This document proposes revisions to NFPA 407 regarding fire protection requirements for aircraft fuel servicing. It suggests lowering the minimum fire extinguisher rating from 80B to 40B given limitations of existing equipment. The submitter argues this would avoid unnecessary replacement of suitable 20lb extinguishers while still providing adequate protection for anticipated class B fuel fires. Attached information provides additional context on fire rating standards and equipment capacities.
This document proposes revisions to NFPA 407 regarding fire protection requirements for aircraft fuel servicing. It suggests lowering the minimum fire extinguisher rating from 80B to 40B given limitations of existing equipment. The submitter argues this would avoid unnecessary replacement of suitable 20lb extinguishers while still providing adequate protection for anticipated class B fuel fires. Attached information provides additional context on fire rating standards and equipment capacities.
This document proposes revisions to NFPA 407 regarding fire protection requirements for aircraft fuel servicing. It suggests lowering the minimum fire extinguisher rating from 80B to 40B given limitations of existing equipment. The submitter argues this would avoid unnecessary replacement of suitable 20lb extinguishers while still providing adequate protection for anticipated class B fuel fires. Attached information provides additional context on fire rating standards and equipment capacities.
This document proposes revisions to NFPA 407 regarding fire protection requirements for aircraft fuel servicing. It suggests lowering the minimum fire extinguisher rating from 80B to 40B given limitations of existing equipment. The submitter argues this would avoid unnecessary replacement of suitable 20lb extinguishers while still providing adequate protection for anticipated class B fuel fires. Attached information provides additional context on fire rating standards and equipment capacities.
TIA Log No.: 1339 Reference: 5.1.10, 6.1.10.1, 6.1.10.2, 8.1.10.1 and 8.1.10.2 Comment Closing Date: October 19, 2017 Submitter: J.R. Nerat, Badger/Kidde Fire Protection
1. Revise 5.1.10 to read as follows:
5.1.10 Fire Protection. At least one fire extinguisher, with a minimum rating of 80 40-B:C, and a minimum capacity of 9.0 kg (20 lb.) of dry chemical agent shall be provided at each fueling vehicle loading position or rack.
2. Revise 6.1.10.1 and 6.1.10.2 to read as follows:
6.1.10 Fire Protection.
6.1.10.1 Each aircraft fuel servicing tank vehicle shall have two listed fire extinguishers, each having a rating of at least of 80 40-B:C and a minimum capacity of 9.0 kg (20 lb.) of dry chemical agent, with one extinguisher mounted on each side of the vehicle. 6.1.10.2 One listed fire extinguisher having a rating of at least 80 40-B:C and a minimum capacity of 9.0 kg (20 lb.) of dry chemical agent shall be installed on each hydrant fuel servicing vehicle or cart.
3. Revise 8.1.10.1 and 8.1.10.2 to read as follows:
8.1.10 Fire Protection.
8.1.10.1 Each facility shall have a minimum of one fire extinguisher with a rating of at least 80 40-B:C and a minimum capacity of 9.0 kg (20 lb.) of dry chemical agent located at the dispenser. 8.1.10.2 At least one fire extinguisher with a rating of at least 80 40-B:C and a minimum capacity of 9.0 kg (20 lb.) of dry chemical agent shall be provided at each emergency fuel shutoff control.
Substantiation. The recent 2017 editions minimum numerical extinguisher rating change from 20B to 80B is currently generating the replacement of existing fire extinguisher models installed at airport sites from 20 pound to 30 pound sizes to comply with NFPA-10 requirements. Because I don’t believe this was the intent of the technical committee, have respectfully submitted a TIA to help avoid the unnecessary/costly replacement of many suitable 20 pound fire extinguisher models and mounting brackets from airport fueling applications.
Since 2007 the NFPA-10 portable fire extinguisher standard has specifically required the use of dry chemical fire extinguisher models having minimum agent discharge rates of at least 1 pound per second for properly addressing potential class “B” Obstacle, 3-Dimensional and Pressure fire situations. (Reference section 5.5) These are the specific types of anticipated class “B” fire situations typically presented during aircraft fueling releases. Other NFPA standards addressing similar fire hazard concerns such as NFPA-385 (Transportation of Flammable and Combustible Liquids) and NFPA-410 (Aircraft Maintenance) specifically also identify and require similar types and sizes of hand portable fire extinguisher models.
Because each class “B” numerical fire rating has a minimum pre-established discharge time, the agent discharge rates from fire extinguishers are often significantly reduced to extended durations and obtain those higher ratings. This is why the “High-Flow” discharge models specifically designated for addressing special class “B” fire hazard situations, commonly carry reduced numerical ratings. Prior to 2007, the NFPA-10 standard simply stated that the class “B” fire extinguisher rating system was not applicable for properly addressing such fire situations and that the equipment manufacturers should be consulted. Other industry standards attempting to establish proper minimum hazard protection needs back then, simply identified minimum extinguisher sizes with lower ratings. The technical committee should note, that most of the large airport flight line wheeled fire extinguisher models having minimum 125 pound agent capacities currently only require and carry 80B ratings for this reason.
While there are number of ways the technical committee could address the current compliance issue, believe the quickest resolution is with a TIA that simply reduces the existing minimum 80B rating requirement to a minimum 40B rating and clarifies the minimum acceptable extinguisher size. This would continue to permit most existing minimum 20 pound dry chemical extinguishers to remain in service, as various models with lower ratings and agent flow rates exceeding 1 pound per second have commonly been installed and utilized at airport fueling sites for over 30 years.
Also attached is additional information for anyone who may want to see and better understand the various existing extinguisher hardware/rating limitations associated with NFPA 10 requirements.
Emergency Nature. The standard contains an error or an omission that was overlooked during the regular revision process. The NFPA Standard contains a conflict within the NFPA Standard or within another NFPA Standard. The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification for the action.
The recent numerical fire extinguisher rating changes within the 2017 edition is currently requiring the replacement of most equipment installed and utilized at airports around the world, to comply with NFPA-10 requirements for the proper protection of special class “B” hazard situations. The existing 20 pound fire extinguisher models would all need to be replaced with much larger 30 pound models for compliance. The proposed TIA language resolves compliance issues and clarifies the desired hazard coverage objectives previously established and utilized for many years. Anyone may submit a comment by the closing date indicated above. To submit a comment, please identify the number of the TIA and forward to the Secretary, Standards Council, 1 Batterymarch Park, Quincy, MA 02169‐7471.
Fire Extinguisher Hardware Availability Chart Extinguisher Standards for Agent Types and Fire Ratings Dry Chemical and Dry Powders (ANSI/UL-299) Carbon Dioxide (ANSI/UL-154) Water Types (ANSI/UL-626) Halon Types (ANSI/UL-1093) Halocarbon Types (ANSI/UL-2129) Film-Forming Foam Types (ANSI/UL-8) Fire Testing & Ratings (ANSI/UL-711)
