of 18 7/28/2014 12:10 PM Public Input No. 4-NFPA 32-2013 [ Global Input ] Note: This Proposal originates from Tentative Interim Amendment 32-11-1 (TIA 999) issued by the Standards Council on October 20, 2010. 1. Revise subsection 1.3.1 to read as follows: 1.3.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. 2. Add a new subsection 1.3.1.1 to read as follows: 1.3.1.1 Any change or modification to the equipment or installation in a facility where the classification of solvent or type of system changes from a previous approval shall be subject to all provisions of this standard. 3. Revise definition 3.3.3 and add a new A.3.3.3 to read as follows: 3.3.3* Conversion. Any modification(s) made to a new, existing, or used drycleaning machine, drying tumbler, or reclaiming tumbler that permits the use of a solvent of a different class or permits a change to a different solvent in the same class, other than that which is specified on the original manufacturersee Annex B, Guidance on Conversion). A.3.3.3 Conversion. Conversion or modification of a new or existing drycleaning machine, drying tumbler, or reclaiming tumbler that permits the use of the same class solvent, but a different solvent than specified by the original equipment manufacturer, is technically feasible, and is being conducted. The AHJ should be notified prior to commencing the modification or conversion of the equipment. Documentation should be provided to the AHJ showing the original manufacturer 4. Change 4.1.2 to read 5. Add new subsections 4.1.2.1.1 and 4.1.2.1.2 to read as follows: 4.1.2.1.1 When a change in solvent used does not reflect a change in the classification or type of system, the new solvent shall be considered a conversion. 4.1.2.1.2 Hazards associated with the conversions described in 1.3.1.1, 3.3.3, and 6.1.2.1, and the type of system the solvent is used in, shall be provided with explosion protection in accordance with NFPA 69, Standard on Explosion Prevention Systems. 6. Add new subsections 6.4.11 and 6.4.12 to read as follows: 6.4.11 Drycleaning machines shall be constructed of materials that are compatible with the solvent(s) for which the machine is designed. 6.4.12 Drycleaning machines shall be constructed to safely handle the expected vapor pressures of the solvents for which it is designed during normal operations. Additional Proposed Changes File Name Proposed_TIA_999_32_.doc Description Approved Balloted TIA 1.3.1 and new 1.3.1.1 The deletion of the clause in 1.3.1, and then addition of 1.3.1.1, addresses a growing issue with the modification of existing equipment to use a solvent that the original equipment was not designed to accommodate. These proposed changes will aid the AHJ in dealing with the changes in equipment and guarantee that the modifications will be covered under this standard. This further clarifies the intent of section 3.3.3 Conversion. 3.3.3 and A.3.3.3 Just switching between solvents in the same solvent class does not ensure that the equipment,
of 18 7/28/2014 12:10 PM as designed and constructed, will safely handle the new solvent. Changes in the solvent vapor pressure under normal operating conditions could exceed the safe operating pressure of some of the equipment. Additionally, changes in the compatibility of the new solvent with potential materials of construction could lead to failures of some of the equipment or devices on the dry cleaning equipment. This helps to ensure that the AHJs have been adequately informed of these changes and any potential impact on the equipment within the facility they are being asked to inspect and/or approve. 4.1.2.1.1 and 4.1.2.1.2 Addition of 4.1.2.1.1 and 4.1.2.1.2 furthers clarifies the necessity for the treating any change in solvent, whether within the same solvent class or not, so that all of the potential hazards of the solvent are taken into account in the conversion process. 6.4.11 and 6.4.12 Addition of 6.4.11 and 6.4.12 is intended to include the materials of construction and the ability to solvents that may have different vapor pressures expected to be utilized in the specific drycleaning machine. Emergency Nature: It is the opinion of the authors that there is a need for the immediate changes to NFPA Standard 32 being proposed in this TIA. Regulatory agencies are continuing to push for the complete phase-out of the primary solvent in the dry cleaning industry, perchloroethylene. In some areas the owners of old perchloroethylene dry cleaning machines are required to replace this technology with a more environmentally acceptable option. However, in the current economic climate, which has hit the dry cleaning industry hard, many cleaners do not have the financial resources to replace old equipment. Therefore, they are looking for a quick, cheap fix to their dilemma. One inexpensive option is to switch the solvent used in the perchloroethylene dry cleaning machine. The current NFPA Standard 32 addresses the change to a solvent of a different class, but does not adequately address the issues associated with switching to a solvent in the same class. Some of the solvent changes to a solvent in the same solvent class results in the new solvent having significantly different chemical and physical properties. These differences can present a hazard to the operators and facilities employing these solvents that was not previously present. The changes that are being proposed are to make the AHJs aware of the solvent changes that are occurring and giving them the ability to ensure that the facility and employees are properly protected. Submitter Full Name: TC on TGC-AAA Organization: TC on Textile and Garment Care Processes Submittal Date: Wed Jun 19 09:28:29 EDT 2013 Resolution: The committee incorporated the TIA requirements into the document at various locations such as chapter 6 and in definition of conversion in chapter 3. Added annex material to clarify what a conversion is and is not.
NFPA 32-2007 and Proposed 2011 Edition Standard for Drycleaning Plants TIA Log No. 999 Reference: 1.3.1, 1.3.1.1, 3.3.3 Conversion, A.3.3.3, 4.1.2, 4.1.2.1.1, 4.1.2.1.2, 6.4.11, and 6.4.12 Comment Closing Date: September 10, 2010 Submitter: James Schreiner, Adco, Inc. 1. Revise subsection 1.3.1 to read as follows: 1.3.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. Where specified, the provisions of this standard shall be retroactive. 2. Add a new subsection 1.3.1.1 to read as follows: 1.3.1.1 Any change or modification to the equipment or installation in a facility where the classification of solvent or type of system changes from a previous approval shall be subject to all provisions of this standard. 3. Revise definition 3.3.3 and add a new A.3.3.3 to read as follows: 3.3.3* Conversion. Any modification(s) made to a new, existing, or used drycleaning machine, drying tumbler, or reclaiming tumbler that allows permits the use of a solvent of a different class or permits a change to a different solvent in the same class, other than that which is specified as specified on the original manufacturer s name plate and as described in 6.1.2.1 (See Annex B, Guidance on Conversion). A.3.3.3 Conversion. Conversion or modification of a new or existing drycleaning machine, drying tumbler, or reclaiming tumbler that permits the use of the same class solvent, but a different solvent than specified by the original equipment manufacturer, is technically feasible, and is being conducted. The AHJ should be notified prior to commencing the modification or conversion of the equipment. Documentation should be provided to the AHJ showing the original manufacturer s approval or verification of the conversion by a certified testing agency of the conversion or modification, with either a new or updated equipment listing, from the original listing agency or new listing agency, that the equipment is compatible with the new solvent. 4. Change 4.1.2 to read Change of Solvent Class 5. Add new subsections 4.1.2.1.1 and 4.1.2.1.2 to read as follows: 4.1.2.1.1 When a change in solvent used does not reflect a change in the classification or type of system, the new solvent shall be considered a conversion. 4.1.2.1.2 Hazards associated with the conversions described in 1.3.1.1, 3.3.3, and 6.1.2.1, and the type of system the solvent is used in, shall be provided with explosion protection in accordance with NFPA 69, Standard on Explosion Prevention Systems. 6. Add new subsections 6.4.11 and 6.4.12 to read as follows: 6.4.11 Drycleaning machines shall be constructed of materials that are compatible with the solvent(s) for which the machine is designed. 6.4.12 Drycleaning machines shall be constructed to safely handle the expected vapor pressures of the solvents for which it is designed during normal operations.
Submitter s Substantiation: 1.3.1 and new 1.3.1.1 The deletion of the clause in 1.3.1, and then addition of 1.3.1.1, addresses a growing issue with the modification of existing equipment to use a solvent that the original equipment was not designed to accommodate. These proposed changes will aid the AHJ in dealing with the changes in equipment and guarantee that the modifications will be covered under this standard. This further clarifies the intent of section 3.3.3 Conversion. 3.3.3 and A.3.3.3 Just switching between solvents in the same solvent class does not ensure that the equipment, as designed and constructed, will safely handle the new solvent. Changes in the solvent vapor pressure under normal operating conditions could exceed the safe operating pressure of some of the equipment. Additionally, changes in the compatibility of the new solvent with potential materials of construction could lead to failures of some of the equipment or devices on the dry cleaning equipment. This helps to ensure that the AHJs have been adequately informed of these changes and any potential impact on the equipment within the facility they are being asked to inspect and/or approve. 4.1.2.1.1 and 4.1.2.1.2 Addition of 4.1.2.1.1 and 4.1.2.1.2 furthers clarifies the necessity for the treating any change in solvent, whether within the same solvent class or not, so that all of the potential hazards of the solvent are taken into account in the conversion process. 6.4.11 and 6.4.12 Addition of 6.4.11 and 6.4.12 is intended to include the materials of construction and the ability to solvents that may have different vapor pressures expected to be utilized in the specific drycleaning machine. Emergency Nature: It is the opinion of the authors that there is a need for the immediate changes to NFPA Standard 32 being proposed in this TIA. Regulatory agencies are continuing to push for the complete phase-out of the primary solvent in the dry cleaning industry, perchloroethylene. In some areas the owners of old perchloroethylene dry cleaning machines are required to replace this technology with a more environmentally acceptable option. However, in the current economic climate, which has hit the dry cleaning industry hard, many cleaners do not have the financial resources to replace old equipment. Therefore, they are looking for a quick, cheap fix to their dilemma. One inexpensive option is to switch the solvent used in the perchloroethylene dry cleaning machine. The current NFPA Standard 32 addresses the change to a solvent of a different class, but does not adequately address the issues associated with switching to a solvent in the same class. Some of the solvent changes to a solvent in the same solvent class results in the new solvent having significantly different chemical and physical properties. These differences can present a hazard to the operators and facilities employing these solvents that was not previously present. The changes that are being proposed are to make the AHJs aware of the solvent changes that are occurring and giving them the ability to ensure that the facility and employees are properly protected.
of 18 7/28/2014 12:10 PM Public Input No. 1-NFPA 32-2013 [ Section No. 1.5.1 ] 1.5.1 Before any Plans and specifications shall be approved before any drycleaning plant is established or constructed, the class of solvent is changed, or an existing plant is remodeled, plans and specifications shall be submitted to the authority having jurisdiction for examination and approval. As written, a plan merely need to be submitted before construction, changes, or remodeling. The plan should be approved, not just submitted for approval. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Thu Apr 11 08:26:24 EDT 2013 Resolution: See FR 1. The committee changed the text to clarify the requirements for the submission of plans to the AHJ for approval in accordance with local and state requirements. Some of these requirements may allow submission of plans only while others may require prior approval.
of 18 7/28/2014 12:10 PM Public Input No. 23-NFPA 32-2013 [ Section No. 4.2.1.3 ] 4.2.1.3 Smoking Prohibited. Smoking in a drycleaning room shall be strictly prohibited and posted. Other NFPA standards, such as NFPA 418 section 4.6.2, require that no-smoking areas be posted as such. How would a smoker know that smoking was prohibited if it were not posted. Submitter Full Name: Jim Muir Organization: Building Safety Division, Clark County Washington Affilliation: NFPA's Building Code Development Committee (BCDC) Submittal Date: Tue Dec 31 15:30:01 EST 2013 Resolution: See FR 30. The posting of signs does not add any additional level of protection.
of 18 7/28/2014 12:10 PM Public Input No. 11-NFPA 32-2013 [ Section No. 4.4.1.3 ] 4.4.1.3 The floor-ceiling or roof and - ceiling construction assembly above a drycleaning room shall have a fire resistance rating of not less than 1 hour. This is standard language used by testing laboratories to identify listed assemblies. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:25:25 EDT 2013 Resolution: The committee agreed however they have removed these specific requirements from NFPA 32 and referred building construction requirements to NFPA 5000. See FR #30.
of 18 7/28/2014 12:10 PM Public Input No. 12-NFPA 32-2013 [ Section No. 4.4.3.1 ] 4.4.3.1 Boilers shall be located, where possible, in a detached building. Add a new annex to 4.4.3.2 to read: Where possible, boilers should be located in a detached building. Move 4.4.3.1 to Appendix note under 4.4.3.2: Requiring boilers to be located where possible in a detached building is advisory to the extent that location in a detached building is not absolutely required under all circumstances. Where possible can be defined many ways (i.e.: financially or physically). An AHJ should not be determining if it is possible to locate the boiler in a detached building. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:27:27 EDT 2013 Resolution: The committee agreed and has incorporated all boiler changes into FR 30.
of 18 7/28/2014 12:10 PM Public Input No. 13-NFPA 32-2013 [ Section No. 4.4.3.2 ] 4.4.3.2 Where located in the drycleaning building and in a room adjoining the drycleaning room, the boiler room shall be separated by fire barrier walls, in accordance with NFPA 5000, Building Construction and Safety Code, without openings, having a fire resistance rating of not less than 2 hours. Verbiage is extraneous. If the boiler room is adjoining the drycleaning room, then it is located in the drycleaning building. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:28:50 EDT 2013 Resolution: The committee agreed and has incorporated all boiler requirements into FR 30 for Chapter 4.
of 18 7/28/2014 12:10 PM Public Input No. 2-NFPA 32-2013 [ Section No. 4.6.3.4 ] 4.6.3.4 Water Mist Fire-Extinguishing Systems. Water mist fire-extinguishing systems shall conform with NFPA 750, Standard on Water Mist Fire Protection Systems and inspected, tested, and maintained in accordance with NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. NFPA 25 now includes a specific chapter that addresses the testing, inspection and maintenance needed for water mist systems. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Thu Apr 11 08:28:33 EDT 2013 Resolution: NFPA 750 already requires inspection and testing in accordance with NFPA 25.
of 18 7/28/2014 12:10 PM Public Input No. 7-NFPA 32-2013 [ Section No. 6.5.4 ] 6.5.4 Cylinder access door(s) shall be interlocked as follows to prevent the following : (1) Opening of the door(s) while there is solvent in the cylinder (2) Opening of the door(s) while the cylinder is rotating (3) Rotation of the cylinder or basket while the door(s) are open Exception: Machines 6.5.4.1 Machines that require inching of the cylinder with the door open shall be permitted to function without an interlock, provided that the solvent has been drained from the cylinder. This suggested change does two things: first, it clarifies what the interlock is intended to prevent. The second change gets rid of the existing exception and converts it to a new code section. This is intended to comply with the NFPA Manual of Style that limits exceptions. This is one of two exceptions currently appearing in the document. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Oct 15 16:34:14 EDT 2013 Resolution: All drycleaning equipment construction requirements were removed from the document (Sections 6.2-6.6.2). Interlocks on equipment are part of the listing requirements for drycleaning equipment therefore such a requirement would be redundant. This document should not include equipment construction requirements.
0 of 18 7/28/2014 12:10 PM Public Input No. 3-NFPA 32-2013 [ Section No. 7.2.1.1 ] 7.2.1.1 Type II drycleaning plants shall be separated from assembly, educational, day care, health care, detention ambulatory health care, detention and correctional, and residential occupancies by a fire barrier having a minimum fire resistance rating of 4 hours. Day care and ambulatory health care occupancies have occupants who are just as vulnerable as those in educational, health care, and other occupancies already noted in the requirement. Submitter Full Name: John Chartier Organization: Northeastern Regional Fire Cod Submittal Date: Thu Apr 11 08:30:19 EDT 2013 Resolution: The committee added these occupancies as suggested. See First Revision #25.
1 of 18 7/28/2014 12:10 PM Public Input No. 14-NFPA 32-2013 [ Section No. 8.1.2.1 ] 8.1.2.1 Separation. Type IIIA drycleaning plants located in buildings with other occupancies shall be separated vertically and horizontally from other occupancies by a fire barrier having a minimum 2-hour fire resistance rating. Location of fire barrier would be defined in the same way that it is defined in Section 7.2.1 under Type II Drycleaning Plants. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:30:48 EDT 2013 Resolution: The committee agreed and made the suggested change along with annex material to clarify that horizontal barriers would only be required when an occupancy was above or below a facility and a vertical barrier would be required when an occupancy was adjacent to the facility. See First Revision # 26.
2 of 18 7/28/2014 12:10 PM Public Input No. 15-NFPA 32-2013 [ Section No. 8.2.3.1 ] 8.2.3.1 Separation. Type IIIB drycleaning plants located in buildings with other occupancies shall be separated vertically and horizontally from other occupancies by a fire barrier having a minimum 1-hour fire resistance rating. Location of fire barrier would be defined in the same way that it is defined in Section 7.2.1 under Type II Drycleaning Plants. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:32:16 EDT 2013 Resolution: The committee agreed and made change as suggested. However Chapter 8 now only has Type III facilities. The document no longer separates out Type IIIA and TYPE IIIB.
3 of 18 7/28/2014 12:10 PM Public Input No. 16-NFPA 32-2013 [ Section No. 8.2.3.3 ] 8.2.3.3 Openings in fire barriers separating drycleaning plants from exit access corridors shall be equipped with opening protection having a minimum 20-minute fire protection rating. Since a Type IIIB drycleaning plant is considered to be an area having a degree of hazard greater than that normal to other occupancies, it is required to be separated from other occupancies by 1-hour fire barriers. It would seem that a door opening between a Type IIIB drycleaning plant and a corridor serving other occupancies should maintain the ¾-hour rating. (For example: When a storage room that is required to be separated as a hazard is located on an 1-hour rated corridor in a business occupancy, the door between the storage room and the corridor is required to be 45-minute rated rather than 20-minute rated.) Sections 8.2.3.1 and 8.2.3.2 adequately define separation requirements. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:33:29 EDT 2013 Resolution: Chapter 8 was revised to delete all requirements specific to Class IIIB solvents. Requirements for Class IIIB solvents are covered in the same way that Class IIIA solvents are covered within the chapter. The change incorporates the suggestion within the new revision. See FR 26 for Chapter 8.
4 of 18 7/28/2014 12:10 PM Public Input No. 9-NFPA 32-2013 [ Section No. 9.2.1.3 ] 9.2.1.3 Apparatus with open flames or with exposed electric heating elements shall be protected from any equipment using Class IV solvents by providing the following: (1) Exterior intakes for combustion air (2) If present, exhaust vents from the drycleaning equipment that are located remotely from the air intakes Exception: Apparatus 9.2.1.3.1 Apparatus located in a separate, enclosed room or cabinet that is independently ventilated to prevent the air from the drycleaning system from being drawn toward the apparatus need not be protected with separate air intakes or exhaust vents. This change gets rid of the existing exception and converts it to a new code section. This is intended to comply with the NFPA Manual of Style that limits exceptions. This is one of two exceptions currently appearing in the document. Submitter Full Name: Doug Hohbein Organization: Northcentral Fire Code Develop Submittal Date: Tue Oct 15 16:36:15 EDT 2013 Resolution: The committee removed the exception as suggested and rewrote the section for clarity. See First Revision # 15.
5 of 18 7/28/2014 12:10 PM Public Input No. 17-NFPA 32-2013 [ New Section after A.3.3.6 ] A.3.3.7 Drycleaning operations can include, but are not limited to, spotting of clothing, sorting of clothing, folding and pressing (finishing) of clothing. A drycleaning room may be the entire plant and, if so, all specific System Type requirements applicable to a drycleaning room are applicable to the entirety of the plant. The proposed appendix note clarifies that drycleaning operations are not limited to storage and machine equipment areas. A clear understanding of how a drycleaning room is differentiated within a drycleaning plant is important when determining where separation is required in sections such as 7.2.3. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:34:35 EDT 2013 Resolution: The committee has clarified in this document when drycleaning rooms are necessary. Drycleaning areas have also been defined.
6 of 18 7/28/2014 12:10 PM Public Input No. 18-NFPA 32-2013 [ New Section after A.7.2.1.3(3) ] A.7.2.1.4 It is not the intent of this section to require separation within the plant of offices and clothing receiving/storage areas that are ancillary to the plant operation. The proposed appendix note clarifies that the occupancies to be separated from the drycleaning plant are separate tenants such as found in a shopping center, or are primary occupancies that a drycleaning operation may be found within such as an office building. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:35:59 EDT 2013 Resolution: See FR 25 and associated annex for 7.2.1
7 of 18 7/28/2014 12:10 PM Public Input No. 19-NFPA 32-2013 [ New Section after A.7.4.4 ] A.8.1.2.1 It is not the intent of this code section to require separation within the plant of offices and clothing receiving/storage areas that are ancillary to the plant operation. The proposed appendix note clarifies that the occupancies to be separated from the drycleaning plant are separate tenants such as found in a shopping center, or are primary occupancies that a drycleaning operation may be found within such as an office building. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:37:05 EDT 2013 Resolution: The committee clarified this by adding mercantile in the definition of drycleaning facility.
8 of 18 7/28/2014 12:10 PM Public Input No. 20-NFPA 32-2013 [ New Section after A.8.1.3.6(3) ] A.8.2.3.1 It is not the intent of this code section to require separation within the plant of offices and clothing receiving/storage areas that are ancillary to the plant operation. The proposed appendix note clarifies that the occupancies to be separated from the drycleaning plant are separate tenants such as found in a shopping center, or are primary occupancies that a drycleaning operation may be found within such as an office building. Submitter Full Name: Bill Galloway Organization: Southern Regional Fire Code De Submittal Date: Tue Oct 29 15:38:04 EDT 2013 Resolution: See FR 26 and annex for 8.2.1