of 62 8/4/17, 2:42 PM Public Input No. 48-NFPA 45-2017 [ Section No. 1.1.2 ] 1.1.2 This standard shall apply to all educational laboratory units and instructional laboratory units in which any quantity of chemicals, as defined in NFPA 704 with one or more of the following hazard ratings, is handled or stored: health 2, 3, or 4: flammability 2, 3, 4; or instability 2, 3, 4. (See also Section B.2). Additional Proposed Changes File Name Description Approved NFPA_45_TIA_15-1_Log_1150.pdf NFPA 45 TIA 15-1 LOG 1150 NOTE: This public input originates from Tentative Interim Amendment No. 15-1 Log 1150 issued by the Standards Council on November 11, 2014 and per the NFPA Regs., needs to be reconsidered by the Technical Committee for the next edition of the document. Submitter s Substantiation: During the 2nd draft meeting for the current revision cycle of NFPA 45, the technical committee deleted the definition of chemical in chapter 3 and moved the wording to paragraph 1.1.1 where the document used to have the wording of in which chemicals, as defined, are handled or stored. This was in response to a public comment on the definition in Chapter 3. During the 1st draft meeting, the technical committee made a first revision to the document adding paragraph 1.1.2 to apply NFPA 45 to all educational and instructional laboratories. The second draft of the 2015 edition reads as follows:1.1.1* This standard shall apply to laboratory buildings, laboratory units, and laboratory work areas whether located above or below grade in which chemicals, as defined, in NFPA 704 with one or more of the following hazard ratings are handled or stored: health 2, 3, or 4; flammability 2, 3, or 4; or instability 2, 3, or 4. (See also Section B.2.). 1.1.2 This standard shall apply to all educational laboratory units and instructional laboratory units in which any quantity of chemicals, as defined, is handled or stored. The bold portion of 1.1.2 is the problem. Since the technical committee deleted the definition of chemical from Chapter 3, this statement is not accurate. I am therefore requesting that analogous language be added to 1.1.2 in order to adequately define the scope of the document. The new wording for 1.1.2 will be similar to 1.1.1 as proposed above. Emergency Nature: This document, if issued as final without the proposed change, will contain an error or an omission that was overlooked during a regular revision process. Neglecting to modify 1.1.2 to match the terminology in 1.1.1 was an oversight by the Technical Committee. Submitter Full Name: TC ON LAB-AAA Organization: NFPA TC ON Laboratories Using Chemicals Submittal Date: Wed Jan 04 15:35:55 EST 2017 Resolution: FR-2-NFPA 45-2017
of 62 8/4/17, 2:42 PM Statement: The Technical Committee is retaining this TIA language for the next edition of the standard. During the 2nd draft meeting for the current revision cycle of NFPA 45, the technical committee deleted the definition of chemical in chapter 3 and moved the wording to paragraph 1.1.1 where the document used to have the wording of in which chemicals, as defined, are handled or stored. This was in response to a public comment on the definition in Chapter 3. During the 1st draft meeting, the technical committee made a first revision to the document adding paragraph 1.1.2 to apply NFPA 45 to all educational and instructional laboratories. The second draft of the 2015 edition reads as follows:1.1.1* This standard shall apply to laboratory buildings, laboratory units, and laboratory work areas whether located above or below grade in which chemicals, as defined, in NFPA 704 with one or more of the following hazard ratings are handled or stored: health 2, 3, or 4; flammability 2, 3, or 4; or instability 2, 3, or 4. (See also Section B.2.). 1.1.2 This standard shall apply to all educational laboratory units and instructional laboratory units in which any quantity of chemicals, as defined, is handled or stored. The bold portion of 1.1.2 is the problem. Since the technical committee deleted the definition of chemical from Chapter 3, this statement is not accurate. I am therefore requesting that analogous language be added to 1.1.2 in order to adequately define the scope of the document. The new wording for 1.1.2 will be similar to 1.1.1 as proposed above.
Tentative Interim Amendment NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals 2015 Edition Reference: 1.1.2 TIA 15-1 (SC 14-8-12 / TIA Log #1150) Note: Text of the TIA issued and incorporated into the text of the document, therefore no separate publication is necessary. 1. Revise 1.1.2 to read as follows: 1.1.2 This standard shall apply to all educational laboratory units and instructional laboratory units in which any quantity of chemicals, as defined in NFPA 704 with one or more of the following hazard ratings, is handled or stored: health 2, 3, or 4; flammability 2, 3, or 4; or instability 2, 3, or 4. (See also Section B.2.). Issue Date: November 11, 2014 Effective Date: December 1, 2014 (Note: For further information on NFPA Codes and Standards, please see www.nfpa.org/codelist) Copyright 2014 All Rights Reserved NATIONAL FIRE PROTECTION ASSOCIATION
of 62 8/4/17, 2:42 PM Public Input No. 50-NFPA 45-2017 [ Section No. 1.2.5 ] 1.2.5 It is not the objective of this standard to address financial losses such as business interruption or property loss when the loss of a laboratory unit is unacceptable. We believe that the use of the term unacceptable in 1.2.5 does not provide clarity or added context to the statement as written and may confuse users of the standard. We note that the NFPA glossary of terms contain no formal definition of unacceptable. The only other appearance of the word unacceptable is in 1.4.2, where the term seems appropriate and is understandable to the reader. Submitter Full Name: Billie Zidek Organization: APPA Submittal Date: Thu Jan 05 14:05:04 EST 2017 Resolution: FR-3-NFPA 45-2017 Statement: The Technical Committee agreed that the use of the term unacceptable in 1.2.5 does not provide clarity and revised the wording.
of 62 8/4/17, 2:42 PM Public Input No. 46-NFPA 45-2017 [ Section No. 1.3.3 ] 1.3.3 Due to the special nature of laboratories using chemicals, this standard modifies and supplements existing codes and standards so as to apply more specifically to buildings or portions of buildings devoted to laboratory-scale operations. Additional Proposed Changes File Name Description Approved NFPA_45_-_PC_13.pdf NFPA 45 PC 13 NOTE: This Public Input appeared as "Reject but Hold" in Public Comment No. 13 of the F2014 Second Draft Report for NFPA 45 and per the Regs. at 4.4.8.3.1. We are in agreement with the technical committee that the proposed new section is not needed and that AHJ can determine the applicability of codes and standards. We recommend consideration be given to study the need to convert NFPA 45 from a standard to a code for laboratories. As Section 1.3.3 states, this standard modifies and supplements existing codes and standards so as to apply more specifically to buildings or portions of buildings devoted to laboratory-scale operations. The criteria in this standard establishes and excellent benchmark for safety in laboratory-scale operations which differ considerably from building codes in that it specifies laboratory units based upon a density method and maximum quantity per laboratory unit as opposed to the control area method that building codes utilize based only upon maximum quantity. The building codes have unrealistic restrictions on the amount of chemicals that can be stored at higher floors whereas NFPA 45 reduces this restriction but adds the requirement for automatic sprinkler systems for new laboratories, sealing floor penetrations liquid tight, and other safety requirements. With research facilities at Colleges and Universities growing, NFPA 45 provides a more realistic and stable approach to support this growth. Applying NFPA 45 as a standard in conjunction with existing building codes presents too many conflicts to apply in a reasonable fashion to new construction and/or renovations to existing structures. Applying existing building codes to existing buildings, many built prior to the control area concept, severely limits the use and upgrade of existing laboratory buildings. NFPA 45, with the density method, would allow better use of buildings, especially multi-story buildings, where the owner agrees to limit the density to NFPA 45 requirements. A code is needed to specifically address laboratory-scale operations and facilities. Submitter Full Name: TC ON LAB-AAA Organization: NFPA TC ON Laboratories Using Chemicals Submittal Date: Wed Jan 04 14:28:03 EST 2017 Resolution: The Technical Committee does not see the need to change from a Standard to a Code.
of 2 http://submittalsarchive.nfpa.org/terraviewweb/formlaunch?id=/terra... 1/4/2017 1:15 PM Public Comment No. 13-NFPA 45-2013 [ Section No. 1.3.3 ] 1.3.3 Due to the special nature of laboratories using chemicals, this standard modifies and supplements existing codes and standards so as to apply more specifically to buildings or portions of buildings devoted to laboratory-scale operations. Statement of Problem and Substantiation for Public Comment We are in agreement with the technical committee that the proposed new section is not needed and that AHJ can determine the applicability of codes and standards. We recommend consideration be given to study the need to convert NFPA 45 from a standard to a code for laboratories. As Section 1.3.3 states, this standard modifies and supplements existing codes and standards so as to apply more specifically to buildings or portions of buildings devoted to laboratory-scale operations. The criteria in this standard establishes and excellent benchmark for safety in laboratory-scale operations which differ considerably from building codes in that it specifies laboratory units based upon a density method and maximum quantity per laboratory unit as opposed to the control area method that building codes utilize based only upon maximum quantity. The building codes have unrealistic restrictions on the amount of chemicals that can be stored at higher floors whereas NFPA 45 reduces this restriction but adds the requirement for automatic sprinkler systems for new laboratories, sealing floor penetrations liquid tight, and other safety requirements. With research facilities at Colleges and Universities growing, NFPA 45 provides a more realistic and stable approach to support this growth. Applying NFPA 45 as a standard in conjunction with existing building codes presents too many conflicts to apply in a reasonable fashion to new construction and/or renovations to existing structures. Applying existing building codes to existing buildings, many built prior to the control area concept, severely limits the use and upgrade of existing laboratory buildings. NFPA 45, with the density method, would allow better use of buildings, especially multi-story buildings, where the owner agrees to limit the density to NFPA 45 requirements. A code is needed to specifically address laboratory-scale operations and facilities. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 14:59:14 EDT 2013 Committee Action: Resolution: Rejected but held As this would be a major change, the technical committee feels that it needs time to investigate and address the impact of changing from a standard to a code. The committee feels that this would be best addressed as part of the next revision cycle and is holding this comment for public input. The committee will be setting up a task group to address the implication of this possible change.
of 2 http://submittalsarchive.nfpa.org/terraviewweb/formlaunch?id=/terra... 1/4/2017 1:15 PM Copyright Assignment I, Bill Galloway, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Bill Galloway, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature
of 62 8/4/17, 2:42 PM Public Input No. 4-NFPA 45-2016 [ Chapter 2 ] Chapter 2 Referenced Publications 2.1 General. The documents or portions thereof listed in this chapter are referenced within this standard and shall be considered part of the requirements of this document.
of 62 8/4/17, 2:42 PM 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 1, Fire Code, 2015 edition. NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 11, Standard for Low-, Medium-, and High-Expansion Foam, 2010 edition. NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2015 edition. NFPA 12A, Standard on Halon 1301 Fire Extinguishing Systems, 2015 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 edition. NFPA 14, Standard for the Installation of Standpipe and Hose Systems, 2013 edition. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2012 edition. NFPA 17, Standard for Dry Chemical Extinguishing Systems, 2013 edition. NFPA 17A, Standard for Wet Chemical Extinguishing Systems, 2013 edition. NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2014 edition. NFPA 30, Flammable and Combustible Liquids Code, 2015 edition. NFPA 33, Standard for Spray Application Using Flammable or Combustible Materials, 2011 edition. NFPA 51, Standard for the Design and Installation of Oxygen Fuel Gas Systems for Welding, Cutting, and Allied Processes, 2013 edition. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 55, Compressed Gases and Cryogenic Fluids Code, 2013 edition. NFPA 58, Liquefied Petroleum Gas Code, 2014 edition. NFPA 69, Standard on Explosion Prevention Systems, 2014 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 72, National Fire Alarm and Signaling Code, 2013 edition. NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 edition. NFPA 86, Standard for Ovens and Furnaces, 2015 edition. NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2015 edition. NFPA 101, Life Safety Code, 2015 edition. NFPA 400, Hazardous Materials Code, 2013 edition. NFPA 495, Explosive Materials Code, 2013 edition. NFPA 496, Standard for Purged and Pressurized Enclosures for Electrical Equipment, 2013 edition. NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, 2012 edition. NFPA 750, Standard on Water Mist Fire Protection Systems, 2015 edition. NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014 edition. NFPA 2001, Standard on Clean Agent Fire Extinguishing Systems, 2015 edition. NFPA 2112, Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2012 edition. 2.3 Other Publications.
of 62 8/4/17, 2:42 PM 2.3.1 ANSI Publications. American National Standards Institute, Inc., 25 West 43rd Street, 4th Floor, New York, NY 10036. ANSI Z535.1, Safety Color Code, 2011. ANSI Z535.2, Environmental and Facility Safety Signs, 2011. ANSI Z535.3, Criteria for Safety Symbols, 2011. ANSI Z535.4, Product Safety Signs and Labels, 2011. ANSI/AIHA Z9.5, Laboratory Ventilation, 2012. 2.3.2 ASME Publications. American Society of Mechanical Engineers, Three ASME International, Two Park Avenue, New York, NY 10016-5990. ASME Boiler and Pressure Vessel Code, Section VIII, 2013 2017. 2.3.3 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 5 D5 /D5M, Standard Test Method of Penetration of Bituminous Materials, 2006 e1 2013. ASTM D 4359 D4359, Standard Test for Determining Whether a Material is a Liquid or a Solid, 2012. ASTM E 84 E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2015b. 2.3.4 NSF Publications. NSF International, P.O. Box 130140, 789 N. Dixboro Road, Ann Arbor, MI 48113-0140. NSF/ANSI 49, Class II (Laminar Flow) Biosafety Cabinetry, 2012. 2.3.5 UL Publications. Underwriters Laboratories, Inc. 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, revised 2010 2013. UL 1275, Standard for Flammable Liquid Cabinets, 2005 2014, revised 2009 2014. UL 1805, Standard for Laboratory Hoods and Cabinets, 2002, revised 2006. 2.3.6 Other Publications. Merriam-Webster s Collegiate Dictionary, 11th edition, Merriam-Webster, Inc., Springfield, MA, 2003. 2.4 References for Extracts in Mandatory Sections. NFPA 54, National Fuel Gas Code, 2015 edition. NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Particulate Solids, 2015 edition. NFPA 99, Health Care Facilities Code, 2015 edition. NFPA 101, Life Safety Code, 2015 edition. NFPA 400, Hazardous Materials Code, 2013 edition. NFPA 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014 edition. NFPA 5000, Building Construction and Safety Code, 2015 edition. Referenced current SDO names, addresses, standard numbers, and editions. Related Public Inputs for This Document Related Input Relationship
of 62 8/4/17, 2:42 PM Public Input No. 5-NFPA 45-2016 [Chapter G] Submitter Full Name: Aaron Adamczyk Organization: [ Not Specified ] Submittal Date: Sat Feb 06 21:49:14 EST 2016 Resolution: FR-27-NFPA 45-2017 Statement: This revision updates references to the current editions.
of 62 8/4/17, 2:42 PM Public Input No. 1-NFPA 45-2015 [ Section No. 2.3.3 ] 2.3.3 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 5 D5/D5M, Standard Test Method of Penetration of Bituminous Materials, 2006 e1 2013. ASTM D 4359 D4359, Standard Test for Determining Whether a Material is a Liquid or a Solid, 1990 ( 2012). ASTM E 84 E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2016. date updates Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Wed Dec 30 20:59:42 EST 2015 Resolution: FR-27-NFPA 45-2017 Statement: This revision updates references to the current editions.
0 of 62 8/4/17, 2:42 PM Public Input No. 3-NFPA 45-2016 [ Section No. 2.3.3 ] 2.3.3 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM D 5, Standard Test Method of Penetration of Bituminous Materials, 2006 e1. ASTM D 4359, Standard Test for Determining Whether a Material is a Liquid or a Solid, 2012. ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2015. Date updates Submitter Full Name: Timothy Earl Organization: GBH International Submittal Date: Mon Jan 04 12:00:51 EST 2016 Resolution: FR-27-NFPA 45-2017 Statement: This revision updates references to the current editions.
1 of 62 8/4/17, 2:42 PM Public Input No. 36-NFPA 45-2017 [ Section No. 2.3.5 ] 2.3.5 UL Publications. Underwriters Laboratories, Inc. 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, revised 2010 2013. UL 1275, Standard for Flammable Liquid Cabinets, 2005, revised 2009 2014. UL 1805, Standard for Laboratory Hoods and Cabinets, 2002. Updating existing standards to current revision dates. Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Tue Jan 03 09:42:12 EST 2017 Resolution: FR-27-NFPA 45-2017 Statement: This revision updates references to the current editions.
2 of 62 8/4/17, 2:42 PM Public Input No. 37-NFPA 45-2017 [ Section No. 2.3.5 ] 2.3.5 UL Publications. Underwriters Laboratories, Inc. 333 Pfingsten Road, Northbrook, IL 60062-2096. ANSI/UL 30, Standard for Metal Safety Cans, 1995, Revised 2009. ANSI/ UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, 2008, revised 2010. ANSI/UL 1313, Standard for Nonmetallic Safety Cans for Petroleum Products, 1993, Revised 2007. UL 1275, Standard for Flammable Liquid Cabinets, 2005, revised 2009. UL 1805, Standard for Laboratory Hoods and Cabinets, 2002. This standard requires safety cans to be listed. This proposal includes the UL standards used to list safety cans, which are also referenced in NFPA 30. Related Public Inputs for This Document Related Input Public Input No. 38-NFPA 45-2017 [Section No. 3.3.57] Relationship Relates standard in the body of the code to the publication list. Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Tue Jan 03 09:50:30 EST 2017 Resolution: These listing standards are not referenced by name in NFPA 45, so they do not belong in Chapter 2.
3 of 62 8/4/17, 2:42 PM Public Input No. 55-NFPA 45-2017 [ New Section after 3.3.39 ] TITLE OF NEW CONTENT Type your content here... 3.3.38 Laboratory User Persons who occupy a Laboratory Work Area to conduct work, testing, analysis, research, instruction, teaching or to engage in learning, or similar activities that involve the use of chemicals. Presently no definition exists for "Laboratory User." This change is proposed to support an additional change I have proposed in wording to 6.5.3.3. The wording of 6.5.3.3 currently places an emphasis on students and instructors and implies that training and emergency planning under the standard applies only to laboratories used for instructional purposes (e.g., chemistry classrooms for K-12 or Post-secondary education or similar). This proposed definition aligns with 3.3.39, definition for Laboratory Work Area and borrows wording from this same definition. Adding this definition and adopting proposed changes to 6.5.3.3 will support understanding that 6.5.3.3 also applies to laboratory settings that are non instructional in nature (i.e., research laboratories, etc.) Submitter Full Name: John Bernhards Organization: APPA Submittal Date: Thu Jan 05 16:36:14 EST 2017 Resolution: FR-9-NFPA 45-2017 Statement: Annex text is added to clarify who a laboratory user might be.
4 of 62 8/4/17, 2:42 PM Public Input No. 38-NFPA 45-2017 [ Section No. 3.3.57 ] 3.3.57 Safety Can. A listed container, of not more than 18 5. 9 L 3 gal ( 5 gal 20L ) capacity, having a screen or strainer in each fill and pour opening and having a spring-closing lid and spout cover and so designed that it will cover designed to safely relieve internal pressure when subjected exposed to fire exposure. [ 30, 2015] This replaces the current definition of safety can with the definition extracted from NFPA 30, which was slightly different from the NFPA 45 definition. Related Public Inputs for This Document Related Input Public Input No. 37-NFPA 45-2017 [Section No. 2.3.5] Relationship Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Tue Jan 03 09:54:37 EST 2017 Resolution: FR-5-NFPA 45-2017 Statement: This replaces the current definition of safety can with the definition extracted from NFPA 30, which was slightly different from the NFPA 45 definition.
5 of 62 8/4/17, 2:42 PM Public Input No. 6-NFPA 45-2016 [ Section No. 5.1.1 ] 5.1.1 The required construction of laboratory units shall be in accordance with Table 5.1.1. Table 5.1.1 Separation Requirements and Height Allowances for Laboratory Units Laboratory Unit a Area of Lab Unit Fire Separation b Permitted Stories Above Permitted Stories Below Grade d A B 929 m 2 ( 10,000 ft 2 ) >929 m 2 (>10,000 ft 2 ) 929 m 2 ( 10,000 ft 2 ) 929 m 2 ( 10,000 ft 2 ) >929 m 2 Grade 2 hours 1 3 Not permitted Not permitted c 1 hour 1 3 1 2 hours 4 6 Not permitted c (>10,000 ft 2 ) C Any size Not required 1 3 1 2 Any size 1 hour 4 6 Any size 2 hours Over 6 D Any size Not required No limit No limit a Refer to Table 9.1.1 for laboratory unit classification. b Separation in this table refers to fire separation from laboratory unit(s) to non-laboratory areas and/or fire separations from laboratory unit(s) of equal or lower hazard classification. c Labs of this classification and size are not permitted. d Laboratory units meeting all the requirements of this standard shall be permitted to store Class I flammable liquids below grade even though NFPA 30 does not permit Class I flammable liquids to be stored in basements.
6 of 62 8/4/17, 2:42 PM NFPA 30, 9.3.6, 9.3.7 and 9.3.8 state the following: 9.3.6 Class I liquids shall not be permitted to be stored in basements as defined in 3.3.4. 9.3.7 Class II and Class IIIA liquids shall be permitted to be stored in basements as defined in 3.3.4, provided the basement is protected in accordance with Chapter 16. 9.3.8 Class IIIB liquids shall be permitted to be stored in basements as defined in 3.3.4. NFPA 101 references NFPA 45 and NFPA 30. Hospital Laboratories are to be built to NFPA 45 in accordance with NFPA 101 Chapter 18. There seems to be conflicts since NFPA 30 is referenced by NFPA 45, but NFPA 30 would not allow storage of Class I flammable liquids in basements. Personally, I don't think it is a good idea to permit Class I flammable liquids to be stored in basements of healthcare occupancies where patients are unable to evacuate the building, even with the safeguards that are in place. However, it appears that NFPA 45 intends to allow Class I flammable liquids to be stored in basements per Table 5.1.1. The conflict should be addressed so that users of NFPA 101, NFPA 45, and NFPA 30 understand what is expected. Presently, NFPA 101, which references NFPA 30, would not permit the storage of Class I flammable liquids in basements, but Table 5.1.1 of NFPA 45 appears to permit it. Do you want to be lying in a hospital bed with 800 gallons of flammable liquids (per Lab unit) in the basement that can't be easily accessed by the fire department? Even if this proposal is not accepted, the conflict between NFPA 45 and NFPA 30 for storing Class I flammable liquids in basements needs to be addressed. Submitter Full Name: Peter Larrimer Organization: US Department of Veterans Affa Submittal Date: Wed Feb 10 10:14:24 EST 2016 Resolution: The submitter did not provide a technical reason for the change and provides too much latitude to contravene NFPA 30 requirements. This issue requires discussion with the local AHJ.
7 of 62 8/4/17, 2:42 PM Public Input No. 21-NFPA 45-2016 [ Section No. 5.1.4 ] 5.1.4* Penetrations through fire-rated floor/ceiling, floor, and wall assemblies shall be protected in accordance with NFPA 101 and NFPA 5000. Construction features should reference the building code and not just NFPA 101. Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County, Washington Affilliation: NFPA's Building Code Development Committee (BCDC) Submittal Date: Thu Jun 16 17:36:25 EDT 2016 Resolution: FR-6-NFPA 45-2017 Statement: Construction features should reference the building and fire code and not just NFPA 101.
8 of 62 8/4/17, 2:42 PM Public Input No. 9-NFPA 45-2016 [ Section No. 5.1.5 ] 5.1.5 Floors, floor openings, floor penetrations, and floor firestop systems shall be sealed to prevent liquid leakage to lower floors. The sealing material shall be compatible with the chemicals being stored or used in the laboratory. Curbing may be used to prevent leakage and meet chemical compatability but, if used, must be sealed in accordance with all local fire and building codes. Curbing with openings inside the curb (the usual installation) was removed as an option to meet fire and building code requirements. However, fire stop sealants often have limited chemical compatibility so allowing sealed curbing is often a better approach. The curbing prevents leakage and keeps the sealant from being exposed to the chemicals. Submitter Full Name: Richard Palluzi Organization: Richard Palluzi LLC Submittal Date: Wed Mar 23 09:05:54 EDT 2016 Resolution: FR-58-NFPA 45-2017 Statement: This revision clarifies that curbing of laboratory floors can be used to prevent liquids from migrating to lower floor levels. The new Annex text was added to further clarify the need to prevent liquids from migrating to lower floor levels.
9 of 62 8/4/17, 2:42 PM Public Input No. 51-NFPA 45-2017 [ Section No. 5.4.3 ] 5.4.3* The required exit access doors of all laboratory work areas within Class C or Class D laboratory units shall be permitted to swing against the direction of exit travel or shall be permitted to be a horizontal sliding door complying with NFPA 101, and with sections 404.2.4.2 Doorways without Doors or Gates Sliding Doors, and Folding Doors and with 404.2.7 Door and Gate Hardware as found in the 2010 ADA Standards for Accessible Design. 5.4.3 does not reference specific ADA requirements for sliding doors as required under federal statute. The 2010 ADA Standards for Accessible Design, sections 404.2.4.2 and 404.2.7, describe ADA requirements for sliding doors and hardware. Referencing these federal regulations within 5.4.3 would ensure awareness of the compliance obligations requirements while supporting the Scope and Purpose of NFPA 45 to protect life and property. Submitter Full Name: Billie Zidek Organization: APPA Submittal Date: Thu Jan 05 15:41:45 EST 2017 Resolution: ADA Regulations are not enforced by the local AHJ, but instead by the US DOJ.
0 of 62 8/4/17, 2:42 PM Public Input No. 42-NFPA 45-2017 [ Section No. 6.3.2 ] 6.3.2 For purposes of sizing and placement of fire extinguishers for Class B fires (see Table 6.3.1.1 of NFPA 10), Class A laboratory units shall be rated as extra (high) hazard extra hazard, and Class B, Class C, and Class D laboratory units shall be rated as ordinary (moderate) hazard ordinary hazard. Editorial and correlation. The words "high" and "moderate" are no longer used in NFPA 10. Submitter Full Name: Jennifer Boyle Organization: FEMA Affilliation: FEMA Submittal Date: Wed Jan 04 08:03:19 EST 2017 Resolution: FR-8-NFPA 45-2017 Statement: The words "high" and "moderate" are no longer used in NFPA 10.
1 of 62 8/4/17, 2:42 PM Public Input No. 54-NFPA 45-2017 [ Section No. 6.5.3.3 ] 6.5.3.3 All laboratory users, including, but not limited to, instructors and students, shall be trained prior to laboratory use and at least annually thereafter on the emergency plan. While 6.5.3.3 references all laboratory users, including but not limited to...", the wording of this section places an emphasis on students and instructors and implies that training and emergency planning under the standard apply only to laboratories used for instructional purposes only (e.g., chemistry classrooms for K-12 or Post-secondary education or similar). A better solution is to formalize the term Laboratory User by adding a definition that aligns with 3.3.39, definition for Laboratory Work Area. If the current wording of this section was to emphasize safety training in campus/school laboratories, it should be noted that many post secondary institutions operate substantial research facilities that include public-private research partnerships and other models that support critical research facilities and that are not necessarily designed for classroom instruction. Use of a definition for "Laboratory User" that is in alignment with 3.3.39 supports broadened relevance of safety training and emergency preparedness to a wider variety of laboratory settings and work areas. To support this proposed change to 6.5.3.3, also please see new proposed definition for Chapter 3 which reads " Laboratory User Persons who occupy a Laboratory Work Area to conduct work, testing, analysis, research, instruction, teaching or to engage in learning, or similar activities that involve the use of chemicals." Thank you for your consideration. John Bernhards APPA -- Leadership in Educational Facilities 1643 Prince Street Alexandria VA 22314 www.appa.org Submitter Full Name: John Bernhards Organization: APPA Submittal Date: Thu Jan 05 16:20:01 EST 2017 Resolution: The existing wording needs to be maintained to emphasize applicability to instructors and students. See FR 9.
2 of 62 8/4/17, 2:42 PM Public Input No. 53-NFPA 45-2017 [ Section No. 7.2.2.1 ] 7.2.2.1 If laboratory exhaust ventilation is out of service or inoperable, all laboratory operations shall be suspended until the deficiency is corrected. All hazardous materials shall be secured in a safe condition or removed from the laboratory during the time that the deficiency exists. New construction with fume hoods should be connected to emergency or stand-by power to insure continued operation in an electrical failure. Existing buildings should be grandfathered. NFPA does not require fume hoods to be connected to emergency or stand-by power to insure continued operation in an electrical failure. It asks that in the event of a power failure all experiments and operations be suspended, materials secured, lab evacuated until declared safe. This does not recognize that some fumes can become toxic/lethal within seconds of loss of containment, not providing enough time to secure and evacuate. Furthermore, some experiments run continuously with little attendance by someone who react to a power failure. Furthermore, a power failure could go unnoticed as these events are generally not alarmed, or the failure could be local and notice is not provided to either the area of failure nor to adjacent areas where normal operation is in process. Providing back-up power to fume hoods also must be factored into design air flow pressures, door swings, latching etc. as full capacity can create situations where the suction against the pull side of a door is enough to inhibit being able to open it. Submitter Full Name: Billie Zidek Organization: APPA Submittal Date: Thu Jan 05 15:52:17 EST 2017 Resolution: As stated in A.7.2.2, it is not the intent of the Technical Committee to require emergency or standby power for laboratory ventilation, as there are other ways to deal with this issue that can be coordinated with the building design and operation, and are less burdensome.
3 of 62 8/4/17, 2:42 PM Public Input No. 45-NFPA 45-2017 [ Section No. 7.3.1 ] 7.3.1 Laboratory ventilation systems shall be designed to ensure that chemical fumes, vapors, or gases originating from the laboratory shall not be recirculated to other spaces. Similar to the A7.4.1 and 7.4.1 public input I have provided, this section is occasionally misunderstood to also apply to ductless and filtered fume hoods even though it is in for supply systems. Recirculation of supply air is acceptable via chilled beams and fan coil units for localized cooling technologies. Submitter Full Name: Kenneth Crooks Organization: Erlab, Inc. Submittal Date: Wed Jan 04 12:56:58 EST 2017 Resolution: FR-10-NFPA 45-2017 Statement: This section is occasionally misunderstood to also apply to ductless and filtered fume hoods even though it is in the section for supply systems. Recirculation of supply air is acceptable via chilled beams and fan coil units for localized cooling technologies per 7.4.2.
4 of 62 8/4/17, 2:42 PM Public Input No. 44-NFPA 45-2017 [ Section No. 7.4.1 ] 7.4.1* Air exhausted from ducted chemical fume hoods and other special local exhaust systems shall not be recirculated. Air exhausted form ductless or filtered chemical fume hoods can be recirculated within the same lab space. (See also 7.3.1.) Similar to the A7.4.1 public input I have provided, the wording in this section does not allow for newer technologies that can safely filter and recirculate the clean air back into the same lab space. It is clear that contaminated (ducted) fume hood exhaust air is not to be recirculated, in the common meaning of the word as with Return Air HVAC systems. That was clearly the intent of this section when first written into the Standard and why the use of the word Discharge in the section heading. Labs are to have single-pass 100% OA systems to provide ventilation air at all times. Thus, the air must also be exhausted from the lab space(s) and, due to the potential of contamination, shall not be recirculated back into the building. None of that changes in any way when ductless or filtered chemical fume hoods are used in the lab as they do not have contaminated exhaust air that requires exhausting from the lab space or otherwise requires discharging. Rather, a ductless or filtered chemical fume hood returns directly to the same lab space cleaner air than that which entered the open sash area. Additionally, the air is not recirculated within the building; it is cleaned and then recirculated within the lab space only. Recirculation of air within the same lab space is permissible by other Standards, the requirements for doing so are detailed in the ANSI/AIHA Z9.5 2012 Standard, section 5.4.7. Submitter Full Name: Kenneth Crooks Organization: Erlab Inc. Submittal Date: Wed Jan 04 12:44:41 EST 2017 Resolution: More guidance is needed to prevent misapplication of ductless fume hoods. A task group has been formed to review the safe use of ductless fume hoods and coordinate with requirements in ANSI Z9.5.
5 of 62 8/4/17, 2:42 PM Public Input No. 49-NFPA 45-2017 [ Section No. 7.4.10 ] 7.4.10 Only Class II, Type B2 biological safety cabinets listed by the National Sanitation Foundation as a nationally recognized testing laboratory as meeting NSF/ANSI 49, Class II (Laminar Flow) Biosafety Cabinetry, shall be permitted to be used in lieu of chemical fume hoods, as determined by a qualified person. Requiring these cabinets to be listed by a single testing organization represents a restraint of trade issue. Any nationally recognized testing laboratory (a term also used in NFPA 45, Section 9.4.1) should be able to certify that the cabinets comply with the NSF/ANSI 49 standard. Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Thu Jan 05 10:20:52 EST 2017 Resolution: FR-11-NFPA 45-2017 Statement: Any nationally recognized testing laboratory (a term also used in NFPA 45, Section 9.4.1) should be able to certify that the cabinets comply with the NSF/ANSI 49 standard.
6 of 62 8/4/17, 2:42 PM Public Input No. 19-NFPA 45-2016 [ Section No. 7.8 ] 7.8 Chemical Fume Hood Construction Requirements. 7.8.1 Chemical Fume Hood Interiors. 7.8.1.1* Materials of construction used for the interiors of new chemical fume hoods or for the modification of the interiors of existing chemical fume hoods shall have a flame spread index of 25 or less when tested in accordance with ASTM E 84, Standard Test Method for Surface Burning Characteristics of Building Materials, or ANSI/UL 723, Standard for Test for Surface Burning Characteristics of Building Materials, unless the interior of the hood is provided with automatic fire protection in accordance with 7.10.2. 7.8.1.2 Chemical fume hoods shall meet the requirements of UL 1805, Standard for Safety Laboratory Hoods and Cabinets, or other approved standards. 7.8.1.3* Baffles shall be constructed so that they are unable to be adjusted to materially restrict the volume of air exhausted through the chemical fume hood. 7.8.1.4* Chemical fume hoods shall be provided with a means of preventing overflow of a spill of 2 L (0.5 gal) of liquid. 7.8.2* Chemical Fume Hood Sash Glazing. The sash, if provided, shall be glazed with material that will provide protection to the operator against the hazards associated with the use of the hood. (See also Annex C.) 7.8.3* Chemical Fume Hood Sash Closure. 7.8.3.1 Chemical Users shall be instructed to keep chemical fume hood sashes shall be kept as closed whenever possible as possible during use and positioned to provide face protection. 7.8.3.2* Where a Users shall be instructed to ensure the sash is fully closed whenever the chemical fume hood is unattended, its sash shall remain fully closed. 7.8.4* Electrical Devices. 7.8.4.1 In installations where services and controls are within the hood, additional electrical disconnects shall be located within 15 m (50 ft) of the hood and shall be accessible and clearly marked. 7.8.4.2 If electrical receptacles are located external to the hood, no additional electrical disconnect shall be required. (See 5.6.1.) 7.8.5 Other Hood Services. 7.8.5.1 For new installations or modifications of existing installations, controls for chemical fume hood services (gas, air, water, etc.) shall be located external to the hood and within easy reach. 7.8.5.2 In existing installations where service controls are within the hood, additional shutoffs shall be located within 15 m (50 ft) of the hood and shall be accessible and clearly marked.
7 of 62 8/4/17, 2:42 PM 7.8.6 Auxiliary Air. For auxiliary air hoods, auxiliary air shall be introduced exterior to the hood face in such a manner that the airflow does not compromise the protection provided by the hood and so that an imbalance of auxiliary air to exhaust air will not pressurize the hood interior. 7.8.7* Hood Proper Function Alarm. A measuring device for indicating that the hood airflow remains within safe design limits shall be provided on each chemical fume hood. 7.8.7.1* The measuring device for hood airflow shall be a permanently installed device and shall provide continuous indication to the hood user of adequate airflow and alert inadequate hood airflow by a combination of an audible and visual alarm. Where an audible alarm could compromise the safety of the user or the research, alternative means of alarm shall be considered. The current title for Section 7.8 limits the scope to construction and suggests paragraph 7.8.3.1 and 2 (which are directions related to sash use) do not belong. Changing this from "Construction" to "Requirements" would allow these sash operation paragraphs to remain without suggesting that they need to be a construction feature. Changing the wording of these two sash use paragraphs will clarify that it is the USER that must comply with these. 7.8.3.1 adjusted to emphasize that the purpose of the sash is to protect the user's face. Submitter Full Name: Andrew Sinnamon Organization: Mott Manufacturing Limited Submittal Date: Thu May 19 10:19:02 EDT 2016 Resolution: Statement: The title of section 7.8 is being revised to more accurately reflect the contents.
8 of 62 8/4/17, 2:42 PM Public Input No. 40-NFPA 45-2017 [ Section No. 7.8.1.2 ] 7.8.1.2 Chemical fume hoods shall be listed and labled meet the requirements of UL 1805, Standard for Safety Laboratory Hoods and Cabinets, or other approved standards. REASON: Fume hood leakage is a hazard to the user. Meeting the requirements does not require performance testing or review of manufacturer processes, Listing does require that to happen proving the fume hood to be safe and can operate according to the standard. The labeling allows users and AHJs to visually confirm that the fume hood is listed. Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Tue Jan 03 10:15:42 EST 2017 Resolution: This requirement would be too restrictive for hoods that meet UL 1805 requirements but have not been specifically listed due to unique configurations.
9 of 62 8/4/17, 2:42 PM Public Input No. 12-NFPA 45-2016 [ Section No. 7.8.2 ] 7.8.2* Chemical Fume Hood Sash Glazing. The sash, if provided, shall be glazed with material that will provide protection to the operator against the hazards associated with the use of the hood. (See also Annex C and UL 1805 sash requirements.) The current wording, and in particular Appendix C, does not offer much practical advice as to what is adequate. As UL 1805 is previously referenced suggesting it's sash requirements seems to make sense. Submitter Full Name: Richard Palluzi Organization: Richard Palluzi LLC Submittal Date: Wed Mar 23 09:17:39 EDT 2016 Resolution: Statement: The current wording, and in particular Appendix C, does not offer much practical advice as to what is adequate. UL 1805 is referenced for more comprehensive requirements for the glazing.
0 of 62 8/4/17, 2:42 PM Public Input No. 41-NFPA 45-2017 [ Section No. 7.10.3.1 ] 7.10.3.1 * Automatic fire dampers shall not be used in laboratory exhaust systems connected to fume hoods. Any exhaust duct conveying fume hood exhaust through a fire rating shall provide an alternative means of protection equal to or greater than the rating through which the duct passes by one of the following:: (1) Wrapped or encased with listed or approved materials materilas having a fire - resistance rating equal to the fire rating after exiting the originating fire compartment for a minimum distance of 3.05 m (10 ft) beyond the opening. [ 91: 4.2.12(1)] barrier for 10 ft (3m) of the duct on each side of the fire barrier including duct supports within this span. (2) Constructed of materials and supports having a minimum fire resistance rating equal to the fire barrier [ 91: 4.2.12(2)]. (3) Enclosed with a shaft that is constructed of material having a fire resistance rating equal to the fire barrier for 10 ft (3m) of the duct on each side of the fire barrier with no inlets to the duct within this distance, and the duct entry into and exit from the shaft is protected in accordance with 4.2.13[NFPA 91,2015]. 7.10.3.1.1 When a branch duct from a fume hood and/or lab exhaust connects to a common riser located in a shaft enclosure that must travel upward, then the connection shall be made utilizing a separate upturned steel subduct of at least 22 gauge and a length of at least 0.56 m (22 in.) prior to joining the riser manifold from each separate branch duct entering the shaft entrance. The current wording about an exhaust duct through a fire rating is grammatically incorrect, NFPA 91 covers exhaust ducts through a fire barrier. Also NFPA 91 now includes three options for protecting exhaust ducts passing through a fire barrier, which are included in items (1) through (3) of this proposal verbatim. Submitter Full Name: Kelly Nicolello Organization: UL LLC Submittal Date: Tue Jan 03 10:24:21 EST 2017 Resolution: FR-61-NFPA 45-2017 Statement: The changes were made to clarify the installation of exhaust ducts through fire rated barriers. Text extracted from NFPA 90A and NFPA 91 were updated to the current edition text. The requirements were moved from 7.10.3, 7.10.4, and 7.10.5 to 7.5 because they apply to all exhaust systems, not just
1 of 62 8/4/17, 2:42 PM fume hoods.
2 of 62 8/4/17, 2:42 PM Public Input No. 47-NFPA 45-2017 [ Chapter 8 [Title Only] ] Chemical Storage, Handling, and Waste Disposal This chapter shall apply to new and existing laboratories Additional Proposed Changes File Name Description Approved NFPA_45_-_PC_20.pdf NFPA 45 PC 20 NOTE: This Public Input appeared as "Reject but Hold" in Public Comment No. 20 of the F2014 Second Draft Report for NFPA 45 and per the Regs. at 4.4.8.3.1 These are operational requirements that primarily apply to existing laboratories, not new construction. This section may not be retroactive in existing laboratories unless specified (Section 1.4.1). Submitter Full Name: TC ON LAB-AAA Organization: NFPA TC ON Laboratories Using Chemicals Submittal Date: Wed Jan 04 14:34:07 EST 2017 Resolution: FR-15-NFPA 45-2017 Statement: Chapter 8 contains operational requirements that need to be applied to existing laboratories, not only new construction.
of 1 http://submittalsarchive.nfpa.org/terraviewweb/formlaunch?id=/terra... 1/4/2017 1:13 PM Public Comment No. 20-NFPA 45-2013 [ Chapter 9 [Title Only] ] Chemical Storage, Handling, and Waste Disposal This chapter shall apply to new and existing laboratories. Statement of Problem and Substantiation for Public Comment These are operational requirements that primarily apply to existing laboratories, not new construction. This section may not be retroactive in existing laboratories unless specified (Section 1.4.1) Submitter Full Name: William Guffey Organization: University of Maryland Affilliation: Office of the Fire Marshal Submittal Date: Fri Nov 15 10:12:35 EST 2013 Committee Action: Resolution: Rejected but held The technical committee is going to hold this comment until the next revision cycle. We are setting up a task group to review which parts of the standards should be retroactive and be applied to both new and existing laboratories. Copyright Assignment I, William Guffey, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am William Guffey, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature
3 of 62 8/4/17, 2:42 PM Public Input No. 13-NFPA 45-2016 [ Section No. 8.2.4.6 ] 8.2.4.6 Laboratory storage facilities shall be inspected at suitable intervals but at least annually to ensure compliance with the provisions of Chapter 8. The current wording allows arguments that a post occupancy initial inspection alone is adequate which is not the intent. By mentioning appropriate intervals it suggests some follow up on the art of the user is required. By specifying annually it suggests a minimum frequency. Submitter Full Name: Richard Palluzi Organization: Richard Palluzi LLC Submittal Date: Wed Mar 23 09:23:05 EDT 2016 Resolution: FR-16-NFPA 45-2017 Statement: The current wording allows arguments that a post occupancy initial inspection alone is adequate which is not the intent. By specifying annually the committee provides a minimum frequency.