Report on Comments Copyright, NFPA NFPA 495 Report of the Committee on

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1 Report of the Committee on Dave McCulloch, Natural Resources Canada, Canada [E] Explosives (Alt. to Juri T. Kasemets) Lawrence Weinman, Luna Tech/Schneier-Weinman Consultants, AL [SE] Thomas P. Dowling, Chair (Alt. to Kenneth L. Kosanke) Harpers Ferry, WV [SE] Ben Barrett, Hodgdon Powder Company, Inc., KS [M] W. S. Chang, Explosives Bureau, NJ [RT] C. James Dahn, Safety Consulting Engineers Inc., IL [SE] Jeffrey L. Dean, International Society of Explosives Engineers, OH [U] Rep. International Society of Explosives Engineers Paul W. Dickinson, Defense Contracts Management Agency, CO [E] Frank H. Fenton, III, The Township of Northampton, PA [E] Larry L. Fluer, Fluer, Inc., CA [M] Rep. Automotive Occupant Restraints Council Mark A. Fry, Mark A. Fry & Associates, Inc., NJ [SE] Robert B. Hopler, Powderman Consulting, Inc., MD [SE] Juri T. Kasemets, Natural Resources Canada, Canada [E] Kenneth L. Kosanke, PyroLabs, Incorporated, CO [SE] Robert C. Morhard, Zukovich, Morhard & Wade, LLC, PA [M] David K. Nichols, TRW Vehicle Safety Systems Inc., AZ [M] Roger N. Prescott, Austin Powder Company, OH [M] Richard L. Rhea, St. Marks Powder, Inc., FL [M] Lon D. Santis, Institute of Makers of Explosives, DC [U] Rep. Institute of Makers of Explosives David S. Shatzer, US Bureau of Alcohol, Tobacco, Firearms & Explosives, DC [E] Robert A. Van Duzer, SAAMI, PA [M] Rep. Sporting Arms & Ammunition Manufacturers Institute Barney T. Villa, Los Angeles County Sheriff s Department, CA [E] Rep. International Assn. of Bomb Technicians & Investigators Bert von Rosen, Canadian Explosives Research Laboratory, Canada [RT] Alternates Douglas H. Delsemme, Hodgdon Powder Company, Inc., KS [M] (Alt. to Ben Barrett) Eldon K. Hurley, Dyno Nobel Incorporated, NY [U] (Alt. to Lon D. Santis) Michael S. Katich, Defense Contracts Management Agency, CO [E] (Alt. to Paul W. Dickinson) Nonvoting Virginia M. Gilman, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration Mark W. Hagemann, US Department of Labor, DC [E] (Alt. to NV Principal) Rep. Occupational Safety & Health Administration Staff Liaison: Guy R. Colonna Committee Scope: This Committee shall have primary responsibility for documents on the manufacture, transportation, storage and use of explosives and related materials. This Committee does not have responsibility for documents on consumer and display fireworks, model and high power rockets and motors, and pyrotechnic special effects. This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book. This portion of the Technical Committee Report of the Committee on Explosives is presented for adoption. This Report on Comments was prepared by the Technical Committee on Explosives, and documents its action on the comments received on its Report on Proposals on NFPA 495, Explosive Materials Code, 2001 edition, as published in the Report on Proposals for the 2005 June Meeting. This Report on Comments has been submitted to letter ballot of the Technical Committee on Explosives, which consists of 21 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report

2 495-1 Log #1 Final Action: Accept in Principle in Part (Entire Document) SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: RECOMMENDATION: Delete all references to Class A, B, and C Explosives. SUBSTANTIATION: These terms have been obsolete since the early 1990s. COMMITTEE MEETING ACTION: Accept in Principle in Part Revise the ROP text as follows based upon the recommendation to delete reference to Class A, B, and C Explosives: Detonators shall not be transported in the same vehicle with other Class 1 materials (Class A or Class B explosives), except as permitted by the U.S. Department of Transportation in 49 CFR (g). In Table (b) delete (Class A explosives) where used in this table in the Storage in Magazines column in the first 3 entries. Delete (Class A or Class C explosives) where it appears in 4th entry. Delete (Class C explosives) where it appears in the 5th entry in the table. Delete (Class B explosives) where it appears in the 8th (last) entry in this table Commercial shipments of smokeless propellants exceeding 45.4 kg (100 lb) or not packaged in accordance with the regulations cited in shall be transported in accordance with the U.S. Department of Transportation regulations for Class B propellant Division 1.1 or 1.3 explosives. A Propellant. It is classified by the U.S. Department of Transportation, Hazardous Materials Regulations as Division 1.1 (Class A) or 1.3 (Class B), depending on its susceptibility to detonation, and it can be reclassed as Division 4.1 (see also ). Annex E.2, note to Table E.2 (b) - delete (Explosive C) and (Explosive A) where it appears and insert Division in front of 1.4 B and 1.4 S and 1.4 B (two places in this note). COMMITTEE STATEMENT: The submitter s recommendation was not specific, so the Committee has reviewed the entire document for the use of Class A, B or C explosives and determined which usages are suitable for deletion as recommended. In a couple of instances, the Committee did not delete the term as the context for that usage necessitated retaining the existing text without revision. The Committee s action accomplished the intent of the submitter. BALLOT RESULTS: Affirmative: 18 Negative: 1 EXPLANATION OF NEGATIVE: DAHN: I do not believe using UN/DoT test protocols will provide adequate safety in in-process materials and conditions Log #11 Final Action: Accept in Principle (Entire Document) SUBMITTER: Larry Fluer, Fluer, Inc. COMMENT ON PROPOSAL NO: RECOMMENDATION: The enclosed comment is a proposal to revise the original proposal as submitted by TRW to create a new Chapter in NFPA 495 (Chapter 5 as issued in response to the ROP meeting of March 3, 2004) and ancillary changes. The entire Chapter is new, and as such would be underlined, however, for ease of understanding the Chapter as initially released in the ROP draft has been put into legislative format to show the changes made since the original submittal. Chapter 5 Manufacturing and Testing 5.1 Scope. Manufacture and, testing of explosives shall be in accordance with the requirements of this chapter Blasting agents shall not be subject to the requirements of this chapter (See Chapter 6) Water gels, slurries, and emulsion explosives shall not be subject to the requirements of this chapter (See Chapter 7). 5.2 General Requirements Emergency Procedures. Emergency procedures shall be developed for each manufacturing facility Posting of pertinent information. Standard operating procedures governing the manufacturing process shall be located at workstations where the work is to be conducted Training. Persons handling explosive materials or working in operating buildings shall be trained in accordance with Sections through The physical and health hazards of the explosive materials to be manufactured The operational activities involved in processing the materials to include instructions in emergencies that are anticipated in the manufacturing process The operating rules applicable to the materials in the manufacturing process Plans for emergency procedures in the event of a fire or explosion Personnel shall be made aware of emergency warning signals and actions to take in the event the warning signal is activated Contract personnel working in explosive manufacturing areas shall be instructed on site specific operating procedures, emergency procedures, hot work operations and procedures applicable to the area prior to engaging in any activity whether maintenance related or not Visitors entering operational areas shall receive orientation training and shall be accompanied by a trained escort * Containers. Bulk explosive materials shall be stored in approved containers when not in use * Waste. When waste receptacles are provided for the collection of waste materials and debris, such waste receptacles shall be Aapproved receptacles and equipped with covers. shall be provided for each location where explosive materials are manufactured for the disposing of waste material and debris Emptying waste containers. Waste receptacles shall be emptied and cleaned in accordance with operating procedures. as often as necessary but not less than once each day or at the end of each shift when more than one shift operations are conducted Collection of spilled material. Spilled or dropped explosive materials which are spilled outside of designated containment or confinement zones shall be collected immediately promptly for disposal or disposition and the area in which the materials were spilled shall be cleaned Contaminated materials. Shipping containers, ccleaning materials or materials that have been contaminated with explosive materials shall be removed daily and disposed of in an approved manner Shipping containers. Shipping containers used for explosive materials shall be allowed to be retained for reuse as required Maintenance. Non-routine Mmaintenance and repair work shall not be performed in an explosive manufacturing area until prescribed clean-up and decontamination has been performed. explosive materials have been removed and the area has been prepared for such maintenance or repair work to be conducted Operational adjustments. Operational adjustments or emergency repairs to mitigate immediate hazardous conditions shall be permitted without having removed the explosive materials from the area.repair work. The area in which repair work is to be conducted shall be inspected and approved by supervisory personnel prior to conducting the work Ignition source control Smoking. Smoking shall be prohibited on the plant site, except where notices permitting it are posted Flame producing devices. Matches, torches or other flame-producing devices shall be prohibited from being taken into explosives manufacturing areas without a written permit signed by an authorized supervisor Portable Electrical Devices. Portable electrical devices including flashlights shall be prohibited from being taken into explosives manufacturing areas Portable electrical equipment. Portable electrical equipment approved for use in the specific manufacturing environment shall be permitted when designated by the manufacturing process and incorporated into the operating instructions described in Section Clothing Type of clothing. Clothing to be worn by persons involved in the manufacturing process shall be of a type approved by management Accessories. Watches, jewelry, finger rings, earrings, and items intended for use as accessories shall not be worn in manufacturing areas where explosive materials are manufactured Contaminated clothing. Persons wearing clothingthat has been contaminated with explosive materials shall not be permitted to enter areas where smoking is permitted or where operations involving the use of open flame or open ignition sources are present Clearance from combustibles. The area within 25 feet (7.6 m) of operating buildings shall be kept clear of brush, leaves, vegetation and other combustible materials Limited access by authorized personnel. Manufacturing areas shall be secured against unauthorized entry with access limited to that necessary for the performance of operating functions Separation of incompatible materials. Incompatible materials in storage and storage of materials incompatible with materials in use shall be separated by one of the following methods: Segregating incompatible materials storage from use by a distance of not less than 20 ft (6.1m) Isolating incompatible materials in storage by a noncombustible partition extending not less than 18 in (46 cm) above and to the sides of the stored material Storing liquid and solid materials in hazardous materials storage cabinets complying with NFPA Housekeeping.

3 Floors. Floors of manufacturing areas shall be swept or otherwise Division 1.3 propellants. The total weight of the propellants alone is maintained to prevent the accumulation of explosive materials. the net explosive weight. The net weight of the propellants shall be used. See Tools and equipment. Tools and equipment shall be kept in Table 5.3.3(b). designated areas when not in use during Combinations of bulk metal powder and pyrotechnic manufacturing operations. compositions. The sum of the net weights of Hot work. Hot work operations shall be conducted in accordance with metal powders and pyrotechnic compositions in the containers. the requirements of NFPA Combinations of mass detonating explosion and nonmassdetonating explosion hazard explosives (excluding Division 1.4) Management. Management shall be responsible for the supervision of hot work activity * When Division 1.1 and 1.2 explosives are located in the same site, Permits. Permits to conduct hot work operations shall be required. determine the distances for the total quantity first as 1.1 and then as 1.2. The 5.3 Classification and characterization of energetic materials used in required distance is the greater of the two. When the Division 1.1 requirements process operations are controlling and the TNT equivalence of the 1.2 is known, the TNT 5.3.1* In-process hazard classification. Explosive materials being processed equivalent weight of the 1.2 items shall be added to the total explosive weight shall be classified with an in-process hazard classification based on the hazards of Division 1.1 items to of the material in the configuration and quantity employed. determine the net explosive weight of explosives for Division 1.1 distance High explosion hazard. The classification of materials that have not determination. See Table 5.3.3(a) or been established by testing or those where the quantity or configuration used 5.3.3(b) as applicable. exhibit a high explosion hazard shall be classified as a high explosion hazard * When Division 1.1 and 1.3 explosives are located in the same site Materials of known character or composition in the configuration and determine the distances for the total quantity first as 1.1 and then as 1.3. The quantity specific to the process where the in-process hazard classification is required distance is the greater of the two. When the division 1.1 requirements approved by the authority having jurisdiction shall be allowed to be classified are controlling and the TNT equivalence of the 1.3 is known, the TNT as other than a high explosion hazard. equivalent weight of the 1.3 items shall be added to the total explosive weight Physical hazards established by testing. When testing is performed of Division 1.1 items to determine the net explosive weight of explosives the Characterization of explosive materials shall be confirmed by utilizing test for division 1.1 distance determination. See Tables 5.3.3(a) or 5.3.3(b) as methods shall be those established by DOD, ATF, UN/DOT or other approved applicable. criteria * When Division 1.1, 1.2 and 1.3 explosives are located in the same Technical assistance. The AHJ shall be permitted to require site, determine the distances for the total quantity first as 1.1, next as 1.2 and a review by an independent third party with expertise in the matter to be finally as 1.3. The required distance is the greatest of the three. As permitted reviewed at the submitter s expense. by Sections and above, TNT equivalent weights for 1.2 and Physical hazards alternative methodology. Materials that have not 1.3 items are allowed to be used to determine the net weight of explosives for been assigned an in-process hazard classification by testing in the configuration Division 1.1 distance determination. Table 5.3.3(a) or 5.3.3(b) shall be used and quantity specific to the process shall be classified as a mass or high when TNT equivalency is used to establish the net explosive weight. explosion hazard Combinations of non-mass-detonating exploding ammunition and Health hazard classification. The health hazards of materials used explosives of different Divisions shall be treated as follows. in the manufacturing process shall be determined in accordance with the Determine the required separation for eachdivision. requirements of NFPA 1. In addition to physical hazards that are present, Use the greatest separation of those determined. materials classified as toxic, highly toxic or corrosive materials shall be 5.3.3* Intraplant separation of operating buildings. Operating buildings, classified as health hazards. including those where explosives charges are assembled, manufactured, Multiple Hazards. Materials that have multiple hazards shall conform prepared or loaded utilizing Division 1.1, 1.2, 1.3, or 1.4 explosives, shall be to the Code requirements for each applicable hazard category specified. separated from all other operating buildings, magazines, inhabited buildings, Quantity of Explosives. The quantity-distance (Q-D) tables in Section public highways, and passenger railways at a distance not less than those shall be used to provide minimum distances from potential explosion shown in Tables 5.3.3(a), 5.3.3(b) or 5.3.3(c) as applicable. Distances to sites. The classification of the explosives and the weight of the explosives are assumed property lines drawn for the purposes of determination of exterior primary characteristics governing the use of these tables. The net explosive wall and opening protection under the requirements of the Building Code shall weight shall be determined in accordance with Sections through not be used to establish the minimum distance for separation between buildings Mass-detonating explosives explosion hazards. Division 1.1or 1.2 on a operating line. explosives. The total net explosive weight shall be used. See Table 5.3.3(a) for operating buildings, and Table for all other cases When the TNT equivalence of the explosive material has been determined, the equivalence is allowed to be used to establish the net explosive weight Non-mass-detonating explosives explosion hazards (excluding Division 1.4)

4 Table X.3.3(a) MINIMUM INTRALINE (INTRAPLANT) SEPARATION DISTANCES (ILD or IPD) BETWEEN BARRICADED a, b, c OPERATING BUILDINGS CONTAINING EXPLOSIVES DIVISION 1.1 or 1.2 MASS EXPLOSION HAZARD NET EXPLOSIVE WEIGHT NET EXPLOSIVE WEIGHT Pounds over 2 Pounds not over 5 Intraline distance (ILD) or Intraplant distance (IPD) (feet) 16 Pounds over Pounds not over Intraline distance (ILD) or Intraplant distance (IPD) (feet) ,000 18, ,000 20, ,000 25, ,000 30, ,000 35, ,000 40, ,000 45, ,000 50, ,000 55, ,000 60, ,000 65, ,000 70, ,000 75, ,000 80, ,000 85, ,000 90, ,000 95, , , , , , , , , , , , , , , , , , , , , ,000 4, , , ,000 5, , , ,000 6, , , ,000 7, , , ,000 8, , , ,000 9, , , ,000 10, , , , , , a. Where a building or magazine containing explosives is not barricaded, the intraline distances shown in this table shall be doubled. b. Linear interpolation between tabular values shall not be allowed. Non-linear interpolation of the values shall be allowed subject to an approved technical opinion and report prepared in accordance with the requirements of NFPA 1. c. Do shall be a minimum of 60 feet. Where a building or magazine containing explosives is barricaded, the minimum distance shall be 30 feet. When the distance is less than 60 feet and the building is un-barricaded the fire-resistance of exterior walls and protection of wall openings shall be in accordance with the building code

5 Table 5.3.3(b) TABLE OF DISTANCES (Q-D) FOR BUILDINGS CONTAINING EXPLOSIVES DIVISION 1.3 MASS FIRE HAZARDa,b,c QUANTITY OF DISTANCES IN FEET DIVISION 1.3 EXPLOSIVES (Net Explosive Weight) Pounds over Pounds not over Inhabited buildings distance IBD Distance to public traffic route (PTR) Intermagazine distance (IMD) Intraline distance (ILD) or Intraplant distance (IPD)d 0 1, ,000 5, ,000 10, ,000 20, ,000 30, ,000 40, ,000 50, ,000 60, ,000 70, ,000 80, ,000 90, , , , , , , a. Black powder, when stored in magazines, is defined as low explosive by the Bureau of Alcohol, Tobacco and Firearms (ATF). b. For quantities less than 1,000 pounds, the required distances are those specified for 1,000 pounds. The user of lesser distances shall be permitted when supported by test data and/or analysis. c. Linear interpolation of explosive quantities between table entries is permitted. d. Do shall be a minimum of 50 feet

6 Table 5.3.3(c) TABLE OF DISTANCES (Q-D) FOR BUILDINGS CONTAINING EXPLOSIVES DIVISION 1.4c,d QUANTITY OF DIVISION 1.4 EXPLOSIVES DISTANCES IN FEET QUANTITY OF DISTANCES IN FEET DIVISION 1.4 EXPLOSIVES (Net Explosives Weight) Pounds over Pounds not over Inhabited buildings distance IBD Distance to public traffic route (PTR) Intermagazine distance a,b (IMD) Intraline distance (ILD) or Intraplant distance (IPD)a, e 50 Not Limited a. A separation distance of 100 feet is required for buildings of other than Type I and II construction as defined in NFPA b. For earth-covered magazines, no specified separation is required. (1) Earth cover material used for magazines shall be cohesive. Solid or wet clay and types of soil that are too cohesive and shall not be used. Soil shall be free from unsanitary organic matter, trash, debris and stones heavier than 10 pounds or longer than 6 inches in diameter. Compaction and surface preparation shall be provided to maintain structural integrity and to prevent erosion. Where cohesive material are not used, as in sandy soil, the earth cover over magazines shall be finished with materials that ensure structural integrity. (2) The earth fill or earth cover between earth-covered magazines shall be either solid or sloped in accordance with the requirements of other construction features. There shall be a minimum of 2 feet of earth cover maintained over the tope of each magazine. The cover shall have a slope of 2 to 1 horizontal to vertical. c. restricted to articles, including articles packaged for shipment, that are not regulated as an explosive by Bureau of Alcohol, Tobacco and Firearms (ATF) regulations, or to unpacked articles used in process operations that do not propagate a detonation or deflagration between articles. d. Linear interpolation between tabular values is not applicable. e. Do shall be a minimum of 50 feet

7 5.3.4 Determination of net explosive weight for operating buildings. In Cleaning of collection systems. Explosive dusts shall be removed addition to the requirements of Section to determine the net explosive from the collection system on a regular basis to prevent overloading and weight for materials stored or used in operating buildings, quantities of accumulation within the system. The system shall be cleaned at a frequency explosives materials stored in magazines located at distances less than intraline that eliminates hazardous concentrations of explosive dusts from accumulating distances from the operating building shall be added to the contents of the in pipes, tubing or ducts. operating building to determine the net explosive weight for the operating 5.5 Operations building Posted limits. Personnel and explosive limits shall be posted within each Indoor magazines. The storage of explosive materials located in indoor operating building. The posted limits shall be able to be seen by operating magazines in operating buildings personnel or those that inspect operating buildings upon entry. shall be limited to a net explosive weight not to exceed 50 pounds Workstation protection. Workstations shall be separated by distance, Outdoor magazines with a net explosive weight less than 50 pounds. barrier or other means that provide The storage of explosive materials in outdoor magazines located at less than equivalent protection. intraline distances from operating buildings shall be limited to a net explosive Fire. Means shall be provided so that fire in one workstation will not weight not to exceed 50 pounds. ignite material in the next workstation Outdoor magazines with a net explosive weight greater than Shielding. Workstations shall be evaluated to determine the need for pounds. The storage of explosive materials in outdoor magazines in quantities operator shielding to protect exceeding 50 pounds net explosive weight shall be limited to storage in outdoor operators from the effects of an inadvertent fire or explosion. When determined magazines located not less than intraline distances from the operating building to be necessary, operators shall be protected by a personnel shield located in accordance with Section between the operator and the explosive device or material being Net explosive weight of materials stored in combination indoor and processed. outdoor magazines. The Construction. When provided, shields and supports shall be aggregate quantity of explosive materials stored in any combination of indoor constructed to a tested design to withstand the effects from the maximum magazines or outdoor magazines amount of explosive materials for which they are designed. located at less than the intraline distances from an operating building shall not Remote processing. When the type of material and processing warrants, exceed 50 pounds. mechanical operations involving the processing of more than 1 pound (0.45 kg) 5.4 Buildings and Equipment of explosive material shall be performed at isolated stations or at Construction. Operating buildings shall be constructed in accordance intraplant distances. with the requirements of NFPA Operator location. When remote processing operations are conducted, operators and controls shall be Location. Operating buildings shall be located in accordance with located behind barricades or at separation distances that provide operator Section based on the net explosive weight of materials contained. protection while machinery is operating Plans. A copy of the construction plans shall be kept on the premises of Protection against entry of foreign objects. Procedures shall be taken, the manufacturing site and shall be provided to the authority having jurisdiction and equipment shall be designed upon request. in a manner that prevents the entry of foreign objects or materials from entering Means of Egress. Obstructions, including storage, shall not be placed in the process in other than a the required width of a means of controlled manner. egress, except projections as allowed by the Building Code. Means of egress Equipment repair. Repairs to explosive material processing equipment shall not be obstructed in any manner and shall remain free of any material shall not be undertaken until or matter where its presence would obstruct or render the means of egress prescribed decontamination of the equipment has been performed. hazardous Supervision. Repair work to be conducted in process areas shall be Maintenance of Exits. The required fire-resistive rating of walls, approved by supervisory personnel ceilings and openings that are part of a before repair work commences. means of egress shall be maintained Examination of repairs. Repaired process equipment shall be Locking of Exits. Exits throughout operating buildings shall be examined and tested for operability unlocked and verified operable before before being place back into service. The required testing shall be verified by operations are begun. supervisory personnel Electrical wiring and equipment Tools. Tools used for repair, construction, cleanup or maintenance in Electrical wiring and equipment shall be installed in accordance with processing areas shall be limited to those described in the operating procedures NFPA 70, National Electrical Code. for the process being operated Bonding and grounding Temperature extremes. Process temperatures and surface temperatures The non-current-carrying metal parts of electrical equipment of equipment that will be in contact with explosive materials, ingredients or including electric motors, generators, mixtures being processed shall be maintained less than the decomposition proportioning devices, and other electrical enclosures serving individual temperature of such materials. manufacturing processes shall be 5.6 Explosive materials testing sites electrically bonded together in accordance with the requirements of NFPA 70, Location. Detonation or ignition of explosive materials shall be National Electrical Code. performed in isolated areas or areas that Where the electrical system is required to be grounded, the grounding have been designed specifically for the tests to be conducted. conductors shall be connected Personnel protection. Protection shall be provided through the use of together and to the supply system grounded conductor in accordance with the barricades, shielding or other means to protect personnel and property from the requirements of NFPA 70, National Electrical Code. effects of explosion or ignition of the materials being tested * Static Electricity Hazards Personal protective equipment. Protective clothing and equipment Static Accumulation. When processes or conditions exist where the shall be provided to protect persons engaged in the testing, ignition or materials in process are able to an explosive mixture is able to be ignited by detonation of explosive materials. static electricity with an intensity capable of propagating ignition, means shall Safeguards. be provided to prevent the accumulation hazardous levels of a static charge Authorized personnel. Test areas shall be restricted to access by Static control. The working area where screening, grinding, blending authorized personnel. and other processing of static-sensitive explosive materials is done shall be Posting. When test areas are located out of doors, areas where provided with approved static controls. explosives are to be ignited shall be provided with means to prevent access by Ventilation. Mechanical ventilation systems shall be in accordance with unauthorized personnel. NFPA 5000 and the Mechanical Code Warning devices. Warning devices shall be used before igniting or Local Exhaust. Local exhaust systems shall be provided to collect detonating explosive materials in test areas to warn persons from any direction and remove moisture and odors, fumes, smoke, gas, mist, heat, dust, or other of approach that they are approaching a danger zone. materials that are in present in quantities that irritate or injure occupants above the limits in applicable federal, state, or local regulations Intrinsically safe ventilation system. Exhaust systems shall be in Also in Chapter 8 add the following: accordance with NFPA Electric motors. Electrical motors used to power fans or blowers Indoor or outdoor magazines utilized in conjunction with operating used in the ventilation system shall be located outside of the duct or portion of buildings shall be in accordance with the requirements of 5.3 and as the system exposed to explosive materials. applicable Explosive dust. Explosive dust shall not be exhausted to the atmosphere. Annex A Dust collection. Explosive dust shall be collected using a wet A Approved containers may include those that are non-static generating, collector system or other approved means. Wetting agents shall be compatible non-sparking or otherwise designed in such a manner as to avoid inadvertent with the explosive materials being collected. ignition of the contained material. Tests or analysis may be required to 495-7

8 The intrinsic chemical or physical properties of a material alone may establish the hazard character, or the hazard character may be influenced by extrinsic factors such as temperature, pressure, arrangement, or the mechanical aspects of the process operations. Various methods can be used to establish the inprocess hazard classification for the materials being manufactured or used within the manufacturing process. Some materials may have well established process parameters where the nature of the process and the nature of the formulations have long been known. Other materials or processes to which the materials are exposed may be new, or the methods or equipment in which they are to be manufactured or handled is either new or outside of the established parameters. In all cases, an in-process hazard classification for the material being formulated or used is required. When decisions are made regarding the siting, occupancy or use of a building in which manufacturing occurs it is critical that each step of the process be evaluated so the appropriate in- Report on Comments Copyright, NFPA NFPA 495 determine the acceptability of the container used. process hazard classification is assigned in order that the building location is A The disposal of hazardous waste may be further regulated by appropriate and that the area of the building utilized is assigned the proper authorities charged with environmental occupancy classification. protection, transportation or regulations of the jurisdiction in which the facility operates. A Tests required for finished goods containing explosive materials in a packaged form suitable for shipment or storage have been established by the U.S. Department of Transportation (DOT) and the Bureau of Alcohol, Tobacco and Firearms (ATF). The tests established for the purposes of shipment do not consider key elements that must be examined in a manufacturing situation. The condition, state, quantity or configuration of the material may vary within the manufacturing process and the hazards of the material may vary accordingly. It is not unusual for the finished materials manufactured to carry a different classification from those of the raw materials used, or the classification assigned as those materials move throughout the manufacturing process. A classification methodology is needed that recognizes the hazards commensurate with the application to the variable physical conditions as well as the potential variation due to the configuration in which the material is found throughout the manufacturing process. The hazard classification, e.g., Division 1.1, 1.3, etc., of explosive materials when packaged for transportation or storage may be different from the hazard classification for these same materials as the materials are manufactured or moved within a process. The differences may be due to quantity or mass of material present, its physical form, the configuration (or arrangement) in which the material is found as well as other extrinsic or intrinsic factors. An in-process hazard classification is used to characterize the hazards of a given material as it exists outside of its packaging within the manufacturing process. The hazard classification of high explosion hazard is generally considered to be the most severe. Materials that are known to have a high explosion hazard are treated as those that mass explode. The code allows the user either to assume that the material presents a high explosion hazard or to demonstrate that the in-process hazard classification is other than a high explosion hazard through documentation, experience with a given process, or by testing. An example of a documented method may include explosives that are manufactured to a published Military Standard and procedure or to another established process that is documented by qualified operating procedures. To be qualified the procedure should assign an in-process hazard classification than can be demonstrated, or a high explosion hazard classification may be assumed. An example of experience with a given process may include a process, equipment and procedures that have been used by multiple manufacturers over a prolonged period of time so that there is an ample database with which to establish the incident history within the manufacturing process as to the hazards the process poses. By testing with an agreed upon protocol an in-process classification may be assigned to one or more steps in the process. The hazard classification of packaged explosive materials may vary as the material is removed from the original shipping container for use in an assembly operation. Similarly, the hazard classification for materials that are in the process of being formulated may vary and the hazard classification of the bulk form of the material may be quite different from that of the same material in its packaged state. The hazard classification of some materials may be said to be package dependent with the hazard character subject to change depending on the type or construction of the packaging used as well as the quantity contained within a given package. An analogy can be made to that of packaged material with unpackaged materials that are being handled in processing operations through the use of mechanical equipment such as mixing, blending or formulation processes. The quantity of material used, the shape of the containers (or configuration) to include the physical dimensions used may all have a bearing on the hazard classification of the material. The critical mass (critical height, and/or critical diameter) is frequently used as a measure of safety in establishing the parameters of the manufacturing process When testing is used to establish the classification tests defined by the Department of Defense (DOD), the Bureau of Alcohol, Tobacco and Fire Arms (ATF), United Nations Transport of Dangerous Goods (UN) or Department of Transportation (DOT) are generally used. Regardless of the specific tests being performed, the protocol as well as the acceptance criteria should be agreed upon between the user and the AHJ. The figures below provide examples of a test protocol in which the in-process hazard classification of materials are established by testing. Figure 1 is used for the in-process classification of substances, and Figure 2 is used for the in-process classification for unpackaged articles. (See Figures on the following pages.) A The case for separation of Division 1.2 materials represents a special case due to the potential production of hazardous fragments. Un-barricaded operating buildings or magazines containing 1.2 explosives may require additional separation distances than indicated in the tables. Such separation is determined on a case by case basis. Section can be used as the authority to engage a third party to assist in this evaluation. A When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity. A When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity. A When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity. A For guidance on static electricity hazards see NFPA 77, Recommended Practice on Static Electricity. Changes to Annex E E.2.5 Informational References add the following: Speed, Thaddeus, C., In-Process Hazard Classification of Explosives, Safety Management Services, Inc., West Jordan, UT, December Changes to Chapter Day Box. A Type 3 magazine Hazardous Material. A chemical or substance that is a physical hazard or health hazard as defined and classified in NFPA 1, whether the material is in usable or waste condition Health Hazard Material. A chemical or substance classified as a toxic, highly toxic, or corrosive material in accordance with the definitions set forth in NFPA xx Incompatible Material(s). Materials that, when in contact with each other and outside of the condition of intended use, have the potential to react in a manner that generates heat, fumes, gases or by-products that are hazardous to life and property. A.3.3.xx. Explosive materials are unique in that they contain materials otherwise considered to be incompatible, e.g., fuels and oxidizers that may be in intimate contact with one another. The conditions of containment and the design of the packaging are such that the reaction that occurs between the materials is controlled by the user. On the other hand explosive materials as such are not necessarily compatible with all other materials and means must be taken to ensure that the materials in their manufactured state will not cause unexpected reactions should inadvertent spills or mixing occur Inhabited Building Distance (IBD). The minimum separation distance between an operating building or magazine containing explosive materials and an inhabited building Intermagazine Distance (IMD). The minimum separation distance between magazines Intraline Distance (ILD) or Intraplant Distance (IPD). The distance to be maintained between any two operating buildings on an explosives manufacturing site at least one of which contains or is designed to contain explosives or the distance between a magazine and an operating building Mass Detonate (Mass Explode). Simultaneous detonation or explosion of the total amount or a substantial amount of a quantity of explosive material caused by the explosion of a unit or part of the explosive material Minimum separation distance (D 0 ). The minimum separation distance between adjacent buildings occupied in conjunction with the manufacture, transportation, storage, or use of explosive materials where one of the buildings contains explosive materials and the other building does not Net Explosive Weight (NEW). The weight of explosive material expressed in pounds. The net explosive weight is the aggregate amount of explosive material contained within buildings, magazines, structures or portions thereof, used to establish quantity-distance relationships.

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10 495-10

11 Operating Building. A building utilized in conjunction with the COMMITTEE MEETING ACTION: Accept in Principle manufacture, transportation, or use of explosive materials. Operating buildings Add a new Chapter 5 on Manufacturing and Testing. are separated from one another with the use of intraplant or intraline distances Operating Line. A group of buildings, facilities, or workstations Chapter 5 Manufacturing and Testing so arranged as to permit performance of the steps in the manufacture of an explosive or in the loading, assembly, modification, and maintenance of 5.1 Scope. Manufacture and testing of explosives shall be in accordance with ammunition or devices containing explosive materials. the requirements of this chapter Physical Hazard Material. A chemical or substance classified as Blasting agents shall not be subject to the requirements of this chapter a combustible liquid, combustible fiber, explosive, flammable cryogen, (See Chapter 6). flammable gas, flammable liquid, flammable solid, organic peroxide, oxidizer, Water gels, slurries, and emulsion explosives shall not be subject to the oxidizing cryogen, pyrophoric, unstable (reactive), or water reactive material in requirements of this chapter (See Chapter 7). accordance with the definitions set forth in this 5.2 General Requirements. code or in NFPA Emergency Procedures. Emergency procedures shall be developed for Public Traffic Route. The minimum separation distance between any each manufacturing facility. public street, road, highway, navigable stream, or passenger railroad that is Posting of pertinent information. Standard operating procedures used for through traffic by the general public and a magazine or operating governing the manufacturing process shall be located at workstations where the building. work is to be conducted Quantity-Distance (Q-D). The quantity of explosive material and Training. Persons handling explosive materials or working in operating separation distance relationships providing protection. These relationships are buildings shall be trained in accordance with Sections through based on levels of risk considered acceptable for the stipulated exposures and The physical and health hazards of the explosive materials to be are tabulated in the appropriate Q-D Tables. The separation distances specified manufactured. afford less than absolute safety The operational activities involved in processing the materials to SUBSTANTIATION: Comment is being issued on NFPA 495 Proposals, include instructions in emergencies that are anticipated in the manufacturing 495-4, and as follows: process. The Automatic Occupant Restraint Council (AORC), of which TRW is a The operating rules applicable to the materials in the manufacturing member is of the opinion that NFPA 495 is technically flawed. The AORC was process. founded in 1965 as the American Seat Belt council to assist in establishing Plans for emergency procedures in the event of a fire or explosion. uniform production and quality standards for seat belts. The name was changed Personnel shall be made aware of emergency warning signals and to Automotive Occupant Restraints Council (AORC) in 1988 to better represent actions to take in the event the warning signal is activated. its diverse membership, which is now international and includes manufacturers Contract personnel working in explosive manufacturing areas shall be and suppliers of air bags, air bag components, and seat belts, as well as instructed on site specific operating procedures, emergency procedures, hot automotive seating and interior safety components. work operations and procedures applicable to the area prior to engaging in any The scope of the code indicates that the code is applicable to the activity whether maintenance related or not. manufacture, transportation, storage, sale, and use of explosive materials Visitors entering operational areas shall receive orientation training and There are no enforceable requirements provided for the manufacture of shall be accompanied by a trained escort. explosive materials, which by definition includes devices. Existing Chapters 5.2.4* Containers. Bulk explosive materials shall be stored in approved 5 and 6 for Blasting Agents and Water Gel and Emulsion Explosive Materials containers when not in use. contain provisions for mixing and blending and what might be viewed as 5.2.5* Waste. When waste receptacles are provided for the collection of waste manufacturing operations involving these select materials. There are no general materials and debris, such waste receptacles shall be approved and equipped provisions that apply to manufacturing of explosive materials or devices other with covers. than the aforementioned materials Emptying waste containers. Waste receptacles shall be emptied and NFPA 5000 has been published as NFPA s Building Construction and Safety cleaned in accordance with operating procedures. Code. It establishes requirements for the construction of buildings to be used Collection of spilled material. Spilled or dropped explosive materials for the manufacture of explosive materials as well as for all other buildings. which are spilled outside of designated containment or confinement zones shall NFPA 1-UFC is NFPA s Fire Prevention Code. The Fire Prevention Code be collected promptly for disposal or disposition and the area in which the in Section refers to NFPA 495 for requirements for the manufacture, materials were spilled shall be cleaned. transportation, storage, sale and use of explosive materials. NFPA 5000, Contaminated materials. Cleaning materials or materials that have section , establishes the location for buildings containing explosive been contaminated with explosive materials shall be removed daily and materials (Protection level 1) and then exempts buildings regulated by NFPA disposed of in an approved manner All other construction related provisions have been developed assuming Shipping containers. Shipping containers used for explosive that mass explosion will occur without recognition of variables inherent with materials shall be allowed to be retained for reuse as required. the hazard class system now recognized and established by UN/DOT. In not Maintenance. Non-routine maintenance and repair work shall addressing the needs for explosives manufacturing, the code user is not able to not be performed in an explosive manufacturing area until clean-up and plan and design compatible buildings, and there are essentially no enforceable decontamination have been performed as required by operating procedures. requirements within NFPA s family of codes that regulate the manufacturing Repair work. Maintenance and repair that is not addressed by the process. operating procedures shall be reviewed and approved by supervisory personnel In today s global economy industry must not only plan the construction prior to conducting the work. of facilities carefully, it is to industry s advantage to standardize on designs Ignition source control. that are based on a set of predictable and enforceable requirements. The Smoking. Smoking shall be prohibited on the plant site, except where lack of consensus in NFPA s codes and standards designed to address the notices permitting it are posted. built community works to the disadvantage of industry seeking to engage Flame producing devices. Matches, torches or other flame-producing in responsible manufacturing operations using or manufacturing explosive devices shall be prohibited from being taken into explosives manufacturing materials. areas without a written permit signed by an authorized supervisor. Recognition of the UN/DOT classification system of hazard classification * Portable electrical and electronic equipment. Portable electrical for this group of materials allows the code to evolve by creating enforceable and electronic equipment shall be permitted only when designated by the hazard based provisions. Building utilization is enhanced when the building manufacturing process and incorporated into the operating instructions related controls are appropriate for the occupancy or use intended, but building described in Section level controls cannot be reasonably prescribed without first providing a A In determining equipment that is appropriate to be included baseline for the regulation of the manufacturing process. By establishing the management should be aware that there is a wide variety of electronic baseline controls that are to be used within NFPA 495 there will be closure to equipment employed today including hearing aids, writing instruments, the issues now raised by the absence of regulatory controls for materials in this communication devices, etc. Procedures for acceptance should consider high hazard class. devices other than portable tools, which has been the traditional point of The provisions contained in the proposed new Chapter have been drawn control. in part from the Uniform Fire Code, which has now evolved into NFPA Clothing. UFC and from good practice recommendations of the Institute of Makers Type of clothing. Clothing to be worn by persons involved in the of Explosives (IME). Every effort has been made to address the negative manufacturing process shall be of a type approved by management. comments issued from committee members during the balloting phase, and Accessories. Watches, jewelry, finger rings, earrings, and items the proposed Chapter has been revised to address the concerns. Related annex intended for use as accessories shall not be worn in manufacturing areas where information has also been expanded and provided in order to better explain the explosive materials are manufactured. need Contaminated clothing. Persons wearing clothing that has been contaminated with explosive materials shall not be permitted to enter areas where smoking is permitted or where operations involving the use of open flame or open ignition sources are present Clearance from combustibles. The area within 25 feet (7.6 m) of