardous (classified) location. The source of electrical power shall be permanently connected to the equipment and shall comply with Section Portable spot-drying, curing, or fusion apparatus shall be permitted to be used in a limited finishing workstation, provided that it is not located within the hazardous (classified) location defined in when spray application operations are being conducted Recirculation of exhaust air shall be permitted only if all provisions of Section 5-5 are met. SUBSTANTIATION: Recently, the automotive refinishing industry has begun using so-called "prep stations" for spray painting of automobiles. Prep stations were initially intended and designed to provide a structure in which surface preparation (sanding, grinding, body-filler work) could be done and to provide some ventilation and filtration, so that fugitive dust could be controlled and not affect other areas of the shop. As use of these units expanded, shops began using them as inexpensive alternatives to a spray booth, as defined and governed by NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials. Initially, the use was limited to spot priming and minor painting. However, this has evolved to the point where some shops use them instead of paint spray booths for all refinishing work, and some 2000 ROP manufacturers openly advertise them as suitable for all spray finishing operations. Use of these prep stations is not currently addressed in NFPA 33, and NFPA 33 considers them to be open spray areas, regardless of any enclosure that might be provided. Typically, confinement is provided only by a flexible curtain or in some cases by an air curtain. These units typically meet few, if any, of NFPA 3Ys requirements for spray booths in such areas as construction, electrical equipment, exhaust ventilation, and fire protection. A Tentative Interin~ Amendment to the 1995 edition of NFPA 33 to address these units was not successful. The Technical Committee has revised its initial proposals and has established two classes of units: limited finishing workstation and preparation workstation, and has developed appropriate requirements for the former. This proposal properly identifies a preparation workstation as being equivalent to an open spray area and having to meet the requirements in NFPA 33 for such use, while establishing appropriate fire safety requirements for the limited finishing workstation. (Log #CP33) (13-1, 13-4, 13-5, , (a), , , , 13-11, , , ): Accept SUBMITrER: Technical Committee on Finishing Processes RECOMMENDATION: Revise Section 13-1 by moving the second and third sentences to the Appendix. Revise Section 154 by deleting the words "properly designed." Revise Section 13-5 by deleting the word "adequately" in both places. Revise the last sentence of Subsection to read: "This requirement shall also apply to any personnel that might enter the area." Revise the first sentence of Subsection (a) by deleting the word "safely." Revise Subsection to read: "The ventilation system shall confine air-suspended powder to the booth and the recovery system at all times." Revise Subsection to read: "Surfaces shall be cleaned in a manner that does not scatter powder or create dust clouds." Revise Subsection by replacing the word "iron" with the word "metal." Revise Section by replacing the words "of sufficient intensity to ignite" with the words "capable of igniting." Revise Subsection to read: "The high voltage circuits shall be designed so that any discharge produced when the charging electrodes of the bed are approached or contacted by a grounded object cannot produce a spark that is capable of igniting the most hazardous powder-air mixture likely to be encountered and so that they cannot result in a shock hazard." Revise the second sentence of Subsection to read: "This requirement shall also apply to any personnel that might enter the area." Revise Subsection by deleting the words "proper" and "regularly." (Log #31) (13-6.1): Accept in Principle SUBMITTER: Western Regional Fire Code Dev. Committee RECOMMENDATION: Revise to read: Electrical equipment and other sources of ignition shall meet both the requirements of Chapter 4 of this standard and Articles 500 m~ao-~through 505 and 516 of NFPA 70, National Electrical Code. 181

14 NFPA 33 m MAY 2000 ROP SUBSTANTIATION: This change reflects changes made in NFPA 70. COMMITTEE ACTION: Accept in Principle. Revise to read: "Electrical utilization equipment and other sources of ignition shall meet both the requirements of Chapter 4 of this standard and Articles 500, 502, 504, and 516 of NFPA 70, National Electrical Code, as applicable." COMMITTEE STATEMENT: This change provides more correct references to the proper sections of NFPA 70. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: 98 (Log #13) (13-7.2): Accept in Principle SUBMITTER: Jeffery W. Sutton, Liberty Mutual Group RECOMMENDATION: Revise paragraph and add the appropriate appendix items as follows: Dust collectors, whether remote or integrated with the spray booth, used to collect powder overspray shall be provided with explosion protection by one of the following means: (a)* Locate the dust collector outside and equip it with deflagration vents. (b)* Locate the dust collector inside a room constructed of damage limiting construction (interior walls pressure resistant and exterior walls pressure relieving). (c)* Locate the dust collector inside the building next to an exterior wall and equip the dust collector with deflagration vents that are ducted to the outside through vent ducts. (d) Install a deflagration suppression system on the dust collector in accordance with Chapter 4 of NFPA 69, Standard for Explosion Prevention Systems. (e) Design the dust collector to contain a deflagration in accordance with Chapter 5 of NFPA 69, Standard for Explosion Prevention Systems. Exception: FM Approved powder coating booths with integrated recovery systems that have been demonstrated not to have a dust explosion potential do not need explosion protection. A (a) Where explosion venting is used, its design should be based on information contained in NFPA 68, Guide for Venting of Deflagrations. A (b) Damage limiting construction should be designed based on information contained in Chapter 4 of NFPA 68, Guide for Venting of Deflagrations. Pred will represent the pressure the pressure resistant components can withstand and Pstat will represent the pressure the pressure relieving components will relieve at. A (c) Where explosion venting is used, its design should be based on information contained in NFPA 68, Guide for Venting of Deflagrations. For explosion relief venting through ducts, consideration should be given to the reduction in explosion venting efficiency caused by the ducts. The ducts should be designed with a cross-sectional area at least as large as the vent, should be structurally as strong as the dust collector and should be limited in length to 20 ft. Since any bends will cause increases in the pressure developed during venting, vent ducts should be as straight as possible. If bends are unavoidable, they should be as shallow angled (i.e., have as long a radius) as practical. SUBSTANTIATION: The majority of powders used in powder coating operations are combustible dusts and do present a dust explosion hazard where they are being used and collected. Ventilation can usually be used to control this hazard in the spray booth and connecting ductwork used in the ventilation / recovery system. However, ventilation cannot be used to adequately control this hazard in the dust collector where the powder is recovered. Therefore, explosion protection is needed on these collectors. Currently, NFPA 33 does not specifically require this. It might be inferred from paragraph , but this paragraph is extremely vague on what needs to be protected and then, it only allows one option on protection, deflagration venting. NFPA 69 does provide other alternatives. This proposal addresses these problems by specifically requiring explosion protection on dust collectors and then provides various options for protection. The current tries to address the issue of spray booths with integrated powder recovery systems by stating that protection measures should be applied. The only exception Iknow to this is that there are some FM Approved booths with integrated recovery systems that have been specifically tested to show that they do not have an explosion hazard and therefore do not need protection. I do not know if any other testing organizations have done similar work. If the committee knows of such work, the exception can be modified accordingly. COMMITTEE ACTION: Accept in Principle. Revise Section 13-7 to read as follows: 13-7" Ventilation, Dust Collection, and Explosion Protection Ductwork. Where powder overspray in conveyed by means of ductwork to a remote recovery system, the following shall apply: (a) Nondeposited, air-suspended powders shall be removed form the spray operation to the powder recovery system. For systems connected by ducts to enclosed collectors, sufficient airflow shall be provided to maintain the exhaust duct at a powder concentration that will not exceed one-half the "minimum explosive concentration" (MEC) of the powder in use. [See (b) for exception]. If the MEC of the powder has not been established, then the exhaust duct powder concentration shall be maintained below oz/ft 3 (15 g/m3). Exhaust equipment shall bear an identification plate stating the ventilation rate for which it was designed (ft3/m3/hr). (b) Where, by design, the coating operation is conducted at an exhaust duct concentration above 50 percent of the MEC, listed explosion suppression equipment shall be provided. (See NFPA 69, Standard on Explosion Prevention Systems.) Air exhausted from the recovery system of a powder operation shall not be recirculated unless the concentration of particulate matter in the exhaust air has been reduced to a level that is considered safe for personnel occupational exposure and suitable equipment continuously monitors the filtration system to signal the operator and to automatically shut down the operation in the event the filtration system fails to maintain the air in this condition " Enclosures. Enclosures shall either be listed for the specific application or shall be designed to resist the destructive effects of an internal deflagration. Any enclosure that is not so listed and is effectively tight, such as a spray booth, dust collector, powder recovery device, or other enclosure, shall be provided with one of the following: (a) Deflagration venting. (b) A deflagration suppression system that meets the requirements of NFPA 69, Standard on Explosion Prevention Systems Ventilation for fluidized beds and electrostatic fluidized beds shall be designed to effectively prevent escape of nondeposited powder from the enclosure Ventilation for spray booths shall be adequate to confine air-suspended powder to the booth and recovery system at all times. A A "tight" enclosure is one in which a deflagration is likely to produce a sustained overpressure of 0.1 psi. See NFPA 68, Guide for Venting of Deflagrations, for information on the design of deflagration vents. COMMITTEE STATEMENT: The Technical Committee has revised the entire section to effect editorial improvement and to address the issues raised by the submitter. The substantive changes made by the Technical Committee provide additional flexibility (13-7.4): Reject (Log #14) SUBMITrER: Jeffery W. Sutton, Liberty Mutual Group RECOMMENDATION: Revise paragraph and add the appropriate appendix items as follows: Powder coating booths where ventilation cannot keep the interior of the booth below 50 percent of the MEC shall be provided with explosion protection by one of the following means. (a)* Locate the spray booth inside a room constructed of damage limiting construction (interior walls pressure resistant and exterior walls pressure relieving) or design the booth of damage limiting construction provided the relieving wail(s) relieve outside. (b)* Locate the spray booth inside the building next to an exterior wall and equip the booth with deflagration vents that are ducted to the outside through vent ducts. (c) Install a deflagration suppression system on the spray booth in accordance with Chapter 4 of NFPA 69, Standard for Explosion Prevention Systems. 182

15 NFPA MAY 2000 ROP (d) Design the spray booth to contain a deflagration in accordance with Chapter 5 of NFDA 69, Standard for Explosion Prevention Systems. A (a) Damage limiting construction should be designed based on information contained in Chapter 4 of NFPA 68, Guide for Venting of Detlagrations. Pred will represent the pressure the pressure resistant components can withstand and Pstat will represent the pressure the pressure relieving components will relieve at. A (b) Where explosion venting is used, its design should he based on information contained in NFPA 68, Guide for Venting of Deflagrations. For explosion relief venting through ducts, consideration should be given to the reduction in explosion venting efficiency cansedby the ducts. The ducts should be designed with a cross-sectional area at least as large as the vent, should be structurally as strong as the spray booth and should be limited in length to 20 ft. Since any bends will cause increases in the pressure developed during venting, vent ducts should be as straight as possible. If bends are unavoidable, they should be as shallow angled (i.e. have as long a radius) as practical. SUBSTANTIATION: Often times, ventilation can be designed to keep the interior of a powder coating booth below 50 percent of themec of the powder, thereby reducing the need for explosion protection. However, in some instances, such aa when the spray patterns from spray guns account for a good portion of the booth volume, ventilation cannot be used effectively to reduce the powder concentration below 50 percent of the MEC~ In instances such as these, explosion protecuon should be applied to the booth. The current is vague onjust what requires protection and then only allows deflagration venting. This proposal is specific on what needs protection and it preatenm options on different types of explosion protection that can be used, COMMITTEE ACTION'Reject. COMMITTEE STATEMENT: NFPA 68, Guide for Venting of Deflagcations, does not apply to deflagration pressure containment; this is covered by NFPA 69, Standard on Explosion Prevention Systems. In agldition, this proposal is to specific and ignores other equally effective protection measures. NUMBER OF COMMn'rF~ MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON C O ~ ACTION: (Log #CPM) (14-3, , 14-5): Accept SUBMITTER: Technical Comnuttee on Finishing Processes RECOMMENDATION: Revise the first sentence of Section 14-$ to read: "Measures shall be taken toprevent..." Revise the first sentence of Subsection t4-$.2 to read: i "Measures shall he taken to prevent..." Delete the second I sentence. Revise Section 14-5 to read: ~Measures shall be taken to ~revent..." UBSTANTIATION: The.proposed changes are editorial in nature. They accomplish the following obj~ective;, replacement of NUMBER OF COMMrITEE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMrrTEE ACTION: (Log #cpss) (15-5.2, , , ): Accept SUBMITIT~ Technical Committee on F'mishing Processes RECOMMENDATION: Revise the second sentence of Sul:eection to read: - "...for the hazardous (classilied) location involved." Revise Subsection by deleting the words "can readily." Revise Subsection by deleting the words "be readily." Revise Subsection by delet~g the word "properly.* nature. They accomplish the following objective;, replacement of COMMnWI~ ACTION: Accept. NUMBER OF COMMITTEE MEMBEILS ELIGIBLE TO VOTE: 28 AFFIRMATIV~ 26 (Log ~]) $ (Chapter 16): Reject SUBMITTER: Charles VKn Ricldey, Rhinolinings U.S.A. RECOMMENDATION: Add new text to Chapter 16 as follows. Renumber the existing Chapter 16 text and following text accordingly. Chapter 16. Polyurethane Plural Component Coatings 16-1 Scope. Thts Chapter shall apply to plural component spray application operations that involve only Class III-B combustible components, utilizing no organic peroxide catalysts or flammable solvents, to form a polyurethane composite coaung General. Spra~t application of polyurethane coatings conducted'in areas with adequate natural or mechanical ventilation shall be exempt from the requirements of this standard pertaining to spray coating operations. 16-$ Ventilations. Enclosed spraying areas shall be provided with mechanical ventilation adequate to prevent the dangerous accumulation of vapors and particles. Mechanical ventilation shall be kept in operation at all times while spraying operations are being conducted. ExCeption: Buildings or enclosed spraying areas that are not enclosed for at Kmst three-quarters oftheirperimeter shall not be required to meet this requirement. 164 Non-complying Plural Component Coating OperationL Plural component spray operations that do not meet the requirements of Sectlon 16.1 shall meet all applicable requirements of this standard pertaining to spray finishing operafiom. SUBSTANTIATION: Sprayable coating materials and spray procemes have been developed, and are in wide use, that consist of two or more Clan III-B materials, and utilize no organic peroxide catalysts or flammable mlven~ The components of thele products are mixed at the spray nozzle, and use low air pressure for delivery to the substrate. These procemes present a lower hazard than the presently exempted Automobile Undercoating. Although it appears that this standard is not intended to regulate tits type of process, enforcement confusion among Authority Having Jurisdiction's requires this process to be addressed. COMMITTEE AL'TION: Reject. COMMITTEE STATEMENTt This proposal is too specific to one type of product. In addition, the Technical Committee has developed its own proposed amendments to Chapter 12. These amendments better addres this issue. NUMBER OF COMMrlWEE MEMBERS ELIGIBLE TO VOTE: 28 AFFIRMATIV~ 26 (Log #CP$6) (16-1.1, ): Accept SUBMITTER: Technical Committee on Finishing Procemes [ RECOMMENDATION: Revise Subsection to read: [ "...as well as emergency procedures." [ Revise Suhsection by deleting the words "some appropriate ]form of." uamre. They accomplish the following objective; replacement of COMMYITEE ACTION: Accept. NUMBER OF COMMITrEg MEMBEI~ ELIGIBLE TO VOTE: 28 VOTE ON COMMITrF~ ACTION: AFFIRMATIV~ 26 (Log#C~17) (A-7-1 (New)): Accept S ~ Technical Committee on Finishing Processes ] RECOMMENDATION: Add an appendix note to read: I W'dtration will not prevent the accumulation of residues in the ] exhaust duct." SUBSTANTIATION: This is to clarify why protection is required in the duct. 183

16 NFPA 33/34 m MAY 2000 ROP (Log #9) (A (New)): Accept in Principle SUBMITTER: W. H. White, Perrysburg, OH RECOMMENDATION: The following will be new appendix material: 7-2.5* Residues will accumulate in the ductwork of any spray booth and since the duct work is part of a spray area, it must be protected. This includes ductwork from water wash booths. SUBSTANTIATION: The committee felt that it was not clear whether or not water wash booths were required to be protected. COMMITTEE ACTION: Accept in Principle. Revise Section 7-1 to read: "7-1 General.* Spray areas, which include by definition the ~ associated exhaust plenums and exhaust ductwork, and mixing!rooms shall be protected with an approved automatic fire extinguishing system. A-7-1 Regardless of filtration, residues will accumulate in the exhaust ductwork. Since the ductwork is part of the spray area, it must be protected. This includes the ductwork from a water-wash booth." COMMITTEE STATEMENT: The Technical Committee's version more clearly expresses the intent of the submitter. ilog #CP2) (A-11-3 (New)): Accept RECOMMENDATION: Add the following Appendix paragraph to Section A-11-3: "When a spray booth or spray room is used for drying or curing at elevated temperatures in accordance with Section 11-3, it is considered a "Class A" oven or furnace as defined by NFPA 86, Standard for Ovens and Furnaces. The requirements specified by NFPA 86 must be given careful consideration in the design and operation of this equipment, due to the potential for increased fuel load in the booth or room, the exhaust plenum, and associated exhaust ductwork." SUBSTANTIATION: This Appendix text will further clarify the reasons for the cross reference to NFPA 86. (Log #CP12) (A-15-3 (New)): Accept SUBMITTER= Technical Committee on Finishing Processes RECOMMENDATION: Add a new Appendix Item A-15-3 to Section 15-3 to read as follows: A-15-3 The determination by the Technical Committee on Finishing Processes that Ordinary Hazard (Group 2) sprinkler design density is sufficient for protecting spray application of styrene cross-linked thermoset resins (commonly known as glass fiber reinforced plastics) is based on several factors: 1. Although the styrene monomer that is a component in unsatucate~t polyester resin is a Class [ flammable liquid by definition, actual burn tests reveal that the resin does not readily ignite and burns slowly when it does ignite. 2. Tests of resin application areas have shown that the processes do not produce vapors that exceed 25 percent of the lower flammable limit (lfl). Resin application tests have also indicated that the maximum levels of vapor concentrations are about 690 parts per million (ppm) for spray applica:tion. The tests were conducted in an enclosed area with no ventilation. This concentration is much less than 25 percent of the lfl, which is 11,000 ppm for styrene. SUBSTANTIATION: This text explains the Technical Committee's rationale for not reqmring Extra Hazard (Group 2) sprinkler systems for resin application areas. This also satisfies a directive from the NFPA Standards Council to provide such a rationale. NUMBER OF COMMITTEE MEMBERS ELIGIBLE TO VOTE: NFPA 33 Editorial Corrections The Technical Committee on Finishing Processes proposes the following editorial changes to NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2000 edition. 1. Section 1-6 Delete "A power ventilated enclosure for a spray application or process " at the end of the definition "Spray Booth". 2. Section (b) The word "or" should be added to the end of this line. 3. Section At the very end of this sub-section, the words "this chapter and all applicable requirements" are out of place and should be deleted. 4. Section Change wording in recommendation to read "Section 13-7", to correct the reference. 5. Section 10-3 The word "shock" should be replaced with the word "ignition". NFPA 34 (Log #CP1) (1-1.2 Exception): Accept SUBM1TTER: Technical Committee on Finishing Processes I RECOMMENDATION: Delete the exception. SUBSTANTIATION: This correlates with the addition of new Subsection (Log #CP2) (1-1.3): Accept RECOMMENDATION: Replace existing Subsection with the following: "Tiffs standard shall also apply to the use of water-borne, waterbased, and water-reducible materials that contain flammable or combustible liquids or that produce combustible deposits or residues. Exception: This standard shall not apply to the use of a liquid that does not have a fire point when tested in accordance with ASTM D 92, Standard Test Method for Flash and Fire Points by Cleveland Open Cup up to the boiling point of the liquid or up to a temperature at which the sample being tested shows an obvious physical change." SUBSTANTIATION: This new addition to the scope clarifies applicability of NFPA 33 to the subject coatings. The replacement text is no longer relevant. Quench tanks are no longer covered in NFPA 34. (Log #CPS) (1-2.1): Accept RECOMMENDATION: In 1-2.1, delete the word"reasonable" in the first sentence. ambiguous text

17 NFPA MAY 2000 ROP Log #CP10) (1-6 Definitions): Accept RECOMMENDATION: Make the following changes to NFPA : In Section 1-6, replace the definition of'boiling Point" with the following: "Boiling Point. x The temperature at which the vapor pressure of a liquid equals the surrounding atmospheric pressure. For purposes of defining the boiling point, atmospheric pressure shall be considered to be 14.7 psia (760 mm Hg). For mixtures that do not have a constant boiling point, the 20 percent evaporated point of a distillation performed in accordance with ASTM D 86 Standard Method of Test for Distillation of Petroleum Products, shall be considered the boiling point. (NFPA 30, 1-7.2)" In Section 1-6, replace the definition of"detearing" with the following: "Detearing. A process fbr removing excess wet coating material from the bottom edge of a dipped or coated object or material by passing it through an electrostatic field." In Section 1-6, amend the definition of'flow Coating" by deleting the word"similar." In Section 1-6, replace the definitions of'labeled" and"listed" with the standard NFPA definitions. In Section 1-6, replace the definition of'liquid" with the following: "Liquid. x Any material that has a fluidity greater than that of 300 )enetration asphalt when tested in accordance with ASTM D5, Test for Penetration for Bituminous Materials. Flammable Liquid. Any liquid that has a closed-cup flash point below 100 F (37.8 C), as determined by the test procedures and apparatus set forth in Flammable liquids shall be classified as Class I as follows: Class I Liquid. Any liquid that has a closed-cup flash point below 100 F (37.8 C) and a Reid vapor pressure not exceeding 40 psia ( mm Hg) at 100 F (37.8 C), as determined by ASTM D323, Standard Method of Test for Vapor Pressure of Petroleum Products (Reid Method). Class I liquids shall be further classified as follows: Class IA liquids shall include those liquids that have flash points below 73 F (22.8 C) aml boiling points below 100 F (37.8 C). Class 1B liquids shall include those liquids that have flash points below 73 F (22.8 C) and boiling points at or above 100 F (37.8 C). Class 1C liquids shall include those liquids that have flash points ~' at or above 73 F (22.8 C), but below 100 F (37.8 C). Combustible Liquid. A combustible liquid shall be defined as any liquid that has a closed-cup flash point at or above 100 F (37.8 C), as determined by the test procedures and apparatus set Forth in Combustible liquids shall be classified as Class II or Class III as follows: Class II Liquid. Any liquid that has a flash point at or above 100 F (37.8 C) and below 140 F (60 C). Class IliA. Any liquid that has a flash point at or above 140 F (60 C), but below 200 F (93 C). Class IIIB. Any liquid that has a flash point at or above 200 F (93 C). (NFPA 30, AND 1-7.3)" In Section 1-6, add a new definition to read as follows: "Ventilation. x As specified in this code, movement of air that is provided for the prevention of fire and explosion. It is considered adequate if it is sufficient to prevent accumulation of significant quantities of vapor-air mixtures in concentrations over one-fourth of the lower flammable limit. (NFPA 30, 1-6) nature. They accomplish the following objectives: * Replacement of ambiguous text. Incorporation of standard NFPA definitions. Incorporation of definitions extracted from NFPA 30, Flammable and Combustible Liquids Code, related to classification of flammable and combustible liquids. Addition of a new definition for"ventilation," extracted from NFPA 30 COMMENT ON AFFIRMATIVE: EUSON: Thp proposed NFPA 34 document sent out prior to the last committee meeting indicates that the definitions of'listed" and"labeled" were changed by committee vote; but these are not included in this list of changes. (Log #CP11) (3-3, ): Accept RECOMMENDATION: In Section 3-3, replace the word"should" with the word"if." Amend Subsection to read: "Heating and cooling units for liquids shall be of an approved type and shall be controlled, serviced, and maintained in accordance with the manufacturers' instructions." ambiguous text. (Log #CP12) (4-3.2, 4-4): Accept RECOMMENDATION: Amend the first sentence of Subsection to read: "The space adjacent to an enclosed dipping or coating process or apparatus shall be classified as nonhazardous for purposes of electrical installations." Retain the existing exception. In the first sentence of Section 4-4, delete the word"adequately." ambiguous text. (Log #CP13) (5-2, 5-2.1): Accept RECOMMENDATION: Amend the second sentence of Section 5-2 to read: "The concentration of the vapors in the exhaust air stream shall not exceed 25 percent of the lower flammable limit." Amend Subsection by deleting the phrase"physical size of a." ambiguous text. (Log #CP14) (6-4): Accept I RECOMMENDATION: In the first sentence of Section 6-4, delete the phrase"properly arranged." ambiguous text. (Log #CP7) (7-3): Accept SUBM1TTER: Technical Committee on Finishing Processes I RECOMMENDATION: Delete current text in Section 7-3 and replace with the following: 7-3 Portable Fire Extinguishers. Portable fire extinguishers shall be provided and located in accordance with NFPA 10, Standard for Portable Extinguishers. 185

18 NFPA 34 ~ SUBSTANTIATION: This correlates with an identical change in NFPA 33. COMMENT ON AFFIRMATIVE: SHEA: Change to read: "Portable fire extinguishers shall be provided and located in accordance with NFPA pamphlet 10, Standard for Portable Fire Extinguishers, for Extra High Hazards. Substantiation: Communicates same language as offered in NFPA 33, Section 7-4. (Log #CP3) (7-4.1 (New)): Accept RECOMMENDATION: Add a new Subsection to read as follows: Ventilation and exhaust systems for dipping and coating process areas shall not be interlocked with the fire alarm system and shall remain functioning during any fire alarm condition. Exception: Where the type of fire extinguishing system used requires that ventilation be discontinued, air make-up and exhaust systems shall be permitted to be shut down and dampers shall be permitted to close. SUBSTANTIATION: This requirement is added to maintain consistency with NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials. The requirement is necessary to ensure that heat and products of combustion released by a fire in the equipment is not forced into the surrounding operating area, where it might pose a threat to personnel or other processes. COMMENT ON AFFIRMATIVE: EUSON: My notes from the last meeting indicate that the committee further amended this sub-section by deleting the words"shall not be interlocked with the fire alarm system and..." (Log #CP8) (7-5): Accept RECOMMENDATION: Revise 7-5 to read as follows: 7-5 Protection for Small Processes. Automatic closing process tank covers or extinguishing systems that meet the reouirements of Section 74 shall be provided for open tanks that do no exceed 150 gal (570 L) capacity or that do not exceed 10 sq ft (1 sq m) of liquid surface area. SUBSTANTIATION: This clarifies what types of extinguishing Stems are permitted. MMITTEE ACTION: Accept. (Log #cpg) (7-5.3): Accept ] RECOMMENDATION: Revise to read as follows: I Chains, wire ropes, or other annroved noncombustible [ ap_p_af._a1~ shall be used to support the cover or operating ] mechanism. All pulleys, catches, and other fasteners shall be metal [ and shall be attached to noncombustible mountings." SUBSTANTIATION: Currently, NFPA 34 does not permit fusible link hinge mechanisms and similar designs, which are regularly and successfully used on small dip tanks. NOT RETURNED: 2 Bannister, johnson MAY 2000 ROP (Log #CP6) (7-6): Accept RECOMMENDATION: Revise Section 7-6 to read as follows: 7-6* Protection for Enclosed and Large Processes. Automatic extinguishing svstems that meet the reuuirements of Sectior~ 7-4 Pr~tcc'd~:. :~-ztcm= shall be provided for enclosed nrocesses, for open nrocesses with nerinheral vanor containment and ventilation and for process tanks of 150 gal (570 L) capacity or more of 10 ft2 (1 m2) in liquid surface area or greater. The systems shall be designed to protect the following areas: (a) For dip tanks, the system shall protect the tank, its drain board, freshly coated objects or material, and any hoods and ducts. (b) For flow coaters, the system shall protect open tanks, vapor drying tunnels, and ducts. Pumps circulating the coating material shall be interlocked to shut off automatically in the event of fire. (c) For curtain and roll coaters or similar processes, the system shall protect the coated objects or material and open troughs or tanks containing coating materials. Pumps circulating the coating material shall be interlocked to shut off automatically in the event of fire. Excention: Annroved automatic-closing process tank covers or fire nrotection systems that meet the reouirements of Se Ootl 7-4 shall loe nermitted for enclosed systems ~hat do O0t exceed 150 gal (570 L) capacity or 10 ft 2 (1 m2i in liquid surface area and for open processes with peripheral vapor containment and ventilation. SUBSTANTIATION: This revision allows alternative protection systems for systems that cannot be readily fitted with automatic closing covers. COMMENT ON AFFIRMATIVE: EUSON: The committee voted to change the words"extinguishing" to"fire protection." My notes indicate that the committee voted to make this change for all references to'extinguishing" in this document. (Log #CP15) (8-3, 8-5, 8-6): Accept RECOMMENDATION: Revise Section 8-3 to read as follows: '%3 Inspection and Testing. Inspections and tests of all process tanks, including covers, overflow pipe inlets, overflow outlets, and discharges, bottom drains, pumps and valves, electrical wiring and ~utilization equipment, bonding and grounding connections, ventilation systems, and all extinguishing equipment shall be made monthly. Any defects found shall be promptly corrected." Revise Section 8-5 to read as follows: '%5 Smoking. "NO SMOKING OR OPEN FLAMES" signs in large letters on contrasting color background shall be conspicuously posted at all dipping and coating areas and paint storage rooms." Revise Section 8-6 to read as follows: "8-6 Hot Work. Welding, cutting, and similar spark-producing operations shall not be permitted in or adjacent to dipping or coating operations until a written permit authorizing such work has been issued. The permit shall be {ssued by a person in authority following his or her inspection of the area to ensure that proper precautions have been taken and will be followed until the job is completed. (See NFPA 51B, Standard for Fire Prevention in Use of Cutung and Welding Processes.)" nature. They accomplish the following objectives; replacement of ambiguous text. NUMBER OF COMMITI'EE MEMBERS ELIGIBLE TO VOTE: 28 VOTE ON COMMITTEE ACTION/ 186