M E M O R A N D U M - NFPA · 2016-03-28 · National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • M E M O

National Fire Protection Association

1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M

To: NFPA Technical Committee on Gaseous Fire Extinguishing Systems

From: Kelly Carey, Administrator, Technical Projects

Date: August 5, 2013

Subject: NFPA 2001 First Draft TC FINAL Ballot Results (F2014)

According to the final ballot results, all ballot items received the necessary affirmative votes to pass ballot.

30 Members Eligible to Vote

5 Not Returned (O. Aron, T. Dillon, B. Maranion, P. Rivers, B. Stilwell) 16 Affirmative on All

3 Affirmative with Comment on one or more first revisions: (R. Kasiski, J. Spalding, T. Wysocki) 6 Negatives on one or more first revisions: (R. Adcock, J. Harrington, R. Kasiski, M. Robin, J.

Spalding, L. Speitel) 0 Abstentions on one or more first revisions The attached report shows the number of affirmative, negative, and abstaining votes as well as the explanation of the vote for each first revision.

There are two criteria necessary for each first revision to pass ballot: (1) simple majority and (2) affirmative 2/3 vote. The mock examples below show how the calculations are determined.

(1) Example for Simple Majority: Assuming there are 20 vote eligible committee members, 11 affirmative votes are required to pass ballot. (Sample calculation: 20 members eligible to vote ÷ 2 = 10 + 1 = 11)

(2) Example for Affirmative 2/3: Assuming there are 20 vote eligible committee members and 1 member did not

return their ballot and 2 members abstained, the number of affirmative votes required would be 12. (Sample calculation: 20 members eligble to vote – 1 not returned – 2 abstentions = 17 x 0.66 = 11.22 = 12 )

As always please feel free to contact me if you have any questions.

NFPA 2001 FIRST DRAFT BALLOT FINAL REPORT

Eligible to Vote: 30Not Returned : 5Paul E. Rivers,Todd A. Dillon,Brad T.

Stilwell,Oded Aron,Bella A. MaranionVote Selection Votes Comments

Affirmative 25Affirmative with Comment 0Negative 0Abstain 0





Stilwell,Oded Aron,Bella A. Maranion

FR-1, Section No. 2.2, See FR-1

FR-25, Global Input, See FR-25

Total Voted : 25

FR-24, Global Input, See FR-24

Total Voted : 25

Page 1 of 38

http://submittals.nfpa.org/TerraViewWeb/FormLaunch?id=/TerraView/Content/2001-2012.ditamap/2/C1366227086864.xml&viewmode=nfpa/xslt/nfpaviewmode.xsl




Vote Selection Votes Comments








FR-3, Section No. 2.3.2, See FR-3

Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 2 of 38












Affirmative 25Affirmative with Comment 0



Total Voted : 25


Total Voted : 25

Page 3 of 38





Negative 0Abstain 0







Eligible to Vote: 30Not Returned : 5

FR-57, New Section after 3.3.21, See FR-57


Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 4 of 38





Paul E. Rivers,Todd A. Dillon,Brad T.










Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 5 of 38






Affirmative 23Affirmative with Comment 0Negative 2Louise C. Speitel I fully agree with Mark Robin's comments: "Section 4.1.2 offers no guidance on how the quality of agent

shall be tested...This issue can be addressed by the addition of the following text to Section 4.1.2:

Verification of Product Quality. Product quality shall be determined by verified industry standard

analytical techniques such as those in ASTM, ISO or ARI Standards."


Page 6 of 38



Mark L. Robin Section 4.1.2 offers no guidance on how the quality of agent shall be tested. To provide such assurance

that the product specifications of NFPA 2001 Section 4.1.2 are actually met, requires the use of

analytical methods that are capable of producing valid results. Furthermore, the analytical methods

employed to determine compliance with the specifications of NFPA 2001 Section 4.1.2 need to be

repeatable and accurate. International standards (e.g., NFPA standards), certifying bodies, and

regulatory agencies all require evidence that analytical methods are capable of producing accurate,

repeatable and valid results.Users of recycled clean agents require the assurance that recycled product

has been tested to meet the required product specifications as defined in NFPA 2001 Paragraph 4.1.2.

To provide such assurance, i.e., to guarantee that the product specifications are actually met, requires

the use of analytical methods that are capable of producing valid results. A basic tenet of analytical

methodology is the requirement of validation – confirmation that a method is suitable for its intended

use and provides accurate and valid results. International standards (e.g., ISO/IEC 17025 , ASTM E2857-

11 and numerous other international consensus standards), certifying bodies, and regulatory agencies

all require evidence that analytical methods are capable of producing valid results. Procedures for the

validation of analytical methods are well-established and are outlined, for example, in ASTM E2857, ISO

17025, and the Eurachem publication, The Fitness for Purpose of Analytical Methods, A Laboratory

Guide to Method Validation and Related Topics. Analytical methods such as those in ASTM, ISO, AHRI

and other consensus standards are widely employed in a wide selection of industries. The fact the these

methods have been subject to independent validation by third parties provides the user of the

standards with confidence that the analytical results obtained/reported are accurate, repeatable and

valid. The use of unvalidated analytical methods fails to provide any guarantee that the results are

accurate, and offers the recycler and the end user no assurance whatsoever that the required

specifications have actually been met. As a result, the recycler and end user have no way of knowing

whether or not the material they are placing into the field indeed meets the required specifications.

Customers look for, and deserve the independent verification that validated technical standards

provide, and it would be a disservice to the clean agent industry to recommend that unknown,

unvalidated analytical methods be employed for verification of product quality. This issue can be

addressed by the addition of the following text to Section 4.1.2: "Verification of Product Quality.

Product quality shall be determined by verified industry standard analytical techniques such as those in

ASTM, ISO or ARI Standards."

Abstain 0

Total Voted : 25

Page 7 of 38




Affirmative 24Affirmative with Comment 1Robert Kasiski

The revised wording can infer that locating the cylinders within the hazard is the only location. A public

comment will be submitted for the 2nd draft to identify the perferred location being outside of the

hazard which is now not included in the standard.

Negative 0Abstain 0






FR-86, Section No. 4.1.4.6, See FR-86


Total Voted : 25


Total Voted : 25

Page 8 of 38













FR-37, New Section after 4.2.1.1.1, See FR-37

Total Voted : 25

FR-12, Section No. 4.2.1.1 [Excluding any Sub-Sections], See FR-12

Total Voted : 25

Total Voted : 25

Page 9 of 38












Affirmative 25Affirmative with Comment 0Negative 0

FR-42, New Section after 4.3.3.5.2, See FR-42

FR-39, New Section after 4.2.5.4, See FR-39

Total Voted : 25

FR-38, Section No. 4.2.1.1.1, See FR-38

Total Voted : 25

Page 10 of 38





Abstain 0










Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 11 of 38













Affirmative 24Affirmative with Comment 1Thomas J. Wysocki See comment on FR 48.

Negative 0Abstain 0

FR-56, Section No. 5.5.1 [Excluding any Sub-Sections], See FR-56


Total Voted : 25

Total Voted : 25

Page 12 of 38














Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 13 of 38









Affirmative 24Affirmative with Comment 1Thomas J. Wysocki Handling of large heavy cylinders in order to determine the contents does pose a safety concern.

Provision of means to determine the contents on a periodic basis as required by the standard without

requiring cylinders to be lifted on to a scale seems to be a worthwhile feature for large heavy cylinders.

That said, the problem seems to be more appropriately addressed by listing/approval agencies than by

this standard.

Negative 0Abstain 0




FR-48, Section No. 5.5.2 [Excluding any Sub-Sections], See FR-48


Total Voted : 25

Total Voted : 25

Page 14 of 38




Thomas J. WysockiChanging the words "minimum anticipated" and "maximum anticipated" temperature to minimum and

maximum "design" temperature leaves the question of how to determine the appropriate design

temperatures open. Generally the minimum and maximum anticipated temperatures within a hazard

would be the corresponding design temperatures. In conjunction with acceptance of this proposal as

well as several others wherein the wording was similarly modified, a definition and guidance for

minimum and maximum design temperature should be added to the standard.

Negative 0Abstain 0



Affirmative 24Affirmative with Comment 1Thomas J. Wysocki Minimum anticipated temperature should be changed to minimum design temperature. Also see

comment on FR48.

Negative 0Abstain 0






Total Voted : 25

Total Voted : 25

Page 15 of 38




Negative 0Abstain 0



Affirmative 24Affirmative with Comment 1Thomas J. Wysocki See comment on FR-48.

Negative 0Abstain 0




FR-52, Section No. 5.6 [Excluding any Sub-Sections], See FR-52


Total Voted : 25

Total Voted : 25

Page 16 of 38




Robert Kasiski

Adequate protection from clean agent systems should be provided for a minimum time period of 10

minutes. This revision allows for protection to be designed and provided for a shorter period relying on

the human element to intervene, defeating the purpose of fixed protection. If response time from

trained personnel is extended or trained personnel no longer available from the original design time

period at a later date, there may be inadequate protection provided to the occupancy. In additon this

revision will effect the listings with FM Approvals and Underwriters Laboratories as the Class 5600 and

UL 2127 and UL 2166, respectively have a 600 second time limit for extinguishment in the Class A fire

test. Fires may not be extinguished if the minimum time period is removed.

Jeffrey L. Harrington

The proposed wording makes it clear that the agent retention time should be 10 minutes if one wishes it

to be, or anything less than that if one wishes it to be without even a lower limit requirement. If I am an

owner, and my clean agent contractor says that my enclosure is like Swiss cheese, and it will cost more

money than I want to spend to seal it up, I can claim that my operators in the NOC room next door to

my data center protected space are all trained on each shift to respond to a fire incident with

extinguishers in hand within 60 seconds and handle any expected incident 24/7. This might be a

statement. In this case, the retention time can be set at 60 seconds in full compliance with the proposed

Section 5.6. The owner is happy to have saved a lot of money otherwise spent sealing up the enclosure.

The retention time has always been tied to the determination of response time of trained personnel.

This is not enforceable in any realistic way and allows too much potential for abuse. It is also not

manageable over the expected life time of the clean agent system, approximately 15 to 20 years. In that

time frame, too many changes will occur in management personnel and in the emergency response

procedures, personnel, and training that affects a given protected space 24/7/365. Section 5.6 should

require a minimum retention time (or hold time if you prefer) of 10 minutes, period. We can still retain

annex guidance suggestion circumstances that might require longer retention times, with cautions

about enclosure strength during discharge into a tightly sealed enclosure and the higher probability that

pressure relief venting may be required in proportion as the retention time increases.

Page 17 of 38


Ronald C. Adcock Comments: Adequate protection from clean agent systems should be provided for a minimum time

period of 10 minutes. This revision allows for protection to be designed and provided for a shorter

period relying on the human element to intervene, defeating the purpose of fixed protection. If

response time from trained personnel is extended or trained personnel no longer available from the

original design time period at a later date, there may be inadequate protection provided to the

occupancy. In addition this revision will effect the listings with FM Approvals and Underwriters

Laboratories as the Class 5600 and UL 2127 and UL 2166, respectively have a 600 second time limit for

extinguishment in the Class A fire test. Fires may not be extinguished if the minimum time period is

removed.

Abstain 0



Affirmative 24Affirmative with Comment 0Negative 1Louise C. Speitel

I agree with Mark Robin's comment: "7.1.4 does not address the quality of recycled material. Users of

recycled clean agents require the assurance that recycled product has been tested to meet the required

product specifications as defined in NFPA 2001 Paragraph 4.1.2. ... This issue can be addressed by the

addition of the following text: "Recycled agent shall comply with the quality specifications of NFPA 4.2.1;

product quality shall be tested utilizing verified analytical methods as described in international industry

standards (e.g., ASTM, ISO)."

Abstain 0


Total Voted : 25

Total Voted : 25

Page 18 of 38














Total Voted : 25


Total Voted : 25

Page 19 of 38





Abstain 0







FR-31, Sections 7.1.4, 7.1.5, See FR-31


Total Voted : 25

Total Voted : 25

Page 20 of 38




Mark L. Robin 7.1.4 does not address the quality of recycled material. Users of recycled clean agents require the

assurance that recycled product has been tested to meet the required product specifications as defined

in NFPA 2001 Paragraph 4.1.2. To provide such assurance, i.e., to guarantee that the product

specifications are actually met, requires the use of analytical methods that are capable of producing

valid results. A basic tenet of analytical methodology is the requirement of validation – confirmation

that a method is suitable for its intended use and provides accurate and valid results. International

standards (e.g., ISO/IEC 17025 , ASTM E2857-11 and numerous other international consensus

standards), certifying bodies, and regulatory agencies all require evidence that analytical methods are

capable of producing valid results. Procedures for the validation of analytical methods are well-

established and are outlined, for example, in ASTM E2857, ISO 17025, and the Eurachem publication,

The Fitness for Purpose of Analytical Methods, A Laboratory Guide to Method Validation and Related

Topics. Analytical methods such as those in ASTM, ISO, AHRI and other consensus standards are widely

employed in a wide selection of industries. The fact the these methods have been subject to

independent validation by third parties provides the user of the standards with confidence that the

analytical results obtained/reported are accurate, repeatable and valid. The use of unvalidated

analytical methods fails to provide any guarantee that the results are accurate, and offers the recycler

and the end user no assurance whatsoever that the required specifications have actually been met. As a

result, the recycler and end user have no way of knowing whether or not the material they are placing

into the field indeed meets the required specifications. Customers look for, and deserve the

independent verification that validated technical standards provide, and it would be a disservice to the

clean agent industry to recommend that unknown, unvalidated analytical methods be employed for

verification of product quality. This issue can be addressed by the addition of the following text:

"Recycled agent shall comply with the quality specifications of NFPA 4.2.1; product quality shall be

tested utilizing verified analytical methods as described in international industry standards (e.g., ASTM,

ISO)."

Abstain 0




Total Voted : 25

Page 21 of 38




Affirmative 24Affirmative with Comment 1John C. Spalding There is not a separate FR for the Annex material associated with this FR-68, as there was for the same

topic when submitted for NFPA 12. We agree with FR-68 that an acceptance test report is desired for all

systems. We do not agree with the sample acceptance report to be published in the annex. The report is

incomplete and can be misleading.

Negative 0Abstain 0








FR-65, Section No. 7.7.2.2.12, See FR-65

Total Voted : 25

Total Voted : 25

Page 22 of 38




Abstain 0






Affirmative 23Affirmative with Comment 0Negative 2Louise C. Speitel I fully agree with Mark Robin's comment: Previous verbiage deleted by FR-71 is valiable to the

understanding of climate change impact and shouldbe reinstated into Section A.1.6.

FR-71, Section No. A.1.6, See FR-71

FR-19, Sections A.1.4.2.2, A.1.4.2.4, See FR-19

Total Voted : 25

Total Voted : 25

Page 23 of 38




Mark L. RobinThere is perhaps no issue related to clean agents that is more misunderstood and misrepresented than

the impact of HFCs in fire suppression applications on climate change, and the current proposed

verbiage, unfortunately, adds to that confusion. The currently proposed verbiage in FR-71 indicates that

"It is important to understand that the impact of a gas on climate change is a function of both the GWP

of the gas and the amount of the gas emitted." This advice is then immediately ignored in the next

sentence, which discusses EMISSIONS (the amount of gas emitted)rather than the IMPACT of those

emissions - it is the IMPACT of an emission that is of concern. The U.S. EPA has employed it vintaging

model to estimate the emissions AND THE IMPACT of emissions of greenhouse gases (GHGs) from

various sources and in fact reports impacts in Tg of CO2 equivalents. The most recent report, Inventory

of US GHG Emissions & Sinks 1990-2011 (April 2013) indicates that the relative impact of HFC emissions

from fire suppression applications represents approximately 0.01% of the total impact of all GHGs; that

is, the impact of HFC emissions from fire protection applications represents approximately 0.01 percent

of the impact of all GHG emissions. The US EPA’s Vintaging Model also indicates that the impact of HFCs

in fire suppression applications has remained steady since 2005. Emissions data are also available for EU-

15 countries, and as is the case for the US, indicate that the relative contribution of HFCs in fire

suppression applications to climate change is minuscule [Annual EU GHG Inventory 1990-2010, and

Inventory Report 2012, (30 May 2012)]. Recent results from the HFC Emissions Estimating Program

(HEEP), which estimates the emissions of HFCs from fire suppression, are in good agreement with the

results of EPA’s vintaging model results for the emission of HFCs from fire suppression applications.

Previous verbiage deleted by FR-71 is valiable to the understanding of climate change ipact and should

be reinstated into Section A.1.6.

Abstain 0




FR-66, Section No. A.4.1.2, See FR-66

Total Voted : 25

Page 24 of 38



Louise C. Speitel Customers look for, and deserve the independent verification that validated technical standards

provide. The chemical manufacturerer's standards do not meet this criteria.

Mark L. Robin

Allowing the verification of product quality by unverified and/or unknown manufacturers' analytical

porocedures provides no assurance of the accuracy of the resultant product assay. Users of recycled

clean agents require the assurance that recycled product has been tested to meet the required product

specifications as defined in NFPA 2001 Paragraph 4.1.2. To provide such assurance, i.e., to guarantee

that the product specifications are actually met, requires the use of analytical methods that are capable

of producing valid results. A basic tenet of analytical methodology is the requirement of validation –

confirmation that a method is suitable for its intended use and provides accurate and valid results.

International standards (e.g., ISO/IEC 17025 , ASTM E2857-11 and numerous other international

consensus standards), certifying bodies, and regulatory agencies all require evidence that analytical

methods are capable of producing valid results. Procedures for the validation of analytical methods are

well-established and are outlined, for example, in ASTM E2857, ISO 17025, and the Eurachem

publication, The Fitness for Purpose of Analytical Methods, A Laboratory Guide to Method Validation

and Related Topics. Analytical methods such as those in ASTM, ISO, AHRI and other consensus standards

are widely employed in a wide selection of industries. The fact the these methods have been subject to

independent validation by third parties provides the user of the standards with confidence that the

analytical results obtained/reported are accurate, repeatable and valid. The use of unvalidated

manufacturer analytical methods fails to provide any guarantee that the results are accurate, and offers

the recycler and the end user no assurance whatsoever that the required specifications have actually

been met. As a result, the recycler and end user have no way of knowing whether or not the material

they are placing into the field indeed meets the required specifications. Customers look for, and deserve

the independent verification that validated technical standards provide, and it would be a disservice to

the clean agent industry to recommend that unknown, unvalidated analytical methods be employed for

verification of product quality.

Abstain 0


FR-80, Section No. A.4.1.4.1, See FR-80

Total Voted : 25

Page 25 of 38













Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 26 of 38









Affirmative 24Affirmative with Comment 0Negative 1John C. Spalding The fire resistance rating of the enclosure is unrelated to the design of the clean agent fire extinguishing

system.

Abstain 0




FR-54, New Section after A.5.2.1, See FR-54

Total Voted : 25

FR-67, Section No. A.5.1.2.2(28), See FR-67

Total Voted : 25

Page 27 of 38














Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 28 of 38













FR-62, New Section after A.6.6, See FR-62


Total Voted : 25


Total Voted : 25

Page 29 of 38





Abstain 0










Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 30 of 38














FR-21, Section No. B.3, See FR-21

Total Voted : 25

FR-69, Section No. A.7.7.2.2.10, See FR-69

Total Voted : 25

Total Voted : 25

Page 31 of 38












Affirmative 25

FR-78, Section No. B.9.1.4.1, See FR-78

FR-75, Section No. B.4.2.11, See FR-75

Total Voted : 25

FR-22, Section No. B.4.1, See FR-22

Total Voted : 25

Page 32 of 38





Affirmative with Comment 0Negative 0Abstain 0







Eligible to Vote: 30



Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 33 of 38





Not Returned : 5Paul E. Rivers,Todd A. Dillon,Brad T.









FR-9, Section No. E.1.1, See FR-9

FR-85, Section No. B.18.1, See FR-85

Total Voted : 25

Total Voted : 25

Page 34 of 38












FR-13, Section No. E.1.2.3, See FR-13


Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 35 of 38









Affirmative 24Affirmative with Comment 1John C. Spalding EDITORIAL COMMENT: The address of the FSSA has changed and the website is in error, as listed on the

FR-83. The address should be: Fire Suppression Systems Association, 3601 E. Joppa Road, Baltimore, MD

21234. WEBSITE: www.fssa.net

Negative 0Abstain 0






Total Voted : 25

Total Voted : 25

Page 36 of 38












FR-16, Section No. E.1.3, See FR-16


Total Voted : 25


Total Voted : 25

Total Voted : 25

Page 37 of 38










FR-18, Section No. E.2, See FR-18

Total Voted : 25

Total Voted : 25

Page 38 of 38


Documents

M E M O R A N D U M - NFPA · 2016-03-28 · National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • M E M O