Public Comment No. 1-NFPA [ New Section after 4.8 ]

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1 Page 1 of 9 Public Comment No. 1-NFPA [ New Section after 4.8 ] Additon of No Swimming Policy. This is in response to submission input by David Rifkin which recommended adding signage prohibiting swimming in marinas. The committee then asked for comments regarding add a No Swimming policy, which would have to be in place before a signage requirement was passed. This change recommendation is to add a No Swimming policy as the precursor to a signage requirement. I defer to the committee's judgement for the most appropriate place in the standard to add this section, along with the new requirements for signage. I can be contacted at qualitymarinesvcs@comcast.net or , and would be happy to discuss with any interested party. And thank you for the opportunity to enhance safety in the marina environment. See discussion below for justification for this addition. David Rifkin, Capt. USN, Ret. Insert new paragraph Swimming Prohibition Swimming within the confines of the marina shall be prohibited. The confines for this purpose will be within 50 yards of any marina structure using AC power, or within 50 yards of any equipment/cabling that could leak electricity into the water Management shall establish procedures to ensure that anyone using, visiting, or working in the marina confines understands that swimming is prohibited Management shall ensure that all employees are trained in the swimming prohibition, and that appropriate action is taken in the event that swimming is observed within the confines of the marina Signs Signs shall be posted in conspicuous locations warning all personnel that swimming is prohibited. They will be positioned such that they will be seen from all approaches to any electrified structure Signage lettering shall be large enough that the No Swimming portion of the verbiage, or the international no swimming diagram (if used instead of lettering) can be read with normal vision from at least 50 yards away Signs shall state, as a minimum: (1) No Swimming Within 50 yds (2) Electric Shock Danger in the Water Insert new paragraph A.4.9. A.4.9. Swimming Prohibition A Consideration may be given to establishing safe swimming areas in a marina provided that the 50 yard criterion of is met. Procedures, policies and physical barriers should be established to ensure the safety of recreational swimmers by preventing them from swimming outside the safe area. A Consideration should be given to establishing policies and procedures for owners or professional divers to safely conduct underwater maintenance on boats within the confines of a marina. These may include: (1) Establishing a scheduled electrical outage period to create a window for safe diving operations.

2 Page 2 of 9 (2) Requiring that the boat or structure being worked on be deenergized (unplugged in the case of portable shore power cables) along with vessels or structures adjacent to or across the dock from the vessel or structure being maintained. (3) Ensuring that boat owners and divers understand that even if the vessel or structure is denergized, that there is still inherent risk of electrical shock from other sources within 50 yards of the work area. David Rifkin qualitymarinesvcs@comcast.net Statement of Problem and Substantiation for Public Comment

3 Page 3 of 9 Problem is that people are being killed and injured due to electrical faults in marinas. Current requirements to improve marina electrical safety (ground fault protection added in NFPA 70, 2011, 555.3) will be very expensive to implement at the marina level. Also, they will not be retroactive so, on a practical basis, most marinas will never be upgraded to the new standard. A simpler, cost effective solution can make an impact right away, and could be required of existing marinas by the AHJ at relatively low cost. Also, protection devices fail. The best way to ensure protection is to not engage in the activity that requires the protection device (especially when the risk involves injury and death). Staying out of the water in a marina is a perfect example of this. Prohibiting swimming, and requiring warning signage will dramatically improve safety in the marina environment. It should also appeal to marina operators as an inexpensive way to reduce their liability in this area (and help them comply with protecting people discussed in NFPA 303, A.5.1. (5)). Discussion: Electric shock drowning (ESD) is a known hazard associated with marinas and boatyards in freshwater locations. Recently Chapter 555 of NFPA 70 was revised to require ground fault protection for marinas and boatyards (555.3). This will greatly improve safety at these locations. However, the cost of ground fault protection upgrades will be significant, and likely will not be deemed retroactive by the local Authority Having Jurisdiction (AHJ). The result will be that not many facilities (if any at all) will be upgraded with this important protection system. The existing dangers will remain for a very long time, even though the Code has been revised. There is something that marina/boartyard operators can do to minimize the chance of an ESD-type accident at their facility. They can establish No-Swimming policies and post signage to prohibit swimming and warn of the danger. This represents a relatively low cost option compared to installing ground fault protection, and will likely appeal to the operators from a liability perspective. Keeping recreational swimmers out of the water within the marina confines is a sure fire way to prevent accidents. Not only are there electrical considerations, but also dangers from moving equipment (like boats and spinning propellers). The 50 yards in the change is based on the line to ground voltage at all but the largest of marinas (240v and below). The maximum line to ground voltage is 120v. If this voltage exists over a water span of 50yds (150ft) or more, then the maximum voltage gradient in the water would be 120v/150ft or 0.8v/ft. The recognized lethal gradient for humans is 2v/ft. Therefore, at 50yds the max gradient would be less than half of the recognized dangerous level for a nominal person. Electrical codes and standards are there to minimize the likelihood of serious injury or death resulting from someone accidentally entering the water. They are not designed nor intended to provide a safe haven from electricity in the water. Consider a basic hair dryer. This device has a mandated integral GFCI within the device itself. They are usually used in bathrooms where receptacles are equipped with their own GFCIs. Even with double GFCI protection, would a rational person consider it safe to sit in the bath tub while drying one s hair? The standards require the GFCI protection in case someone foolishly decides to do this, but not to facilitate this behavior. Procedures and policies to prevent swimming in marinas and boatyards will save lives. This is, for the most part, a cultural change. We have always gone swimming at the local lake, river, or pond. Then came the docks, and the swimming continued safely. Then came electrification of docks (for boats, lighting, entertainment, etc.). At that point swimming became a significant hazard and a risk for ESD. We have documented hundreds of injuries and deaths from swimming around boats and docks using electrical

4 Page 4 of 9 power. There are things a marina can do to allow safe swimming at their facilities. One thing would be set up designated swimming areas. These areas would be at least 50 yds from any potential source of electricity. They can also place some controls on diving activites within the confines of their facilities. This same No Swimming policy and signage requirement can be applied to all marinas; fresh, salt, and brackish. The physical dangers remain the same, and the potential for electric shock and injury can still be very dangerous even in a saltwater marina (consider someone in the saltwater reaching up and grabbing something on a boat or dock that is energized to line potential). Thank you for your consideration of this important change. David Rifkin Capt. USN, Ret. Please feel to contact me to discuss this change , qualitymarinesvcs@comcast.net. Related Item Committee Input No. 13-NFPA [New Section after 4.6.2] Submitter Information Verification Submitter Full DAVID RIFKIN Name: Organization: Quality Marine Services, LLC Board Member, Electric Shock Drowning Prevention Association. Affilliation: President/Owner Quality Marine Services, LLC Street Address: City: State: Zip: Submittal Date: Tue Feb 18 22:05:58 EST 2014 Committee Statement

5 Page 5 of 9 Committee Rejected Action: Resolution: The comment lacked sufficient sourced information to validate if a 50 yard swimming prohibition was satisfactory to prevent electric shock drowning incidents. The Committee is aware of an ongoing project by the Fire Protection Research Foundation (FPRF) to collect credible data that clarifies the problem and provides guidance towards the most appropriate mitigation strategy to address identified hazards associated with electric shock drowning incidents in the vicinity of marinas, boatyards and floating buildings. The FPRF report is expected to be completed in October The Committee believes that the FPRF report should be the basis for any changes to the Standard. Any changes to the document in advance of the Committee's consideration of the FPRF report is premature. It was the consensus of the members that the requirements as written in the comment are not enforceable. The Committee thought that the signage criteria as proposed in the public comment was vague and may not be compliant with other existing signage requirements. For example, the comment lacked a definition for what "normal vision" is and there is no definition for structure in the comment which could lead to confusion in the application of these requirements. The Committee is also concerned that the prohibition of swimming as proposed in the public comment could prevent necessary maintenance and repair activities involve commercial diving and hull cleaning within the marina and boatyard.

6 Page 6 of 9 Public Comment No. 2-NFPA [ Section No ] Placement of portable fire extinguishers on piers and along bulkheads where vessels are moored or are permitted to be moored shall meet the following criteria: (1) Extinguishers listed for Class A, Class B, and Class C fires shall be installed at the pier/land intersection on a pier that exceeds 25 ft (7.62 m) in length. (2) Additional fire extinguishers shall be placed such that the maximum travel distance to an extinguisher does not exceed 75 ft (22.86 m). (3) To be protected where exposed to environmental exposures to prevent damage and lack of operability. Statement of Problem and Substantiation for Public Comment In 6.1 suggest to add sentence to protect from environmental conditions to reduce incidence of damage to fire extinguishers located outdoors. High humidity areas, rain, freezing temperatures and high winds could cause corrosion and other damage to fire extinguishers that are not protected. According to the type of conditions fire extinguishers are located they should be protected by use of weather covers, cabinets, etc. in order to prevent climate conditions to negatively affect the expected performance of the fire extinguisher. Related Item Public Input No. 13-NFPA [Section No. 6.1] Submitter Information Verification Submitter Full Name: LISA COCKERILL Organization: REGION OF PEEL Street Address: City: State: Zip: Submittal Date: Thu Mar 06 12:15:45 EST 2014 Committee Statement

7 Page 7 of 9 Committee Accepted Action: Resolution: SR-2-NFPA Statement: The Committee amended the proposed text to make the new requirement a complete sentence in accordance with the Manual of Style (MOS). The requirement is intended to protect from environmental conditions to reduce incidence of damage to fire extinguishers located outdoors as recommended in the public comment. High humidity areas, rain, freezing temperatures, exposure to sunlight, exposure to salt water, and high winds could cause corrosion and other damage to fire extinguishers that are not protected. According to the type of conditions wherein fire extinguishers are located they should be protected by use of weather covers, cabinets, etc. in order to prevent climate conditions to negatively affect the expected performance of the fire extinguisher.

8 Page 8 of 9 Public Comment No. 3-NFPA [ Section No ] Supply piping for standpipes on piers and bulkheads shall be sized for the minimum flow rate for Class II systems with a minimum flow rate of 300 gpm (1136 L/min). Statement of Problem and Substantiation for Public Comment There are four reasons for the proposal; (1) most fire service fog nozzles have a minimum gpm delivery of 150 gpm, (2) two hose streams are generally employed to extinguish a recreational vessel fire and/or protect adjacent vessels, (3) vessel and flammable liquid fires are best extinguished through the application of foam, (4) exposure protection with water streams limits potential damage from contact foam solution. Related Item Public Input No. 8-NFPA [Section No ] Submitter Information Verification Submitter Full Name: Kelly Nicolello Organization: Western Regional Fire Code Dev Street Address: City: State: Zip: Submittal Date: Tue Apr 01 18:16:49 EDT 2014 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-1-NFPA Statement: The Committee removed the reference to a Class II System. As per NFPA 14, Class II Systems are designed for minimum flow rate for the hydraulically most remote hose connection of 100 gpm (379 L/min). Combining the Class II System size criteria with a new 300 gpm (1136 L/min) flow rate requirement is confusing to Standard users and contrary to criteria for stand pipes found in NFPA 14. Otherwise the Committee agreed with the commenter's substantiation in Public Comment No. 3-NFPA that a flow rate 300 gpm (1136 L/min) is an appropriate minimum flow rate to address marina and boatyard fires. A flow rate of 300 gpm was established to provide adequate water supply for two fire service hose streams.

9 Page 9 of 9 Public Comment No. 4-NFPA [ New Section after ] ADD New Sections See attached Word Document Additional Proposed Changes File Name NFPA_303.docx Description Approved New sections Statement of Problem and Substantiation for Public Comment NFPA 303 needs to provide guidance for materials used for standpipes on docks. This submittal will allow the used of materials that are acceptable for underground installations. These materials are more corrosion resistant. Related Item Public Input No. 15-NFPA [New Section after 6.4] Submitter Information Verification Submitter Full Name: Peter Schwab Organization: Wayne Automatic Fire Sprinkler Street Address: City: State: Zip: Submittal Date: Wed May 14 10:07:31 EDT 2014 Committee Statement Committee Action: Resolution: Rejected The Standard requires standpipe systems where installed shall be in accordance with NFPA 14, Standard for the Installation of Standpipe and Hose Systems except for provisions specifically addressed in NFPA 303. The requirements for piping, fittings and joining of pipe material found in NFPA 14 are established requirements and do not need to be duplicated or amended within NFPA 303.

10 6.3.8 Piping Piping Materials. Piping shall be listed for fire protection or shall comply with the standards in Table Table Ferrous Piping (Welded and Seamless) Specification for Black and Hot-Dipped Zinc-Coated (Galvanized) Welded and Seamless Steel Pipe for Fire Protection Use Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless Wrought Steel Pipe Specification for Electric-Resistance-Welded Steel Pipe Copper Tube (Drawn, Seamless) Specification for Seamless Copper Tube Specification for Seamless Copper Water Tube Specification for General Requirements for Wrought Seamless Copper and Copper-Alloy Tube Specification for Liquid and Paste Fluxes for Soldering Applications of Copper and Copper-Alloy Tube Brazing Filler Metal (Classification BCuP-3 or BCuP-4) Solder Metal, Section 1: Solder Alloys Containing Less Than 0.2% Lead and Having Solidus Temperatures Greater than 400 F Alloy Materials PLASTIC Nonmetallic Piping Specification for Special Listed Chlorinated Polyvinyl chloride (CPVC) Pipe Polyvinyl Chloride (PVC) Pressure Pipe, 4 in. Through 12 in., for Water Distribution Polyvinyl Chloride (PVC) Pressure Pipe, 14 in. Through 48 in., for Water Distribution Polyethylene (PE) Pressure Pipe and Fittings, 4 in. (100 mm) Through 63 in. (1575 mm) for Water Distribution ASTM A 795 ANSI/ASTM A 53 ANSI/ASME B36.10M ASTM A 135 ASTM B 75 ASTM B 88 ASTM B 251 ASTM B 813 AWS A5.8 ASTM B 32 ASTM B 446 ASTM F 442 AWWA C900 AWWA C905 AWWA C906

11 Brass Pipe Specification for Seamless Red Brass Pipe Ductile Iron Cement Mortar Lining for Ductile Iron Pipe and Fittings for Water Polyethylene Encasement for Ductile Iron Pipe Systems Rubber-Gasket Joints for Ductile Iron Pressure Pipe and Fittings ASTM B 43 AWWA C104 AWWA C105 AWWA C111 Flanged Ductile Iron Pipe with Ductile Iron or Gray Iron Threaded Flanges Thickness Design of Ductile Iron Pipe Ductile Iron Pipe, Centrifugally Cast for Water Standard for the Installation of Ductile Iron Water Mains and Their Appurtenances AWWA C115 AWWA C150 AWWA C151 AWWA C Piping shall be rated for the maximum system working pressure to which they are exposed but shall not be rated at less than 150 psi (10 bar) Non metallic piping shall be evaluated for exposure to direct ultra violet rays of sunlight Where required to be protected from ultra violet rays of sunlight, the method shall be approved Fittings Fittings shall be listed for fire protection or shall be in accordance with Table Table Cast Iron Gray Iron Threaded Fittings, Classes 125 and 250 Gray Iron Pipe Flanges and Flanged Fittings, Classes 12, 125, and 250 Malleable Iron Malleable Iron Threaded Fittings, Class 150 and 300 Steel Factory-Made Wrought Steel Buttweld Fittings Buttwelding Ends ASME B16.4 ASME B16.1 ASME B16.3 ASME B16.9 ASME B16.25

12 Specification for Piping Fittings of Wrought Carbon Steel and Alloy Steel for Moderate and Elevated Temperatures Pipe Flanges and Flanged Fittings, NPS 1 2 Through 24 Forged Steel Fittings, Socket Welded and Threaded Copper Wrought Copper and Bronze Solder Joint Pressure Fittings Cast Bronze Solder Joint Pressure Fittings CPVC Chlorinated Polyvinyl Chloride (CPVC) Specification for Schedule 80 CPVC Threaded Fittings ASTM A 234 ASME B16.5 ASME B16.11 ASME B16.22 ASME B16.18 ASTM F 437 Specification for Schedule 40 CPVC Socket-Type Fittings ASTM F 438 Specification for Schedule 80 CPVC ASTM F 439 Socket-Type Fittings Bronze Fittings Cast Bronze Threaded Fittings ASTM B16.15 Ductile Iron Cement Mortar Lining for Ductile Iron Pipe AWWA C104 and Fittings for Water Ductile Iron and Gray Iron Fittings, 3 in. Through 48 in., for Water and Other Liquids AWWA C110 Rubber-Gasket Joints for Ductile Iron Pressure Pipe and Fittings Flanged Ductile Iron Pipe with Ductile Iron or Gray Iron Threaded Flanges Protective Fusion-Bonded Epoxy Coatings for the Interior and Exterior Surfaces of Ductile-Iron and Gray-Iron Fittings for Water Supply Service Ductile-Iron Compact Fittings for Water Service AWWA C111 AWWA C115 AWWA C116 AWWA C Fittings shall be rated for the maximum system working pressure to which they are exposed but shall not be rated at less than 150 psi (10 bar) Joining of Pipe and Fittings Joints shall be approved All threaded steel pipe and fittings shall have threads cut in accordance with B

13 Pipes joined with grooved fittings shall be joined by a listed combination of fittings, gaskets, and grooves Joints for the connection of copper tube shall be brazed or joined using pressure fittings as specified in Table Except as permitted by , all joints shall be mechanically restrained The following joining methods shall not be required to be mechanically restrained at every joint: (1) Locking mechanical push on joints (2) Mechanical joints utilizing setscrew retainer glands (2) Bolted flange joints (3) Heat fused joints (4) Welded joints (5) CPVC welded joints (6) Threaded joints (7) Grooved joints Hanging of Pipe and Fittings All piping shall be supported in accordance with NFPA 13.

IAPMO GUIDE CRITERIA FOR BALL VALVES IAPMO IGC PURPOSE

INTERNATIONAL ASSOCIATION OF PLUMBING AND MECHANICAL OFFICIALS IAPMO GUIDE CRITERIA FOR BALL VALVES IAPMO IGC 157-20067 1 PURPOSE 1.1 The purpose of this standard is to establish an acceptable standard