ICC Publishes Reasons for Approvals/Disapprovals:
Public comment period now open
Patrick Serfass, National Hydrogen Association

Actually, to be correct, at the Code Development Hearings the committees recommended approval or disapproval of the different code proposals. The final decisions will be made by the ICC membership coming up in Rochester, NY, May 21-26, 2007. 

The Report on the ICC Code Development Hearings (September 20-October 1 in Orlando, FL) is out. Below, you can find the reason statements for various code proposals—the official reasons for why a proposal was recommended for approval or disapproval.

To get up to speed on the ICC Code Development process, please read the "Background" section of"Your Hydrogen Guide to the 2006/2007 ICC Code Development Hearings"(Aug 06, HFCSR).


The reason statements appear after a summary of each code proposal. The "Committee Action" shows the result of the committee’s voting at the hearings. "Assembly Action" shows the result of a hand vote (which is rarely requested) of ICC members present in the hearing room. Assembly action is generally requested when someone (usually the proponent) thinks that the ICC members are in disagreement with the code development committee. If a floor vote was taken, the result is shown as "Assembly Action." 

What Next?
The Public Comment Period is now open until January 24, 2007. During this time, using the proper form, anyone can comment on the proposals. The comments are basically letters showing support or opposition to the proposal or the committee’s action. Before the Final Action Hearings in May, the comments will all be published for review. In May, anyone present at the hearings who is an ICC member can vote on any proposal. 

If you would like to express your opinion on any proposal, please use the links immediately below for instructions.

06/07 ICC Code Proposals Related to Hydrogen

International Fire Code

F53-06/07
"Lithium Metal Polymer batteries"

F54-06/07
"Required automatic status monitoring of lead acid battery room ventilation systems"

F154-06/07
"Vehicle overpressure protection"

F155-06/07
"Indoor fast-fill dispensing"

F156-06/07
"Electrostatic discharge for fueling pads"

F157-06/07
"Consistent 'listing' of lighter-than-air gas detection systems"

F172-06/07
"Addressing hydrogen cylinders stored in outdoor cabinets"

F175-06/07
"Diking around above ground LH2 storage"

F191-06/07
"Movement of LH2 language and new LH2 tank requirements from CGA"

F193-06/07
"Telecomm cabinets and transfer switches near outdoor hydrogen cabinets"

F194-06/07
"Guidance for metal hydride systems"

F229-06/07
"New requirements for indoor hydrogen storage"

International Mechanical Code

M56-06/07
"Ventilation requirement moved from exhaust to ventilation"

 International Fuel Gas Code

FG54-06/07
"H2 Piping-Concealed Locations"

 Fire Safety Code of the International Building Code

FS37-06/07
"Fire barrier definition"

 International Fire Code

F53-06/07
"Lithium Metal Polymer batteries" [download PDF] 
Proponent: Ronald Marts, Telcordia Technologies, representing AT&T, SBC, Ameritech, PacBell, Cincinnati Bell, Qwest, Southern New England Telephone

Summary: This proposed change simply adds Lithium Metal Polymer (LMP) batteries to the following sections of the International Fire Code:
Chapter 6: Building services and systems
Section 602: Definitions
Section 608: Stationary storage battery systems

Interested parties should also take a look at F54 "Required attendant for battery storage ventilation systems" for any potential impact on this code proposal. 

Committee Action: Disapproved
Committee Reason: The proposal would exclude other Lithium Metal Polymer technologies, such as magnesium dioxide cathodes, and the hazards of thermal runaway have not been addressed. Also, the proposed definition includes text that is essentially commentary.
Assembly Action: None


[Return to List of Proposals]


F54-06/07
"Required automatic status monitoring of lead acid battery room ventilation systems" [download PDF]
Proponent: Lynne M. Kilpatrick, Fire Department, City of Seattle, WA

Summary: This code change is a new section proposed for 608.6 of the International Fire Code: 
Chapter 6: Building services and systems. 
Section 608: Stationary storage battery systems
Section 608.6: Ventilation

This change requires that the ventilation systems in 608.6.1 (room ventilation) and 608.6.2 (cabinet ventilation) which are required to insure that the concentration of hydrogen does not exceed 1% or present an explosion hazard. This proposal adds an additional requirement for supervision by an "approved central, proprietary, or remote station service" or the activation of "an audible and visual signal at a constantly attended on-site location." According to a discussion with the proponent, this proposal only applies to stationary lead-acid battery systems with an electrolyte capacity >50 gal. and would require status monitoring of the ventilation system (air flow - no air flow) already required by 608.5. This is typically accomplished with a vane-type paddle in the duct that changes position when there is no airflow and activates a position switch that can be monitored by the fire alarm system. Although this change will increase the cost of new installations, cost may not increase by much since the smoke detectors already required (by 608.8) will make sure a fire alarm system is present and a fire alarm circuit is nearby. 

Interested parties should also take a look at F53 "Lithium Metal Polymer batteries" for any potential impact. 

Committee Action: Disapproved
Committee Reason: The proposal provides no justification as to why supervision should be required now after many years of battery operated equipment (e.g., golf carts, etc.) charging for prolonged periods. It also does not specify what aspects of the ventilation system are to be supervised. 
Assembly Action: Approved as Submitted

[Return to List of Proposals]

F154-06/07
"Vehicle overpressure protection" [download PDF]
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal is for Chapter 22 (Motor fuel-dispensing facilities and repair garages) of the International Fire Code. 

This proposal suggests the level at which the overpressure system on the dispenser side of the vehicle fueling system should activate to prevent overwhelming the vehicle fuel system. The level was chosen to be consistent with overpressure levels as determined by SAE. SAE has recently tweaked their overpressure level from 140% to 138% to be consistent with other requirements. Safety-wise, this should be a negligible change. 

Committee Action: Approved as Submitted
Committee Reason: Based on the proponent’s reason statement. The proposal provides a provision that is already in NFPA 52 to provide protection for vehicle tanks when they are connected for refilling.
Assembly Action: None

[Return to List of Proposals]

F155-06/07
"Indoor fast-fill dispensing"[download PDF] 
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal suggests new language for Chapter 22 (Motor fuel-dispensing facilities and repair garages) of the International Fire Code. Current provisions of the code do not address the requirements for indoor attended fast fill systems (systems designed to provide a fuel fill rate greater than or equal to 12 Standard Cubic Feet per Minute (SCFM)). According to the proponent, fast fill hydrogen fuel dispensing can be safely accomplished with the requirements added by this new section 2209.5. 

Committee Action: Disapproved
Committee Reason: The proponent requested disapproval to work through a number of technical issues with the proposal..
Assembly Action: None

Editor’s Note: This proposal was significantly improved in the minds of many industry companies just before the Code Development Hearings. However, since there were so many changes presented just before the proposal was heard, there was not enough time for the Fire Code Development Committee to review the modifications to the submitted proposal. It is likely that the modifications will be suggested through the Public Comment period. 

[Return to List of Proposals]

F156-06/07
"Electrostatic discharge for fueling pads" [download PDF] 
Proponent: Thomas Joseph, Chair, Hydrogen Industry Panel on Codes

Summary: This proposal suggests new language for Chapter 22 (Motor fuel-dispensing facilities and repair garages) and Chapter 45 (Referenced standards) of the International Fire Code as well as Chapters 4 (Special Detailed Requirements Based On Use And Occupancy) and 45 of the International Building Code. The current language does not address safety issues associated with electrostatic discharges (ESD). According to the proponent, fueling surfaces for hydrogen powered vehicles should be at least as protective regarding ESD issues as those fueling surfaces used for petroleum powered vehicles. This language is intended to reduce the probability of a static spark by requiring that the pad the vehicle sits on will effectively ground the vehicle. The proposal references a European Standard. Although the European standard (DIN/CEN 1081) was not developed through the American ANSI process (a criterium for ICC Codes), it was developed in a very similar, consensus-based process. Many industry professionals believe that the alternative standard applicable in this instance, ASTM F 150, is inferior because the process described to measure resistivity is not easily repeatable in a consistent fashion. 

ICC Staff Note: The following analysis was not in the Code Change Proposal book but was published in the "Errata to the 2006/2007 Proposed Changes to the International Codes and Analysis of Proposed Referenced Standards" provided at the code development hearings: Analysis: Review of the proposed new standard indicated that, in the opinion of ICC staff, the standard did not comply with ICC standards criteria, Sections 3.6.2.11 and 3.6.3.2. 

Editor’s Note: It is likely that industry representatives, during the comment period, will suggest modifications that will either show that DIN/CEN 1081 is appropriate for reference in an ICC Code or allow the code user to choose between applicable standards. 

PART I — IFC
Committee Action: Disapproved
Committee Reason: In was unclear how the proposed standard for resilient floor coverings would apply to non-coated concrete.
Assembly Action: None

PART II — IBC GENERAL
Committee Action: Disapproved
Committee Reason: The standard proposed for inclusion had not been provided for review by the committee.
Assembly Action: None

[Return to List of Proposals]

F157-06/07
"Consistent 'listing' of lighter-than-air gas detection systems"[download PDF]
Proponent: Greg Rogers, South Kitsap Fire & Rescue, representing ICC Joint Fire Service Review Committee

Summary: This code change proposes modifications to subsections 2211.7.2 and 2211.7.2.1 of the International Fire Code:
Chapter 22: Motor fuel-dispensing facilities and repair garages
Section 2211: Repair garages
Section 2211.7: Repair garages for vehicles fueled by lighter-than-air fuels
Section 2211.7.2: Operation
Section 2211.7.2.1: System design

The code change will change gas detection systems from requiring to be "approved" to requiring that they be "listed or approved." The proponent says this change is needed because similar sections in other parts of Chapter 22 (See 2208.2.2 which deals with natural gas motor fuel dispensing facilities and 2209.2.2 which deals with hydrogen motor fuel-dispensing and generation facilities) require gas detection systems to be "listed." Both 2208 and 2209 require that some types of equipment be "approved," some "listed" and others "listed and labeled." In sections, 2208.2.2 and 2209.2.2, gas detection systems are required to be "listed." This code change would require gas detection systems in repair garages for vehicles fueled by lighter-than-air fuels to be "listed or approved." 

Committee Action: Approved as Modified
Modify the proposal as follows:
2211.7.2 Gas detection system. Repair garages used for repair of vehicles fueled by nonodorized gases, such as hydrogen and nonodorized LNG, shall be provided with a flammable gas detection system. 

2211.7.2.1 System design. The flammable gas detection system shall be listed or approved and shall be calibrated to the types of fuels or gases used by vehicles to be repaired. The gas detection system shall be designed to activate when the level of flammable gas exceeds 25 percent of the lower flammable limit (LFL). Gas detection shall also be provided in lubrication or chassis repair pits of repair garages used for repairing nonodorized LNG-fueled vehicles. 
Committee Reason: The proposal adds consistency to the gas detection system requirements. The modification will provide an alternative approval to listing.
Assembly Action: None

[Return to List of Proposals]

F172-06/07
"Addressing hydrogen cylinders stored in outdoor cabinets"[download PDF] 
Proponent: Paul J. Buehler, Jr., Plug Power, Inc. 

Summary: This code change has three parts. Part one proposes new sections 3003.7.11 through 3003.7.11.2. Part two proposes new section 3504.2.2. Part three proposes a new reference in Chapter 45. All parts pertain to sections of the International Fire Code. 

Part One
Chapter 30: Compressed Gases
Section 3003: General requirements
Section 3003.7: Separation from hazardous conditions
Section 3003.7.11: Exposure to fire

Part Two
Chapter 35: Flammable Gases
Section 3504: Storage
Section 3504.2: Outdoor storage

Part Three
Chapter 45: Referenced standards

According to the proponent, this proposal revises outdated material because current International Fire Code and NFPA 55 sections do not deal with the storage of bottled hydrogen out of doors inside cabinets, but rather only consider "naked" cylinders or indoor gas cabinets per Sections 2703.8.6 "hazardous material gas cabinet construction requirements" and 3006.2.3 "medical gas system cabinets." This amendment pertains directly to the hydrogen storage and appears to facilitate the placement of bottled hydrogen in outdoor cabinets in proximity to low powered electrical equipment. Interested parties should view the actual code change by clicking the F172 link above to note the maximum allowed quantity of hydrogen that can be stored in an outdoor cabinet and separation distances to both combustible waste/vegetation and electrical equipment. 

ICC Staff Note: The following analysis was not in the Code Change Proposal book but was published in the "Errata to the 2006/2007 Proposed Changes to the International Codes and Analysis of Proposed Referenced Standards" provided at the code development hearings:
Analysis: Review of the proposed new standard indicated that, in the opinion of ICC staff, the standard did not comply with ICC standards criteria, Sections 3.6.2.11 and 3.6.3.2. 

Committee Action: Disapproved
Committee Reason: Chapter 30 is a general compressed gas chapter. The proposed provisions more appropriately belong in the material-specific chapter for flammable gas, Chapter 35. The proposal would allow telecommunication cabinets to be used as hazardous materials storage cabinets with no apparent approval guidance for the fire code official. The proposed standard does not comply with ICC standards criteria and it is unclear whether it would be suitable if applied to the subject matter of this proposal. The standard discussed hydrogen offgassing in battery charging applications but it is unclear how that relates to cylinder storage.
Assembly Action: None

[Return to List of Proposals]

F175-06/07
"Diking around above ground LH2 storage" [download PDF] 
Proponent: John C. Dean, The National Association of State Fire Marshals

Summary: This code change proposes additional language to the drainage subsection of the outdoor storage of cryogenic fluids section (3204.3.1.3) in the International Fire Code.
Chapter 32: Cryogenic Fluids
Section 3204: Storage
Section 3204.3: Outdoor storage
Section 3204.3.1: Stationary containers

According to the proponent: 
There has been considerable discussion on the requirement for, or prohibition of, or restriction on, the use of diking around above-ground LH2 storage. The proposed language captures the intent to prevent liquid hydrogen from entering areas not zoned/rated for flammable gas, and to control the ground-level vapor cloud, to the extent possible, to within areas designed to address a flammable mixture. 

There are advantages and disadvantages to diking. The disadvantage is that it may increase the resident time of a vapor cloud over the affected area. However, this is also considered a positive, as it reduces the total affected area. This may be particularly important if adjacent property is not properly zoned to address a hydrogen leak. The proposed language serves to minimize the affected area to the extent possible, while still preventing additional hazards from forming. 

While the language in the proposal does not directly require diking (it is one option for containment), many industry professionals believe it is unwise to offer diking as an option because it is more likely to cause harm than provide benefits to public safety. One opponent at the Code Development Hearings stated that in a few decades of handling liquid hydrogen and after specific testing designed to determine if liquid hydrogen will pool if spilled, his company never saw pooled liquid hydrogen. The situation diking is designed to prevent, in their opinion, is non-existent due to the specific properties of liquid hydrogen. 

Committee Action: Disapproved
Committee Reason: The scope of the proposal exceeds the nature of the LH2 hazard since it would take an extremely large and rapid leak to get a pool of LH2 large enough to warrant such site work.
Assembly Action: None

[Return to List of Proposals]

F191-06/07
"Movement of LH2 language and new LH2 tank requirements from CGA" [download PDF] 
Proponent: Larry Fluer, Fluer, Inc., representing Compressed Gas Association

Summary: This code change proposal has several parts to it. In general, it appears to try to keep Chapter 32 (Cryogenic Fluids) as a general chapter (not specific to any particular cryogenic liquid). As a result, the proponent is proposing to change the title of Chapter 35 (currently Flammable Gases) to become "Flammable Gases and Flammable Cryogenic Fluids" This simple change could have a potential impact on F175 (Dean/NASFM-see above) which proposes hydrogen-specific changes to the general chapter 32. 

Other new language proposed in 3501.1 suggests that above ground hydrogen storage systems shall be in accordance with Chapter 22 (Motor fuel-dispensing facilities and repair garages). This modification could have an impact on F172 (Buehler/Plug-see above) which deals with above ground storage of outdoor hydrogen cabinets. 

Part 1. NFPA 55 contains material specific provisions for "bulk" hydrogen systems. The term "bulk" has been added to direct the user to the applicable sections of the Standard. Two new definitions have been added to define "bulk liquefied" and "bulk compressed" gas systems where specific details surrounding such installations can be found. 

Part 2. Chapter 32 was intended to be a generic chapter for all cryogenic fluids. Hazards relating to specific cryogenic fluids (like liquid hydrogen) were to be placed into the appropriate chapter based on the nature of the material. A code change was introduced into the last code cycle (F216-04/05 Fluer, representing CGA) to relocate the requirements for liquid hydrogen tanks to Chapter 35, however, the necessary correlating changes and references were overlooked and the code change was rejected at the request of the proponent. 

The provisions for liquid hydrogen have now been proposed to be relocated without change to the language from Chapter 32 (cryogenic fluids) to Chapter 35 (Flammable Gases and Flammable Cryogenic Fluids) in the specific section 3506. Section 3506 is the only section in the chapter intended to apply to cryogenic fluids, and hydrogen is the sole cryogenic fluid provided for at this time. 

Sub-section 3506.3 has been added as a new section to address the requirements for tank construction in a more specific manner than that described by Section 2703.2.1. The design criteria are found in newly published CGA Standard H-3-2006 Cryogenic Hydrogen Storage. According to the proponent, the minimum design requirements established by Section 3506.3 coupled with the general requirements of Chapter 32 applicable to all cryogens improve the code resulting in greater consistency and an increase in public safety.

Approval of this code change will help Chapter 32 to remain as a generic chapter applicable to all cryogens while placing material specific requirements into the material specific chapters as desired. 

Committee Action: Approved as Modified
Modify the proposal as follows:
3501.1 Scope. The storage and use of flammable gases shall be in accordance with this chapter. Compressed gases shall also comply with Chapter 30 and cryogenic fluids shall also comply with Chapter 32. Bulk hydrogen compressed gas systems and bulk liquefied hydrogen gas systems shall also comply with NFPA 55.

Exceptions:

1.     Gases used as refrigerants in refrigeration systems (see Section 606).

2.     Liquefied petroleum gases and natural gases regulated by Chapter 38.

3.     Fuel-gas systems and appliances regulated under theInternational Fuel Gas Code.

4.     Hydrogen motor fuel-dispensing stations and repair garages and their associated above ground hydrogen storage systems designed and constructed in accordance with Chapter 22.

5.     Pyrophoric gases in accordance with Chapter 41.
(Portions of proposal not shown remain unchanged)

Committee Reason: Based on the proponent’s reason statement. The proposal will continue Chapter 32 as the general cryogens chapter while Chapter 35 will continue to develop as the material-specific chapter for flammable gases and cryogenic fluids. Additional correlation of in-code references is also provided along with clearer direction on the application of the referenced standard, NFPA 55, to bulk systems. The modification clarifies that the exception is only applicable to tanks associated with fuel dispensing.
Assembly Action: None

[Return to List of Proposals]

F193-06/07
"Telecomm cabinets and transfer switches near outdoor hydrogen cabinets" [download PDF] 
Proponent: Paul J. Buehler, Jr., Plug Power, Inc. 

Summary: This code change proposes a modification to Table 3504.2.1 "Flammable gases-Distance from storage to exposures" in:
Chapter 35: Flammable Gases
Section 3504: Storage
Section 3504.2 Outdoor storage

According to the proponent, the purpose of F172 is to clear up some language and to allow the use of NEBS rated fuel cell systems within 5 feet of NEBS rated telephone equipment. 

This code change will allow the location of NEBS rated telecommunications cabinets and National Electrical Manufacturers Association (NEMA) rated outdoor transfer switches to be located within 5 feet of the outdoor hydrogen cabinets discussed in F172. NEBS is an acronym which stands for Network Equipment Building Systems, and is controlled by a series of Telcordia documents. It is the telephone company equivalent of UL listing, essentially. It is very strict, and requires equipment to stand up to brushfire, gunshot, earthquake and wind-driven rain tests. It also has requirements for radio-frequency shielding and a whole host of other things that are not applicable here. 

Also, with this code addition, the disconnect switches will be located between 0 and 4 feet above ground. 

Again, according to the proponent:
The disconnect switch is required for personnel protection while working on the circuitry between the fuel cell and the load. It is not a device which is activated for any other purpose. Therefore, the use of fuses in the disconnect switch is not required. Plus, fuses are placed inside the fuel cell and sometimes at the load, making disconnect fuses redundant and also a possible location for electrical faults. Fuses, unless they are potted, are a spark source, so it is best to avoid them in this application. 

The disconnect switch would only be activated then by a workman. And, logically, the fuel cell would not be in operation when the switch is thrown for electrical reasons. So, the hazard in using an unfused switch is "close to nil." 

Now, that then leads us to the next portion of the question, where should such a switch be located? It needs to be in close proximity to the fuel cell, within 6 feet, depending on how one interprets the National Electric Code. Using certain scientific studies, we know we want this switch to be located someplace where hydrogen gas normally cannot be present - below the ridge vent. 

But, what if there is a low-pressure leak in the external tubing between cabinets? Could not that hydrogen collect in a bad place? The answer is that if a rupture occurs the excess flow valve in the fuel cell system operates and shuts off the flow of hydrogen from the tanks. Then the volume of expelled gas is essentially just that which is in the low pressure tubing, 6.1 cubic inches, which does not constitute a flammable mixture. 

Therefore, this code change proposes that the unfused disconnect switch be allowed to be housed in a general purpose box, at an elevation not to exceed 48 inches above ground. This provides a small factor of safety with reference to the elevation of the ridge vent, 70 inches above ground. 

Committee Action: Disapproved
Committee Reason: For consistency with the action on F172-06/07.
Assembly Action: None


[Return to List of Proposals]


F194-06/07
"Guidance for metal hydride systems" [download PDF] 
Proponent: Larry Fluer, Fluer, Inc., representing Compressed Gas Association

Summary: This proposal adds new sections 3506 and 3502.1 dealing with metal hydride hydrogen storage systems in:
Chapter 35: Flammable Gases (F191 suggests a change to this chapter's title)
Section 3502: Definitions
Section 3506: Metal hydride storage systems

This proposal adds language relevant to metal hydrides. Part of the language had been a part of the fire code before, and was deleted during the last cycle. The committee approved the deletion of the above text based on the fact that it leads the code official to believe that there are listed systems available when, in fact there were none. In addition, standards for testing and listing of the systems were not yet final. In support of the action to strike the language from the code the committee suggested that until such time as there are listing standards… "it would be better if the code included, in codified form, the safeguards that are currently used by the industry for the systems that are currently in use in the field." 

The code change now proposed by the Compressed Gas Association (CGA) is an effort to bring the parties to consensus in a manner that recognizes the presence of these unique systems, and to place fundamental requirements in the code to address their use. 

Like the language approved and rejected before, this proposed language (with some additions) still proposes that the metal hydride container be treated as a flammable gas and not with any special treatment to whatever materials may make up the metal hydride mixture. The reason this is consider a safe practice is because the metal hydride tanks are designed to always contain the metal hydride. Since the metal hydride is expected to always remain in its tank, the thought is that only the substance entering and leaving the tank should be regulated-in this case, the flammable gas: hydrogen. 

Absence of this language will give the code official no guidance on how to regulate metal hydride systems, but interested parties should look at the specific language proposed to identify any impacts to their business. 

Committee Action: Approved as Submitted
Committee Reason: Based on the proponent’s reason statement. The proposal will add needed code provisions on metal hydride storage systems for the absorption and storage of hydrogen.
Assembly Action: None

[Return to List of Proposals]

F229-06/07
"New requirements for indoor hydrogen storage" [download PDF]
Proponent: John C. Dean, The National Association of State Fire Marshals

Summary: This proposal suggests the creation of a new section on indoor hydrogen storage in Chapter 7 of the International Fuel Gas Code.
Chapter 7: Gaseous Hydrogen Systems
Section 706: Location of gaseous hydrogen systems
Section 706.4: Indoor storage of hydrogen

This proposal adds new language to the International Fuel Gas Codeproviding requirements for indoor storage of hydrogen. Interested parties should compare these requirements with other sections in theInternational Fire Code (Chapters 27, 30 and 35) for relevance to indoor hydrogen storage. According to the proponent, these additions differ from anything in existing code in that they stipulate pressure limits, not just quantities of hydrogen gas. Ventilation and alarms are required so that should there be a gas leak, it is detected and there is no chance of asphyxiation. 

Committee Action: Disapproved
Committee Reason: Should be a subsection in IFGC Section 706.2.
Assembly Action: None


[Return to List of Proposals]


International Mechanical Code

M56-06/07
"Ventilation requirement moved from exhaust to ventilation"[download PDF] 
Proponent: Ronald Marts, Telcordia, representing AT&T, SBC, Ameritech, PacBell, Cincinnati Bell, BellSouth, Qwest and Southern New England Telephone

Summary: This proposal moves language from the exhaust section of Chapter 5 of the International Mechanical Code to the ventilation section. It appears that the ventilation requirement for stationary storage battery systems was inadvertently put in the "exhaust" chapter of the IMC instead of the ventilation chapter. Language appears to be unchanged during the relocation. 

Chapter 5: Exhaust systems
Section 502: Required systems

Chapter 4: Ventilation Systems
Section 407 (New section): Ventilation of Stationary Storage Battery Systems

Analysis from Fire Code Committee: It is not clear why the proponent did not propose to relocate other sections of 502 that also address ventilation rather than exhaust. The code does not distinguish between ventilation by means of exhaust systems or by means of supply air systems

Committee Action: Disapproved
Committee Reason: The proposal was not considered to be comprehensive enough; there are other sections in the exhaust section that also address ventilation.
Assembly Action: None

[Return to List of Proposals]

International Fuel Gas Code

FG54-06/07
"H2 Piping-Concealed Locations" [download PDF]
Proponent: Guy Tomberlin, Fairfax County, Virginia, representing Virginia Plumbing and Mechanical Inspectors Association (VPMIA) and the Virginia Building Code Officials Association (VBCOA) 

Summary: This code proposal suggests the deletion of a couple words in part of the International Fuel Gas Code
Chapter 7: Gaseous hydrogen systems
Section 704: Piping, use and handling
Section 704.1: Applicability
Section 704.1.2: Piping systems
Section 704.1.2.3 Piping design and construction
Section 704.1.2.3.5: Protection against physical damage

In the last cycle, it was approved to not permit hydrogen piping to be located inside in a concealed location. This will maintain clarity in a section affected by the previous decision. The rest of the text is important to remain because piping could potentially be installed that is exposed on one side of a wall ceiling or floor but could still have a covering installed on the other. 

Committee Action: Approved as Submitted
Committee Reason: Current code does not permit hydrogen piping to be concealed.
Assembly Action: None

[Return to List of Proposals]

Fire Safety Code of the International Building Code

FS37-06/07
"Fire barrier definition" [download PDF] 
Proponent: Philip Brazil, P.E, Reid Middleton, Inc., representing himself

Summary: The definition of fire barrier was revised last cycle from begin a vertical or horizontal assembly to being a wall assembly and by deleting the provisions for horizontal fire barriers. The proposal, however, did not make the necessary revisions to other sections of the International Building Code, which are needed in order for the concept to be fully incorporated into the provisions of the IBC. The purpose of this proposal is to make the necessary revisions to the provisions in those code sections. 

This proposal recommends small changes to many different sections of several I-Codes. 

Errata: Replace the proposal shown in the monograph with the text in this errata:

FS37-06/07 Errata (99Kb PDF) 


PART I — IBC FIRE SAFETY
Committee Action: Approved as Submitted
Committee Reason: The proponent has correctly addressed an inconsistency in the code which has been caused by the changes made by FS2-04/05 in a previous code change cycle. Those changes made the distinction that fire barriers were walls and did not include horizontal assemblies. By going through these sections and making these changes, it provides consistency between the intent of FS2-04/05 and between the sections which were not addressed by that proposal. This action also is consistent with the action taken by the IFC committee earlier.
Assembly Action: None

PART II — IBC GENERAL
Committee Action: Approved as Submitted
Committee Reason: The revisions to add horizontal assemblies in addition to fire barriers are consistent with changes made to other portions of the code in the 2006 edition. This action is also consistent with the action on Part I of the proposal.
Assembly Action: None

PART III — IBC MEANS OF EGRESS
Committee Action: Approved as Submitted
Committee Reason: The revised language in Sections 1021.3 and 1022.2. would provide consistency in the code for the usage of the terms fire barriers and horizontal assemblies.
Assembly Action: None

PART IV — IFC
Committee Action: Approved as Submitted
Committee Reason: The proposal completes a needed correlation effort undertaken in the 2004/2005 cycle to provide consistent terminology and references when referring to fire barrier and horizontal assembly enclosures.
Assembly Action: None

Reference

Industry Responds to DOT Gap Analysis
Karen Hall, National Hydrogen Association

In its report entitled Hydrogen Infrastructure Safety Technical Assessment and Research Results Gap Analysis, DOT-T-06-01, April 2006, (DOT Report - see Hydrogen and Fuel Cell Safety, August 2006) the U.S. Department of Transportation (DOT) has provided a starting point for assessing existing regulations within DOTs purview, and determining where research is needed to revise existing regulations or develop new regulations, and where amendments may be necessary to enable the hydrogen infrastructure. DOT has identified the status of applicable regulations for hydrogen infrastructure. DOT is requested stakeholder feedback on its report to assist in prioritizing future efforts.

The NHA took up the challenge to coordinate feedback. Two articles describing the report and inviting stakeholder input were published in the NHA’s Hydrogen and Fuel Cell Safety Report (August 2006 andJuly 2006). In addition, the NHA’s Codes & Standards Coordinating Committee and the US Fuel Cell Council were specifically asked for input and to review draft responses. The topic was also the subject of an In-Person meeting of the National Hydrogen and Fuel Cell Codes & Standards Steering Committee (Hydrogen and Fuel Cell Safety, September 2006, listed under item 4.0) in September in Detroit, Michigan.

After many discussions and iterations, I am pleased to announce that the US Fuel Cell Council and the NHA Codes & Standards Steering Committee have endorsed the industry report. It was delivered to DOT on December 5, and contains specific feedback on the following topics:

Issues Raised by the Industry Sector

  • Issues from Original Equipment Manufacturers (OEMs)
  • Hydrogen Infrastructure
  • Fuel Cell Manufacturers
  • Portable Power Suppliers

Discussion of Gaps

  • Stationary Applications
  • Transportation Applications
  • Portable and Micro Applications
  • Hydrogen Infrastructure

The industry welcomes further dialog with DOT on the issues identified. Through continued coordination, research funding can be targeted at areas with the greatest needs, consistent with commercialization timeframes, and consistent to support related research work timetables, reducing the need for duplication of effort.

Final Industry Report on the DOT Gap Analysis (191Kb PDF)

Which Type of Document?
Karen Hall, National Hydrogen Association

There are many types of documents of interest to those of us involved in developing codes and standards, but how do they differ? This article provides basic information on the definitions of codes, standards, regulations, technical specifications, technical reports, information reports, and recommended practices. It is intended to help the reader understand what is implied by the type of document chosen, and to help assess which type may be most appropriate for a new activity.

Codes
The Merriam Webster dictionary defines a code as a "systematic statement of a body of law," or "a system of principles or rules." They generally apply to construction, or the built environment. Codes establish minimum requirements for things like offset distances between permanent fixtures, ventilation requirements, plumbing and electrical requirements, and other items relating to a built environment. A code may reference a standard. If you are adding a deck onto your home, or expanding your porch, or installing a hot tub on your deck, you will need to get a permit. The jurisdiction having authority over your project will want to see proof that the job will be done in a way that conforms to existing codes. The code may reference applicable standards, such as Underwriters Laboratory (UL) standards, for example.

Codes are meaningless unless a state or local jurisdiction adopts them. There are over 44,000 local code enforcement agencies in the US alone. They have the option of adopting any model code from any year, and may make local code amendments. This leads to the potential for a lot of variation in codes. Codes most often encountered in the hydrogen and fuel cell arena include ICC and NFPA codes.

Standards
Webster defines a standard as "something set up as a rule for measuring or as a model to be followed." This does not appear to be very different from a code. In some cases, they really aren’t very different. Often when we talk about a standard for hydrogen system or component, we are talking about standards for the component or system, rather than the standard for installation, although those exist as well. A standard might be performance based, i.e., "each unit must meet the following tests," or it may be a design standard, i.e., "the nozzle must be made of the following materials, and have the following dimensions." Standards for manufacturing or testing unit are independent of where the unit will be used. But standards are not mandatory until they are called out someplace, such as in a code, regulation, procurement contract, or other requirements document. What standards do allow, however, is a consensus process for developing minimum technical requirements to assure uniformity of the product, including safety and performance. And often when a regulator or code official is unfamiliar with an emerging technology or new equipment design, having a standard gives that official a starting place for evaluating the technology. In addition, it gives the official some confidence that the information is based on best practices and industry consensus. It takes much of the guesswork out of the equation.

Regulations
Webster further defines a regulation as "a rule dealing with details of procedure," or "an order issued by an executive authority of a government and having the force of law." For example, in the United States we have regulations from the Department of Transportation that relate to transporting dangerous and hazardous goods. The Federal Aviation Administration (FAA) has regulations regarding what can and cannot be brought onboard an aircraft, how often an aircraft is inspected, how many consecutive hours a pilot can be on duty, etc. These regulations are generally safety-oriented.

Technical Specifications (TS)
Technical Specifications are used by ISO and IEC, among others, when the subject in question is still under development, or where for any other reason there is a future but not immediate possibility of an agreement to publish a standard. In this case it is used for "pre-standardization purposes."

A TS may also be used when the required support cannot be obtained for a final draft International Standard to pass the approval stage, or in case of doubt concerning consensus. In ISO and IEC, Technical Specifications are subject to review by the technical committee or subcommittee not later than 3 years after their publication. The purpose of this review is to re-examine the situation which resulted in the publication of a Technical Specification and if possible to achieve the agreement necessary for the publication of an International Standard to replace the Technical Specification.

Publicly Available Specifications (PAS)
In ISO or IEC a PAS may be an intermediate specification, published prior to the development of a full International Standard, or, in IEC may be a “dual logo” publication published in collaboration with an external organization. It is a document not fulfilling the requirements for a standard. A PAS remains valid for an initial maximum period of 3 years. The validity may be extended for a single 3-year period, following which it shall be revised to become another type of normative document (such as an International Standard), or shall be withdrawn.

Technical Reports (TR)
When a technical committee or subcommittee has collected data of a different kind from that which is normally published as an International Standard (this may include, for example, data obtained from a survey carried out among the members, or data on the "state of the art" in relation to standards of national bodies on a particular subject), the work may be published in the form of a Technical Report. TRs are entirely informative in nature. The technical committee or subcommittee responsible decides on withdrawal of a Technical Report.

SAE Documents
The Society of Automotive Engineers (SAE) issues the following types of documents. The descriptions of each type was found on the SAE website at www.sae.org.

  • SAE Standards: These Technical Reports are a documentation of broadly accepted engineering practices or specifications for a material, product, process, procedure or test method.
     
  • SAE Recommended Practices: These Technical Reports are documentations of practice, procedures and technology that are intended as guides to standard engineering practice. Their content may be of a more general nature, or they may propound data that have not yet gained broad acceptance.
     
  • SAE Information Reports: These Technical Reports are compilations of engineering reference data or educational material useful to the technical community.

So while codes, standards, and regulations are each important requirements to protect the public, in most cases each has a unique niche. Codes generally apply to the built environment. Standards generally apply to components, systems, and testing. And regulations generally apply to transportation or rules of procedure. Each standards development organization and code development organization has specific rules for their process for consensus, and the requirements for different document types vary. For example, the ISO process for a Technical Report requires less consensus, and therefore less time, than the process for an International Standard, which has the most stringent requirements to assure consensus.

Now that we have a general feel for the differences, I’d like to point out one very real similarity. Development of a new code, standard, regulation, or any other document type listed above takes 2-5 years on average (sometimes MUCH longer). That is due to the fact that industry consensus is required, sometimes nationally, sometimes internationally. Often there is too little data available upon which to proceed. So the process slows while appropriate testing is conducted.

The need is real for hydrogen and fuel cell safety documents. And in many cases it is more immediate than the 2-5 year timeframe. I encourage you to be an active participant in the process. Those who take part in the development of the codes and standards are part of the consensus process. Please don’t rely on your competitors to do it for you. If you do, the resulting document may not support your product, and it may take longer to get a suitable document published.

We recognize that most companies cannot dedicate the resources necessary to participate in every code or standard activity. It is even difficult to identify what activities are most important for your industry or product. That is why the NHA has a robust codes and standards program. It is also why the U.S. Department of Energy, through the National Renewable Energy Laboratory, has created the National Hydrogen and Fuel Cell Codes and Standards Coordination Committee. Together, we will help provide the tools and information you need to determine where to spend your resources. Please take a few moments each month to review the Hydrogen & Fuel Cell Safety Report. Review the Documents for Review section periodically to review ongoing efforts, and provide comments. In this way, your concerns can be noted and brought to the appropriate code or standard activity. Review the posted Minutes of the monthly National Hydrogen and Fuel Cell Codes & Standards Coordinating Committee meetings. And please take a moment to review the hydrogen and fuel cell codes and standards Matrix, maintained by Kelvin Hecht and located at www.fuelcellstandards.com/Matrix.htm. Feedback is important to allow us to keep helping you. Remember we all need to work together. Safety is not proprietary, and the documents don’t write themselves!

Safety Training Course Planned for NHA’s Annual Conference
Karen Hall, National Hydrogen Association

The National Hydrogen Association has announced it has reached agreement with the European Natural Gas Vehicle Association to conduct a 1-day seminar in conjunction with the NHA’s Annual Conference being held March 19-22, 2007 in San Antonio, Texas. NATURAL GAS AND HYDROGEN SAFETY TRAINING: A One Day Seminar on Vehicles and Fuelling Systems will be held on Friday March 23. A separate registration fee is required for this course, which in the past has been presented at the ENGVA headquarters in Amsterdam, The Netherlands. Interested parties will be able to register for this seminar shortly online atwww.hydrogenconference.org.

This one day training seminar covers all the safety aspects about natural gas vehicles (NGVs), hydrogen vehicles (H2Vs) as well as natural gas and hydrogen fuelling stations. Both compressed and liquefied gaseous fuels (cryogenics) are included.

Course Description (141Kb PDF)

To see the Program for the NHA's 2007 Hydrogen Conference and Hydrogen Expo, please visit www.hydrogenconference.org.