Public Comment No. 3-NFPA [ Section No ]

Transcription

1 Public Comment No. 3-NFPA [ Section No ] 17.4 Location of Process Plant Permanent and Portable Buildings, Process Vessels and Process Equipment Liquid-processing vessels and equipment shall be located in accordance with the requirements of this section Processing vessels and buildings containing such processing vessels shall be located so that a fire involving the vessels does not constitute an exposure hazard to other occupancies Permanent process plant buildings shall be located in accordance with the requirements of API RP 752, "Manangement of Hazards Associated with Location of Permanent Process Buildings." Portable process plant buildings shall be loacted in accordancw with the requirements of API RP 753, "Management of Hazards Associated with Location of Process Plant Portable Builtings." The minimum distance of a processing vessel to a property line that is or can be built upon, including the opposite side of a public way; to the nearest side of a public way; or to the nearest important building on the same property shall be one of the following: (1) In accordance with Table (2) Determined by an engineering evaluation of the process, followed by application of sound fire protection and process engineering principles Table Location of Process Vessels with Respect to Property Lines, Public Ways, and the Nearest Important Building on the Same Property Protection for Exposures Is Provided Page 1 of 15

2 Vessel Maximum Operating Liquid Capacity (gal) 275 or less 276 to to 12,000 12,001 to 30,000 30,001 to 50,000 50,001 to 100,000 Over 100,000 For SI units, 1 gal = 3.8 L; 1 ft = 0.3 m; 1 psi = a gauge pressure of 6.9 kpa. Note: Double all of above distances where protection for exposures is not provided. *Gauge pressure Where process vessels are located in a building and the exterior wall facing the exposure (line of adjoining property that is or can be built upon or nearest important building on the same property) is greater than 25 ft (7.6 m) from the exposure and is a blank wall having a fire resistance rating of not less than 2 hours, any greater distances required by Table shall be permitted to be waived. If the exterior wall is a blank wall having a fire resistance rating of not less than 4 hours, all distances required by Table shall be permitted to be waived All the distances given in Table shall be doubled where protection for exposures is not provided * Page 2 of 15

3 Liquid-processing equipment, such as pumps, heaters, filters, and exchangers, shall not be located closer than 25 ft (7.6 m) to property lines where the adjoining property is or can be built upon or to the nearest important building on the same property that is not an integral part of the process. This spacing requirement shall be permitted to be waived where exposures are protected in accordance with Processing equipment in which unstable liquids are handled shall be separated from unrelated plant facilities by either of the following: (1) 25 ft (7.6 m) clear spacing (2) A wall having a fire resistance rating of not less than 2 hours and explosion resistance consistent with the expected hazard Statement of Problem and Substantiation for Public Comment This will bring the requirements of API RP 752 and 753 in the NFPA 30 code to provide for appropriate protection of new permanent structures in new and existing facilities and for the protection of temporary structures in new and extisting facilities, such as tents, trailers, etc used in turnaround and construction activities.. Copies of API safety related RPs are available to the public at Page 3 of 15

4 Submitter Information Verification Submitter Full Name: Richard Kraus Organization: API/Petroleum Safety Consultan Street Address: City: State: Zip: Submittal Date: Fri Mar 01 09:02:58 EST 2013 Committee Statement Committee Rejected Action: Resolution: Public Comment No. 3 has been incorporated into Second Revision No. 3. The NFPA 30 Technical Committee on Operations agrees with the references to the American Petroleum Institute s Recommended Practices RP 752 and RP 753, but has determined that these two documents are specific to process buildings and are more appropriately located in Section Copyright Assignment I, Richard Kraus, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am Richard Kraus, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 4 of 15

5 Public Comment No. 11-NFPA [ Section No ] Transfer of liquids among vessels, containers, tanks, and piping systems by means of air or inert gas pressure shall be permitted only under all of the following conditions: (1) The vessels, containers, tanks, and piping systems shall be designed for such pressurized transfer and shall be capable of withstanding the anticipated operating pressure. (2) Safety and operating controls, including pressure-relief devices, shall be provided to prevent overpressure of any part of the system. (3) Only inert gas shall be used to transfer Class I liquids when pressures above 6 psig are used. Only inert gas shall be used to transfer Class II and Class III liquids that are heated above their flash points when pressures above 6 psig are used. Additional Proposed Changes File Name Description Approved CIBA_1.pdf CIBA Rpt #1 GT_PED_2.pdf GT PED # _GoatThroat_Pump_3.pdf GoatThroat Pump Rpt #3 Statement of Problem and Substantiation for Public Comment Page 5 of 15

6 RE Public Input No. 21-NFPA Section No The NFPA 30 Technical Committee on Operations did not accept the amendment proposed by Westcott Distribution Inc for the change to the standard, which was, (3) Only inert gas shall be used to transfer Class 1 liquids when pressures above 8 psig are used. Only inert gas shall be used to transfer Class II and III liquids that are heated above their flash points when pressures above 8 psig are used. The reason this public input was not accepted was, because of the absence of data showing that there is no hazard in the use of hand-operated compressed air devices to transfer Class I liquids or Class II or III liquids heated up to or above their flash points. The Technical Committee requested that a public comment be submitted, at the appropriate time, along with a risk-based or technical analysis showing that the hazard of using such a device is no greater than that posed by other liquid transfer systems, i.e., gravity dispensing or use of a hand pump. Based on our consultants advice, we suggest the following revision to NFPA (3) : (3) Only inert gas shall be used to transfer Class 1 liquids when pressures above 6 psig are used. Only inert gas shall be used to transfer Class II and III liquids that are heated above their flash points when pressures above 6 psig are used. In support of this revised proposal and to comply with the request by the Technical Committee for a risk based analysis showing that the hazard of using such a devise is no greater than that posed by other liquid transfer systems, Westcott engaged Consultants to review and conduct such assessments. Attached are 3 documents in support of our revised proposal: 1) CIBA GoatThroatReport.pdf 2) GT PED Statement nw.pdf 3) GoatThroat Pump Risk Desktop Assessment _Final Report_ pdf A synopsis of the findings of each consultant are below: 1) CIBA GoatThroatReport.pdf: The SCP line of pumps meets the criteria which prevents the accumulation of static electricity. 2) GT PED Statement nw.pdf T.U.V. Sud America evaluated the SCP pump lines with regard to P.E.D. Pressure Equipment Directive 97/23/EC, requirements. Their conclusions, are: (A) Regarding the SCP Line (Static Conductive Pump) and the standard line which both have automatic pressure relief at 8psig: the above mentioned GoatThroat Pumps (drawings #s s. Table II are subject to the Pressure Equipment Directive (97/23/EC) and do fall under Article 3(3) of the Pressure Equipment directive. And, (B) Regarding the SCP 6 Line (Static Conductive Pump) and the GT-6 which both have automatic pressure relief at 6psig: the above mentioned GoatThroat Pump (drawing #s s. Table 1) are not subject to the Pressure Equipment Directive (97/23/EC) since the design pressure is identified below the applicability limits for the Pressure Equipment Directive (97/23/ED) of 0.5 bar. 3) GoatThroat Pump Risk Desktop Assessment _Final Report_ pdf Page 6 of 15

7 Westcott then engaged Chilworth Technology Inc. to conduct a risk based assessment of the GT SCP line of Pumps which have automatic pressure relief at 6psig. Their conclusion regarding Flammable Atmosphere: The flash point of a liquid increases with increased pressure. At a system pressure of 6.0 psig (1070 mm Hg) and 12 degrees C, the concentration is too lean to ignite. A flammable atmosphere will exist inside of vessels containing flammable liquids, in many cases. This atmosphere will not significantly change regardless of whether the vapor space is at ambient pressure or pressures above ambient. Furthermore, there is no oxygen enrichment at elevated pressures which could increase the sensitivity of the flammable atmosphere to ignition. For these reasons, there is no additional flammability risk posed by using low pressure (6 psig or less) air to dispense liquids as compared to a dispensing system that uses suction. Their conclusions regarding Explosion Severity are: As regards rotary and piston pumps (the) gap around the bung may allow a weak explosion occurring at a temperature near the flash point (LFL) to vent in the form of a flame jet exiting near the bung at high velocity and high temperature. This jet could injure personnel working in close proximity to the container. As regards GoatThroat Pumps A reduced risk would be expected where a pressure pump is being used and the vessel does not rupture as a result of an ignition inside. In this case, the energy from the ignition will be confined to the vessel and not escape to possibly injure personnel. Their conclusions regarding risk assessment are: use of the GoatThroat SCP line of pressure pumps to dispense flammable or combustible liquids, at pressure up to 6psig, is not considered to present any additional ignition, flammable atmosphere or leak/spill hazard when compared to suction pumps used for the same purpose. Thank you for your consideration.. Submitter Information Verification Submitter Full Name: NANCY WESTCOTT Organization: Westcott Distribution Inc., GOATTHROAT PUMPS Division Street Address: City: State: Zip: Submittal Date: Sat Apr 27 07:15:28 EDT 2013 Committee Statement Page 7 of 15

8 Committee Rejected but see related SR Action: Resolution: SR-6-NFPA Statement: The NFPA 30 Technical Committee on Operations has reviewed the information that has been submitted to it in support of Public Comment No. 11 and has developed language that is appropriate to ensure safe use of such hand-operated devices for dispensing Class I liquids using air pressure. Copyright Assignment I, NANCY WESTCOTT, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am NANCY WESTCOTT, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 8 of 15

9 Public Comment No. 18-NFPA [ New Section after ] 19.7 Cooking Oil Storage Tank Systems in Commercial Kitchens Scope This section shall apply to cooking oil storage tank systems located in commercial kitchens where tank capacities are greater than 60 gallons This section applies to both fresh and waste cooking oil storage tank systems Where there are conflicts in the requirements of other chapters of this code and this section, the requirements of this section shall take precedent Design and Construction of Cooking Oil Storage Tanks Materials of Construction. Tanks shall be of metallic or nonmetallic construction The materials of construction for tanks and their appurtenances shall be compatible with cooking oil * For tanks storing waste cooking oil, the materials of construction for tanks and their appurtenances shall be compatible with cooking oil at minimum temperatures of 140 F (60 C) continuous and 235 F (113 C) intermittent. A Waste oil is drained from a commercial fryer, via a transfer pump and lines, to a waste oil storage tank. The oil in the fryer may be hot, up to 375 F, still well below the oil flash point. Experience shows that the oil loses significant heat in the transfer process. The maximum temperature of waste cooking oil entering the storage tank are typically below 235 F (113 C). The materials of construction must be designed to be used with cooking oil in this temperature range Design Standards * M etallic cooking oil storage tanks shall be listed in accordance with ANSI/UL 142, Standard for Steel Aboveground Tanks for Flammable and Combustible Liquids, or ANSI/UL 80, Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids. A Existing steel tanks listed for flammable and combustible liquids are considered acceptable for waste oil use. These tank standards contain design and construction requirements that would not meet food code requirements, making the tanks unacceptable for storage of liquid food products (fresh cooking oil) Nonmetallic cooking oil storage tanks shall be in accordance with all of the following: (1) Tanks shall be listed in for use with cooking oil, unless otherwise approved. (2) Tanks shall not exceed 200 gallons per tank Normal Venting Normal venting shall be located above the maximum normal liquid line The size of the vent shall have a minimum effective area at least as large as the largest filling or withdrawal connection. Page 9 of 15

10 Normal vents, including vent piping, smaller than 1.25 in. (32 mm) nominal inside diameter shall be tested to verify internal tank pressures remain below a gauge pressure of 0.5 psi (3.5 kpa) under maximum flow rates for tank filling and withdrawal. These tests shall be permitted to be conducted by a qualified, impartial outside agency or by the manufacturer if certified by a qualified, impartial observer * Normal vents shall be permitted to vent inside the building. A Ignitable vapors are not created with high flash point cooking oil stored under the conditions required in Section Emergency Venting Cooking oil storage tanks shall contain emergency relief venting in accordance with Chapter * For non-metallic cooking oil storage tanks, emergency relief venting shall be permitted to be in the form of construction. This includes the low melting point of the tank material. A Nonmetallic tanks will melt above the liquid line as an exposure fire progresses, venting the vapor space of the tank Emergency relief venting in the form of construction for metallic tanks shall be prohibited Emergency vents shall be permitted to vent inside the building * Prevention of Overfilling of Cooking Oil Storage Tanks. Every cooking oil storage tank shall be provided with means to prevent an accidental overfill. Such means shall be automatic and fail-safe in nature. A Although generally not required for tank storage of Class IIIB liquids, overfill protection is provided for the cooking oil storage to prevent inadvertent spillage from a tank Tank Heating * Electrical equipment used for heating cooking oil shall be listed to ANSI/UL 499, Standard for Electrical Heating Appliances, and shall comply with NFPA 70, National Electric Code. Use of electrical immersion heaters shall be prohibited in nonmetallic tanks. A The prohibition of an electrical immersion heater in nonmetallic tanks eliminates a primary ignition scenario for the oil stored in a nonmetallic tank * Electrical equipment used for heating cooking oil shall comply with NFPA 70 and shall be equipped with automatic means that limit the temperature of the contents of the tank to less than 140 F (60 C). A The temperature limitation of 140 F corresponds to ASTM C1055 (ISO ) restrictions for maximum allowable temperatures of nonmetallic industrial surfaces for human contact Tank Installation and Testing Location of Cooking Oil Storage Tanks. Tanks shall be installed in locations appropriate for storage of foodstuffs or inventory, and shall not be installed in areas designated as cooking areas * Tanks shall be spaced at least 3 ft. (0.9 m) away from any cooking appliance or surface heated to above 140 (60 C) continuous, and at least 6 ft. (1.8 m) away from any open flame. A The kitchen cooking area has historically been an area where fires occur. It is appropriate to locate tanks away from this potential ignition source * Tanks shall not be installed under commercial kitchen ventilation hoods. A This is an area of potential accidental ignition. Page 10 of 15

11 Tanks shall not be required to be separated from one another Foundations for and Anchoring of Cooking Oil Storage Tanks Tanks supports shall be secured to the tank and the floor to prevent the tank from tipping over. For flat-bottom tanks resting directly on the floor, the tank shall be secured to the floor to prevent the tank from tipping over In areas subject to earthquakes, tank supports, foundation and anchoring shall meet the requirements of the applicable building code for the specific seismic zone. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement Where a tank is located in areas subject to flooding, the method for anchoring the tank to the floor shall be able to prevent the tank, either full or empty, from floating during a rise in water level up to the established maximum flood stage. Engineering evaluation by a qualified, impartial outside agency shall be an acceptable method of meeting this requirement Tank Openings Other than Vents Each connection to the tank below the normal liquid line through which liquid can normally flow shall be provided with an internal or external valve located as close as possible to the shell of the tank, in accordance with Chapter * Each connection to the tank above the normal liquid line through which liquid can normally flow shall not be required to have a valve, provided there exists a liquid-tight closure at the opposite end of the line. The liquid-tight closure shall be in the form of a valve, a plug, or a coupling or fitting with positive shut-off. A An example of a fitting with a positive shut-off is a spring-loaded check valve or a hydraulic quick-coupler with a spring-loaded poppet Field Testing * As an alternate method to testing requirements in Chapter 21, cooking oil storage tanks shall be tested for leaks at the time of installation by filling the tank with cooking oil to a liquid level above the highest tank seam or connection within the normal liquid level. Before the tank is placed in service, all leaks shall be corrected in an approved manner or the tank shall be replaced. A Cooking oil storage tanks are atmospheric tanks with open vents. The requirement in Chapter 21 to pressurize the tank for leak testing would be difficult to achieve in the field due to tank construction and configuration. It is also desirable to prevent the contamination of water in a cooking oil tank. A more appropriate test would be to fill the tank with cooking oil to cover all connections and seams below the normal liquid level line An approved listing mark on a cooking oil storage tank shall be considered to be evidence of compliance with tank testing requirements Fire Protection for Cooking Oil Storage Tanks Identification for Emergency Responders. A sign or marking that meets the requirements of NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, or another approved system, shall be applied to each cooking oil storage tank in accordance with Chapter 21. Additional signage shall be applied to each tank identifying the contents of the tank as cooking oil, either fresh or waste * In areas where tanks are located, no additional ventilation is required provided adequate general human occupancy ventilation is provided, and all cooking equipment is provided with exhaust systems in accordance with NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations. A Supplemental ventilation, as is required for cooking operations, is not needed for cooking oil storage tanks. Page 11 of 15

12 If ventilation is not provided as described in Step , then the tank shall be vented to another room inside the building that meets these requirements, or the tank shall be vented to outside the building Transfer Lines * Design and Construction of Fresh Cooking Oil Transfer Lines. Fresh cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil and food products. In addition, nonmetallic transfer lines shall also meet the following requirements: (1) Transfer lines used for pressure applications shall be rated for 100 psi (689 kpa) working pressure at 70 F (21 C), or the maximum output pressure of the transfer pump, whichever is higher. (2) Transfer lines used for suction applications shall be rated for full vacuum at 70 F (21 C). (3) Transfer lines shall be rated for temperatures up to 120 F (49 C) continuous. (4) The maximum nominal inside diameter shall be no larger than 1.25 in. (32 mm). (5) Leakage shall be controlled through the use of check valves or anti-siphon valves at points where the lines connect to the fresh oil tank. A Transfer lines will contain oil during fill and removal operations. Waste oil lines are generally pumped until there is little residual oil remaining in the lines. Fresh cooking oil lines are likely to contain residual oil after fill and removal operations. Restricting the fresh oil line size to 1.25 inches maximum inside diameter limits the amount of oil in the line. Additionally, the requirement for check valves or anti-siphon valves on the lines at points where the lines connect to the tank eliminates the possibility of a compromised line siphoning the contents of the tank * Design and Construction of Waste Cooking Oil Transfer Lines. Waste cooking oil transfer lines shall be permitted to be constructed of metallic or nonmetallic materials which are compatible with cooking oil Transfer lines shall be rated for use with cooking oil at elevated temperatures of 275 F (135 C) continuous and 350 F (177 C) intermittent Nonmetallic transfer lines shall be rated for pressures up to 250 psi (1724 kpa) working pressure at 275 F (135 C). A The temperature and pressure ratings for the waste oil lines are consistent with the maximum expected conditions Flow Control. Cooking oil transfer lines shall be equipped with means to prevent unintended transfer or dispensing of cooking oil. These means are allowed to be in the form of momentary control switches, valves, check valves, anti-siphon valves, plugs, couplings, fittings, or any combination thereof that are fail-safe in nature Pressure Control. Pumping systems used to transfer cooking oil shall have means to prevent over-pressurization of transfer lines. These means shall be in the form of relief valves, bypass valves, pressure sensor devices, or the pressure limitation of the pump itself Installation of Cooking Oil Transfer Lines in Plenum-rated Spaces. Cooking oil transfer lines installed in plenum-rated spaces shall be enclosed in noncombustible raceways or enclosures, or shall be covered with a material listed and labeled for installation within a plenum Testing of Cooking Oil Transfer Lines. Cooking oil transfer lines shall be tested after installation and prior to use. Testing shall be with cooking oil at the normal operating pressures. Any leaks discovered in transfer lines as a result of testing shall be repaired or the transfer lines replaced prior to placing the transfer lines into service. Section/paragraph Chapter 19, Section 19.2 Page 12 of 15

13 Add a new definition and associated annex material * Cooking Oil. Where used in this chapter, cooking oil shall be defined as a Class IIIB combustible liquid. This definition shall apply to both fresh, or new, cooking oil and waste, or used, cooking oil. A Cooking oil is a Class IIIB liquid with a high flash point typically above 500 F. Because of this high flash point, it represents a lower fire hazard than other Class IIIB liquids having a flash point lower than 500 F. Fresh, or new, cooking oil is supplied to the user for cooking operations. As the oil becomes degraded through repeated use, it must be replaced with fresh oil. This waste oil, or used oil, is recovered from the cooking appliance and temporarily stored for offsite removal. To maintain fluidity in the transfer process, the waste oil must be heater. This heating is on the order of 100 F, well below the flash point temperature. Section/paragraph Chapter 2, Sections 2.2 and 2.3 Add the following reference standard to Chapter 2, Section 2.2: NFPA 96, Standard for Ventilation Control and Fire Protection of Commercial Cooking Operations, 2011 edition. Add the following reference standard to Chapter 2, Section 2.3.9: ANSI/UL 499, Electric Heating Appliances, Statement of Problem and Substantiation for Public Comment Page 13 of 15

14 Substantiation: The revised material has been developed based on the direction provided by NFPA 30 Technical Committee at the Public Input Meeting. Committee Input # was created, originally based on Public Input #115, during this meeting. Current NFPA 30 requirements present a practical challenge to new restaurant technologies, which entirely eliminate manual handling of cooking oil. These systems provide personnel safety and environmental improvements to existing manual or semimanual oil handling operations. 1. Current fire codes have added requirements for the storage of cooking oil in commercial kitchens. These codes reference or adopt NFPA 30 requirements for specific attributes of Class IIIB storage and handling systems. a. The fire code requirements as written emphasize used, spent, and inedible cooking oil. b. For systems which include fresh cooking oil supply, tanks and components must be food grade. The steel oil burner and industrial aboveground storage tank standards currently referenced in the fire codes do not anticipate food grade processes. 2. The current requirements in NFPA 30 do not explicitly recognize non-metallic systems currently approved for food grade processes. There are limitations in listing metallic tanks, using the standards specified, for food grade processes. These limitations include requirements for welds and fillets for metallic tanks which conflict with food grade requirements. The proposal addresses this limitation by adding requirements for nonmetallic tanks, with a requirement for listing tanks used with cooking oil. 3. Current design criteria in NFPA 30 are more relevant to industrial flammable and combustible liquid tank requirements. High flash point cooking oil in a restaurant back-ofhouse setting represents a different, and generally lower, hazard than commonly anticipated by NFPA 30. The revised Operations Section unifies all pertinent fire safety requirements into Section 19.7, providing ease of use for users and fire officials. This establishes the level of safety applicable to this hazard. 4. Modifications to current requirements for venting and electrical design have been made to accurately reflect the level of protection for this hazard as established in NFPA 30. Recognizing the low fire hazard associated with high flash point Class IIIB liquids, NFPA 30 permits vents from tanks storing Class IIIB liquids to discharge within a building, and permits non-classified electrical equipment for Class IIIB storage installations inside buildings. 5. Associated requirements for liquid transfer lines have been included. A companion code change has been made to NFPA 1, which has passed the Public Input stage. The approval of this proposal would allow the new NFPA 1 language to correlate with NFPA 30, since NFPA 1 adopts NFPA 30 in its entirety. Submitter Information Verification Submitter Full Name: ANDREW BURKE Organization: RESTAURANT TECHNOLOGIES INC Street Address: City: State: Zip: Submittal Date: Thu May 02 17:05:39 EDT 2013 Committee Statement Page 14 of 15

15 Committee Rejected but see related SR Action: Resolution: SR-7-NFPA Statement: Second Revision No. 7 is based on the direction provided to the submitter of Public Comment No. 18 by the NFPA 30 Technical Committee on Operations, at the NFPA 30 First Draft Meeting. During that meeting, Public Input No. 115 was revised to create Committee Input No. 20. Current code requirements present a practical challenge to new restaurant technologies that entirely eliminate manual handling of cooking oil. These systems provide personnel safety and environmental improvements to existing manual or semi -manual oil handling operations. Current fire codes have added requirements for the storage of cooking oil in commercial kitchens and these codes reference or adopt NFPA 30 requirements for specific attributes of Class IIIB storage and handling systems. These fire code requirements emphasize used, spent, and inedible cooking oil. For systems which include fresh cooking oil supply, tanks and components must be food grade. The steel oil burner and industrial aboveground storage tank standards currently referenced in the fire codes do not anticipate food grade processes. NFPA 30 currently does not explicitly recognize nonmetallic systems for food grade processes. There are limitations in listing metallic tanks, using the standards specified, for food grade processes; these include requirements for welds and fillets for metallic tanks that conflict with food grade requirements. The proposal addresses this limitation by adding requirements for non-metallic tanks, with a requirement for listing tanks used with cooking oil. Current design criteria in NFPA 30 are more relevant to industrial flammable and combustible liquid tank requirements. High flash point cooking oil in a restaurant back-of-house setting represents a different, and generally lower, hazard than commonly anticipated by NFPA 30. The proposed new Section 19.7 that is presented in Second Revision No. 7 unifies all pertinent fire safety requirements into a single location, providing ease of use for users and fire officials. This establishes the level of safety applicable to this hazard. Modifications to current requirements for venting and electrical design have been made to accurately reflect the level of protection for this hazard, as established in NFPA 30. Recognizing the low fire hazard associated with high flash point Class IIIB liquids, NFPA 30 permits vents from tanks storing Class IIIB liquids to discharge within a building and permits non-classified electrical equipment for Class IIIB storage installations inside buildings. Associated requirements for liquid transfer lines have been included. The NFPA 30 Technical Committee on Operations understands that a companion code change has been proposed NFPA 1, Fire Code, and that this has passed the First Draft stage. Approval of Second Revision No. 7, and its companion Second Revisions (Nos. 9 and 11), will allow the new NFPA 1 language to correlate with NFPA 30, since NFPA 1 adopts NFPA 30 in its entirety. Copyright Assignment I, ANDREW BURKE, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am ANDREW BURKE, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature Page 15 of 15