Public Comment No. 4-NFPA [ Section No ] Statement of Problem and Substantiation for Public Comment

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1 Public Comment No. 4-NFPA [ Section No ] ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM D5, Standard Test Method for Penetration of Bituminous Materials, 2006 e1. ASTM D323, Standard Test Method for Vapor Pressure of Petroleum Products, ASTM E84, Standard Test Method for Surface Burning Characteristics of Building Materials, ASTM E136, Standard Test Method for Behavior of Materials in a Vertical Tube Furnace at 750 C, standards date updates Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Thu May 02 19:25:48 EDT 2013 Committee Action: Accepted Resolution: SR-1-NFPA standards date updates I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above and the

2 Public Comment No. 6-NFPA [ Section No ] Physical Hazards. The following material categories shall be classified as physical hazards, and a material with a primary classification as a physical hazard can pose a health hazard; (1) Flammable and combustible liquids (2) Flammable solids and gases (3) Oxidizer materials (4) Pyrophoric liquids, gases, and solids (5) Unstable (reactive) materials (6) Water-reactive solids and liquids (7) Cryogenic fluids (8) Compressed Gases Compressed gases inherently pose a physical hazard due to the pressure under which they are stored. Submitter Full Name: Phillip Mariscal Organization: Compressed Gas Association Submittal Date: Fri May 03 14:36:29 EDT 2013 Committee Accepted Action: Resolution: SR-2-NFPA Compressed gases inherently pose a physical hazard due to the pressure under which they are stored. I, Phillip Mariscal, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Phillip Mariscal, and I agree to be legally bound by the above and the

3 Public Comment No. 3-NFPA [ Section No [Excluding any Sub-Sections] ]

4 Hazardous chemicals in the fabrication area shall be limited to those needed for operations and maintenance and as required by and , with quantities not exceeding the limitations specified in Table The limits of Table shall be permitted to be exceeded, provided a submittal using alternate methods and materials is approved by the authority having jurisdiction (AHJ). Table Quantity Limits for Hazardous Materials in a Single Fabrication Area Hazard Category Physical Hazard Materials?Combustible liquid Solids Liquids Gas kg/m 2 lb/ft 2 L/m 2 gal/ft 2 m NTP/m 2?Class II ?Class III-A ?Class III-B?Combination Class I, II, and III-A Cryogenic?Flammable c c b b Not limited Not limited Note Note 3 NTP/ft 2?Oxidizing Flammable gas?gaseous c c?liquefied c c b b Flammable liquid b b Note Note?Class I-A ?Class I-B ?Class I-C ?Combination Class I-A, I-B, and I-C ?Combination Class I, II, and III-A Flammable solid Organic peroxide?unclassified detonable Note a Note a Note a Note a?class I Note a Note a Note a Note a?class II ?Class III Note Note

5 Note: Hazardous materials within piping not to be included in the calculated quantities. a Quantity of hazardous materials in a single fabrication not to exceed exempt amounts in NFPA 1, Fire Code. b 3 The aggregate quantity of flammable, pyrophoric, toxic, and highly toxic gases not to exceed m (9000 ft 3 ) a density limit of.2 ft3 per ft2 at NTP. c The aggregate quantity of pyrophoric gases in the building limited to the amounts for which detached storage is not required as set forth in NFPA 1, Fire Code. 1. The industry needs these gases in the fabrication area (subfab) as low vapor pressure gases need to be close to the tool and need to be in the subfab due to the inability to deliver these gases with excessive line lengths. 2. Fabs are getting larger, which increases gas line lengths to the tools, which makes low vapor pressure gases hard to located in an HPM room for a larger fab, and increases the volume of subfab gas installations for low vapor pressure gases larger fabs, more tools. When the 9000 cu ft criteria was established, fabs we typically in the 50,000 ft3 range. The first 100, 000 fabs we seen in the US in the 1990's, and now the are becoming even larger MM is increasing the volumes of material usage, as well as the fab square footage. 4. Density limits are the norm in Table for liquids and solids and there is a precedent that this is effective. Larger fabs can work with this limits due to the restriction being normalized versus an absolute limit. 5. Fabs have shown a good history of safely managing toxic and flammable gases with safety controls such as exhausted gas cabinets, continuously welded gas lines, and gas detection with auto-shutdown. Submitter Full Name: Scott Swanson Organization: Intel Corporation Submittal Date: Fri Mar 22 13:39:38 EDT 2013 Committee Accepted Action: Resolution: SR-3-NFPA The industry needs these gases in the fabrication area (subfab) as low vapor pressure gases need to be close to the tool and need to be in the subfab due to the inability to deliver these gases with excessive line lengths. 2. Fabs are getting larger, which increases gas line lengths to the tools, which makes low vapor pressure gases hard to located in an HPM room for a larger fab, and increases the volume of subfab gas installations for low vapor pressure gases larger fabs, more tools. When the 9000 cu ft criteria was established, fabs we typically in the 50,000 ft3 range. The first 100, 000 fabs we seen in the US in the 1990's, and now the are becoming even larger MM is increasing the volumes of material usage, as well as the fab square footage. 4. Density limits are the norm in Table for liquids and solids and there is a precedent that this is effective. Larger fabs can work with this limits due to the restriction being normalized versus an absolute limit. 5. Fabs have shown a good history of safely managing toxic and flammable gases with safety controls such as exhausted gas cabinets, continuously welded gas lines, and gas detection with auto-shutdown.

6 I, Scott Swanson, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Scott Swanson, and I agree to be legally bound by the above and the

7 Public Comment No. 7-NFPA [ Section No ] Material for tubing, piping, and fittings used for distribution of compressed gases or hazardous production material gases shall be compatible with those gases. The new term, hazardous production material gases may not be encompassing enough to cover all hazardous gases. This new definition only addresses those gases with a 3 or 4 health hazard rating. There are compressed gases with health rating of other than 3 or 4 for which material compatibility must be considered. For example, the requirements in would not apply to compressed oxygen (health hazard = 0), but oxygen does warrant such safety consideration. Adding the term compressed gases as defined in would extend the requirements in to gases such as oxygen. Oxygen materials compatibility is dependent on many factors and thus, materials compatibility in oxygen is application-specific. In general, acceptance criteria for materials in a given oxygen application depend on two key factors, flammability and ignitability. Submitter Full Name: Phillip Mariscal Organization: Compressed Gas Association Submittal Date: Fri May 03 14:40:13 EDT 2013 Committee Accepted Action: Resolution: SR-4-NFPA The new term, hazardous production material gases may not be encompassing enough to cover all hazardous gases. This new definition only addresses those gases with a 3 or 4 health hazard rating. There are compressed gases with health rating of other than 3 or 4 for which material compatibility must be considered. For example, the requirements in would not apply to compressed oxygen (health hazard = 0), but oxygen does warrant such safety consideration. Adding the term compressed gases as defined in would extend the requirements in to gases such as oxygen. Oxygen materials compatibility is dependent on many factors and thus, materials compatibility in oxygen is application-specific. In general, acceptance criteria for materials in a given oxygen application depend on two key factors, flammability and ignitability. I, Phillip Mariscal, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Phillip Mariscal, and I agree to be legally bound by the above and the

8 Public Comment No. 8-NFPA [ Section No ] * Materials for tubing, piping, and fittings used for the distribution of compressed gas or hazardous production material gases shall be of noncombustible construction or of combustible construction contained in a noncombustible outer jacket. The new term, hazardous production material gases may not be encompassing enough to cover all hazardous gases. This new definition only addresses those gases with a 3 or 4 health hazard rating. There are compressed gases with health rating of other than 3 or 4 for which material compatibility must be considered. For example, the requirements in would not apply to compressed hydrogen (health hazard = 0), but hydrogen does warrant such safety consideration. Adding the term compressed gases as defined in would extend the requirements in to gases such as hydrogen. Submitter Full Name: Phillip Mariscal Organization: Compressed Gas Association Submittal Date: Fri May 03 14:41:44 EDT 2013 Committee Accepted Action: Resolution: SR-5-NFPA The new term, hazardous production material gases may not be encompassing enough to cover all hazardous gases. This new definition only addresses those gases with a 3 or 4 health hazard rating. There are compressed gases with health rating of other than 3 or 4 for which material compatibility must be considered. For example, the requirements in would not apply to compressed hydrogen (health hazard = 0), but hydrogen does warrant such safety consideration. Adding the term compressed gases as defined in would extend the requirements in to gases such as hydrogen. I, Phillip Mariscal, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Phillip Mariscal, and I agree to be legally bound by the above and the

9 Public Comment No. 10-NFPA [ Section No ] * Subatmospheric Gas Systems Sources (SAGS). All (both Type 1 and Type 2) SAGS shall meet all requirements for gases found in this standard, except as provided for in through * SAGS cylinders with incompatible gases shall be permitted to occupy the same gas cart, gas cabinet, or exhausted enclosure * Ventilation in the enclosure or gas cabinets shall be sufficient to maintain vapors below 25 percent of LFL and below IDLH Purge gas supply, referenced in , shall be permitted from a house system Shared purge panels for incompatible gases shall be permitted for SAGS sources * The requirements for automatic shutoff valves under shall not be required for SAG containing pyrophoric gases * The requirements for an RFO shall not apply to SAGS Type 1 cylinders containing hazardous production material gases. Additional Proposed Changes File Name Description Approved pdf Cover Sheet ( to us by Phillip Mariscal) Changing Systems to Sources aligns the SAGS term with the section description (7.14 Dopant Gas Sources ) and the term used in , Subatmospheric Gas Source. A system entails the cylinder, valve, piping, and controls where the source refers to the cylinder and valve only. Submitter Full Name: JERROLD SAMETH Organization: CGA Submittal Date: Thu May 09 14:57:29 EDT 2013 Committee Action: Accepted Resolution: SR-8-NFPA Changing Systems to Sources aligns the SAGS term with the section description (7.14 Dopant Gas Sources ) and the term used in , Subatmospheric Gas Source. A system entails the cylinder, valve, piping, and controls where the source refers to the cylinder and valve only.

10 0 I, JERROLD SAMETH, 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 By checking this box I affirm that I am JERROLD SAMETH, and I agree to be legally bound by the above and the

11 1 Public Comment No. 11-NFPA [ Section No ] * The requirements for automatic shutoff valves under shall not be required for SAG SAGS containing pyrophoric gases. Additional Proposed Changes File Name Description Approved pdf Cover Sheet ( to us by Phillip Mariscal) This is a minor editorial comment. The TerraView version of the NFPA 318 First Draft does not include the addition of S to SAG in The First Draft MS Word legislative document does include the addition of S to SAG. Submitter Full Name: JERROLD SAMETH Organization: CGA Submittal Date: Thu May 09 15:01:15 EDT 2013 Committee Accepted Action: Resolution: SR-9-NFPA This is a minor editorial comment. The TerraView version of the NFPA 318 First Draft does not include the addition of S to SAG in The First Draft MS Word legislative document does include the addition of S to SAG. I, JERROLD SAMETH, 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 By checking this box I affirm that I am JERROLD SAMETH, and I agree to be legally bound by the above and the

12 2 Public Comment No. 9-NFPA [ Section No ] The system shall be designed to provide a density of 12 mm 12 lpm / min m 2 (0.30 gpm/ft 2 ) over the external surface area of the trailers for a 2-hour duration. Mm/min is an incorrect a unit of measure for this context, referring to velocity and not density. Lpm/m2 (liter per minutes per square meter) is proper unit of measure for density in the context of , and corresponds to the US unit of measure. Submitter Full Name: Phillip Mariscal Organization: Compressed Gas Association Submittal Date: Fri May 03 14:47:14 EDT 2013 Committee Action: Rejected Resolution: The unit mm/min is consistant with other NFPA documents. I, Phillip Mariscal, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Phillip Mariscal, and I agree to be legally bound by the above and the

13 3 Public Comment No. 5-NFPA [ Section No. D ] D ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA IEEE/ASTM SI10, Standard for Use of the International System of Units (SI): The Modern Metric System, ASTM E1354, Standard Test Method for Heat and Visible Smoke Release Rates for Materials and Products Using an Oxygen Consumption Calorimeter, 2010b ASTM E2058, Standard Test Methods for Measurement of Synthetic Polymer Material Flammability Using a Fire Propagation Apparatus (FPA), standards date updates Submitter Full Name: Marcelo Hirschler Organization: GBH International Submittal Date: Thu May 02 19:27:10 EDT 2013 Committee Action: Accepted Resolution: SR-7-NFPA standards date updates I, Marcelo Hirschler, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in By checking this box I affirm that I am Marcelo Hirschler, and I agree to be legally bound by the above and the

Public Comment No. 39-NFPA [ Section No ] Statement of Problem and Substantiation for Public Comment Related Item

Public Comment No. 39-NFPA [ Section No ] Statement of Problem and Substantiation for Public Comment Related Item National Fire Protection Association Report of 66 http://submittals.nfpa.org/terraviewweb/contentfetcher?commentpara... 8/12/2014 12:07 PM Public Comment No. 39-NFPA 55-2014 [ Section No. 2.3.3 ] 2.3.3