Second Revision No. 1-NFPA [ Section No. 2.2 ] Submitter Information Verification. Committee Statement 9/12/ :41 AM

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1 Second Revision No. 1-NFPA [ Section No. 2.2 ] 2.2 NFPA Publications. National Fire Protection Association, 1 Batterymarch Park, Quincy, MA NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition. NFPA 13, Standard for the Installation of Sprinkler Systems, edition. NFPA 15, Standard for Water Spray Fixed Systems for Fire Protection, 2012 edition. NFPA 70, National Electrical Code, 2014 edition. NFPA 72, National Fire Alarm and Signaling Code, edition. NFPA 80, Standard for Fire Doors and Other Opening Protectives, edition. NFPA 90A, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2015 edition. NFPA 101, Life Safety Code, 2015 edition. NFPA 220, Standard on Types of Building Construction, 2015 edition. NFPA 221, Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier Walls, 2015 edition. Submittal Date: Tue Jul 29 16:07:09 EDT 2014 Committee Statement: Response Message: Update referenced standards, which are in the same revision cycle as NFPA 40, to most recent edition. of 14 9/12/ :41 AM

2 of 14 9/12/ :41 AM Second Revision No. 2-NFPA [ Section No ] ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA ASTM E 84 E84, Standard Test Method for Surface Burning Characteristics of Building Materials, 2013a 2014 edition. Submittal Date: Tue Aug 05 11:00:26 EDT 2014 Committee Statement: This revision updates the standard to the most recent edition. Public Comments 3 and 8 were both accepted. Response Message: Public Comment No. 3-NFPA [Section No ] Public Comment No. 8-NFPA [Section No ]

3 of 14 9/12/ :41 AM Second Revision No. 3-NFPA [ Sections , ] Decomposition Vent. A vent to permit the escape of gases resulting from partial burning or decomposition of decomposition or from incomplete combustion of nitrate film. Submittal Date: Tue Aug 05 11:12:54 EDT 2014 Committee Statement: Response Message: The committee agrees that revisions to provide clarity to the document, but should remain as written. The ignition materials are decomposition gases. Public Comment No. 11-NFPA [Sections , ]

4 of 14 9/12/ :41 AM Second Revision No. 12-NFPA [ Section No. 6.1 ] 6.1 General. Nitrate film that is not in process or being worked on shall be stored as follows: (1) (2) * Amounts exceeding 11 kg (25 lb), or 5 standard rolls, but not exceeding 340 kg (750 lb), or 150 standard rolls, shall be stored in approved cabinets or in vaults. (See Sections 6.2 and 6.3.) * Amounts exceeding 340 kg (750 lb), or 150 standard rolls, shall be stored in vaults. (See Section 6.3.) (3) Extended term storage film shall be stored in extended term storage cabinets or extended term storage vaults, which are subject to the limitations of Section 6.1(1) and 6.1(2). (See Sections 6.4 and 6.5.) Supplemental Information File Name A.6.1.1_and_.2_lm_edit.docx Description Submittal Date: Tue Aug 12 11:25:30 EDT 2014 Committee Statement: The committee agrees with the Public Comment but moved some unenforceable, explanatory text to Annex A. This change incorporates approximate equivalencies into the body of the code, where they are more likely to be recognized by archivists and AHJs. At the time of this writing, few institutions with flat film holdings are in compliance with NFPA 40. One reason for this lack of compliance appears to be a general understanding that NFPA 40 applies to motion picture film alone--an understanding that is somewhat encouraged by the text of the code. This change also incorporates an equivalency based upon volume. The task force convened by NFPA 40 weighed sheet film stored in individual sleeves in a storage container measuring 4 x 9 x 10.5 (0.22 cubic feet). The total mass of cellulose nitrate in the box was kg. We therefore estimate that a single cubic foot would contain approximately 7.5 kg of cellulose nitrate material. Flat film storage contains a significant quantity of other flammable content. Best preservation practice calls for the storage of negatives in individual sleeves, usually constructed of paper or inert plastic. Due to the sheer quantity of this content in a typical flat film storage container, the task force believes it to be a mitigating factor for fire risk. In the storage container sampled by the task force, there was 1.38 kg of paper--a mass nearly equal to the mass of cellulose nitrate material. Annex: The new annex sections A.6.1(1) and A.6.1(2) make A.6.1 redundant.

5 of 14 9/12/ :41 AM Response Message: Public Comment No. 14-NFPA [Section No. 6.1] Public Comment No. 15-NFPA [Section No. A.6.1]

6 A.6.1 (1) For reference, 11 kg (25 lb) corresponds to approximately five 1000 ft rolls of 35 mm motion picture film, or approximately in. negatives, or approximately in. negatives. 11 kg (25 lb) also corresponds to approximately 0.5 ft 3 of motion picture film, or 1.5 ft 3 of individually sleeved, flat film negatives. A.6.1 (2) For reference, 340 kg (750 lb) corresponds to approximately ft rolls of 35 mm motion picture film, or approximately 45 ft 3 of individually sleeved flat film negatives. 340 kg (750 lb) also corresponds to approximately 15 ft 3 of motion picture film, or 45 ft 3 of individually sleeved, flat film negatives.

7 Second Revision No. 13-NFPA [ Section No. 6.4 ] 6.4* Extended Term Storage Cabinets Extended term storage cabinets shall be provided with individual drawers or compartments, each holding not more than 610 m (2000 ft) of film. Individual compartments shall be separated by 9.5 mm ( 3 8 in.) of noncombustible insulating material. Each compartment shall be provided with a hinged damper or similar device to allow release of decomposition gases into the cabinet vent Extended term storage cabinets shall be provided with automatic sprinklers when holding more than 23 kg (51 lb) of nitrate film * Each extended term storage cabinet having a capacity of more than 23 kg (51 lb), or 10 standard rolls, of film shall be provided with a vent to the outside of the building. The vent shall have a minimum crosssectional area of 90 cm 2 per 45 kg (14 in. 2 per 100 lb), or 200 standard rolls of film capacity Decomposition vent pipes shall be of No. 18 U.S. gauge riveted steel or equivalent. Where located within the building, decomposition vent pipes shall be covered with 25 mm (1 in.) of noncombustible insulating material. Supplemental Information File Name A.6.4_lm._edited.docx Description Submittal Date: Tue Aug 12 13:38:38 EDT 2014 Committee Statement: This revision adds Annex A material to section 6.4. The committee agrees with Public Comment 17 but made a minor change to the language. The best available data suggests that the majority of archival institutions can (and do already) pragmatically implement similar storage. 63% of CoSA members who are subject to special extended term storage requirements under NFPA 40 already use some sort of freezer storage for their nitrate, while 9% use NFPA 40 compliant extended term vault or cabinet storage. Subfreezing temperatures halt cellulose nitrate decay. Freezing is the only known method for halting the secondary autocatalytic mechanisms of decay. (Heckman 2010, p. 500 citing Bigourdan, From the Nitrate Experience p 61.) This revision covers configurations for varying quantities. Note: Supporting documentation was provided in the first round of public input. of 14 9/12/ :41 AM

8 of 14 9/12/ :41 AM Response Message: Public Comment No. 17-NFPA [New Section after A.6.4.3]

9 A.6.4 Low temperatures slow nitrate decay. Freezing temperatures halt nitrate decay. Laboratory-grade refrigerators or freezers are recommended for extended term storage of amounts of cellulose nitrate film not exceeding 11 kg (25 lb). A freezer or refrigerator complying with through is acceptable for extended term storage of cellulose nitrate film in amounts exceeding 11 kg (25 lb) but not exceeding 340 kg (750 lb). Low or freezing temperatures are also recommended for vault storage complying with through for amounts exceeding 340 kg (750 lb).

10 Second Revision No. 5-NFPA [ Section No. 7.2 ] 7.2 Containers Required. All nitrate film shall be kept in closed, individual metal cans or DOT- approved containers unless in use * Nitrate motion picture film shall be stored in closed metal cans or DOT-authorized containers * Nitrate flat film shall be stored in DOT-authorized containers. Supplemental Information File Name A.7.2.1_and_7.2.2_edited.docx Description Submittal Date: Tue Aug 05 11:51:05 EDT 2014 Committee Statement: DOT-authorized containers may be used in place of metal cans for motion picture film. This revision also specifies that DOT-authorized containers should be used to store flat film. Annex material provides guidance on DOT-authorized containers and best practices for storing flat film. The word individual is ambiguous in the current code. Its meaning is not clear to the members of the task force, and the task force recommends that it be removed. Multiple rolls might be stored in a single can, but in this case, the total quantity of cellulose nitrate film would be less than 1,000 feet. No 1,000 foot size 35mm cans known to the task force are currently manufactured that would store more than a single roll of approximately 1,000 feet. Annex: Annex material proposed by Public Comment 20 has been attached to section in Second Revision 5. Section 7.2 is now a heading, and A.7.2 is to be deleted. Response Message: Public Comment No. 19-NFPA [Section No. 7.2] Public Comment No. 20-NFPA [Section No. A.7.2] of 14 9/12/ :41 AM

11 A Examples of DOT-authorized containers are in 49 CFR A Flat film should be stored in individual buffered (high calcium carbonate reserve) four-fold envelopes in DOT-authorized containers. Buffering will help neutralize the acid. Examples of DOT-authorized containers are in 49 CFR

12 of 14 9/12/ :41 AM Second Revision No. 6-NFPA [ Section No ] 8.1.2* No more than 34 kg (75 lb) of nitrate film shall be allowed in the projection booth unless stored in an approved cabinet in accordance with Chapter 6. Supplemental Information File Name A.8.1.2_lm._edited.docx Description Submittal Date: Tue Aug 05 13:10:57 EDT 2014 Committee Statement: Projectionists are accustomed to length, rather than weight, measurements. This additional language will help to clarify the amounts allowed. The typical reel size in a modern projection booth is 2,000 feet. The committee moved the explanatory material converting the mass of film to length of film to the annex. Response Message: Public Comment No. 21-NFPA [Section No ]

13 A Thirty-four kg (75 lb) of nitrate film is approximately 15,000 linear feet.

14 0 of 14 9/12/ :41 AM Second Revision No. 10-NFPA [ Section No. B.1 ] B.1 Hazards. The most dangerous aspects of cellulose nitrate motion picture film are its ease of ignition, its very high rate of combustion, and its extremely poisonous combustion gases. Cellulose nitrate film decomposes readily when heated to temperatures above ambient but below its ignition temperature. The decomposition is both exothermic and autocatalytic. The quantity of heat produced by decomposition is such that, if not dissipated, it can rapidly raises the temperature of the film to the ignition point. Even local heating can raise the temperature of the film to a dangerous level, initiating decomposition in the entire mass. Cellulose nitrate also contains enough oxygen within its molecule so that decomposition or combustion proceeds rapidly, even in a limited air supply. A fire in cellulose nitrate film, therefore, cannot be extinguished by smothering. Cellulose nitrate film is not itself explosive and is less flammable than certain other nitrated compounds. Its ignition temperature is given generally as about 149 C (300 F), but the exact value depends on the duration of exposure, size and purity of film, and other factors. For example, in a laboratory test a sample of fresh nitrate film base ignited in air at 163 C (325 F) within 80 seconds; at 204 C (400 F), ignition occurred in 10 seconds; and at 260 C (500 F), in only 3 seconds. Residual chemicals from processing, dirt, or foreign material can lower the ignition temperature. Investigations conducted after the Cleveland Clinic fire of 1929 showed that temperatures above 93 C (200 F) were unsafe for nitrate film and that exposed steam pipes and unprotected light bulbs were dangerous in rooms containing nitrate film. Improperly cared-for nitrate film has caused fires after several hours storage at temperatures as low as 49 C (120 F). Also, spontaneous ignition is believed to have been responsible for a number of nitrate film fires that have occurred in storage vaults in the summer, following periods of 38 C (100 F) weather (Cummings, Hutton, and Silton, Spontaneous Ignition of Decomposing Cellulose Nitrate Film ). The actual heat of combustion of cellulose nitrate film is low compared with that of more common fuels. (See Table B.1.) Table B.1 Heat Rates of Combustion Nitrate Film vs. Common Fuels kj/kg Btu/lb Nitrate film 13,944 18, Wood 16,268 18, Alcohol 27,005 11,620 Coal, bituminous 23,240 32,536 10,000 14,000 Gasoline 52,900 22,750 However, the rate of combustion of nitrate film is about 15 times greater than the combustion rate of wood in any form so that the heat evolved per minute is initially much greater. This rate results in a rapid temperature increase and a very intense fire. A nitrate film fire burns so fiercely and spreads so quickly that it is virtually impossible to control or extinguish it except by automatic sprinklers. Submittal Date: Tue Aug 05 14:04:47 EDT 2014

15 1 of 14 9/12/ :41 AM : This revision aligns with the rejected definition of decomposition. Response Message: Public Comment No. 13-NFPA [Section No. B.1]

16 2 of 14 9/12/ :41 AM Second Revision No. 11-NFPA [ Section No. B.3 ] B.3 Detection and Disposal of Unstable Nitrate Film. New nitrate film was made to be as stable as possible, and some many nitrate films, which are 30 or 40 years old regardless of age, still appear to be in reasonably good condition. However, all nitrate cellulose-based film deteriorates with age, and the deterioration can be increased by chemical contamination and improper storage conditions. Nitrate film in advanced stages of deterioration can be less stable and can ignite at lower temperatures than nitrate film in good condition. All nitrate films that are to be saved for future reprocessing or for extended term storage purposes should be examined carefully throughout their length prior to being stored in a vault. Further, they should be re-examined periodically. For moderate storage temperatures and where both temperature and humidity are controlled, inspections should be made at least once annually. Where conditions are not controlled, examinations should be made every six months. In tropical climates, inspection intervals might have to be decreased to two or three months. Any films that, upon examination, show yellow discoloration, fading of the image, undue brittleness, stickiness of the emulsion, or any other signs of deterioration should be copied onto safety film reformatted as soon as practical possible. Any films in cans that are corroded on the inside should be recanned. Such corrosion can indicate an imminent deterioration problem. Films that have degraded to the point of complete image loss should be disposed of. The disposal of deteriorated or unstable nitrate film presents a problem nitrate film should be handled as hazardous waste in accordance with local, state, and federal regulations. Nitrate film should not be mixed with ordinary rubbish. Such film should be kept under water in a steel drum until disposal can be arranged. Safe disposal should be arranged through proper authorities. Submittal Date: Tue Aug 05 14:09:12 EDT 2014 Committee Statement: The changes to this section more accurately reflect the observed and measured variable nature of nitrate decay. In accelerated aging trials and archival observations, many nitrate pieces--some more than 100 years old today--have proved extraordinarily stable. Others decayed decades ago. Evidence for the idea that increased degradation correlates in a straightforward way with heightened fire risk is mixed at best. The committee believed that including local, state, and federal regulations removed the need for an approved container. They also remove language suggesting that annual inspections are mandatory. Archivists and AHJs do not always understand that the annex is for informational purposes only. Removing the section about annual inspections allows more flexibility, especially for large institutions. Nitrate holdings are increasingly centralized at a handful of institutions, many of which have such vast holdings that annual inspections are simply not feasible. Finally, the task force recommends removing the phrase steel drum, and replacing it with the more flexible approved container to accommodate a wider range of equally safe practices.

17 3 of 14 9/12/ :41 AM Response Message: Public Comment No. 18-NFPA [Section No. B.3]

18 4 of 14 9/12/ :41 AM Second Revision No. 14-NFPA [ Section No. D ] D U.S. Government Publications. U.S. Government Printing Office, Washington, DC Baker, Lt. Col. Walter C. Proceedings of a Board of the Chemical Warfare Service Appointed for the Purpose of Investigating Conditions Incident to the Disaster at the Cleveland Hospital Clinic, Cleveland, OH, on May 15, Title 49, Code of Federal Regulations, Part Submittal Date: Tue Aug 12 14:05:25 EDT 2014 Committee Statement: Response Message: 49 CFR is referenced in sections A and A.7.2.2, created by Second Revision 5.

First Revision No. 1-NFPA [ Section No ] Submitter Information Verification. Committee Statement

First Revision No. 1-NFPA [ Section No ] Submitter Information Verification. Committee Statement First Revision No. 1-NFPA 268-2015 [ Section No. 2.3.1 ] 2.3.1 ASTM Publications. ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA 19428-2959. ASTM E 176 E176, Standard Terminology