committee on nfpa 18a · for use by the manufacturer shall have an lc50 greater than 10 mg/l in...

Committee on NFPA 18A

M E M O R A N D U M TO: NFPA Technical Committee on Water Additives for Fire Control and Vapor Mitigation FROM: Patti Mucci, Administrative Assistant DATE: May 10, 2010 SUBJECT: NFPA 18A ROC Letter Ballot The ROC letter ballot for NFPA 18A is attached. The ballot is for formally voting on whether or not you concur with the committee’s actions on the comments. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible, but no later than Monday, May 24, 2010. As noted on the ballot form, please return the ballot to Patti Mucci either via e-mail to [email protected] or via fax to 617-984-7110. You may also mail your ballot to the attention of Patti Mucci at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Comments

Report on Comments – November 2010 NFPA 18A_______________________________________________________________________________________________18A-1 Log #CC1

_______________________________________________________________________________________________Technical Committee on Water Additives for Fire Control and Vapor Mitigation,

18A-1Under section 2.3.1, include reference to the following standard:

ASTM D 2240, Standard Test Method for Rubber Property-Durometer Hardness, 2005.Under section 2.3.7, delete reference to the following standard:Federal Test Standard No. 601, Methods 3021 and 3025 (April 12, 1985).

This updates reference to other organizations documents. Federal Test Standard No. 601, Methods3021 and 3025 are old methods that have been revised to reference ASTM D 2240. Supporting material regarding thechanges to Federal Test Standard No. 601, Methods 3021 and 3025 are included in Change Notice No. 7 to FederalTest Standard No. 601.

_______________________________________________________________________________________________18A-2 Log #8

_______________________________________________________________________________________________Bob Eugene, Underwriters Laboratories Inc.

18A-7

Underwriters Laboratories, Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.UL 162, 1994, revised 1999.ANSI/UL 711/CAN/ULC S508, 2004, revised 20072009.

Add CAN and ANSI approval designations to UL standards as applicable. Include a reference to themost recent revisions to the UL standards.

_______________________________________________________________________________________________18A-3 Log #9


18A-7

Underwriters’ Laboratories of Canada, 7 Underwriters Road, Toronto ON M1R 3B4.CAN/ULC S560, , 2006.

Add CAN designation to ULC standards as applicable.

1Printed on 5/10/2010

Report on Comments – November 2010 NFPA 18A_______________________________________________________________________________________________18A-4 Log #1

_______________________________________________________________________________________________James Everitt, Western Regional Fire Code Development Committee

18A-15Reconsider the original proposal and accept:

1. Water additive concentrate of different brands and other types of concentrate intended for fire prevention, control,suppression, extinguishment, or vapor mitigation additives shall not be mixed with other water additives.2. Premixed solution prepared with water additive concentrate of different brands and premixed solution prepared with

other types of concentrate intended for fire prevention, control, suppression, extinguishment, or vapor mitigation Wateradditive solutions shall not be mixed within the same storage container. with other water additive solutions.3. Water additive solutions Solution generated separately with water additive concentrate of different brands shall be

permitted to be applied to a fire in sequence or simultaneously.4. Solution generated with water additive concentrate and solution generated with other types of concentrate intended

for fire prevention, control, suppression, extinguishment, or vapor mitigation shall be permitted to be applied to a fire insequence or simultaneously when approved by the authority having jurisdiction.5. The mixing of these additives concentrates can have adverse effects and render solutions or systems ineffective for

fire prevention, control, suppression, extinguishment, or vapor mitigation.We agree with the negative of Hubert. We would hope that all the committee members would vote on

the proposals.

See the Action and Statement on Comment 18A-5 Log #13

_______________________________________________________________________________________________18A-5 Log #13

_______________________________________________________________________________________________

Blake M. Shugarman, Underwriters Laboratories Inc.18A-15

Revise text to read as follows:Premixed solution prepared with water additive concentrate of different brands and premixed solution prepared

with other types of concentrate intended for fire prevention, control, suppression, extinguishment, or vapor mitigationWater additive solutions shall not be mixed within the same container. with other water additive solutions.

The proposed revisions provide clarification of intended compatibility use and consideration ofcompatibility with other types of concentrates intended for fire prevention, control, suppression, extinguishment, or vapormitigation. The other types of concentrate include Class B foam concentrate [NFPA 11], Class A foam concentrate[NFPA 1150], wetting agent concentrate [NFPA 18], and water additive concentrate [NFPA 18A].

Revise text to read as follows:Premixed solution prepared with water additive concentrate of different brands and premixed solution prepared

with other types of concentrate intended for fire prevention, control, suppression, extinguishment, or vapor mitigationWater additive solutions shall not be mixed within the same container. with other water additive solutions.

The committee revised 4.3.2 of the submitters recommended revisions by removing the word"storage."



_______________________________________________________________________________________________


Revise text to read as follows:

Water additive concentrates and water additive solutions prepared at the concentrations specified for use by themanufacturer’s recommended use level ( s) shall be subjected to the tests in this chapter.

The tests detailed in this chapter shall be conducted by an approved independent laboratory using laboratorypractices in accordance with ISO/IEC 17025, 40 CFR 160, 40 CFR 792, or equivalent as applicable.

The information developed gathered in response to the requirements of this chapter shall be reported on themanufacturer’s technical data sheet and made available to potential users.

The proposed revisions maintain consistency between NFPA 18 and NFPA 18A.

Revise text as follows:The tests detailed in this chapter shall be conducted by an approved independent laboratory using laboratory

practices in accordance with 40 CFR 160, 40 CFR 792, and calibration competency in accordance with ISO/IEC 17025,or equivalent as applicable.

The committee revised 5.1.2 text to be consistent with NFPA 18 and addressed the negativecomments. The remainder of the submitters recommendation remains unchanged.



_______________________________________________________________________________________________



Water additive concentrates and water additive solution prepared at the maximum concentration specified foruse by the manufacturer their solutions shall be tested in accordance comply with the following EPA OPPTS tests ortheir equivalent:(1) 870.1100 Acute Oral Toxicity(2) 870.1200 Acute Dermal Toxicity(3) 870.2400 Acute Eye Irritation(4) 870.2500 Acute Dermal Irritation

The water additive concentrate and water additive solution prepared at the maximum concentration specifiedfor use by the manufacturer its solutions prepared at the maximum and minimum use concentrations recommended bythe manufacturer shall not exceed the toxicity limits established in Table 5.2.6.1.2 when tested in accordance with5.2.6.1.1.

The water additive shall have an LC50 greater than 10 mg/l in ASTM soft water (described in ASTM E 729)when measured after 96 hours of static exposure.

Water additive concentrates and water additive solution prepared at the maximum concentration specifiedfor use by the manufacturer their solutions shall be tested, using (rainbow trout), in accordancewith ASTM E 729 or OPPTS 850.1075 or an equivalent test procedure that is recognized by the authority havingjurisdiction where the water additive is to be used.

In accordance with ASTM E 729, 10 fish that are 60 days ± 15 days post-hatch shall be exposed understatic conditions to each level of a water additive solution in soft water for 96 hours at 12°C ± 1°C (54°F ± 2°F).

The water additive concentrate and water additive solution prepared at the maximum concentration specifiedfor use by the manufacturer shall have an LC50 greater than 10 mg/l in ASTM soft water (described in ASTM E 729)when measured after 96 hours of static exposure.

The proposed revisions provide consistency, as applicable, between NFPA 18 and NFPA 18A.Section 5.2.6.2 should be included under Aquatic Toxicity and the sections renumbered.

The committee agrees that the original language is correct.



_______________________________________________________________________________________________

Bob Carter, Hazard Control Technologies, Inc.18A-26

Sections 5.2.6.2 and 5.2.6.3 be removed entirely and replaced with the following:5.2.6.3 Aquatic Toxicity:5.2.6.3.1 The water additive and/or constituent Chemical Abstract Substance (CAS) ingredients must be submitted to

USEPA (or Federal AHJ equivalent) for evaluation. All CAS items must be included on US EPA monitored TSCA (orfederal AHJ equivalent).5.2.6.3.2 Notification must be made by manufacturer or importing agency responsible for the sale and use of the water

additive to be sure the water additive is properly registered with the appropriate federal authorities having jurisdiction forthe manufacture, transport and/or use of the water additive in any foreign national market.5.2.6.3.3 Manufacturers their agents and assigns should make every effort to encourage the safe handling of fire water

run-off to help ensure reducing the risk of contaminating aquatic water bodies.NFPA 18A Technical Committee does not have authority to include clause as worded.

The committee does not agree with the submitters substantiation that the toxicity of acomposition can be determined by testing the individual components.



_______________________________________________________________________________________________



Testing of the corrosive effects of water additive concentrates and its solutions prepared at the minimum andmaximum concentration specified for use by the manufacturer shall be conducted in accordance with either NACEStandard Test Method TM0169 or ASTM G1 and ASTM G31, and in accordance with 5.2.7.2 through 5.2.7.7.

The water additives and its solutions shall not have corrosion rates exceeding those shown in Table 5.2.7.7.2.1when tested in accordance with 5.2.7.

Testing of the corrosive effects of water additive concentrates and solutions shall be conducted in accordancewith either NACE TM0169 or ASTM G 1 and ASTM G 31, and in accordance with 5.2.7.5 through 5.2.7.10.

4 The results of the testing shall be included in the manufacturer’s technical data sheet.

Each test liquid, the The water additive concentrate and its solutions prepared at the minimum and maximumconcentrations specified for use by the manufacturer, shall be tested for corrosion with coupons prepared from samplesof 4130 mild steel, 2024-T3 aluminum, and UNS C27000 yellow brass (65 percent copper, 35 percent zinc) for each ofthe coupon immersion and incubator temperature test conditions specified in Table 5.2.7.5.1.

***Insert Table 5.2.5.5.1 Here***

The water additive concentrate and its solutions shall be tested at the maximum and minimum useconcentrations specified by the manufacturer.

A minimum of three test coupons of each material shall be exposed to each test liquid for each testcondition. A minimum of one control coupon of each material shall also be tested without liquid immersion.

Each coupon, approximately 25 mm × 102.6 mm × 3.2 mm (1 in. × 4 in. × 1/8in.), shall be marked by vibrating engraver with a unique identification code, drilled in the upper center to insert thebraided Dacron® string used to suspend it, and then its length, width, and thickness measured to the nearest 0.01 mm(0.000394 in.) for length, width, and thickness.

Each coupon shall be degreased and rinsed in tap water.The degreased coupon shall not be touched with a bare hand.

The coupons shall be cleaned chemically as described in Table 5.2.7.7.2.1, rinsed in distilled water, wipedto remove the water film, and dried at approximately 55°C (130°F) for 15 to 30 minutes.

The coupons shall be cooled to room temperature, weighed to 0.1 mg (0.00154 grain), and either usedimmediately or stored in a desiccator until use.

The coupon weight shall be recorded for use in determining weight loss at the end of the 90-day testingperiod.

One coupon shall be suspended by a length of braided Dacron fishing line in a 0.95 L (32 oz)glass jar in such a way that the coupon does not touch the sides or bottom of the jar.

Each jar shall contain 0.8 L (24 oz) of liquid for total immersion tests or 0.4 L (12 oz) of liquid for partialimmersion tests.

For total immersion tests, the coupon shall be completely covered with liquid.For partial immersion tests, the coupon shall be suspended so that 50 % ± 5 % of one-half its length is

immersed in the liquid and 50 % ± 5 % of one-half its length is exposed to the vapor.Each jar shall be closed and sealed with a screw cap, labeled with coupon identification and starting date,

and put in an incubator at 21°C or 49°C (70°F or 120°F), dependent on the desired test condition.Jars containing the test liquid (three at each exposure and temperature) shall


18A_Log#17_Tb 5.2.5.5.1_Rec F2010 ROC 1

Table 5.2.5.5.1 Test Liquid, Coupon Immersion and Incubator Temperature Test Conditions

Coupon Immersion and Incubator Temperature Test Conditions Total Immersion Partial Immersion

Test Liquid °C °F °C °F °C °F °C °F Concentrate 21 + 2 (70 + 4) 49 + 3 (120 + 5) 21 + 2 (70 + 4) 49 + 3 (120 + 5) Minimum Use Concentration

21 + 2 (70 + 4) 49 + 3 (120 + 5) 21 + 2 (70 + 4) 49 + 3) (120 + 5)

Maximum Use Concentration

21 + 2 (70 + 4) 49 + 3 (120 + 5) 21 + 2 (70 + 4) 49 + 3) (120 + 5)

Report on Comments – November 2010 NFPA 18Astand undisturbed for 90 days.

At the end of the 90-day test period, the coupons shall be removed from the liquid and rinsed under runningwater to remove loosely attached corrosion products.

The coupons shall be lightly scrubbed with a toothbrush or other nonmetallic brush to aid in removal of scale.The coupons shall be cleaned chemically using the same procedures that were used initially in accordance

with Table 5.2.7.7.2.1.A clean, unused coupon shall be cleaned in the same manner at the same time to serve as a control for

weight lost during the cleaning process.After rinsing in distilled water, oven-drying, and cooling the coupons, the final weight of each coupon shall be

determined to 0.1 mg (0.00154 grain).

The corrosion rate ( ) in mils per year (mpy) shall be calculated for each sample as follows:

***Insert Equation #1 (E18A-1) Here***

where: = corrosion rate (mpy)= initial test coupon weight (mg)= final test coupon weight (mg)= initial control coupon weight (mg)= final control coupon weight (mg)

= surface area of the test coupon (in2)= surface area of the control coupon (in2)

= exposure of the test coupon (hours)= exposure of the control coupon (hours)= density of the alloy [g/cm3 (lb/in3)] as follows:

4130 steel = 7.86 g/cm3 (0.28 lb/in3);yellow brass = 8.53 g/cm3 (0.3 lb/in3);2024-T3 aluminum = 2.77 g/cm3 (0.1 lb/in3)

***Insert Equation #2 (E18A-2) Here***

where:= corrosion rate (mpy)= initial coupon weight (mg)= final coupon weight (mg)= weight loss of the control (mg)

= area of the coupon (in.2)= exposure (hours)= density of the alloy [g/cm3 (lb/in. 3)] as follows:

4130 steel = 7.86 g/cm3 (0.28 lb/in. 3);yellow brass = 8.53 g/cm3 (0.3 lb/in. 3);2024-T3 aluminum = 2.77 g/cm3 (0.1 lb/in. 3)

Results of replicate tests shall be averaged and rounded to the nearest 0.1 mpy.Common degreasers can include all-purpose cleaners and dishwasher soaps. The chosen degreaser should

be used for all comparative testing.The proposed revisions provide consistency between NFPA 18 and NFPA 18A. The proposed

revisions to the corrosion rate formula includes all of the variables that are measured.Since 5.2.7.3 is the same as 5.2.7.1 and 5.2.7.2 includes an incorrect reference to Table 5.2.7.7.2.1, it is proposed that

5.2.7.2 and 5.2.7.3 be deleted and subsequent sections be renumbered.

The committee does not agree that the recommended changes would provide consistency


18A_L17_Eq 18A-1 F2010 ROC 1

18A_L17_Eq 18A-2 F2010 ROC 1

Report on Comments – November 2010 NFPA 18Abetween NFPA 18 and NFPA 18A. Also the recommended text deletes the requirement criteria for the evaluationresults. The committee agrees with the submitter that there was an incorrect reference to the table. The reference toTable 5.5.1 will be correct with the re-numbering in Proposal 18A-16.

_______________________________________________________________________________________________18A-10 Log #CC3


18A-30

The hardness of the samples shall be determined following ASTM D 2240, Federal Test Standard No. 601,Methods 3021 and 3025, both prior to and following the procedure described in 5.6.2.


_______________________________________________________________________________________________18A-11 Log #CC2


18A-16

The hardness of the samples shall be determined following ASTM D 2240, Federal Test Standard No. 601,Methods 3021 and 3025, both prior to and following the procedure described in 5.7.2 5.6.2.




_______________________________________________________________________________________________



The ability of water additive solutions to extinguish surface wood panel fires shall be determined with solutionprepared at the minimum concentration specified for use by the manufacturer according to the procedures detailed inthis section and UL 711/ULC S508, for Class A fires utilizing using a 4-A wood panel.

The water additive solution shall be prepared at the concentration recommended by the manufacturer andapplied The solution shall be applied with a nozzle acceptable to the listing agency at a rate of 19 L/min (5 gpm) for 30seconds, by which time extinguishment shall have been achieved.

The solution shall be applied at a rate of 19 L/min (5 gpm).Solution shall be applied for 30 seconds, by which time extinguishment shall have been achieved.

Observations shall be continued for 15 minutes following the end of discharge, during which time reignition shallnot occur.

The proposed revisions clarify that the wood panel fire test is to be conducted with the minimumconcentration specified by the manufacturer and provides consistency, as applicable, with the format and contentbetween NFPA 18A wood crib and wood panel fire tests. The content relative to the solution concentration of 5.9.2 hasbeen proposed to be incorporated into 5.9.1. The content of 5.9.3 and 5.9.4 has been proposed to be combined with5.9.2. 5.9.5 has been proposed to be renumbered to 5.9.3.

See the Action on Comment 18A-13 Log #3.

_______________________________________________________________________________________________18A-13 Log #3

_______________________________________________________________________________________________Blake M. Shugarman, Underwriters Laboratories Inc.

18A-34Accept the proposal as revised during the Committee Meeting.

1. The current requirements in Section 5.9.2 do not address the possibility that a manufacturer mayhave more than one recommended concentration and/or a range of recommended concentrations. The proposedrevisions require the wood panel fire test be conducted with solution prepared at the minimum concentration specifiedby the manufacturer, which is considered representative.Regarding the Explanation of Negative Ballots and referring to the proposal as revised during the Committee Meeting,

[1] the acceptable performance criteria for extinguishment is specified in 6.2.2, [2] the acceptable performance criteriaregarding reignition is specified in 6.2.3. In addition, as referenced in 11thedition, Merriam-Webster, Inc., Springfield, MA, 2003 [NFPA 18A-2007, Section 2.3.8], “extinguish” is defined as “tocause to cease burning.”



_______________________________________________________________________________________________

Bob Eugene, Underwriters Laboratories Inc.18A-35

Revise text to read as follows:5.9.1 The ability of water additive solutions to extinguish surface fires shall be determined according to the procedures

detailed in this section and ANSI/UL 711/CAN/ULC S508, using a 4-A wood panel.The ANSI and CAN/designation should be added to UL 711/ULC S508 to reflect the approval of the

referenced standard.

_______________________________________________________________________________________________18A-15 Log #10


18A-35

5.9.1 6.2.1 The ability of water additive solutions to extinguish surface fires shall be determined according to theprocedures detailed in this section and ANSI/UL 711/CAN/ULC S508, using a 4-A wood panel.

The ANSI and CAN/designation should be editorially added to UL 711/ ULC S508 to reflect theapproval of the referenced standard consistent with the committee action on proposals 18A-6, 18A-8, 18A-54 and18A-56. The section number has been modified to be consistent with the committee action on proposal 18A-16.



_______________________________________________________________________________________________



The ability of water additive solutions to extinguish wood crib fires shall be determined with solution prepared atthe minimum concentration specified for use by the manufacturer according to the procedures detailed in this sectionand UL 711/ULC S508, for Class A fires utilizing using a 4-A wood panel.

The water additive solution shall be prepared at the concentration recommended by the manufacturer andapplied The solution shall be applied with a nozzle acceptable to the listing agency at a rate of 19 L/min (5 gpm) for 30seconds, by which time extinguishment shall have been achieved.

The solution shall be applied at a rate of 19 L/min (5 gpm).Solution shall be applied for 30 seconds, by which time extinguishment shall have been achieved.

Observations shall be continued for 15 minutes following the end of discharge, during which time reignitionshall not occur.

The proposed revisions clarify that the wood crib fire test is to be conducted with the minimumconcentration specified by the manufacturer and provides consistency, as applicable, with the format and contentbetween NFPA 18 and NFPA 18A. The content relative to the solution concentration of 5.10.2 has been proposed to beincorporated into 5.10.1. The content of 5.10.3 and 5.10.4 has been proposed to be combined with 5.10.2. 5.10.5 hasbeen proposed to be renumbered to 5.10.3.

See the action on Comment 18A-17 Log #4.

_______________________________________________________________________________________________18A-17 Log #4


18A-36Revise as follows:

Accept the proposal as revised during the Committee Meeting except delete 6.3.4 since this information is containedin 6.3.2.

1. The current requirements in Section 5.10.2 do not address the possibility that a manufacturer mayhave more than one recommended concentration and/or a range of recommended concentrations. The proposedrevisions require the wood crib fire test be conducted with solution prepared at the minimum concentration specified bythe manufacturer, which is considered representative.Regarding the Explanation of Negative Ballots and referring to the proposal as revised during the Committee Meeting,

[1] the acceptable performance criteria for extinguishment is specified in 6.3.2, [2] the acceptable performance criteriaregarding reignition is specified in 6.3.3. In addition, as referenced in 11thedition, Merriam-Webster, Inc., Springfield, MA, 2003 [NFPA 18A-2007, Section 2.3.8], “extinguish” is defined as “tocause to cease burning.”



_______________________________________________________________________________________________

Bob Eugene, Underwriters Laboratories Inc.18A-37

Revise text to read as follows:5.10.1 The ability of water additive solutions to extinguish wood crib fires shall be determined according to the

procedures detailed in this section and ANSI/UL 711/CAN/ULC S508 using a 4-A wood crib.The ANSI and CAN/designation should be added to UL 711/ULC S508 to reflect the approval of the

referenced standard.

_______________________________________________________________________________________________18A-19 Log #11


18A-37

5.10.1 6.3.1 The ability of water additive solutions to extinguish wood crib fires shall be determined according to theprocedures detailed in this section and ANSI/UL 711/CAN/ULC S508 using a 4-A wood crib.

The ANSI and CAN/designation should be editorially added to UL 711/ ULC S508 to reflect theapproval of the referenced standard consistent with the committee action on proposals 18A-6, 18A-8, 18A-54 and18A-56. The section number has been modified to be consistent with the committee action on proposal 18A-16.



_______________________________________________________________________________________________



When tested as described in this section, a water additive solution prepared at the minimum concentrationspecified for use by the manufacturer shall achieve 100 percent extinguishment in an average of not more than 60seconds.

The burnback resistance shall be confined to an area of 1.15 m2 (12.4 ft2) or 25 percent for an average of 180seconds.

The 4.6 m2 (50 ft2) fire test shall be conducted indoors in a level 2.43 m (7.97 ft) inside diameter pan fabricatedfrom 6mm (1.4 in.) thick steel having sides 125 mm (5 in.) high.

The pan shall contain 38 L (10 gal) heptane on a substrate of water.The water shall be used only to ensure complete coverage of the pan and shall not exceed 5 mm (3/16 in.) in

depth at the shallowest point of the pan.All fire tests shall be conducted on a surface that is flushed free of fuel and water additive solution from

previous tests.The fire test pan shall be cool to the touch before retesting.

The air-aspirated or non-air-aspirated nozzle or compressed air system, as specified by the manufacturer, shallhave a flow rate of 18.9 L/min (5 gpm).

When an air-aspirated nozzle or compressed air system is used, foam quality tests shall be conducted andreported in accordance with ULC S560.

The temperature of the solution shall be 20°C ± 3°C (68°F ± 5°F).Thirty-eight L (10 gal) of commercial grade heptane conforming to UL 162 shall be used.Fuel temperature shall not be less than 10°C (50°F).Tests shall be conducted only when the ambient temperature is above 5°C (40°F).

For air-aspirated nozzles and compressed air systems, expansion and drainage testing as described in ULCS560 shall be conducted prior to initiation of fire testing to confirm equipment functionality.

Tests shall be conducted and reported using a solution of water additive liquid concentrate, as received, infresh and synthetic seawater.

Two sets of two tests, one set with fresh water and one set with synthetic seawater, shall be conducted toderive average extinguishment and burnback times.

In the event that either of the averages after the two tests do not meet the requirements of this standard, onemore test shall be conducted, with the results of all three tests being averaged.

No further testing shall be conducted if either of the averages fails to meet the requirements following the thirdtest.

The complete fuel charge shall be emptied into the pan.The fuel shall be ignited within 60 seconds after completion of fueling and shall be permitted to burn freely for

15 seconds before application of the water additive solution.The water additive solution shall be applied for a period of 90 seconds, and the fire shall be extinguished in

accordance with the manufacturer’s application instructions.The nozzle shall be permitted to be moved throughout the duration of the solution application or fixed in

position for part or all of the solution application, but at no time shall the nozzle tip extend beyond the plane of the edgeof the pan.


Report on Comments – November 2010 NFPA 18AThe operator shall be permitted to move around the entire area of the pan.

A weighted 300 mm (12 in.) diameter pan, having 50 mm (2 in.) side walls, charged with 1.1 L (0.3 gal) ofheptane shall be placed in the center of the test area.

An eyebolt with a 20 mm (3.4 in.) shaft attached to the center of the pan, and a 3 m (10 ft) pole with a hook onthe end, shall facilitate the placement of the pan.

The fuel shall be ignited, and the burnback pan shall be placed in the 4.6 m2 (50 ft2) fire test pan within 15seconds after solution application is terminated.

Burnback time shall commence at the time of placement of the burnback pan and shall terminate when 25percent of the fire test pan area is a flame.

The burnback pan shall be left in the fire test pan until 25 percent burnback has been achieved.The following data shall be recorded for each test:

(1) Time for extinguishment (seconds)(2) Time for 25 percent burnback (seconds)(3) Ambient temperature(4) Expansion and drainage (for air-aspirated nozzles or compressed air systems)

The listed application rate shall be 6.89 (L/min)/m2 (0.17 gpm/ft2).Although water additive solutions and Class B foams are required to pass Class B fire performance tests to

obtain a listing, the tests are different. Some of the most important differences are as follows:(1) The tested application rate for water additive solutions is different from the tested application rate for Class B foam

solutions in NFPA 11.(2) The burnback resistance time is 180 seconds for water additive solutions compared to 360 seconds for foam

solutions.(3) The published application rate for water additive solutions is 5/3 × test application rate (rounded up) compared to

5/3 for protein and fluoroprotein foam and 5/2 for AFFF and FFFP.Ghost flames or intermittent “flashovers” can occur. They are not to be considered a part of the burnback area

unless sustained burning occurs for more than 30 seconds.Proposed revisions provide clarification that testing is to be conducted with the minimum concentration

solution.

See the Committee Action on Comment 18A-5.

_______________________________________________________________________________________________18A-21 Log #5


18A-39Accept the proposal.

1. The current requirements in Section 7.2.1 do not address the solution concentration to be used forthe spill fire test. The proposed revisions require the test be conducted with solution prepared at the minimumconcentration specified by the manufacturer, which is considered representative.Regarding the Explanation of Negative Ballots and referring to the proposal, [1] the acceptable performance criteria for

extinguishment is specified in 7.2.1, 7.2.7, and 7.2.8.3; and [2] the acceptable performance criteria does not includereignition, but does include burnback resistance as specified in 7.2.2 and 7.2.7. In addition, as referenced in

11th edition, Merriam-Webster, Inc., Springfield, MA, 2003 [NFPA 18A-2007,Section 2.3.8], “extinguish” is defined as “to cause to cease burning.”



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Water additive solutions prepared at the minimum concentration specified for use by the manufacturershall be tested in accordance with this section for use on fuels pooled to a depth of 101 mm (4 in.) or less.

A water additive in combination with an 18.9 L/min (5 gpm) nozzle shall be tested in accordance with thissection and comply with the requirements specified.


The water additive solution discharged onto flammable liquid test fires shall comply with 7.3.2.1through 7.3.2.4.

The fire shall be completely extinguished during or at the end of discharge.The test fuel surface shall not reignite when a lighted torch is moved over all areas of the surface.Candling, flaming, or flashover that self-extinguishes shall be permitted provided that the phenomenon does

not remain in one area for more than 30 seconds.When the stovepipe is removed, the liquid surface shall react in either of the following ways:

(1) Restrict the spread of fire at any time during the 3-minute duration to a total area of not more than 0.92 m2 (10 ft2)(2) Flow over and extinguish the burning area

Each water additive concentrate to be tested shall be taken from its container as received fromthe manufacturer, following storage at room temperature for at least 24 hours.

The test fuel of commercial grade heptane conforming to UL 162 shall be placed in a 4.6 m2 (50 ft2) fire testpan constructed in accordance with UL 162.

The pan shall be located on the floor.A fuel layer at least 101 50.8 mm (4 in. 2 in.) deep shall be floated on a layer of water, as applicable not less

than 25 mm (1 in.) deep.The fuel or water depth shall be adjusted to provide a distance from the top of the pan to the surface of the

liquid not less than 202 mm (8 in.).Fuel temperature shall not be less than 10°C (50°F).

The nozzle shall be positioned in front of and above the test pan.The nozzle shall be permitted to be moved throughout the duration of water additive solution application or

fixed in position for part of or all of the application.Until approximately 90 percent of flame reduction is attained, all water additive solution application shall be

from behind one side of the test pan and discharged directly onto the fuel surface.After approximately 90 percent of flame reduction is attained, water additive solution application shall be

permitted to be from the front and one adjacent side and shall be permitted to be directed onto the inside of the test pan.The nozzle shall be permitted to be moved beyond the adjacent side extensions.The nozzle shall not be permitted to extend over any part of the test pan.

After the fuel has been added to the test pan and the nozzle has been arranged, the fuel shall beignited and the resulting fire allowed to burn freely for a 60-second preburn.

At the end of the 60-second preburn, the water additive solution shall be discharged for 5 minutes.The fire shall be completely extinguished at or before the end of discharge.After all discharge is complete, the test fuel with water additive solution shall be left undisturbed for 5 minutes.

During the time the water additive solution with test fuel is left undisturbed, a lighted torch constructed asdescribed in UL 162 shall be passed approximately 25 mm (1 in.) above the entire liquid surface, including corners, in


Report on Comments – November 2010 NFPA 18Aan attempt to reignite the fuel.

The torch test shall be conducted once during this period and shall commence 2 minutes after the end of agentdischarge and prior to the ignition of the 300 mm (12 in.) diameter stovepipe.

The torch test shall be conducted for not less than 1 minute.The fuel shall not reignite while the torch is being passed over the fuel.Candling, flaming, or flashover that self-extinguishes shall be permitted provided that the phenomenon does

not remain in one area for more than 30 seconds.

After completion of attempt to reignite the fuel with the lighted torch, a stovepipe constructed as described inUL 162 shall be lowered into the liquid.

The stovepipe shall be placed approximately 0.76 m (2-1/2 ft) from each of two adjacent sides of the test panin the corner considered to cause the most severe burnback condition and lowered in such a manner that the liquidsurface is not disturbed.

The portion of the foam blanket that is enclosed by the stovepipe shall be removed with as little disturbance aspossible of the foam blanket outside of the stovepipe.

If no foam blanket is present, 1 L (0.26 gal) of heptane shall be poured into the stovepipe.The fuel cleared or placed inside the stovepipe shall be ignited 5 minutes after the end of agent discharge and

allowed to burn for 1 minute.The stovepipe then shall be slowly removed from the pan while the fuel continues to burn.When the stovepipe is removed, the liquid surface shall react in either of the following ways:

(1) Restrict the spread of fire at any time during a 3-minute duration to a total area of not more than 0.92 m2 (10 ft2)(2) Flow over and extinguish the burning area

The spread of fire caused by candling, ghosting, or flashover, in which the flame height exceeds 0.6 m (2 ft)but then self-extinguishes, shall be considered unacceptable if the total area involved in flame exceeds 0.92 m 2 (10 ft2)at any time during the 3-minute duration 7.3.9.7(1).

The listed application rate shall be 10.19 (L/min)/m2 (0.25 gpm/ft2).Although water additive solutions and Class B foams solutions are required to pass Class B fire performance

tests to obtain a listing, the tests are different. Some of the most important differences are as follows: (1) The testedapplication rate for water additive solutions in NFPA 18A is different from the tested application rate for Class B foamsolutions in UL 162. (2) The burnback or sealability requirements for water additive solutions are less than those foragents tested to UL 162. (3) The application rate in NFPA 18A is 10.19 (L/min)/m2 (0.25 gpm/ft2), which is a 5/2 safetyfactor over the test application rate. This is the same safety factor as applied to AFFF and FFFP. Experience with theextinguishment of fires in extreme depth such as tank or dike fires is limited, if any.

Since a water additive solution may provide emulsification, Section 7.3.4.3 is proposed to be revisedconsistent with the intended fuel depth specified in 7.3.1.As a reduction in the flame may be difficult to characterize, Sections 7.3.5.3 and 7.3.5.4 are proposed to be revised to

include "approximately".To better define the test parameters, Sections 7.3.8.1 and 7.4.9.1 are proposed to reference the construction described

in UL 162 for the torch and stovepipe.7.2.4.5 has been added for consistency with 7.2.5.3.

See the Committee Action and Statement on Comment 18A-23 Log #6.





1. The current requirements in Section 7.3.1 do not address the solution concentration to be used forthe pool fire test. The proposed revisions require the test be conducted with solution prepared at the minimumconcentration specified by the manufacturer, which is considered representative.2. The current requirements in Section 7.3.8.1 do not address the construction of the torch. The proposed revisions

reference UL 162 for the construction of the torch.3. The current requirements in Section 7.3.9.1 do not address the construction of the stovepipe. The proposed

revisions reference UL 162 for the construction of the stovepipe.Regarding the Explanation of Negative Ballots and referring to the current content of NFPA 18A-2007, [1] the

acceptable performance criteria for extinguishment is specified in 7.3.2.1; and [2] the acceptable performance criteria forreignition is specified in 7.3.2.2 and 7.3.8. In addition, as referenced in 11thedition, Merriam-Webster, Inc., Springfield, MA, 2003 [NFPA 18A-2007, Section 2.3.8], “extinguish” is defined as “tocause to cease burning.”

Revise text as follows:Until at least 90 percent flame reduction is attained, all water additive solution application shall be from behind

one side of the test pan and discharged directly onto the fuel surface.After at least 90 percent flame reduction is attained, water additive solution application shall be permitted to be

from the front and one adjacent side and shall be permitted to be directed onto the inside of the test pan.The committee agrees to retain the text revisions in the committee action on Proposal 18A-40

except to revise 7.3.5.3 and 7.3.5.4.



_______________________________________________________________________________________________



Water additive concentrates shall be evaluated for aviation applications or industrial applications, or both, andshall be listed only for those applications for which they have been successfully tested.

To be listed for the extinguishment of three dimensional fires, water additive solutions prepared at the minimumconcentration specified for use by the manufacturer of the water additive concentrate prepared at the manufacturer’srecommended concentration shall be tested and listed as described in this section.

Water additives shall be tested against a free-flowing running fuel fire.For aviation ( ) applications, the fuel shall be Jet Petroleum Grade A.For industrial ( ) applications, the fuel shall be commercial heptane.

For the purpose of this fire test, fuel shall be adjusted to slowly flow down both sides of thevertical cascade at a total fuel flow rate of 13.25 L/min ± 1.9 L/min (3.5 gpm ± 0.5 gpm).

Maximum wind speed for this test sequence shall be less than 8 kph (5 mph).

The lower collection basin of the tower system shall be charged with 101mm (4 in.) of fresh water at less than38°C (100°F).

The vertical tower column shall have water free flowing through the tower cooling system, and the verticaltower temperature prior to the test shall be below 38°C (100°F).

The basin area shall contain 18.9 L (5 gal) of fuel prior to ignition.The fuel shall be ignited and allowed to preburn for a minimum of 45 seconds.In the event both faces of the test apparatus are not fully involved after 45 seconds, the preburn time shall be

extended until this is achieved.

Water additive solution shall be applied with a nonair- aspirated nozzle, an air-aspirated nozzle, or acompressed air foam system.


For aviation fuel, water additive solution application rate shall be a maximum of 151 L/min (40 gpm), andextinguishment shall occur in 20 seconds or less.

For industrial applications, water additive solution application rate shall be a maximum of 227 L/min (60 gpm),and extinguishment shall occur in 45 seconds or less.

At the start of application, fire fighters shall position themselves at the front of the cascade system at least 6.1m (20 ft) from the closest corner of the cascade fuel basin.

At no time shall a fire fighter get closer than 3 m (10 ft) to accomplish the extinguishing process.Fire fighters shall remain within an arc of no more than 1.52 m (5 ft) left or right of the closest corner starting

point of the collection basin.For each application ( or ) to be listed, three fires in a maximum of six total trials shall meet the

performance requirements of 7.4.7.3 and 7.4.7.4.A slight adjustment in fuel flow is permitted to ensure that both top plates of the vertical cascade receive equal

quantities of fuel flowing down both sides of the front vertical column of the cascade test device.Proposed revisions provide clarification that testing is to be conducted with the minimum concentration

solution.


Report on Comments – November 2010 NFPA 18ASee the Committee Action on Comment 18A-7.

_______________________________________________________________________________________________18A-25 Log #7


18A-41Accept the proposal.

1. The current requirements in Section 7.4.1.2 do not address the possibility that a manufacturer mayhave more than one recommended concentration and/or a range of recommended concentrations. The proposedrevisions require the three-dimensional fuel fire test be conducted with solution prepared at the minimum concentrationspecified by the manufacturer, which is considered representative.Regarding the Explanation of Negative Ballots and referring to the proposal, [1] the acceptable performance criteria for

extinguishment is specified in 7.4.9, 7.4.7.3, and 7.4.7.4; [2] the fuel flow is specified in 7.4.3; [3] the water additivesolution application rate (i.e., flow) is specified in 7.4.7.3 and 7.4.7.4; and [4] the maximum extinguishment time isspecified in 7.4.7.3 and 7.4.7.4. In addition, as referenced in 11th edition,Merriam-Webster, Inc., Springfield, MA, 2003 [NFPA 18A-2007, Section 2.3.8], “extinguish” is defined as “to cause tocease burning.”



_______________________________________________________________________________________________



This section shall cover test procedures to evaluate the ability of a water additive solution to render ahydrocarbon fuel nonflammable through emulsification.

The following materials shall be provided for the test:(1) 6.35 mm (1/4 in.) thick steel pan measuring 1.2 m × 1.2 m × 202 mm (4 ft × 4 ft × 8 in.)(2) Amount of water additive concentrate as specified by the manufacturer for the fuel being tested(3) Types Liters (gallons) of fuels as specified in 7.6.2.2(4) Amount of water needed to meet the manufacturer’s specified concentration ratio(5) Ignition source consisting of a propane torch producing a minimum 25 mm (1 in.) flame

The following fuels shall be tested:(1) Heptane(2) Gasoline as defined in 40 CFR 86.113-94(3) Gasoline with 10 percent ethanol(4) Gasoline with 18 percent MTBE(5) No. 2 diesel(6) Jet A

The emulsification test shall be set up as follows:(1) The steel pan shall be thoroughly washed with clean water and dried.(2) The full amount of fuel shall be poured into the pan.(3) The full amount of water additive concentrate shall be mixed into the fuel within a one minute duration.(4) The full amount of water shall be added within a one minute duration in a manner to agitate the resulting mixture.

Following addition of the water, agitation is to be stopped.

Ignition tests for each fuel in 7.6.2.2 shall be conducted in accordance with 7.6.4.2 and 7.6.4.3.

One minute after completion of agitation, the ignition torch described in 7.6.2.1(5) shall be passed over theentire liquid surface, including corners, with the tip of the flame impinging on the surface, in an attempt to reignite thefuel.

The fuel shall not reignite while the torch is being passed over the fuel.

Two hours after completion of agitation, the ignition torch described in 7.6.2.1(5) shall be passed over theentire liquid surface, including corners, with the tip of the flame impinging on the surface, in an attempt to reignite thefuel.

The fuel shall not reignite while the torch is being passed over the fuel.A water additive concentrate shall be listed for vapor mitigation when the

requirements of 7.6.4.2 and 7.6.4.3 have been met for all fuels in 7.6.2.2.

An emulsifying agent is one that is capable of rendering the fuel nonflammable by encapsulating thehydrocarbon molecules.

This represents the application ratio (Agent:Fuel:Water).The proposed revisions provide additional details for the test method.

As referenced in NFPA 18A, Section 1.2, the purpose of this standard is intended for the use and guidance of thoseresponsible for purchasing, testing, listing, and using water additives. Since Section 7.6.6 does not provide guidance fortesting, it is proposed that this section be deleted.


Report on Comments – November 2010 NFPA 18ASee the Committee Action and Statement on Comment 18A-2.

_______________________________________________________________________________________________18A-27 Log #2



1. Section 7.6.2.1 (3) references a quantity of fuel as specified in 7.6.2.2; however, 7.6.2.2 does notspecify a quantity of fuel, but does specify the type of fuel. The quantity of fuel is a function of the application ratio(Agent:Fuel:Water) and the total volume of the Agent:Fuel:Water mixture is limited by the total volume of the pan.Therefore, a specific quantity of fuel cannot be specified.2. Section 7.6.3 does not include limitations for the time necessary to add the water additive concentrate or the water

to the fuel in the pan. Since the ignition tests (7.6.4.2 and 7.6.4.3) are to be conducted at the specified times “afteragitation”, it is necessary to specify the end of agitation.3. The steel pan needs to be cleaned and dried to prevent potential contaminants from the previous test, which could

include agent, fuel, solution, and/or water.Regarding the Explanation of Negative Ballots and referring to the proposal as revised during the Committee Meeting,

[1] the acceptable performance criteria is specified in 7.6.5; [2] the solution is required to render the fuels nonflammableas specified in 7.6.1; and [3] there are no extinguishment requirements, since the ignition of the fuel would beconsidered unacceptable.

Revise Title of Section 7.6 as follows:7.6 Emulsification TestIn the seventh row of Figure 8.2 revise "Vapor Mitigation" to "Emulsification."In the seventh row of Figure A.8.2 revise "Vapor Mitigation" to "Emulsification."In 7.6.5 revise "vapor mitigation" to "emulsification"In 7.1 (5) change "Vapor Mitigation" to "Emulsification."

The committee revised the Title and other references to more accurately name the test. Theother recommended changes proposed by the committee on Proposal 18A-43 remain unchanged.

_______________________________________________________________________________________________18A-28 Log #12


18A-7

Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.UL 162, , 1994, revised 1999.ANSI/UL 300, 2005.ANSI/UL 711/CAN/ULC S508, , 2004, revised 2007 2009.

Consistent with Mr. Johnson’s comment on the affirmative and committee action on Proposals 18A-6,18A-8 and 18A-56. The revision date to ANSI/UL 711/CAN/ULC S508 is updated to the most current revision. Thisrevision is issued to extend the effective date for clause 7.2.


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