National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: MEMORANDUM To: From: NFPA Technical Committee on Gas Hazards Lawrence Russell, Staff Liaison Date: March 20, 2012 Subject: NFPA 306 ROP TC Circulation Ballot (A2013) The March 16, 2012 date for receipt of the NFPA 306 ROP TC letter ballot has passed. The preliminary ROP ballot results are as follows: 14 Members Eligible to Vote 4 (J. Daddura, P. Manzi and J. Riva) In accordance with the NFPA Regulations Governing Committee Projects, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or before Wednesday, March 28, Members who have not returned a ballot may do so now. Such changes should be sent to Diane Matthews via either to dmatthews@nfpa.org or via fax to You may also mail your ballot to the attention of Diane Matthews at NFPA, 1 Batterymarch Park, Quincy, MA The return of ballots is required by the Regulations Governing Committee Projects. Attachment: Circulation Explanation Report

2 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Entire Document (Log # CP1 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Entire Document (Log # CP9 ) Affirmative with Comment

3 2 Raffo, D. The 306 committee requested that I provide a rewrite of the old chapter 4 which is confusing and does not follow the natural progression of an inspection. A proposal is included which changes the sequence and deletes duplicate instructions. It is requested that the committee consider this rewrite. It should be noted that some of the wording does not include the proposed changes to 306. If the new wording is accepted it will replace the current wording. No new requirements have been imposed and a minimum of wording has been added. The new sequence follows the way a Marine Chemist conducts their inspection and I believe it is clearer without changing the intent or existing requirements. The committee should consider this change. It was presented at the Atlantic Sectional Seminar and the chemists agreed that it is clearer and follows the way inspections are conducted. The suggested changes are below. PROPOSED NEW CHAPTER 6 (From old Chapter 4) Chapter 6 Requirements Prior to and During a Marine Chemist Inspection 6.1 Calibration of Instrumentation and Record Keeping 6.1.1* The accuracy and sampling integrity of all instruments used by the Marine Chemist shall be verified before each day's use by using with a known concentration of test gases in a manner consistent with the manufacturer's recommendations This record of calibration shall be maintained for at least 3 months. 6.2 Determinations Required Prior to Inspection The Marine Chemist's determinations shall include the following: (1) The three previous cargo loadings (2) Nature and extent of the work (3) Starting time and duration of the work 6.3 Determinations Required During Inspection The Marine Chemist shall personally determine conditions, and shall whenever possible, physically enter each compartment or space to be certified and adjacent spaces when necessary to conduct a visual inspection to the extent necessary to determine atmospheric or fire hazards that may exist within each (affected) compartment or space, ensuring compliance with the minimum applicable requirements prior to issuing a Certificate For repair or alterations involving entry or hot work Marine Chemist shall carry out tests in the affected space and in the case of hot work on all adjacent spaces to determine the atmospheric or fire hazards that may exist within each affected compartment or space, ensuring compliance with the minimum applicable requirements prior to issuing a Certificate During the inspection the Marine Chemist shall. (1) Conduct tests of cargo lines, vent lines, manifolds, heating coils or other pipelines and accessible openings associated with the scope of work on or in the compartments concerned. (2) Verify that cargo lines, vent lines, manifolds, heating coils or other pipelines associated with the scope of work on or in the compartments concerned which could release hazardous materials into spaces that will be certified ATMOSPHERE SAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by a positive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict, operation Current wording follows. Chapter 4 Minimum Requirements for Issuance of Marine Chemist's Certificate and Maintenance Conditions 4.1 Determination of Conditions. The Marine Chemist shall personally determine conditions, and shall be permitted to issue a Marine Chemist's Certificate setting forth in writing that the prescribed work to a vessel can be undertaken with safety. The Marine Chemist shall, whenever possible, physically enter each compartment or space and conduct a visual inspection to the extent necessary to determine the atmospheric or fire hazards that exist. The Marine Chemist shall carry out tests within each compartment or space, ensuring compliance with the minimum applicable requirements prior to issuing a Certificate. 4.2 Procedures Prior to Issuance of a Certificate.

4 4.2.1 Calibration and Function Verification The accuracy and sampling integrity of all instruments used by the Marine Chemist shall be verified before each day's use by using with a known concentration of test gases in a manner consistent with the manufacturer's recommendations This record of calibration shall be maintained for at least 3 months The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified; and for repair or alterations involving hot work, all adjacent cargo tanks, spaces adjacent to cargo tanks, and other adjacent spaces containing or having contained flammable or combustible cargo, fuels, or oils in accordance with 4.3.4(4). The determinations also shall include the following: (1) The three previous cargo loadings (2) Nature and extent of the work (3) Starting time and duration of the work (4) Tests of cargo and vent lines at manifolds and accessible openings (5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERE SAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by a positive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict, operation (6) Tests of cargo heating coils Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 69 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 104 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : and A.1.4 (Log # 72 ) 3

5 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Chapter 2 (Log # CP2 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 105 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 2.2, 2.4, E.1(a), (b), (c), and F.1.1 (Log # 61 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Chapter 3 Various Definitions (Log # 62 )

6 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : x Gas-Free (New) (Log # 106 ) Affirmative with Comment Raffo, D. While I agree with the committee's action, I believe the substantiation could be changed. The term gas free in its various forms is used about six times in 306. It is also used throughout the industry and means many things. The use of the term can indicate a process and can also indicate a condition. It is also defined differently by different industry groups. An attempt to define it tailored to 306 could potentially create additional confusion in the industry. Therefore I agree that it should not be defined in 306, but my reason differs from the committee statement/substantiation Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Adjacent Spaces (Log # 31 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Adjacent Spaces (Log # 73 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Adjacent Spaces (Log # 92 )

7 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Combustible Material (Log # 90 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Marine Chemist and A (New) (Log # 91 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Marine Chemist's Certificate (Certificate) (Log # 41 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Marine Chemist's Certificate (Certificate) (Log # 74 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Subject Space (New) (Log # 58 )

8 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Vessel (Log # 96 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Barge (Log # 45 ) Affirmative with Comment Raksnis, R. Committee statement should include stating that bow thrusters are not considered primary means of propulsion but assist in maneuvering the barge alongside the pier or other vessels Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Hot Work (Log # 70 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Hot Work (Log # 102 )

9 8 Affirmative with Comment Raffo, D. I believe that the word "safe" was left out in section C during the committee action. I believe that section C should read: (C) Grinding, drilling, abrasive blasting, the activation of non-intrinsically safe or non-explosion-proof equipment or similar operations in the presence of or against accumulations of readily combustible materials or flammable or combustible liquids or their vapors when the atmosphere exceeds 10 percent of the LEL Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : Hot Work (Log # 103 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 44 ) Eligible To Vote:14 Affirmative: 9 Negative: 1 Abstain: 0 : and A (New) (Log # 75 ) Negative

10 9 Raksnis, R. I oppose removal of "in a manner consistent with manufacturer's recommendations" as I see this as an important step to ensure the calibration and testing of equipment is performed in the right manner. I have concerns that marine chemists may choose an alternate method which may produce a false positive indicating that equipment has been calibrated when it is actually out of calibration. Affirmative with Comment Blaize, L. A we should look at the committee action to assure that because this is in the annex it will allow for a CMC to "verify the accuracy" if cal gas is not available. Raffo, D. During discussion with chemists during the mini seminar the following change was suggested to this section. The word calibration can mean many things and may not include a bump test. To cover this issue the committee should consider the following wordin: * The accuracy and sampling integrity of instruments used by the Marine Chemist shall be verified before each day's use. Verification of sensors accuracy shall be conducted using a known concentration of test gas. Calibration of sensors shall be verified using a known concentration of test gas Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 76 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 54 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 55 )

11 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 77 ) Affirmative with Comment Blaize, L. (7) add "as necessary" after "carry out tests" so all combustibles will not have to be tested. Raffo, D. The following change in wording is suggested. The current wording may be interpreted as requiring a chemist to carry out a test to determine if a rug can be a fire hazard. The suggested change follows: (7) In spaces which are not cargo tanks or are not adjacent to cargo tanks the Marine Chemist shall carry out tests and/or inspections as necessary to determine the atmospheric or fire hazards that may exist within each affected compartment or space, and any adjacent spaces which may be affected by hot work, ensuring compliance with the minimum applicable requirements prior to issuing a Certificate Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 95 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (1) (Log # 35 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (1) (Log # 38 )

12 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (5) (Log # 1 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (6) (Log # 47 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (7) (New) (Log # 94 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 2 )

13 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 3 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : and 4.6 (Log # 63 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 32 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 37 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 93 )

14 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) (Log # 78 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (1) (New) (Log # 39 ) Affirmative with Comment Raffo, D. The word "or" should be inserted to make it clear that either ppe or clothing or time requirements shall be required. The current wording may lead someone to think that both ppe and clothing is required. Suggested wording follows: (1) The Certificate shall include a statement describing the specific conditions of personal protection equipment or clothing, or time, or any, or all of the aforementioned. These areas shall be listed on the Certificate under the heading "Restrictions." Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 4 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 57 )

15 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 5 ) Affirmative with Comment Blaize, L. (3) add "soft and greasy" before "preservative coatings" Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 52 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) (Log # 6 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) (Log # 53 )

16 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) and (5) (Log # 79 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (5) (Log # 7 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (6) (Log # 8 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 71 )

17 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 80 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (D) (Log # 66 ) Affirmative with Comment Raksnis, R. Suggest add word "materials" after the word "combustible" to be consistent with rest of document Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 81 ) Affirmative with Comment Raffo, D. The committee failed to address section c in its action. While sections a and b were addressed, c was missed and was not included in the substantiation. I believe section c should be included and should read as follows: (c) Portions of the space or compartment meet the requirements of 4.3.4(3) and (4) or (5), as well as the applicable portions of 5.1.3, and the hot work shall be limited to the location or locations described in the "limitations" in 4.3.6(2) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3)(b) (Log # 42 )

18 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (1) (Log # 50 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (2) (Log # 9 ) Affirmative with Comment Blaize, L. Add "cargo and fuel" after "space". Raffo, D. I suggest inserting the word "or" into the sentence to make it grammatically correct. Spaces other than cargo tanks or fuel tanks have has been filled to overflow with water and the water level shall be maintained throughout the intended work. Valves shall be tagged or by written notice positioned to restrict operation to maintain the water level. If any headspace remains in the tank, it shall meet the requirements of 4.3.4(2). Any such procedure shall be approved by the Marine Chemist Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 10 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) (Log # 11 )

19 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 33 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 43 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 107 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : and A (Log # 82 )

20 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (d) (Log # 51 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (1) (Log # 67 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 28 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (3) (Log # 97 ) Eligible To Vote:14 Affirmative: 9 Negative: 1 Abstain: 0 : (3) and A.4.6.2(2) (New) (Log # 83 )

21 20 Negative Raksnis, R. I am concerned that although work may not be done directly on the subject space, other type of work outside the space may affect the integrity of the space in continuing to meet the conditions on the Certificate. For example, an unmarked valve may be opened in a remote space which may impact the piping network in the subject space. Under the proposed changes, the competent person would not have to check the space since no work was actually done or planned to be done in the space. Allowing the competent person to skip a couple days of testing puts at risk that conditions could change without their knowledge putting at risk the entry personnel. Affirmative with Comment Raffo, D. There is an error in the heading which indicates a change to section A.4.6.2(2). The correct section should be A (3) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (4) (Log # 30 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Chapter 5 (Log # 12 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Chapter 5, Title (Log # 101 )

22 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 49 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # CP6 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 48 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (C) (Log # 13 )

23 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 14 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : , , and (Log # 64 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 56 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 15 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 84 )

24 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 16 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 17 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 85 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 86 )

25 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 87 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 18 ) Eligible To Vote:14 Affirmative: 9 Negative: 1 Abstain: 0 : and A.5.8 (New) (Log # 88 ) Negative Blaize, L. 5.8 leave out "immediately". It is either adjacent or not. Trying to define immediately as some nebulous distance would be confusing. A.5.8 leave out totally. We have referenced OSHA 1915 in the text and there is no need to single out this part for special attention in the annex. It was poorly written by OSHA and has been misunderstood and misapplied by industry ever since Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 19 )

26 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 20 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 21 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 22 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 23 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 65 )

27 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Chapter 7 (Log # CP7 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 24 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 25 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # CP8 )

28 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 26 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : (Log # 27 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (New) (Log # 60 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 40 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (New) (Log # 59 )

29 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 99 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 100 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A.4.3.1(3) (Log # 34 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A.4.3.1(3) (Log # 46 )

30 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 108 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 29 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (Log # 89 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A.4.6.2(3) (Log # 98 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A.5.1, A.5.2, A.5.3, A.5.4, A.5.5, A.5.8 (New) (Log # CP4 )

31 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 A (New) (Log # CP5 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Annex B (Log # CP11 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Annex C (Log # 109 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 D.1(2) (Log # 110 )

32 Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Table E.1(a), Table E.1.(b) (Log # CP10 ) Eligible To Vote:14 Affirmative: 10 Negative: 0 Abstain: 0 : 4 Annex F (Log # CP3 )