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

Explosives

Thomas P. Dowling, Chair

Harpers Ferry, WV [SE]

Ben Barrett, Hodgdon Powder Company, Inc., KS [M] W. S. Chang, Explosives Bureau, NJ [RT] C. James Dahn, Safety Consulting Engineers Inc., IL [SE] Jeffrey L. Dean, International Society of Explosives Engineers, OH [U] Rep. International Society of Explosives Engineers Paul W. Dickinson, Defense Contracts Management Agency, CO [E] Frank H. Fenton, III, The Township of Northampton, PA [E] Larry L. Fluer, Fluer, Inc., CA [M] Rep. Automotive Occupant Restraints Council Mark A. Fry, Mark A. Fry & Associates, Inc., NJ [SE] Robert B. Hopler, Powderman Consulting, Inc., MD [SE] Juri T. Kasemets, Natural Resources Canada, Canada [E] Kenneth L. Kosanke, PyroLabs, Incorporated, CO [SE] Robert C. Morhard, Zukovich, Morhard & Wade, LLC, PA [M] David K. Nichols, TRW Vehicle Safety Systems Inc., AZ [M] Roger N. Prescott, Austin Powder Company, OH [M] Richard L. Rhea, St. Marks Powder, Inc., FL [M] Lon D. Santis, Institute of Makers of Explosives, DC [U] Rep. Institute of Makers of Explosives David S. Shatzer, US Bureau of Alcohol, Tobacco, Firearms & Explosives, DC [E] Robert A. Van Duzer, SAAMI, PA [M] Rep. Sporting Arms & Ammunition Manufacturers Institute Barney T. Villa, Los Angeles County Sheriff’s Department, CA [E] Rep. International Assn. of Bomb Technicians & Investigators Bert von Rosen, Canadian Explosives Research Laboratory, Canada [RT]

Alternates

Douglas H. Delsemme, Hodgdon Powder Company, Inc., KS [M] (Alt. to Ben Barrett) Eldon K. Hurley, Dyno Nobel Incorporated, NY [U] (Alt. to Lon D. Santis) Michael S. Katich, Defense Contracts Management Agency, CO [E] (Alt. to Paul W. Dickinson)

Dave McCulloch, Natural Resources Canada, Canada [E] (Alt. to Juri T. Kasemets) Lawrence Weinman, Luna Tech/Schneier-Weinman Consultants, AL [SE] (Alt. to Kenneth L. Kosanke)

Nonvoting

Virginia M. Gilman, US Department of Labor, DC [E] Rep. Occupational Safety & Health Administration Mark W. Hagemann, US Department of Labor, DC [E] (Alt. to NV Principal) Rep. Occupational Safety & Health Administration

Staff Liaison: Guy R. Colonna

Committee Scope: This Committee shall have primary responsibility for documents on the manufacture, transportation, storage and use of explosives and related materials. This Committee does not have responsibility for documents on consumer and display fireworks, model and high power rockets and motors, and pyrotechnic special effects.

This list represents the membership at the time the Committee was balloted on the text of this edition. Since that time, changes in the membership may have occurred. A key to classifications is found at the front of this book.

This portion of the Technical Committee Report of the Committee on Explosives is presented for adoption.

This Report on Comments was prepared by the Technical Committee on Explosives, and documents its action on the comments received on its Report on Proposals on NFPA 495, Explosive Materials Code, 2001 edition, as published in the Report on Proposals for the 2005 June Meeting.

This Report on Comments has been submitted to letter ballot of the Technical Committee on Explosives, which consists of 21 voting members. The results of the balloting, after circulation of any negative votes, can be found in the report.

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Report on Comments — Copyright, NFPA NFPA 495 ________________________________________________________________ 495-1 Log #1 Final Action: Accept in Principle in Part (Entire Document) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-1 RECOMMENDATION: Delete all references to Class A, B, and C Explosives. SUBSTANTIATION: These terms have been obsolete since the early 1990s. COMMITTEE MEETING ACTION: Accept in Principle in Part Revise the ROP text as follows based upon the recommendation to delete reference to Class A, B, and C Explosives: 8.1.8 Detonators shall not be transported in the same vehicle with other Class 1 materials (Class A or Class B explosives) , except as permitted by the U.S. Department of Transportation in 49 CFR 177.835 (g). In Table 9.3.1 (b) delete “(Class A explosives)” where used in this table in the “Storage in Magazines” column in the first 3 entries. Delete “(Class A or Class C explosives)” where it appears in 4th entry. Delete “(Class C explosives)” where it appears in the 5th entry in the table. Delete “(Class B explosives)” where it appears in the 8th (last) entry in this table. 14.3.5 Commercial shipments of smokeless propellants exceeding 45.4 kg (100 lb) or not packaged in accordance with the regulations cited in 14.3.4 shall be transported in accordance with the U.S. Department of Transportation regulations for Class B propellant Division 1.1 or 1.3 explosives. A.3.3.58 Propellant. It is classified by the U.S. Department of Transportation, “Hazardous Materials Regulations” as Division 1.1 (Class A) or 1.3 (Class B) , depending on its susceptibility to detonation, and it can be reclassed as Division 4.1 (see also 14.3.4). Annex E.2, note to Table E.2 (b) - delete “(Explosive C)” and “(Explosive A)” where it appears and insert “Division” in front of “1.4 B and 1.4 S” and “1.4 B” (two places in this note). COMMITTEE STATEMENT: The submitter’s recommendation was not specific, so the Committee has reviewed the entire document for the use of “Class A, B or C explosives” and determined which usages are suitable for deletion as recommended. In a couple of instances, the Committee did not delete the term as the context for that usage necessitated retaining the existing text without revision. The Committee’s action accomplished the intent of the submitter. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 18 Negative: 1 BALLOT NOT RETURNED: 2 FRY, VILLA EXPLANATION OF NEGATIVE: DAHN: I do not believe using UN/DoT test protocols will provide adequate safety in in-process materials and conditions. _______________________________________________________________ 495-2 Log #11 Final Action: Accept in Principle (Entire Document) ________________________________________________________________ SUBMITTER: Larry Fluer , Fluer, Inc. COMMENT ON PROPOSAL NO: 495-4 RECOMMENDATION: The enclosed comment is a proposal to revise the original proposal as submitted by TRW to create a new Chapter in NFPA 495 (Chapter 5 as issued in response to the ROP meeting of March 3, 2004) and ancillary changes. The entire Chapter is new, and as such would be underlined, however, for ease of understanding the Chapter as initially released in the ROP draft has been put into legislative format to show the changes made since the original submittal. Chapter 5 Manufacturing and Testing

5.1 Scope. Manufacture and, testing of explosives shall be in accordance with the requirements of this chapter.5.1.1 Blasting agents shall not be subject to the requirements of this chapter (See Chapter 6).5.1.2 Water gels, slurries, and emulsion explosives shall not be subject to the requirements of this chapter (See Chapter 7).5.2 General Requirements.5.2.1 Emergency Procedures. Emergency procedures shall be developed for each manufacturing facility.5.2.2 Posting of pertinent information. Standard operating procedures governing the manufacturing process shall be located at workstations where the work is to be conducted.5.2.3 Training. Persons handling explosive materials or working in operating buildings shall be trained inaccordance with Sections 5.2.3.1 through 5.2.3.5.5.2.3.1 The physical and health hazards of the explosive materials to be manufactured.5.2.3.2 The operational activities involved in processing the materials to include instructions in emergencies that are anticipated in the manufacturing process.5.2.3.3 The operating rules applicable to the materials in the manufacturing process.

5.2.3.4 Plans for emergency procedures in the event of a fire or explosion.5.2.3.5 Personnel shall be made aware of emergency warning signals and actions to take in the event the warningsignal is activated.5.2.3.6 Contract personnel working in explosive manufacturing areas shall be instructed on site specificoperating procedures, emergency procedures, hot work operations and procedures applicable to the area prior toengaging in any activity whether maintenance related or not.5.2.3.7 Visitors entering operational areas shall receive orientation training and shall be accompanied by a trainedescort.5.2.4* Containers. Bulk explosive materials shall be stored in approved containers when not in use.5.2.5* Waste. When waste receptacles are provided for the collection of waste materials and debris, such waste receptacles shall be Aapproved receptacles and equipped with covers. shall be provided for each location where explosive materials are manufactured for the disposing of waste material and debris.5.2.5.1 Emptying waste containers. Waste receptacles shall be emptied and cleaned in accordance with operating procedures. as often as necessary but not less than once each day or at the end of each shift whenmore than one shift operations are conducted.5.2.5.2 Collection of spilled material. Spilled or droppedexplosive materials which are spilled outside of designated containment or confinement zones shall be collected immediately promptly for disposal or disposition and the area in which the materials were spilled shall be cleaned.5.2.5.3 Contaminated materials. Shipping containers, cCleaning materials or materials that have been contaminated with explosive materials shall be removed daily and disposed of in an approved manner.5.2.5.3.1 Shipping containers. Shipping containers used for explosive materials shall be allowed to be retained for reuse as required.5.2.6 Maintenance. Non-routine Mmaintenance and repair work shall not be performed in an explosive manufacturing area until prescribed clean-up and decontamination has been performed. explosive materials have been removed and the area has been prepared for such maintenance or repair work to be conducted.5.2.6.1 Operational adjustments. Operational adjustments or emergency repairs to mitigate immediate hazardous conditions shall be permitted without having removed the explosive materials from the area.Repair work. The area in which repair work is to be conducted shall be inspected and approved by supervisory personnel prior to conducting the work.5.2.7 Ignition source control.5.2.7.1 Smoking. Smoking shall be prohibited on the plant site, except where notices permitting it are posted.5.2.7.2 Flame producing devices. Matches, torches or other flame-producing devices shall be prohibited frombeing taken into explosives manufacturing areas without a written permit signed by an authorized supervisor.5.2.7.3 Portable Electrical Devices. Portable electrical devices including flashlights shall be prohibited from being taken into explosives manufacturing areas.5.2.7.3.1 Portable electrical equipment. Portable electrical equipment approved for use in the specific manufacturing environment shall be permitted when designated by the manufacturing process and incorporated into the operating instructions described in Section 5.2.2.5.2.8 Clothing.5.2.8.1 Type of clothing. Clothing to be worn by persons involved in the manufacturing process shall be of a type approved by management.5.2.8.2 Accessories. Watches, jewelry, finger rings, earrings, and items intended for use as accessories shall notbe worn in manufacturing areas where explosive materials are manufactured.5.2.8.3 Contaminated clothing. Persons wearing clothingthat has been contaminated with explosive materials shall not be permitted to enter areas where smoking is permitted or where operations involving the use of open flame or open ignition sources are present.5.2.9 Clearance from combustibles. The area within 25 feet (7.6 m) of operating buildings shall be kept clear of brush, leaves, vegetation and other combustible materials.5.2.10 Limited access by authorized personnel. Manufacturing areas shall be secured against unauthorizedentry with access limited to that necessary for the performance of operating functions.5.2.11 Separation of incompatible materials. Incompatible materials in storage and storage of materialsincompatible with materials in use shall be separated by one of the following methods:5.2.11.1 Segregating incompatible materials storage from use by a distance of not less than 20 ft (6.1m)5.2.11.2 Isolating incompatible materials in storage by a noncombustible partition extending not less than 18 in (46 cm) above and to the sides of the stored material.5.2.11.3 Storing liquid and solid materials in hazardous materials storage cabinets complying with NFPA 1.5.2.12 Housekeeping.

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Report on Comments — Copyright, NFPA NFPA 495 5.2.12.1 Floors. Floors of manufacturing areas shall be swept or otherwise maintained to prevent the accumulation of explosive materials.5.2.12.2 Tools and equipment. Tools and equipment shall be kept in designated areas when not in use duringmanufacturing operations.5.2.13 Hot work. Hot work operations shall be conducted in accordance with the requirements of NFPA 1.5.2.13.1 Management. Management shall be responsible for the supervision of hot work activity.5.2.13.2 Permits. Permits to conduct hot work operations shall be required.5.3 Classification and characterization of energetic materials used in process operations5.3.1* In-process hazard classification. Explosive materials being processed shall be classified with an in-process hazard classification based on the hazards of the material in the configuration and quantity employed.5.3.1.1 High explosion hazard. The classification of materials that have not been established by testing or those where the quantity or configuration used exhibit a high explosion hazard shall be classified as a high explosion hazard.5.3.1.1.1 Materials of known character or composition in the configuration and quantity specific to the process where the in-process hazard classification is approved by the authority having jurisdiction shall be allowed to be classified as other than a high explosion hazard.5.3.1.1.2 Physical hazards established by testing. When testing is performed the Characterization of explosive materials shall be confirmed by utilizing test methods shall be those established by DOD, ATF, UN/DOT or other approved criteria.5.3.1.1.1 2Technical assistance. The AHJ shall be permitted to require a review by an independent third party with expertise in the matter to be reviewed at the submitter’s expense.5.3.1.2 Physical hazards alternative methodology. Materials that have not been assigned an in-process hazard classification by testing in the configuration and quantity specific to the process shall be classified as a mass or high explosion hazard.5.3.1.3 Health hazard classification. The health hazards of materials used in the manufacturing process shall be determined in accordance with the requirements of NFPA 1. In addition to physical hazards that are present, materials classified as toxic, highly toxic or corrosive materials shall be classified as health hazards.5.3.1.4 Multiple Hazards. Materials that have multiple hazards shall conform to the Code requirements for each applicable hazard category specified.5.3.2 Quantity of Explosives. The quantity-distance (Q-D) tables in Section 5.3.3 shall be used to provide minimum distances from potential explosion sites. The classification of the explosives and the weight of the explosives are primary characteristics governing the use of these tables. The net explosive weight shall be determined in accordance with Sections 5.3.2.1 through 5.3.2.4.5.3.2.1 Mass-detonating explosives explosion hazards. Division 1.1or 1.2 explosives. The total net explosive weight shall be used. See Table 5.3.3(a) for operating buildings, and Table 9.4.1 for all other cases.5.3.2.1.1 When the TNT equivalence of the explosive material has been determined, the equivalence is allowed tobe used to establish the net explosive weight.5.3.2.2 Non-mass-detonating explosives explosion hazards (excluding Division 1.4).

5.3.2.2.1 Division 1.3 propellants. The total weight of the propellants alone is the net explosive weight. The net weight of the propellants shall be used. See Table 5.3.3(b).5.3.2.2.2 Combinations of bulk metal powder and pyrotechnic compositions. The sum of the net weights ofmetal powders and pyrotechnic compositions in the containers.5.3.2.3 Combinations of mass detonating explosion and non-massdetonating explosion hazard explosives (excluding Division 1.4).5.3.2.3.1* When Division 1.1 and 1.2 explosives are located in the same site, determine the distances for the total quantity first as 1.1 and then as 1.2. The required distance is the greater of the two. When the Division 1.1 requirements are controlling and the TNT equivalence of the 1.2 is known, the TNT equivalent weight of the 1.2 items shall be added to the total explosive weight of Division 1.1 items todetermine the net explosive weight of explosives for Division 1.1 distance determination. See Table 5.3.3(a) or5.3.3(b) as applicable.5.3.2.3.2* When Division 1.1 and 1.3 explosives are located in the same site determine the distances for the total quantity first as 1.1 and then as 1.3. The required distance is the greater of the two. When the division 1.1 requirements are controlling and the TNT equivalence of the 1.3 is known, the TNT equivalent weight of the 1.3 items shall be added to the total explosive weight of Division 1.1 items to determine the net explosive weight of explosives for division 1.1 distance determination. See Tables 5.3.3(a) or 5.3.3(b) as applicable.5.3.2.3.3* When Division 1.1, 1.2 and 1.3 explosives are located in the same site, determine the distances for the total quantity first as 1.1, next as 1.2 and finally as 1.3. The required distance is the greatest of the three. As permitted by Sections 5.3.2.3.1 and 5.3.2.3.2 above, TNT equivalent weights for 1.2 and 1.3 items are allowed to be used to determine the net weight of explosives for Division 1.1 distance determination. Table 5.3.3(a) or 5.3.3(b) shall be used when TNT equivalency is used to establish the net explosive weight.5.3.2.4 Combinations of non-mass-detonating exploding ammunition and explosives of different Divisions shall be treated as follows.5.3.2.4.1. Determine the required separation for eachdivision.5.3.2.4.2. Use the greatest separation of those determined.5.3.3* Intraplant separation of operating buildings. Operating buildings, including those where explosives charges are assembled, manufactured, prepared or loaded utilizing Division 1.1, 1.2, 1.3, or 1.4 explosives, shall be separated from all other operating buildings, magazines, inhabited buildings, public highways, and passenger railways at a distance not less than those shown in Tables 5.3.3(a), 5.3.3(b) or 5.3.3(c) as applicable. Distances to assumed property lines drawn for the purposes of determination of exterior wall and opening protection under the requirements of the Building Code shall not be used to establish the minimum distance for separation between buildings on a operating line.

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Report on Comments — Copyright, NFPA NFPA 495

Table X.3.3(a)MINIMUM INTRALINE (INTRAPLANT) SEPARATION DISTANCES (ILD or IPD) BETWEEN BARRICADED

OPERATING BUILDINGS CONTAINING EXPLOSIVES – DIVISION 1.1 or 1.2 – MASS EXPLOSION HAZARD a, b, c

NET EXPLOSIVE WEIGHT NET EXPLOSIVE WEIGHTPounds over Pounds not over Intraline distance

(ILD) or Intraplant dis-

tance (IPD) (feet)

Pounds over Pounds not over Intraline distance(ILD) or

Intraplant dis-tance (IPD) (feet)

2 5 16 12000 14000 2205 10 20 14000 16000 23010 20 25 16,000 18,000 23820 30 28 18,000 20,000 24530 40 31 20,000 25,000 26540 50 34 25,000 30,000 28050 75 38 30,000 35,000 29575 100 42 35,000 40,000 310100 125 45 40,000 45,000 320125 150 48 45,000 50,000 330150 200 53 50,000 55,000 340200 250 57 55,000 60,000 350250 300 60 60,000 65,000 360300 400 66 65,000 70,000 370400 500 71 70,000 75,000 380500 600 76 75,000 80,000 390600 700 80 80,000 85,000 395700 800 84 85,000 90,000 400800 900 87 90,000 95,000 410900 1,000 90 95,000 100,000 420

1,000 1200 96 100,000 110,000 4301200 1400 101 110,000 120,000 4451,400 1600 106 120,000 130,000 4551600 1800 110 130,000 140,000 4651800 2000 113 140,000 150,000 4752,000 2500 122 150,000 160,000 4852500 3000 130 160,000 170,000 4953,000 4,000 143 170,000 180,000 5054,000 5,000 154 180,000 190,000 5155,000 6,000 164 190,000 200,000 5256,000 7,000 172 200,000 210,000 5357,000 8,000 180 210,000 230,000 5558,000 9,000 190 230,000 250,000 5759,000 10,000 200 250,000 275,000 60010,000 12000 210 275,000 300,000 635

a. Where a building or magazine containing explosives is not barricaded, the intraline distances shown in this table shall be doubled.b. Linear interpolation between tabular values shall not be allowed. Non-linearinterpolation of the values shall be allowed subject to an approved technical opinion and report prepared in accordance with the requirements of NFPA 1.c. Do shall be a minimum of 60 feet. Where a building or magazine containingexplosives is barricaded, the minimum distance shall be 30 feet. When the distance is less than 60 feet and the building is un-barri-caded the fire-resistance of exterior walls and protection of wall openings shall be in accordance with the building code.

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Report on Comments — Copyright, NFPA NFPA 495 Table 5.3.3(b)

TABLE OF DISTANCES (Q-D) FOR BUILDINGSCONTAINING EXPLOSIVES – DIVISION 1.3

MASS FIRE HAZARDa,b,cQUANTITY OF DISTANCES IN FEET

DIVISION 1.3 EXPLOSIVES

(Net Explosive Weight) Pounds over Pounds not over Inhabited

buildings distance IBD

Distance to public traffic route

(PTR)

Intermagazine distance (IMD)

Intraline distance (ILD) or Intraplant

distance

(IPD)d 0 1,000 75 75 50 50

1,000 5,000 115 115 75 75

5,000 10,000 150 150 100 100

10,000 20,000 190 190 125 125

20,000 30,000 215 215 145 145

30,000 40,000 235 235 155 155

40,000 50,000 250 250 165 165

50,000 60,000 260 260 175 175

60,000 70,000 270 270 185 185

70,000 80,000 280 280 190 190

80,000 90,000 295 295 195 195

90,000 100,000 300 300 200 200

100,000 200,000 375 375 250 250

200,000 300,000 450 450 300 300

a. Black powder, when stored in magazines, is defined as low explosive by the Bureau ofAlcohol, Tobacco and Firearms (ATF).b. For quantities less than 1,000 pounds, the required distances are those specified for1,000 pounds. The user of lesser distances shall be permitted when supported by test dataand/or analysis.c. Linear interpolation of explosive quantities between table entries is permitted.d. Do shall be a minimum of 50 feet.

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Report on Comments — Copyright, NFPA NFPA 495 Table 5.3.3(c)

TABLE OF DISTANCES (Q-D) FOR BUILDINGSCONTAINING EXPLOSIVES – DIVISION 1.4c,d

QUANTITY OFDIVISION 1.4EXPLOSIVES

DISTANCES IN FEETQUANTITY OF DISTANCES IN FEET

DIVISION 1.4

EXPLOSIVES

(Net Explosives Weight)

Pounds over Pounds not over Inhabited buildings

distance IBD

Distance to public traffic route (PTR)

Intermagazine distance a,b (IMD)

Intraline distance (ILD) or Intraplant

distance (IPD)a, e

50 Not 100 100 50 50

Limited

a. A separation distance of 100 feet is required for buildings of other than Type I and II construction as defined in NFPA 5000.b. For earth-covered magazines, no specified separation is required.(1) Earth cover material used for magazines shall be cohesive. Solid or wet clay and types of soil that are too cohesive and shall not be used. Soil shall be free from unsanitary organic matter, trash, debris and stones heavier than 10 pounds or longer than 6 inches in diameter. Compaction and surface preparation shall be provided to maintain structural integ-rity and to prevent erosion. Where cohesive material are not used, as in sandy soil, the earth cover over magazines shall be finished with materials that ensure structural integrity.(2) The earth fill or earth cover between earth-covered magazines shall be either solid or sloped in accordance with the requirements of other construction features. There shall be a minimum of 2 feet of earth cover maintained over the tope of each magazine. The cover shall have a slope of 2 to 1 horizontal to vertical.c. restricted to articles, including articles packaged for shipment, that are not regulated as an explosive by Bureau of Alcohol, Tobacco and Firearms (ATF) regulations, or to unpacked articles used in process operations that do not propa-gate a detonation or deflagration between articles.d. Linear interpolation between tabular values is not applicable.e. Do shall be a minimum of 50 feet.

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Report on Comments — Copyright, NFPA NFPA 495 5.3.4 Determination of net explosive weight for operating buildings. In addition to the requirements of Section 5.3.2 to determine the net explosive weight for materials stored or used in operating buildings, quantities of explosives materials stored in magazines located at distances less than intraline distances from the operating building shall be added to the contents of the operating building to determine the net explosive weight for the operating building.5.3.4.1 Indoor magazines. The storage of explosive materials located in indoor magazines in operating buildingsshall be limited to a net explosive weight not to exceed 50 pounds.5.3.4.2 Outdoor magazines with a net explosive weight less than 50 pounds. The storage of explosive materials in outdoor magazines located at less than intraline distances from operating buildings shall be limited to a net explosive weight not to exceed 50 pounds.5.3.4.3 Outdoor magazines with a net explosive weight greater than 50 pounds. The storage of explosive materials in outdoor magazines in quantities exceeding 50 pounds net explosive weight shall be limited to storage in outdoor magazines located not less than intraline distances from the operating building in accordance with Section 5.3.3.5.3.4.4 Net explosive weight of materials stored in combination indoor and outdoor magazines. Theaggregate quantity of explosive materials stored in any combination of indoor magazines or outdoor magazineslocated at less than the intraline distances from an operating building shall not exceed 50 pounds.5.4 Buildings and Equipment5.4.1 Construction. Operating buildings shall be constructed in accordance with the requirements of NFPA5000.5.4.1.1 Location. Operating buildings shall be located in accordance with Section 5.3.3 based on the net explosive weight of materials contained.5.4.2 Plans. A copy of the construction plans shall be kept on the premises of the manufacturing site and shall be provided to the authority having jurisdiction upon request.5.4.3 Means of Egress. Obstructions, including storage, shall not be placed in the required width of a means ofegress, except projections as allowed by the Building Code. Means of egress shall not be obstructed in any manner and shall remain free of any material or matter where its presence would obstruct or render the means of egress hazardous.5.4.3.1 Maintenance of Exits. The required fire-resistive rating of walls, ceilings and openings that are part of ameans of egress shall be maintained.5.4.3.2 Locking of Exits. Exits throughout operating buildings shall be unlocked and verified operable beforeoperations are begun.5.4.4 Electrical wiring and equipment.5.4.4.1 Electrical wiring and equipment shall be installed in accordance with NFPA 70, National Electrical Code ®.5.4.4.2 Bonding and grounding.5.4.4.2.1 The non-current-carrying metal parts of electrical equipment including electric motors, generators,proportioning devices, and other electrical enclosures serving individual manufacturing processes shall beelectrically bonded together in accordance with the requirements of NFPA 70, National Electrical Code ®.5.4.4.2.2 Where the electrical system is required to be grounded, the grounding conductors shall be connectedtogether and to the supply system grounded conductor in accordance with the requirements of NFPA 70, National Electrical Code ®.5.4.5* Static Electricity Hazards.5.4.5.1 Static Accumulation. When processes or conditions exist where the materials in process are able to an explosive mixture is able to be ignited by static electricity with an intensity capable of propagating ignition, means shall be provided to prevent the accumulation hazardous levels of a static charge.5.4.5.2 Static control. The working area where screening, grinding, blending and other processing of static-sensitive explosive materials is done shall be provided with approved static controls.5.4.6 Ventilation. Mechanical ventilation systems shall be in accordance with NFPA 5000 and the Mechanical Code.5.4.6.1 Local Exhaust. Local exhaust systems shall be provided to collect and remove moisture and odors, fumes, smoke, gas, mist, heat, dust, or other materials that are in present in quantities that irritate or injure occupants above the limits in applicable federal, state, or local regulations.5.4.6.2 Intrinsically safe ventilation system. Exhaust systems shall be in accordance with NFPA 654.5.4.6.2.1 Electric motors. Electrical motors used to power fans or blowers used in the ventilation system shall be located outside of the duct or portion of the system exposed to explosive materials.5.4.6.3 Explosive dust. Explosive dust shall not be exhausted to the atmosphere.5.4.6.3.1 Dust collection. Explosive dust shall be collected using a “wet” collector system or other approved means. Wetting agents shall be compatible with the explosive materials being collected.

5.4.6.3.2 Cleaning of collection systems. Explosive dusts shall be removed from the collection system on a regular basis to prevent overloading and accumulation within the system. The system shall be cleaned at a frequency that eliminates hazardous concentrations of explosive dusts from accumulating in pipes, tubing or ducts.5.5 Operations5.5.1 Posted limits. Personnel and explosive limits shall be posted within each operating building. The posted limits shall be able to be seen by operating personnel or those that inspect operating buildings upon entry.5.5.2 Workstation protection. Workstations shall be separated by distance, barrier or other means that provideequivalent protection.5.5.2.1 Fire. Means shall be provided so that fire in one workstation will not ignite material in the next workstation.5.5.2.2 Shielding. Workstations shall be evaluated to determine the need for operator shielding to protectoperators from the effects of an inadvertent fire or explosion. When determined to be necessary, operators shall be protected by a personnel shield located between the operator and the explosive device or material beingprocessed.5.5.2.2.1 Construction. When provided, shields and supports shall be constructed to a tested design to withstand the effects from the maximum amount of explosive materials for which they are designed.5.5.3 Remote processing. When the type of material and processing warrants, mechanical operations involving the processing of more than 1 pound (0.45 kg) of explosive material shall be performed at isolated stations or atintraplant distances.5.5.3.1 Operator location. When remote processing operations are conducted, operators and controls shall belocated behind barricades or at separation distances that provide operator protection while machinery is operating.5.5.4 Protection against entry of foreign objects. Procedures shall be taken, and equipment shall be designedin a manner that prevents the entry of foreign objects or materials from entering the process in other than acontrolled manner.5.5.5 Equipment repair. Repairs to explosive material processing equipment shall not be undertaken untilprescribed decontamination of the equipment has been performed.5.5.5.1 Supervision. Repair work to be conducted in process areas shall be approved by supervisory personnelbefore repair work commences.5.5.5.2 Examination of repairs. Repaired process equipment shall be examined and tested for operabilitybefore being place back into service. The required testing shall be verified by supervisory personnel.5.5.5.3 Tools. Tools used for repair, construction, cleanup or maintenance in processing areas shall be limited to those described in the operating procedures for the process being operated.5.5.6 Temperature extremes. Process temperatures and surface temperatures of equipment that will be in contact with explosive materials, ingredients or mixtures being processed shall be maintained less than the decomposition temperature of such materials.5.6 Explosive materials testing sites5.6.1 Location. Detonation or ignition of explosive materials shall be performed in isolated areas or areas thathave been designed specifically for the tests to be conducted.5.6.1.1 Personnel protection. Protection shall be provided through the use of barricades, shielding or other means to protect personnel and property from the effects of explosion or ignition of the materials being tested.5.6.1.2 Personal protective equipment. Protective clothing and equipment shall be provided to protect persons engaged in the testing, ignition or detonation of explosive materials.5.6.1.3 Safeguards.5.6.1.3.1 Authorized personnel. Test areas shall be restricted to access by authorized personnel.5.6.1.3.2 Posting. When test areas are located out of doors, areas where explosives are to be ignited shall be provided with means to prevent access by unauthorized personnel.5.6.1.3.3 Warning devices. Warning devices shall be used before igniting or detonating explosive materials in test areas to warn persons from any direction of approach that they are approaching a danger zone.

Also in Chapter 8 add the following:

8.4.1.1 Indoor or outdoor magazines utilized in conjunction with operating buildings shall be in accordance with the requirements of 5.3 and 5.3.4 as applicable.

Annex AA.5.2.4 Approved containers may include those that are non-static generating, non-sparking or otherwise designed in such a manner as to avoid inadvertent ignition of the contained material. Tests or analysis may be required to

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Report on Comments — Copyright, NFPA NFPA 495 determine the acceptability of the container used.A.5.2.5 The disposal of hazardous waste may be further regulated by authorities charged with environmentalprotection, transportation or regulations of the jurisdiction in which the facility operates.A.5.3.1 Tests required for finished goods containing explosive materials in a packaged form suitable for shipment or storage have been established by the U.S. Department of Transportation (DOT) and the Bureau of Alcohol, Tobacco and Firearms (ATF). The tests established for the purposes of shipment do not consider key elements that must be examined in a manufacturing situation. The condition, state, quantity or configuration of the material may vary within the manufacturing process and the hazards of the material may vary accordingly. It is not unusual for the finished materials manufactured to carry a different classification from those of the raw materials used, or the classification assigned as those materials move throughout the manufacturing process. A classification methodology is needed that recognizes the hazards commensurate with the application to the variable physical conditions as well as the potential variation due to the configuration in which the material is found throughout the manufacturing process.

The hazard classification, e.g., Division 1.1, 1.3, etc., of explosive materials when packaged for transportation or storage may be different from the hazard classification for these same materials as the materials are manufactured or moved within a process. The differences may be due to quantity or mass of material present, its physical form, the configuration (or arrangement) in which the material is found as well as other extrinsic or intrinsic factors. An “in-process” hazard classification is used to characterize the hazards of a given material as it exists outside of its packaging within the manufacturing process.

The hazard classification of high explosion hazard is generally considered to be the most severe. Materials that are known to have a high explosion hazard are treated as those that mass explode. The code allows the user either to assume that the material presents a high explosion hazard or to demonstrate that the “in-process” hazard classification is other than a high explosion hazard through documentation, experience with a given process, or by testing.

• An example of a documented method may include explosives that are manufactured to a published Military Standard and procedure or to another established process that is documented by qualified operating procedures. To be qualified the procedure should assign an in-process hazard classification than can be demonstrated, or a high explosion hazard classification may be assumed.

• An example of experience with a given process may include a process, equipment and procedures that have been used by multiple manufacturers over a prolonged period of time so that there is an ample database with which to establish the incident history within the manufacturing process as to the hazards the process poses.

• By testing with an agreed upon protocol an in-process classification may be assigned to one or more steps in the process.

The hazard classification of packaged explosive materials may vary as the material is removed from the original shipping container for use in an assembly operation. Similarly, the hazard classification for materials that are in the process of being formulated may vary and the hazard classification of the bulk form of the material may be quite different from that of the same material in its packaged state. The hazard classification of some materials may be said to be “package dependent” with the hazard character subject to change depending on the type or construction of the packaging used as well as the quantity contained within a given package.

An analogy can be made to that of packaged material with unpackaged materials that are being handled in processing operations through the use of mechanical equipment such as mixing, blending or formulation processes. The quantity of material used, the shape of the containers (or configuration) to include the physical dimensions used may all have a bearing on the hazard classification of the material. The critical mass (critical height, and/or critical diameter) is frequently used as a measure of safety in establishing the parameters of the manufacturing process.

The intrinsic chemical or physical properties of a material alone may establish the hazard character, or the hazard character may be influenced by extrinsic factors such as temperature, pressure, arrangement, or the mechanical aspects of the process operations. Various methods can be used to establish the “in-process” hazard classification for the materials being manufactured or used within the manufacturing process. Some materials may have well established process parameters where the nature of the process and the nature of the formulations have long been known. Other materials or processes to which the materials are exposed may be new, or the methods or equipment in which they are to be manufactured or handled is either new or outside of the established parameters. In all cases, an in-process hazard classification for the material being formulated or used is required. When decisions are made regarding the siting, occupancy or use of a building in which manufacturing occurs it is critical that each step of the process be evaluated so the appropriate in-

process hazard classification is assigned in order that the building location is appropriate and that the area of the building utilized is assigned the proper occupancy classification.

When testing is used to establish the classification tests defined by the Department of Defense (DOD), the Bureau of Alcohol, Tobacco and Fire Arms (ATF), United Nations Transport of Dangerous Goods (UN) or Department of Transportation (DOT) are generally used. Regardless of the specific tests being performed, the protocol as well as the acceptance criteria should be agreed upon between the user and the AHJ. The figures below provide examples of a test protocol in which the in-process hazard classification of materials are established by testing. Figure 1 is used for the in-process classification of substances, and Figure 2 is used for the in-process classification for unpackaged articles.(See Figures on the following pages.)A.5.3.3 The case for separation of Division 1.2 materials represents a special case due to the potential production of hazardous fragments. Un-barricaded operating buildings or magazines containing 1.2 explosives may require additional separation distances than indicated in the tables. Such separation is determined on a case by case basis. Section 5.3.1.1.2 can be used as the authority to engage a third party to assist in this evaluation.A.5.3.2.3.1. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.3.2.3.2. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.3.2.3.3. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.4.5 For guidance on static electricity hazards see NFPA 77, Recommended Practice on Static Electricity.

Changes to Annex E

E.2.5 Informational References add the following:

Speed, Thaddeus, C., “In-Process Hazard Classification of Explosives,” Safety Management Services, Inc., West Jordan, UT, December 2003.

Changes to Chapter 3

3.3.16 Day Box. A Type 3 magazine.3.3.31 Hazardous Material. A chemical or substance that is a physical hazard or health hazard as defined and classified in NFPA 1, whether the material is in usable or waste condition.3.3.32 Health Hazard Material. A chemical or substance classified as a toxic, highly toxic, or corrosive material in accordance with the definitions set forth in NFPA 1.3.3.xx Incompatible Material(s). Materials that, when in contact with each other and outside of the condition of intended use, have the potential to react in a manner that generates heat, fumes, gases or by-products that are hazardous to life and property. A.3.3.xx. Explosive materials are unique in that they contain materials otherwise considered to be incompatible, e.g., fuels and oxidizers that may be in intimate contact with one another. The conditions of containment and the design of the packaging are such that the reaction that occurs between the materials is controlled by the user. On the other hand explosive materials as such are not necessarily compatible with all other materials and means must be taken to ensure that the materials in their manufactured state will not cause unexpected reactions should inadvertent spills or mixing occur.3.3.31 Inhabited Building Distance (IBD). The minimum separation distance between an operating building or magazine containing explosive materials and an inhabitedbuilding.3.3.32 Intermagazine Distance (IMD). The minimum separation distance between magazines.3.3.33 Intraline Distance (ILD) or Intraplant Distance (IPD). The distance to be maintained between any two operating buildings on an explosives manufacturing site atleast one of which contains or is designed to contain explosives or the distance between a magazine and an operating building.3.3.37 Mass Detonate (Mass Explode). Simultaneous detonation or explosion of the total amount or a substantial amount of a quantity of explosive material caused by theexplosion of a unit or part of the explosive material.3.3.39 Minimum separation distance (D0). The minimum separation distance between adjacent buildings occupied in conjunction with the manufacture, transportation, storage, or use of explosive materials where one of the buildings contains explosive materials and the other building does not.3.3.41 Net Explosive Weight (NEW). The weight of explosive material expressed in pounds. The net explosive weight is the aggregate amount of explosive material contained within buildings, magazines, structures or portions thereof, used to establish quantity-distance relationships.

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Report on Comments — Copyright, NFPA NFPA 495 3.3.45 Operating Building. A building utilized in conjunction with the manufacture, transportation, or use of explosive materials. Operating buildings are separated from one another with the use of intraplant or intraline distances.3.3.46 Operating Line. A group of buildings, facilities, or workstations so arranged as to permit performance of the steps in the manufacture of an explosive or in the loading, assembly, modification, and maintenance of ammunition or devices containing explosive materials.3.3.49 Physical Hazard Material. A chemical or substance classified as a combustible liquid, combustible fiber, explosive, flammable cryogen, flammable gas, flammable liquid , flammable solid, organic peroxide, oxidizer, oxidizing cryogen, pyrophoric, unstable (reactive), or water reactive material in accordance with the definitions set forth in thiscode or in NFPA 1.3.3.58 Public Traffic Route. The minimum separation distance between any public street, road, highway, navigable stream, or passenger railroad that is used for through traffic by the general public and a magazine or operating building.3.3.59 Quantity-Distance (Q-D). The quantity of explosive material and separation distance relationships providing protection. These relationships are based on levels of risk considered acceptable for the stipulated exposures and are tabulated in the appropriate Q-D Tables. The separation distances specified afford less than absolute safety. SUBSTANTIATION: Comment is being issued on NFPA 495 Proposals, 495-4, 495-8 and 495-53 as follows: The Automatic Occupant Restraint Council (AORC), of which TRW is a member is of the opinion that NFPA 495 is technically flawed. The AORC was founded in 1965 as the American Seat Belt council to assist in establishing uniform production and quality standards for seat belts. The name was changed to Automotive Occupant Restraints Council (AORC) in 1988 to better represent its diverse membership, which is now international and includes manufacturers and suppliers of air bags, air bag components, and seat belts, as well as automotive seating and interior safety components. The scope of the “code” indicates that the code is applicable to the manufacture, transportation, storage, sale, and use of explosive materials. There are no enforceable requirements provided for the manufacture of explosive materials, which by definition includes devices. Existing Chapters 5 and 6 for Blasting Agents and Water Gel and Emulsion Explosive Materials contain provisions for mixing and blending and what might be viewed as manufacturing operations involving these select materials. There are no general provisions that apply to manufacturing of explosive materials or devices other than the aforementioned materials. NFPA 5000 has been published as NFPA’s Building Construction and Safety Code. It establishes requirements for the construction of buildings to be used for the manufacture of explosive materials as well as for all other buildings. NFPA 1-UFC is NFPA’s Fire Prevention Code. The Fire Prevention Code in Section 65.9.1 refers to NFPA 495 for requirements for the manufacture, transportation, storage, sale and use of explosive materials. NFPA 5000, section 34.3.3.3, establishes the location for buildings containing explosive materials (Protection level 1) and then exempts buildings regulated by NFPA 495. All other construction related provisions have been developed assuming that mass explosion will occur without recognition of variables inherent with the hazard class system now recognized and established by UN/DOT. In not addressing the needs for explosives manufacturing, the code user is not able to plan and design compatible buildings, and there are essentially no enforceable requirements within NFPA’s family of codes that regulate the manufacturing process. In today’s global economy industry must not only plan the construction of facilities carefully, it is to industry’s advantage to standardize on designs that are based on a set of predictable and enforceable requirements. The lack of consensus in NFPA’s codes and standards designed to address the built community works to the disadvantage of industry seeking to engage in responsible manufacturing operations using or manufacturing explosive materials. Recognition of the UN/DOT classification system of hazard classification for this group of materials allows the code to evolve by creating enforceable hazard based provisions. Building utilization is enhanced when the building related controls are appropriate for the occupancy or use intended, but building level controls cannot be reasonably prescribed without first providing a baseline for the regulation of the manufacturing process. By establishing the baseline controls that are to be used within NFPA 495 there will be closure to the issues now raised by the absence of regulatory controls for materials in this high hazard class. The provisions contained in the proposed new Chapter have been drawn in part from the Uniform Fire Code, which has now evolved into NFPA 1-UFC and from good practice recommendations of the Institute of Makers of Explosives (IME). Every effort has been made to address the negative comments issued from committee members during the balloting phase, and the proposed Chapter has been revised to address the concerns. Related annex information has also been expanded and provided in order to better explain the need.

COMMITTEE MEETING ACTION: Accept in Principle Add a new Chapter 5 on Manufacturing and Testing.

Chapter 5 Manufacturing and Testing

5.1 Scope. Manufacture and testing of explosives shall be in accordance with the requirements of this chapter.5.1.1 Blasting agents shall not be subject to the requirements of this chapter (See Chapter 6).5.1.2 Water gels, slurries, and emulsion explosives shall not be subject to the requirements of this chapter (See Chapter 7).5.2 General Requirements.5.2.1 Emergency Procedures. Emergency procedures shall be developed for each manufacturing facility.5.2.2 Posting of pertinent information. Standard operating procedures governing the manufacturing process shall be located at workstations where the work is to be conducted.5.2.3 Training. Persons handling explosive materials or working in operating buildings shall be trained in accordance with Sections 5.2.3.1 through 5.2.3.5.5.2.3.1 The physical and health hazards of the explosive materials to be manufactured.5.2.3.2 The operational activities involved in processing the materials to include instructions in emergencies that are anticipated in the manufacturing process.5.2.3.3 The operating rules applicable to the materials in the manufacturing process.5.2.3.4 Plans for emergency procedures in the event of a fire or explosion.5.2.3.5 Personnel shall be made aware of emergency warning signals and actions to take in the event the warning signal is activated.5.2.3.6 Contract personnel working in explosive manufacturing areas shall be instructed on site specific operating procedures, emergency procedures, hot work operations and procedures applicable to the area prior to engaging in any activity whether maintenance related or not.5.2.3.7 Visitors entering operational areas shall receive orientation training and shall be accompanied by a trained escort.5.2.4* Containers. Bulk explosive materials shall be stored in approved containers when not in use.5.2.5* Waste. When waste receptacles are provided for the collection of waste materials and debris, such waste receptacles shall be approved and equipped with covers.5.2.5.1 Emptying waste containers. Waste receptacles shall be emptied and cleaned in accordance with operating procedures.5.2.5.2 Collection of spilled material. Spilled or dropped explosive materials which are spilled outside of designated containment or confinement zones shall be collected promptly for disposal or disposition and the area in which the materials were spilled shall be cleaned.5.2.5.3 Contaminated materials. Cleaning materials or materials that have been contaminated with explosive materials shall be removed daily and disposed of in an approved manner.5.2.5.3.1 Shipping containers. Shipping containers used for explosive materials shall be allowed to be retained for reuse as required.5.2.6 Maintenance. Non-routine maintenance and repair work shall not be performed in an explosive manufacturing area until clean-up and decontamination have been performed as required by operating procedures.5.2.6.1 Repair work. Maintenance and repair that is not addressed by the operating procedures shall be reviewed and approved by supervisory personnel prior to conducting the work.5.2.7 Ignition source control.5.2.7.1 Smoking. Smoking shall be prohibited on the plant site, except where notices permitting it are posted.5.2.7.2 Flame producing devices. Matches, torches or other flame-producing devices shall be prohibited from being taken into explosives manufacturing areas without a written permit signed by an authorized supervisor.5.2.7.3* Portable electrical and electronic equipment. Portable electrical and electronic equipment shall be permitted only when designated by the manufacturing process and incorporated into the operating instructions described in Section 5.2.2.A.5.2.7.3 In determining equipment that is appropriate to be included management should be aware that there is a wide variety of electronic equipment employed today including hearing aids, writing instruments, communication devices, etc. Procedures for acceptance should consider devices other than portable tools, which has been the traditional point of control.5.2.8 Clothing.5.2.8.1 Type of clothing. Clothing to be worn by persons involved in the manufacturing process shall be of a type approved by management.5.2.8.2 Accessories. Watches, jewelry, finger rings, earrings, and items intended for use as accessories shall not be worn in manufacturing areas where explosive materials are manufactured.5.2.8.3 Contaminated clothing. Persons wearing clothing that has been contaminated with explosive materials shall not be permitted to enter areas where smoking is permitted or where operations involving the use of open flame or open ignition sources are present.5.2.9 Clearance from combustibles. The area within 25 feet (7.6 m) of

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Report on Comments — Copyright, NFPA NFPA 495 operating buildings shall be kept clear of combustible materials.5.2.10 Limited access by authorized personnel. Manufacturing areas shall be secured against unauthorized entry with access limited to that necessary for the performance of operating functions.5.2.11 Separation of incompatible materials. Incompatible materials in storage and storage of materials incompatible with materials in use shall be separated by one of the following methods:5.2.11.1 Segregating incompatible materials storage from use by a distance of not less than 20 ft (6.1m)5.2.11.2 Isolating incompatible materials in storage by a noncombustible partition extending not less than 18 in (46 cm) above and to the sides of the stored material.5.2.11.3 Storing liquid and solid materials in hazardous materials storage cabinets complying with NFPA 1.5.2.12 Housekeeping.5.2.12.1 Floors. Floors of manufacturing areas shall be swept or otherwise maintained to prevent the accumulation of explosive materials.5.2.12.2 Tools and equipment. Tools and equipment shall be kept in designated areas when not in use during manufacturing operations.5.2.13 Hot work. Hot work operations shall be conducted in accordance with the requirements of NFPA 1.5.2.13.1 Management. Management shall be responsible for the supervision of hot work activity.5.2.13.2 Permits. Permits to conduct hot work operations shall be required.5.3 Classification and characterization of energetic materials used in process operations.5.3.1* In-process hazard classification. Explosive materials being processed shall be classified with an in-process hazard classification based on the hazards of the material in the configuration and quantity employed.5.3.1.1 High explosion hazard. The classification of materials that have not been established by testing or those where the quantity or configuration used exhibit a high explosion hazard shall be classified as a high explosion hazard.5.3.1.1.1 Materials of known character or composition in the configuration and quantity specific to the process where the in-process hazard classification is approved by the authority having jurisdiction shall be allowed to be classified as other than a high explosion hazard.5.3.1.1.2 Physical hazards established by testing. When testing is performed, the test methods shall be those established by DOD, ATF, UN/DOT or other approved criteria.5.3.1.1.2 Technical assistance. The AHJ shall be permitted to require a review by an independent third party with expertise in the matter to be reviewed at the submitter’s expense.5.3.1.2 Health hazard classification. The health hazards of materials used in the manufacturing process shall be determined in accordance with the requirements of NFPA 1. In addition to physical hazards that are present, materials classified as toxic, highly toxic or corrosive materials shall be classified as health hazards.5.3.1.3 Multiple Hazards. Materials that have multiple hazards shall conform to the Code requirements for each applicable hazard category specified.5.3.2 Quantity of Explosives. The quantity-distance (Q-D) tables in Section 5.3.3 shall be used to provide minimum distances from potential explosion sites. The classification of the explosives and the weight of the explosives are primary characteristics governing the use of these tables. The net explosive weight shall be determined in accordance with Sections 5.3.2.1 through 5.3.2.4.5.3.2.1 Mass explosion hazards. Division 1.1or 1.2 explosives. The total net explosive weight shall be used.See Table 5.3.3(a) for operating buildings, and Table 9.4.1 for all other cases.

5.3.2.1.1 When the TNT equivalence of the explosive material has been determined, the equivalence is allowed to be used to establish the net explosive weight.5.3.2.2 Non-mass explosion hazards (excluding Division 1.4).5.3.2.2.1 Division 1.3 propellants. The total weight of the propellants alone is the net explosive weight. The net weight of the propellants shall be used. See Table 5.3.3(b).5.3.2.2.2 Combinations of bulk metal powder and pyrotechnic compositions. The sum of the net weights of metal powders and pyrotechnic compositions in the containers shall be used.5.3.2.3 Combinations of mass explosion and non-mass explosion hazard explosives (excluding Division 1.4).5.3.2.3.1* When Division 1.1 and 1.2 explosives are located in the same site, determine the distances for the total quantity first as 1.1 and then as 1.2. The required distance is the greater of the two. When the Division 1.1 requirements are controlling and the TNT equivalence of the 1.2 is known, the TNT equivalent weight of the 1.2 items shall be added to the total explosive weight of Division 1.1 items to determine the net explosive weight of explosives for Division 1.1 distance determination. See Table 5.3.3(a) or 5.3.3(b) as applicable.5.3.2.3.2* When Division 1.1 and 1.3 explosives are located in the same site determine the distances for the total quantity first as 1.1 and then as 1.3. The required distance is the greater of the two. When the division 1.1 requirements are controlling and the TNT equivalence of the 1.3 is known, the TNT equivalent weight of the 1.3 items shall be added to the total explosive weight of Division 1.1 items to determine the net explosive weight of explosives for division 1.1 distance determination. See Tables 5.3.3(a) or 5.3.3(b) as applicable.5.3.2.3.3* When Division 1.1, 1.2 and 1.3 explosives are located in the same site, determine the distances for the total quantity first as 1.1, next as 1.2 and finally as 1.3. The required distance is the greatest of the three. As permitted by Sections 5.3.2.3.1 and 5.3.2.3.2 above, TNT equivalent weights for 1.2 and 1.3 items are allowed to be used to determine the net weight of explosives for Division 1.1 distance determination. Table 5.3.3(a) or 5.3.3(b) shall be used when TNT equivalency is used to establish the net explosive weight.5.3.2.4 Combinations of non-mass-exploding ammunition and explosives of different Divisions shall be treated as follows.5.3.2.4.1. Determine the required separation for each division.5.3.2.4.2. Use the greatest separation of those determined.5.3.3* Separation of operating buildings. Operating buildings, including those where explosives are assembled, manufactured, prepared or loaded utilizing Division 1.1, 1.2, 1.3, or 1.4 explosives, shall be separated from all other operating buildings, magazines, inhabited buildings, public highways, and passenger railways at a distance not less than those shown in Tables 9.4.1, 5.3.3(a), 5.3.3(b), or 5.3.3(c) as applicable. Distances to assumed property lines drawn for the purposes of determination of exterior wall and opening protection under the requirements of the Building Code shall not be used to establish the minimum distance for separation between buildings on an operating line.5.3.3.1 The minimum separation distance (D

0) required by footnote c to Table

5.3.3(a) shall be allowed to be reduced to less than 60 ft (m) when the fire-resistance of exterior walls and protection of wall openings is in accordance with the building code.

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Table 5.3.3(a)MINIMUM INTRALINE (INTRAPLANT) SEPARATION DISTANCES (ILD or IPD) BETWEEN BARRICADED

OPERATING BUILDINGS CONTAINING EXPLOSIVES – DIVISION 1.1 or 1.2 – MASS EXPLOSION HAZARD a, b, c

NET EXPLOSIVE WEIGHT NET EXPLOSIVE WEIGHTPounds over Pounds not over Intraline dis-

tance (ILD) or

Intraplant distance (IPD)

(feet)

Pounds over Pounds not over Intraline distance(ILD) or Intraplant dis-

tance (IPD) (feet)

2 5 16 12000 14000 2205 10 20 14000 16000 23010 20 25 16,000 18,000 23820 30 28 18,000 20,000 24530 40 31 20,000 25,000 26540 50 34 25,000 30,000 28050 75 38 30,000 35,000 29575 100 42 35,000 40,000 310100 125 45 40,000 45,000 320125 150 48 45,000 50,000 330150 200 53 50,000 55,000 340200 250 57 55,000 60,000 350250 300 60 60,000 65,000 360300 400 66 65,000 70,000 370400 500 71 70,000 75,000 380500 600 76 75,000 80,000 390600 700 80 80,000 85,000 395700 800 84 85,000 90,000 400800 900 87 90,000 95,000 410900 1,000 90 95,000 100,000 420

1,000 1200 96 100,000 110,000 4301200 1400 101 110,000 120,000 4451,400 1600 106 120,000 130,000 4551600 1800 110 130,000 140,000 4651800 2000 113 140,000 150,000 4752,000 2500 122 150,000 160,000 4852500 3000 130 160,000 170,000 4953,000 4,000 143 170,000 180,000 5054,000 5,000 154 180,000 190,000 5155,000 6,000 164 190,000 200,000 5256,000 7,000 172 200,000 210,000 5357,000 8,000 180 210,000 230,000 5558,000 9,000 190 230,000 250,000 5759,000 10,000 200 250,000 275,000 60010,000 12000 210 275,000 300,000 635

a. Where a building or magazine containing explosives is not barricaded, the intraline distances shown in this table shall be doubled.b. Linear interpolation between tabular values shall not be allowed. Non-linear interpolation of the values shall be allowed sub-ject to an approved technical opinion and report prepared in accordance with the requirements of NFPA 1.c. Do shall be a minimum of 60 feet. Where a building or magazine containing explosives is barricaded, the minimum distance shall be 30 feet.

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TABLE OF DISTANCES (Q-D) FOR BUILDINGSCONTAINING EXPLOSIVES – DIVISION 1.3

MASS FIRE HAZARDa,b,c

QUANTITY OF DISTANCES IN FEET

DIVISION 1.3

EXPLOSIVES

(Net Explosive Weight)

Pounds over

Pounds not over Inhabited buildings

distance IBD

Distance to public traffic route (PTR)

Intermagazine distance (IMD)

Intraline distance (ILD) or Intraplant distance

(IPD)d

0 1,000 75 75 50 50

1,000 5,000 115 115 75 75

5,000 10,000 150 150 100 100

10,000 20,000 190 190 125 125

20,000 30,000 215 215 145 145

30,000 40,000 235 235 155 155

40,000 50,000 250 250 165 165

50,000 60,000 260 260 175 175

60,000 70,000 270 270 185 185

70,000 80,000 280 280 190 190

80,000 90,000 295 295 195 195

90,000 100,000 300 300 200 200

100,000 200,000 375 375 250 250

200,000 300,000 450 450 300 300

a. Black powder, when stored in magazines, is defined as low explosive by the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF).b. For quantities less than 1,000 pounds, the required distances are those specified for 1,000 pounds. The user of lesser distances shall be permitted when supported by test data and/or analysis.c. Linear interpolation of explosive quantities between table entries is permitted.d. Do shall be a minimum of 50 feet.

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TABLE OF DISTANCES (Q-D) FOR BUILDINGSCONTAINING EXPLOSIVES – DIVISION 1.4c,d

QUANTITY OFDIVISION 1.4EXPLOSIVES

DISTANCES IN FEETQUANTITY OF DISTANCES IN FEET

DIVISION 1.4

EXPLOSIVES

(Net Explosives Weight)

Pounds over Pounds not over

Inhabited buildings distance IBD

Distance to public traffic route (PTR)

Intermagazine distance a,b (IMD)

Intraline distance (ILD) or

Intraplant distance (IPD)a, e

50 Not 100 100 50 50

Limited

a. A separation distance of 100 feet is required for buildings of other than Type I and II construction as defined in NFPA 5000.b. For earth-covered magazines, no specified separation is required.c. restricted to articles, including articles packaged for shipment, that are not regulated as an explosive by Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regulations, or to unpacked articles used in process operations that do not propagate a detonation or deflagration between articles.d. Linear interpolation between tabular values is not applicable.e. Do shall be a minimum of 50 feet.

5.3.4 Determination of net explosive weight for operating buildings. In addition to the requirements of Section 5.3.2 to determine the net explosive weight for materials stored or used in operating buildings, quantities of explosives materials stored in magazines located at distances less than intraline distances from the operating building shall be added to the contents of the operating building to determine the net explosive weight for the operating building.5.3.4.1 Indoor magazines. The storage of explosive materials located in indoor magazines in operating buildings shall be limited to a net explosive weight not to exceed 50 pounds.5.3.4.2 Outdoor magazines with a net explosive weight less than 50 pounds. The storage of explosive materials in outdoor magazines located at less than intraline distances from operating buildings shall be limited to a net explosive weight not to exceed 50 pounds.5.3.4.3 Outdoor magazines with a net explosive weight greater than 50 pounds. The storage of explosive materials in outdoor magazines in quantities exceeding 50 pounds net explosive weight shall be limited to storage in outdoor magazines located not less than intraline distances from the operating building in accordance with Section 5.3.3.5.3.4.4 Net explosive weight of materials stored in combination indoor and outdoor magazines. The aggregate quantity of explosive materials stored in any combination of indoor magazines or outdoor magazines located at less than the intraline distances from an operating building shall not exceed 50 pounds.5.4 Buildings and Equipment5.4.1 Construction. Operating buildings shall be constructed in accordance with the requirements of NFPA5000.5.4.1.1 Location. Operating buildings shall be located in accordance with Section 5.3.3 based on the net explosive weight of materials contained.

5.4.2 Plans. A copy of the construction plans shall be kept on the premises of the manufacturing site and shall be provided to the authority having jurisdiction upon request.5.4.3 Means of Egress. Obstructions, including storage, shall not be placed in the required width of a means of egress, except projections as allowed by the Building Code. Means of egress shall not be obstructed in any manner and shall remain free of any material or matter where its presence would obstruct or render the means of egress hazardous.5.4.3.1 Maintenance of Exits. The required fire-resistive rating of walls, ceilings and openings that are part of a means of egress shall be maintained.5.4.3.2 Locking of Exits. Exits throughout operating buildings shall be unlocked and verified operable before operations are begun.5.4.4 Electrical wiring and equipment.5.4.4.1 Electrical wiring and equipment shall be installed in accordance with NFPA 70, National Electrical Code ®.5.4.4.2 Bonding and grounding.5.4.4.2.1 The non-current-carrying metal parts of electrical equipment including electric motors, generators, proportioning devices, and other electrical enclosures serving individual manufacturing processes shall be electrically bonded together in accordance with the requirements of NFPA 70, National Electrical Code ®.5.4.4.2.2 Where the electrical system is required to be grounded, the grounding conductors shall be connected together and to the supply system grounded conductor in accordance with the requirements of NFPA 70, National Electrical Code ®.5.4.5* Static Electricity Hazards.5.4.5.1 Static Accumulation. When processes or conditions exist where the materials in process are able to be ignited by static electricity with an intensity

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Report on Comments — Copyright, NFPA NFPA 495 capable of propagating ignition, means shall be provided to prevent the accumulation of hazardous levels of static charge.5.4.5.2 Static control. The working area where screening, grinding, blending and other processing of static sensitive explosive materials is done shall be provided with approved static controls.5.4.6 Ventilation. Mechanical ventilation systems shall be in accordance with NFPA 5000 and the Uniform Mechanical Code.5.4.6.1 Local Exhaust. Local exhaust systems shall be provided to collect and remove moisture and odors, fumes, smoke, gas, mist, heat, dust, or other materials that are in present in quantities above the limits in applicable federal, state, or local regulations.5.4.6.2 Electric motors. Electrical motors used to power fans or blowers used in the ventilation system shall be located outside of the duct or portion of the system exposed to explosive materials.5.4.6.3 Explosive dust. Explosive dust shall not be exhausted to the atmosphere.5.4.6.3.1 Dust collection. Explosive dust shall be collected using a “wet” collector system or other approved means. Wetting agents shall be compatible with the explosive materials being collected.5.4.6.3.2 Cleaning of collection systems. Explosive dusts shall be removed from the collection system on a regular basis to prevent overloading and accumulation within the system. The system shall be cleaned at a frequency that eliminates hazardous concentrations of explosive dusts from accumulating in pipes, tubing or ducts.5.5 Operations5.5.1 Posted limits. Personnel and explosive limits shall be posted within each operating building. The posted limits shall be able to be seen by operating personnel or those that inspect operating buildings upon entry.5.5.2 Workstation protection. Workstations shall be separated by distance, barrier or other means that provide equivalent protection.5.5.2.1 Fire. Means shall be provided so that fire in one workstation will not ignite material in the next workstation.5.5.2.2 Shielding. Workstations shall be evaluated to determine the need for operator shielding to protect operators from the effects of an inadvertent fire or explosion. When determined to be necessary, operators shall be protected by a personnel shield located between the operator and the explosive device or material being processed.5.5.2.2.1 Construction. When provided, shields and supports shall be constructed to withstand the effects from the maximum amount of explosive materials for which they are designed.5.5.3 Remote processing. When the type of material and processing warrants, mechanical operations involving the processing of more than 1 pound (0.45 kg) of explosive material shall be performed at isolated stations or at intraplant distances.5.5.3.1 Operator location. When remote processing operations are conducted, operators and controls shall be located behind barricades or at separation distances that provide operator protection while machinery is operating.5.5.4 Protection against entry of foreign objects. Procedures shall be taken, and equipment shall be designed in a manner that prevents the entry of foreign objects or materials from entering the process in other than a controlled manner.5.5.5 Equipment repair. Repairs to explosive material processing equipment shall not be undertaken until prescribed decontamination of the equipment has been performed.5.5.5.1 Supervision. Repair work to be conducted in process areas shall be approved by supervisory personnel before repair work commences.5.5.5.2 Examination of repairs. Repaired process equipment shall be examined and tested for operability before being place back into service. The required testing shall be verified by supervisory personnel.5.5.5.3 Tools. Tools used for repair, construction, cleanup or maintenance in processing areas shall be limited to those described in the operating procedures for the process being operated.5.5.6 Temperature extremes. Process temperatures and surface temperatures of equipment that will be in contact with explosive materials, ingredients or mixtures being processed shall be maintained less than the decomposition temperature of such materials.5.6 Explosive materials testing sites5.6.1 Location. Detonation or ignition of explosive materials shall be performed in isolated areas or areas that have been designed specifically for the tests to be conducted.5.6.1.1 Personnel protection. Protection shall be provided through the use of barricades, shielding or other means to protect personnel and property from the effects of explosion or ignition of the materials being tested.5.6.1.2 Personal protective equipment. Protective clothing and equipment shall be provided to protect persons engaged in the testing, ignition or detonation of explosive materials.5.6.1.3 Safeguards.5.6.1.3.1 Authorized personnel. Test areas shall be restricted to access by authorized personnel.5.6.1.3.2 Posting. When test areas are located out of doors, areas where explosives are to be ignited shall be provided with means to prevent access by unauthorized personnel.5.6.1.3.3 Warning devices. Warning devices shall be used before igniting or detonating explosive materials in test areas to warn persons from any direction

of approach that they are approaching a danger zone.

Also in Chapter 8 add the following:

8.4.1.1 Indoor or outdoor magazines utilized in conjunction with operating buildings shall be in accordance with the requirements of 5.3 and 5.3.4 as applicable.

Annex A

A.5.2.4 Approved containers include those that are non-static generating, non-sparking or otherwise designed in such a manner as to avoid inadvertent ignition of the contained material. Tests or analysis may be required to determine the acceptability of the container used.

A.5.2.5 The disposal of hazardous waste might be further regulated by authorities charged with environmental protection, transportation or regulations of the jurisdiction in which the facility operates.

A.5.3.1 The hazard classification, e.g., Division 1.1, 1.3, etc., of explosive materials when packaged for transportation or storage could be different from the hazard classification for these same materials as the materials are manufactured or moved within a process. The differences can be due to quantity or mass of material present, its physical form, the configuration (or arrangement) in which the material is found as well as other extrinsic or intrinsic factors. An “in-process” hazard classification is used to characterize the hazards of a given material as it exists outside of its packaging within the manufacturing process.

The hazard classification of high explosion hazard is generally considered to be the most severe. Materials that are known to have a high explosion hazard are treated as those that mass explode. The code allows the user either to assume that the material presents a high explosion hazard or to demonstrate that the “in-process” hazard classification is other than a high explosion hazard through documentation, experience with a given process, or by testing.

• An example of a documented method can include explosives that are manufactured to a published Military Standard and procedure or to another established process that is documented by qualified operating procedures. To be qualified the procedure should assign an in-process hazard classification than can be demonstrated, or a high explosion hazard classification may be assumed.

• An example of experience with a given process can include a process, equipment and procedures that have been used by multiple manufacturers over a prolonged period of time so that there is an ample database with which to establish the incident history within the manufacturing process as to the hazards the process poses.

• By testing with an agreed upon protocol an in-process classification can be assigned to one or more steps in the process.

The hazard classification of packaged explosive materials might vary as the material is removed from the original shipping container for use in an assembly operation. Similarly, the hazard classification for materials that are in the process of being formulated might vary and the hazard classification of the bulk form of the material can be quite different from that of the same material in its packaged state. The hazard classification of some materials can be said to be “package dependent” with the hazard character subject to change depending on the type or construction of the packaging used as well as the quantity contained within a given package.

An analogy can be made to that of packaged material with unpackaged materials that are being handled in processing operations through the use of mechanical equipment such as mixing, blending or formulation processes. The quantity of material used, the shape of the containers (or configuration) to include the physical dimensions used can all have a bearing on the hazard classification of the material. The critical mass (critical height, and/or critical diameter) is frequently used as a measure of safety in establishing the parameters of the manufacturing process.

The intrinsic chemical or physical properties of a material alone might establish the hazard character, or the hazard character can be influenced by extrinsic factors such as temperature, pressure, arrangement, or the mechanical aspects of the process operations. Various methods can be used to establish the “in-process” hazard classification for the materials being manufactured or used within the manufacturing process. Some materials might have well established process parameters where the nature of the process and the nature of the formulations have long been known. Other materials or processes to which the materials are exposed could be new, or the methods or equipment in which they are to be manufactured or handled is either new or outside of the established parameters. In all cases, an in-process hazard classification for the material being formulated or used is required. When decisions are made regarding the siting, occupancy or use of a building in which manufacturing occurs it is critical that each step of the process be evaluated so the appropriate in-process hazard classification is assigned in order that the building location

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Report on Comments — Copyright, NFPA NFPA 495 is appropriate and that the area of the building utilized is assigned the proper occupancy classification.

When testing is used to establish the classification tests defined by the Department of Defense (DOD), the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), United Nations Transport of Dangerous Goods (UN) or Department of Transportation (DOT) are generally used. Regardless of the specific tests being performed, the protocol as well as the acceptance criteria should be agreed upon between the user and the AHJ. The figures below provide examples of a test protocol in which the in-process hazard classification of materials are established by testing. Figure 1 is used for the in-process classification of substances, and Figure 2 is used for the in-process classification for unpackaged articles. (See Figures 1 and 2 on the following pages.)A.5.3.3 The case for separation of Division 1.2 materials represents a special case due to the potential production of hazardous fragments. Un-barricaded operating buildings or magazines containing 1.2 explosives might require additional separation distances than indicated in the tables. Such separation is determined on a case by case basis. Section 5.3.1.1.2 can be used as the authority to engage a third party to assist in this evaluation.A.5.3.2.3.1. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.3.2.3.2. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.3.2.3.3. When TNT equivalency is used the highest TNT equivalency measured on impulse or overpressure should be used as the basis to determine quantity.A.5.4.5 For guidance on static electricity hazards see NFPA 77, Recommended Practice on Static Electricity.

Changes to Annex E

E.2.5 Informational References add the following:Speed, Thaddeus, C., “In-Process Hazard Classification of Explosives,” Safety Management Services, Inc., West Jordan, UT, December 2003.

Changes to Chapter 3

3.3.16 Day Box. A Type 3 magazine.3.3.31 Hazardous Material. A chemical or substance that is a physical hazard or health hazard as defined and classified in NFPA 1, whether the material is in usable or waste condition.3.3.32 Health Hazard Material. A chemical or substance classified as a toxic, highly toxic, or corrosive material in accordance with the definitions set forth in NFPA 1.3.3.xx Incompatible Material(s). Materials that, when in contact with each other and outside of the condition of intended use, have the potential to react in a manner that generates heat, fumes, gases or by-products that are hazardous to life and property. A.3.3.xx. Explosive materials are unique in that they contain materials otherwise considered to be incompatible, e.g., fuels and oxidizers that may be in intimate contact with one another. The conditions of containment and the design of the packaging are such that the reaction that occurs between the materials is controlled by the user. On the other hand explosive materials as such are not necessarily compatible with all other materials and means must be taken to ensure that the materials in their manufactured state will not cause unexpected reactions should inadvertent spills or mixing occur.3.3.32 Intermagazine Distance (IMD). The minimum separation distance between magazines.3.3.33 Intraline Distance (ILD) or Intraplant Distance (IPD). The distance to be maintained between any two operating buildings on an explosives manufacturing site at least one of which contains or is designed to contain explosives or the distance between a magazine and an operating building.3.3.37 Mass Detonate (Mass Explode). Simultaneous detonation or explosion of the total amount or a substantial amount of a quantity of explosive material caused by the explosion of a unit or part of the explosive material.3.3.39 Minimum separation distance (D0). The minimum separation distance between adjacent buildings occupied in conjunction with the manufacture, transportation, storage, or use of explosive materials where one of the buildings contains explosive materials and the other building does not.3.3.41 Net Explosive Weight (NEW). The weight of explosive material expressed in pounds. The net explosive weight is the aggregate amount of explosive material contained within buildings, magazines, structures or portions thereof, used to establish quantity-distance relationships.3.3.45 Operating Building. A building utilized in conjunction with the manufacture, transportation, or use of explosive materials. Operating buildings are separated from one another with the use of intraplant or intraline distances.

3.3.46 Operating Line. A group of buildings, facilities, or workstations so arranged as to permit performance of the steps in the manufacture of an explosive or in the loading, assembly, modification, and maintenance of ammunition or devices containing explosive materials.3.3.49 Physical Hazard Material. A chemical or substance classified as a combustible liquid, combustible fiber, explosive, flammable cryogen, flammable gas, flammable liquid, flammable solid, organic peroxide, oxidizer, oxidizing cryogen, pyrophoric, unstable (reactive), or water reactive material in accordance with the definitions set forth in this code or in NFPA 1.3.3.59 Quantity-Distance (Q-D). The quantity of explosive material and separation distance relationships providing protection. These relationships are based on levels of risk considered acceptable for the stipulated exposures and are tabulated in the appropriate Q-D Tables. The separation distances specified afford less than absolute safety.COMMITTEE STATEMENT: The Committee made some editorial modifications to the proposed chapter. One technical change was to not accept the recommended text as proposed in 5.4.6.2 since this was to incorporate a reference to NFPA 654 for exhaust system design. The application section of NFPA 654 excludes applicability to explosives, so including this provision in NFPA 495 would not be appropriate. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 17 Negative: 2 BALLOT NOT RETURNED: 2 FRY, VILLA EXPLANATION OF NEGATIVE: DAHN: I do not believe using UN/DoT test protocols will provide adequate safety in in-process materials and conditions. RHEA: My name is Richard Rhea and I am a recently appointed member of the EXP-AAA Technical Committee. I was appointed after the last committee meeting and therefore do not have the benefit of the discussions involved. I respectfully vote NEGATIVE on Comment 495-2 Log No 11. I believe there are serious flaws that need to be readdressed in a Technical Committee meeting. While some of these flaws are structural, I will only list some of the technical reasons for my negative vote here per the ballot instructions. This document is too important to the explosives manufacturing industry to not be clear. I would be glad to discuss my concerns with any member of the Technical Committee. Some of my technical reasons for voting negative include: 1. Section 5.2.2. SOPs need to be available to applicable personnel, just as MSDSs and other pertinent information needs to be available. Requiring that information to be a “posting” or “at workstations” is not necessary. Computer availability of reference information should be acceptable and computers are not available at all workstations. 2. Section 5.2.3.6. “Contract personnel” may include: production operators contracted from a labor service, on-site maintenance contractors, or contracted construction personnel. This section must be clear on who is included in which requirement. 3. Section 5.2.5. I do not know why covers would be required on waste receptacles. 4. Section 5.2 6. “Operating procedures” in my company do not include routine maintenance and repair. We have other procedures that deal with that. The word “Operating” should be deleted. 5. Section 5.2.7.1 “Plant site” is nebulous. Is an administrative building outside controlled access operating areas included? This must be clearer. 6. Section 5.2.7.2 This and all other sections applying to hot work permits should be combined and consistent. 7. Section 5.2.8.2. I don’t believe restricting rings, watches, etc., is common practice in the explosives manufacturing industry, nor is it necessary. 8. Section 5.2.9. This is far too ambiguous a statement to include. A regulator could interpret this as “no paper in to be within 25 feet of an operating building. 9. Section 5.2.10. Limiting access to those “necessary for the performance of operating functions” is not necessary and inappropriate. This could mean the plant safety manager could not enter manufacturing areas! 10. Section 5.2.11. The list of methods is over restrictive. The separation practice is good, but methods need not be listed. 11. Section 5.2.13.1. This could be interpreted as constant active visual control by supervision. This is not necessary. Also see my comment 6. 12. Table 5.3.3(b). I don’t know the rationale for stopping at 300,000 pounds. If it is because of a BATF limit, realize some explosives are exempt from BATF requirements such as propellants for small arms ammunition. 13. Section 5.4.3. “The Building Code” is not appropriate wording. Neither is the word “obstructed” appropriate. 14. Section 5.4.3.2. “Verified operable” is not necessary. 15. Section 5.5.2. Separation of workstations is not always possible. I respectfully reserve additional comments and concerns that may come up with additional review, study, and discussion.

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Test Series 1(Required fundamental processing and handling tests)Impact Sensitivity TestFriction Sensitivity TestESD Sensitivity TestThermal Stability Test

Test Series 3Small-Scale Burning Test#8 Cap TestNOL Card Gap TestKoenen TestTime/Pressure Test

Test Series 4Appropriate Process/Equipment Simulationand/or:Critical Diameter TestCritical Height (Mass) TestVenting Parameters:(Internal Ignition 10-gram bag and/or Koenen Test)

1.

2.a

3.

4.

5.

2.b

Test Series 2UN/DOT Zero Gap Test orNOL Zero Card Gap TestInternal Ignition 20-gram bag

PerformTest Series 2

(special precautions for very sensitive

materials)

Is the bulk material very

sensitive?

Is the process designed

to maintain material response to less than

mass explosion hazard?

Is material hazard a mass

explosion (1.1)?

Is the bulk material

explosive?

Is the bulk material

explosive?

Not an explosive hazard

(Not Class 1)

Mass fire hazard(with engineered controls)

(1.3)

The material is Class 1

Assume a mass explosion (1.1) hazard?

Mass/high explosion hazard

(1.1)

No

No

No

Yes Yes

No

No

No

Yes

Yes

Yes

Yes

PerformTest Series 1

PerformTest Series 2

PerformTest Series 3

PerformTest Series 4

Figure 1

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Test Series 5(Required fundamental processing and handling tests)Drop TestThermal Stability Test

1.

2.Test Series 6Worst-Case Propagation TestExternal Fire Test

Is the unfinished article very sensitive?

Did either test result in a mass

explosion?

Did either test result in a mass

fire hazard?

Did either test result in a fragment

hazard?

Mass fire hazard(1.3)

Mass/high explosion hazard

(1.1)

No mass reaction hazard

(1.4)

No

No

No

No

Yes

Fragmentation hazard(1.2)

Yes

Yes

Yes

PerformTest Series 5

PerformTest Series 6

Figure 2

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Report on Comments — Copyright, NFPA NFPA 495 _______________________________________________________________ 495-3 Log #12 Final Action: Reject (Entire Document) ________________________________________________________________ SUBMITTER: Larry Fluer, Fluer, Inc. COMMENT ON PROPOSAL NO: 495-4 RECOMMENDATION: Insert new text as follows: 1.3.7 This code shall not apply to the manufacture of explosive materials or devices other than those operations regulated by Chapters 5 and 6. SUBSTANTIATION: NFPA 495 does not provide enforceable hazard based requirements for the manufacture of explosive materials. There are requirements that pertain to the mixing and blending of blasting agents and for water gel and emulsion explosive materials; but there are no general provisions in the code that address the manufacture of explosives. The inclusion of term “manufacturing” in the scope of the code is misleading to the public and to regulatory authority. Until such time as explosives manufacturing is regulated by the code it should be exempted from the provisions. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The Committee approved the addition of requirements for manufacturing explosives applicable to other than water gels, slurries, emulsions, and blasting agents. The recommendation submitted in this proposal would be to act in a way that would be inconsistent with the Committee’s action to include these new requirements. See Committee Action on Public Comment 495-2 (Log #11). NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA COMMENT ON AFFIRMATIVE FLUER: The action of the committee to reject the proposal is supported with the proviso that Comment No. 495-2 which was voted during the ROC meeting to Accept in Principle passes the committee ballot. If for some reason Comment No. 495-2 does not garner sufficient votes in the letter ballot, then Comment No. 495-3 should be accepted in order to clarify the committee position for manufacturing of explosive materials. NICHOLS: TRW supports the committee’s action to reject this recommendation based on the committee’s action to Accept in Principle, Proposal 495-3 which, when approved, will add a new chapter on Manufacturing and Testing. _______________________________________________________________ 495-4 Log #10 Final Action: Accept in Principle (New Chapter) ________________________________________________________________ SUBMITTER: James Everitt, Western Regional Fire Code Development Committee COMMENT ON PROPOSAL NO: 495-4 RECOMMENDATION: Reconsider the original text and accept. SUBSTANTIATION: We believe that manufacturers should have some safety requirements for dealing with manufacturing of fireworks. We agree with the submitter’s substantiation and the committee should look further into the proposed text to incorporate into the standard. COMMITTEE MEETING ACTION: Accept in Principle See Committee Action on Comment 495-2 (Log #11). The action on the referenced comment accomplishes the recommendation of the submitter. COMMITTEE STATEMENT: See Committee Action and Committee Statement on Comment 495- 2 (Log #11). The intent of the submitter has been accomplished through the action on the referenced comment. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-5 Log #CC3 Final Action: Accept (1.4) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-1 RECOMMENDATION: Revise Section 1.4 Retroactivity by replacing “standard” with “code” where it appears 3 times in 1.4, 3 times in 1.4.1 and one time each in 1.4.2 and 1.4.3. SUBSTANTIATION: This is an editorial change; when the Retroactivity section was added to this document, the correct form of document (code) was not indicated. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-6 Log #8 Final Action: Accept in Principle (Table 8.4.1) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-39 RECOMMENDATION: Third column heading, “A to D ”. If this is not a

typographical error, include the definition of “D.” SUBSTANTIATION: The term is not common in the industry and, therefore, is confusing and unclear. COMMITTEE MEETING ACTION: Accept in Principle Delete “ Class A to D ” in the 3rd column of Table 9.4.1 (per ROP draft). Replace with “ Traffic Volume of 3000 Vehicles/Day or Less ” Retain footnote to this column, footnote 11. COMMITTEE STATEMENT: The “A to D” applies to classification of public highways based upon traffic volume; the classifications are no longer utilized within the IME publication and the limit to 3000 vehicles or less corresponds to the IME publication. This action by the Committee accomplishes the intent of the submitter. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-7 Log #9 Final Action: Reject (8.4.4) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Delete text as follows: An indoor magazine shall be located only on a floor that has an entrance at or a ramp to grade level. It shall be located no more than 3 m (10 ft) from the entrance. It shall be located as approved by the authority having jurisdiction to facilitate rapid removal in an emergency . SUBSTANTIATION: Two points: 1) The distance tables take into account the types and quantities of explosives stored outdoors; greater quantities of more dangerous classes require greater distances. However, there are no equivalent considerations for indoor storage. Any quantity or any type of the explosive (up to 50 pounds) stored indoors currently must meet the same requirements. In the aerospace industry, indoor magazines are typically used to store limited quantities of DOT Class 1.4 explosives - normally less than 2 pounds. Holding such type and quantity storage to the same requirements as for 50 pounds of DOT 1.1 is unnecessarily restrictive. 2) We question the validity of requiring casters and placement of indoor magazines “for rapid removal in an emergency.” That practice appears counter to the primary emphasis which should be on personnel safety. The recommended change would allow the approving authority having jurisdiction to require placement and evacuation provisions based on the quantity and type of explosives stored and other considerations. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The proposed change to this requirement would eliminate options for actions related to the removal of indoor magazines in the event of an incident. This action is more restrictive or limiting and does not increase the safety of the workers and forces evacuation as the only action. The proposed wording also adds no guidance and defers solely to the AHJ for location of the magazine. The submitter has identified an area that requires further evaluation of possible solutions; however, the proposed change does not provide an acceptable solution as submitted. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-8 Log #2 Final Action: Reject (8.6.2.2(a)) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Delete the following text: The magazine shall have substantial wheels or casters to facilitate its removal from the building in case of emergency. SUBSTANTIATION: We question the validity of requiring casters and placement of indoor magazines “for rapid removal in an emergency.” That practice is counter to the primary emphasis which should be personnel safety. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The proposed change to delete the existing text would leave the code with no alternative to facilitate removal of the magazine. It provides no alternative or option and elimination of this provision forces evacuation of the facility and eliminates all other mitigating actions. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-9 Log #3 Final Action: Accept (8.6.2.2(b)) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Revise text to read as follows:

495-21

Report on Comments — Copyright, NFPA NFPA 495 The cover or door of the magazine shall have substantial strap henges hinges and a means for locking. The magazine shall be kept locked with a five-tumbler padlock or its equivalent. SUBSTANTIATION: The term “cover” is vague and not consistent with industry or regulatory terms. “Substantial strap hinges” unnecessarily restricts the permissible type of substantial hinges acceptable. The containers typically used in our experience are 12 gauge steel, heavy construction, with welded hinges that are “substantial” but not of the “strap variety”. The proposed change also corrects the spelling of “Hinges.” COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-10 Log #4 Final Action: Accept in Principle (8.6.2.2(c)) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Revise text to read as follows: 8.6.2.2(c) The magazine shall be painted red, and equipped with a sign reading the top shall bear the words “Explosives - Keep Fire Away” in white letters at least 76 mm (3 in.) high. The sign shall be positioned so it is clearly visible from the approach side or sides of the magazine. SUBSTANTIATION: Many indoor magazines are upright containers six or more feet tall, so positioning the sign on the top of those magazines would not be useful. The proposed change will better describe appropriate marking for all sizes of magazines. COMMITTEE MEETING ACTION: Accept in Principle Revise text to read as follows: 8.6.2.2(c) The magazine shall be painted red, and shall bear the warning “Explosives - Keep Fire Away” in white letters at least 76 mm (3 in.) high so that the warning is visible from the approach side or sides of the magazine. COMMITTEE STATEMENT: The Committee accomplished the intent of the submitter with this action. The Committee deleted the word “clearly” which modifies “visible” as it seems redundant. In addition, the Committee modified the text to remove the specific requirement for a “sign” and incorporated the marking or labeling with a warning in a way that provides options as to the best method for achieving the intent of the requirement. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-11 Log #5 Final Action: Accept (8.6.2.2(d)) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Add new text as follows: Type 2 indoor magazines constructed of wood shall have sides, bottoms, and covers or doors constructed of 51-mm (2-in.) hardwood that are well braced at corners. The magazines shall be covered with sheet metal of not less than 26 gauge. Nails exposed to the interior of the magazines shall be countersunk . , made of non-sparking metal, or be covered with a non-sparking coating. SUBSTANTIATION: The added provides equally effective alternatives to countersinking. Magazine manufacturers sometimes use aluminum nails, or cover exposed nails with caulk-like coating. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-12 Log #6 Final Action: Reject (8.7.2) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-44 RECOMMENDATION: Add new text to read as follows: All magazines containing explosive materials located in remote, unprotected areas shall be opened and inspected at maximum intervals of three days to determine whether there has been an unauthorized or attempted entry into the magazines or whether there has been unauthorized removal of the magazines or their contents. Magazines located in fenced, guarded, and access-controlled areas shall be opened for similar inspections at maximum intervals of seven days.

SUBSTANTIATION: A requirement to open and inspect magazines located in fenced and guarded industrial areas every three days is unnecessarily restrictive. Further, 27 CFR 55.204 specifies 7 days. COMMITTEE MEETING ACTION: Reject COMMITTEE STATEMENT: The Committee does not advocate a revision to the Code that would reduce the inspection frequency for magazines. The proposed change weakens the existing inspection requirements by making them applicable only for “remote, unprotected areas.” It is possible that there might be a category of magazine that would not be addressed by either of the categories defined by this proposed change. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-13 Log #7 Final Action: Accept in Principle (8.7.7) ________________________________________________________________ SUBMITTER: Harold Reed, The Boeing Company / Rep. Company Safety and Health COMMENT ON PROPOSAL NO: 495-3 RECOMMENDATION: Delete text as follows: Containers of explosive materials shall be piled stacked in a stable manner and laid flat with the top side up. SUBSTANTIATION: “Stacked” is more appropriate. The dictionary definition of “pile” doesn’t fit this use. The dictionary defines “stack” as a neat pile. COMMITTEE MEETING ACTION: Accept in Principle Revise 9.7.8 (ROP text) as follows: 9.7.8* Containers of explosive materials shall be arranged piled in a stable manner and laid flat with the top side up . Add Annex material to 9.7.8 to read as follows: A.9.7.8 Markings regarding the orientation of the containers should be followed. COMMITTEE STATEMENT: The Committee accomplished the intent of the submitter and removed the prescriptive statement regarding “laying flat with top side up” and replaced that text with the annex material that notes that the orientation markings on the container should be observed and followed. NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-14 Log #CC2 Final Action: Accept (Table 9.3.1(b)) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-1 RECOMMENDATION: In Table 9.3.1 (b) in the eighth line replace “BATF” where it appears with “ATF.” In A.4.8.5 change “Bureau of Alcohol, Tobacco, and Firearms” to “Bureau of Alcohol, Tobacco, Firearms, and Explosives.” In A.3.3.2.2 (6) change “Bureau of Alcohol, Tobacco, and Firearms, U.S. Department of the Treasury” to “Bureau of Alcohol, Tobacco, Firearms, and Explosives, and U.S. Department of Justice”. SUBSTANTIATION: These are editorial changes to include the appropriate name or reference for the ATF. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-15 Log #CC5 Final Action: Accept (Table 9.4.1) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-40 RECOMMENDATION: Add a metric equivalent table for Table 9.4.1 and Table 9.4.2.2 (ROP draft numbering) using the IME metric equivalent table as a basis. (See Tables on the following pages.)

495-22

Report on Comments — Copyright, NFPA NFPA 495

Table 9.4.1

495-23

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Table 9.4.1 Continued

495-24

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Table 9.4.1 Continued

495-25

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Table 9.4.2.2

495-26

Report on Comments — Copyright, NFPA NFPA 495 SUBSTANTIATION: Metric equivalents are provided elsewhere in the code and should be included for these tables as well. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-16 Log #CC6 Final Action: Accept (Table 9.4.1(b) (New) ) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-41 RECOMMENDATION: Add a new Table 9.4.1(b) (using ROP numbering) on Low Explosives.

Table 9.4.1(b) Table of Distances for Storage of Low ExplosivesPounds From

inhab-ited

build-ing dis-tance(ft)

From pub-

lic rail-roadAnd high-way dis-

tance(ft)

From above

groundmagazine

(ft)

Over Not over

0 1,000 75 75 501,000 5,000 115 115 755,000 10,000 150 150 100

10,000 20,000 190 190 12520,000 30,000 215 215 14530,000 40,000 235 235 15540,000 50,000 250 250 16550,000 60,000 260 260 17560,000 70,000 270 270 18570,000 80,000 280 280 19080,000 90,000 295 295 19590,000 100,000 300 300 200

100,000 200,000 375 375 250200,000 300,000 450 450 300

Table: Department of Defense Ammunition and Explosives Standards, Table 5-4.1Extract; 4145.27 M, March 1969

SUBSTANTIATION: The addition of this table makes the code more complete; this was approved by the Committee, but the specific table was not provided in the ROP draft. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-17 Log #CC1 Final Action: Accept (Table 9.4.2.2) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-42 RECOMMENDATION: Delete the existing notes to Table 9.4.2.2 (as shown in the ROP draft) and replace with the following: Notes to Table of Recommended Separation Distances of Ammonium Nitrate and Blasting Agents from Explosives or Blasting Agents NOTE 1 – Recommended separation distances to prevent explosion of ammonium nitrate and ammonium nitrate-based blasting agents by propagation from nearby stores of high explosives or blasting agents referred to in the Table as the “donor.” Ammonium nitrate, by itself, is not considered to be a donor when applying this Table. Ammonium nitrate, ammonium nitrate-fuel oil or combinations thereof are acceptors. If stores of ammonium nitrate are located within the sympathetic detonation distance of explosives or blasting agents, one-half the mass of the ammonium nitrate should be included in the mass of the donor. NOTE 2 – When the ammonium nitrate and/or blasting agent is not barricaded, the distances shown in the Table shall be multiplied by six. These distances allow for the possibility of high velocity metal fragments from mixers, hoppers, truck bodies, sheet metal structures, metal containers, and the like which may enclose the “donor.” Where storage is in bullet-resistant magazines 1 recommended for explosives or where the storage is protected by a bullet-resistant wall, distances and barricade thicknesses in excess of those prescribed in the American Table of Distances are not required.

NOTE 3 – The distances in the Table apply to ammonium nitrate and ammonium nitrate based materials that show “negative” (-) result in the UN Test Series 2 Gap Test and show “positive” (+) result in the UN Test Series 1 Gap Test. Ammonium nitrate and ammonium nitrate based materials that are DOT hazard Class 1 sensitive shall be stored at separation distances determined by the American Table of Distances. NOTE 4 – These distances apply to blasting agents which pass the insensitivity test prescribed in regulations of the U.S. Department of Transportation and the U.S. Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives. NOTE 5 – Earth, or sand dikes, or enclosures filled with the prescribed minimum thickness of earth or sand are acceptable artificial barricades. Natural barricades, such as hills or timber of sufficient density that the surrounding exposures which require protection cannot be seen from the “donor” when the trees are bare of leaves, are also acceptable. 1 For construction of bullet-resistant magazines see Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice, Publication ATF P 5400.7 (9/00), Federal Explosives Law and Regulations. NOTE 6 – For determining the distances to be maintained from inhabited buildings, passenger railways, and public highways, use the American Table of Distances for Storage of Explosive Materials (see Table 9.4.1). SUBSTANTIATION: The notes to Table 9.4.2.2 have been updated by the Institute of Makers of Explosives (IME). This change brings the table and associated notes up to date with the IME publication. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA _______________________________________________________________ 495-18 Log #CC4 Final Action: Accept (A.3) ________________________________________________________________ SUBMITTER: Technical Committee on Explosives COMMENT ON PROPOSAL NO: 495-1 RECOMMENDATION: Make the following editorial corrections to the numbering for the Annex items for Chapter 3, Definitions. As shown in ROP draft Should be A.3.3.6 A.3.3.5 A.3.3.9 A.3.3.8 A.3.3.12 A.3.3.11 A.3.3.13 A.3.3.20.1 A.3.3.14 A.3.3.20.2 A.3.3.18 A.3.3.15 A.3.3.22 A.3.3.18 A.3.3.23 A.3.3.19 A.3.3.26 A.3.3.22 A.3.3.27 A.3.3.23 A.3.3.28 A.3.3.24 A.3.3.34 A.3.3.29 A.3.3.51 A.3.3.45 A.3.3.58 A.3.3.51 A.3.3.59 A.3.3.52 A.3.3.61 A.3.3.54 A.3.3.65 A.3.3.58 A.3.3.67 A.3.3.60 A.3.3.69 A.3.3.62 A.3.3.73 A.3.3.20.5 A.3.3.75 A.3.3.67 A.3.3.78 A.3.3.69 SUBSTANTIATION: During the Manual of Style editing and renumbering, the annex items were not renumbered correctly. This comment provides the corrected numbering based upon the ROP draft. COMMITTEE MEETING ACTION: Accept NUMBER ELIGIBLE TO VOTE: 21 BALLOT RESULTS: Affirmative: 19 BALLOT NOT RETURNED: 2 FRY, VILLA