FSSA NEWS

DOT vs NFPA REQUIREMENTS FOR TESTING OF SYSTEM CYLINDERS Do DOT Regulations or NFPA Standards require fire system cylinders containing gaseous fire extinguishing agents to be periodically removed from service, emptied and hydrostatically tested? Please click here to download the White Paper* from the Fire Suppression Systems Association (FSSA) to help you answer that question. *This document provides general guidelines and is not intended to provide all information necessary to determine test requirements for all cylinders. Always refer to the most current equipment manufacturer’s instructions and recommendations, DOT regulations, NFPA Standards, along with other codes and regulations that may apply.*

FSSA HAS NAMED NEW VICE CHAIR OF MANUFACTURERS DIVISION The recently vacated Vice Chair of the Manufacturers Division  has been filled.  A vote was conducted by the principle Manufacturers and the results are in. The FSSA would like to congratulate and welcome Kevin Murray of Siemens Industry to the Board of Directors.

FSSA 2014 ANNUAL FORUM REGISTRATION IS OPEN The FSSA 32nd Annual Forum registration is now open.  Mark your calendar for February 22 - 25, 2014 in San Diego, CA. Click here to make your reservation now.  Sponsorship opportunities are still available. The forum agenda is currently being crafted by the Program Committee and may be viewed here.  Stay tuned for more updates!

PASSING OF CHARLES WILLMS Charles Fredrick Willms, 84, passed away September 14, 2013. Born in Hudson County, NJ, on June 28, 1929, he was the son of the late Sadie and Fredrick Willms. An award winning rifleman, Charles served in the US National Guard, and was honorably discharged with the rank of Master Sergeant. Charles attended NJ Institute of Technology where he graduated Summa Cum Laude with a BS degree in Mechanical Engineering. A registered professional engineer, he was a member of the Tau Beta Phi National Engineering Honor Society, Phi Tau Sigma, ASME, CGA, IAC, US TAG, and served as technical director of the FSSA, and chairman of the NFPA. Charles worked as Director of Engineering for Fire Protections Systems for Walter Kidde, in NC, and was then self-employed as a Product Liability Consultant for fire protection products. He enjoyed playing the drums and spending time with his family. Charles was preceded in death by his beloved wife of 58 years, Maryann E. Willms. He is survived by his loving daughter, Beverly, of Raleigh, NC; son, Roger, and his wife, Melinda, of Charlotte; grandchildren, Dean and Madolyn, of Charlotte; brother, Fred Willms, of NJ; and several nieces and nephews.

FSSA TRAINING PROGRAM The FSSA Training program is live!  If you reserved a spot at the forum invoices were emailed in May. For questions regarding the training program or to reserve your space, please contact Vince Mullhausen at FSSA HQ.   Information was received via email from the FSSA publication "Annunciator." To join the distribution list please visit http://fssa.net/

DOT Updates Courtesy of NAFED

NAFED News

DOT Updates for Jan. 2013

• By: Admin
• On: 01/29/2013 12:11:02
• In: Industry News

The DOT has issued its final rule regarding the transportation of fire extinguishers. Read on to learn the latest updates.

The United States Department of Transportation, Pipeline and Hazardous Materials Administration (PHMSA) has issued a final rule regarding Docket No. PHMSA-2009-0126 (HM-215K); RIN 2137-AE83.

This final rule has a major impact on the transportation of fire extinguishers. NAFED’s federal regulations committee has reviewed this final rule and will submit a more detailed report in the near future. Detailed information will also be provided at NAFED’s DOT Train-the-Trainer Seminar in Austin, Texas, on March 1, 2013. In addition, a four-hour pre-conference DOT seminar is scheduled for all three of NAFED’s 2013 conferences. For more information and to register for any of these seminars please visit the event calendar.

Some of the key points addressed in this new rulemaking are:

1. Fire extinguishers that are being transported to or from a facility for service (e.g., recharging, hydrostatic testing, internal maintenance, etc.) may be transported as Material of Trade (MOT) in accordance with CFR 49 §173.6. This would include carbon dioxide fire extinguishers or other fire extinguishers that do not meet the DOT 173.309 definition of fire extinguisher. Please note that the maximum amount of MOT allowed by the regulations is 440 pounds. Also all fire extinguishers transported as MOT must be labeled and marked as per Table 172.101 (UN1044, Fire Extinguisher; UN1013, Carbon Dioxide, etc.)
   
2. 49 CFR §173.309, Fire Extinguisher, was drastically revised by the DOT. This section was reorganized to clarify the requirements based upon the type of cylinder used. Series 3 and 4 specification cylinders are addressed in §173.309(a), specification 2P and 2Q cylinders are addressed in §173.309(b), and non-specification cylinders are addressed in §173.309(c)
   
3. §173.309(c) (5) states: “Each non-specification fire extinguisher must be packaged as an inner packaging within a combination outer packaging. Examples of acceptable outer packagings for non-specification fire extinguishers include large cartons, racks, cages, or other suitable enclosures.”
   
4. §173.309(d) states that fire extinguishers shipped as limited quantity “are excepted from shipping papers (except when offered for transportation by aircraft or vessel), labeling (except when offered by transportation by aircraft) placarding…”

NAFED’s federal regulations committee recommends the following for compliance:

• Any fire extinguisher that is not enclosed in a carton should have a label indentifying it as a UN1044 Fire Extinguisher.
• All fire extinguishers must be properly secured in the vehicle at all times when in transportation.
• Stored-pressure wheeled units must be labeled and included on a shipping paper.
• Currently all packagings containing Limited Quantity fire extinguishers may be marked with UN 1044 Fire Extinguishers up until the end of 2014. After that time, with the new requirement, the outside packagings will have to be marked with the Limited Quantity square-on-point limited quantity label shown in CFR 49 §172.315.

NAFED realizes that there may be some confusion with these latest changes so we are offering the training opportunities listed above, and we will issue additional information at a later date. As with any major regulatory change, there can be different interpretations. The federal regulations committee wishes to provide an accurate analysis of these regulations and, if required, we will submit formal requests for interpretations.

DOT Transportation of Fire Extinguishers: July Update

The US DOT recently issued two interpretations that directly affect the transportation of fire extinguishers. The PHMSA (Pipeline and Hazardous Material Safety Administration) conducted a two-day seminar in Atlanta on June 19-20 to review their hazardous material regulations. This seminar included a breakout session dedicated to the transportation, labeling, marking, and shipping paper entries for fire extinguishers. NAFED's federal regulations committee was represented at this seminar by committee chairman John Lewandowski and committee members John Gioseffi and Norb Makowka. The DOT representatives at this seminar were very informative and provided their interpretations on several areas. Two key interpretations discussed were: fire extinguishers can no longer be labeled and marked as "Nitrogen, Compressed UN1066" and only specific fire extinguishers (detailed below) may be transported as "Materials of Trade."

The DOT has opened a Notice of Proposed Rulemaking (NPRM) 77 FR31274 [Docket No. PHMSA 2009 0126 (HM 215K)] that provides you the opportunity to view the DOT's proposed revisions to CFR 49 Section 173.309 Fire Extinguishers and allows you to propose changes to this section. The closing date for comments is July 24, 2012. You can view this NPRM at this link.

The following is a list of key points in the DOT's interpretations. As a reminder, the DOT definition of fire extinguishers in CFR 49 Section 173.309 is:
§173.309 Fire extinguishers
(a) Fire extinguishers charged with a limited quantity of compressed gas to not more than 1660 kPa (241 psig) at 21° C (70° F) are excepted from labeling (except when offered for transportation by air) and the specification packaging requirements of this subchapter when shipped under the following conditions. In addition, shipments are not subject to subpart F of part 172 of this subchapter, to part 174 of this subchapter except §174.24 or to part 177 of this subchapter except §177.817.
(1) Each fire extinguisher must have contents which are nonflammable, non-poisonous, and noncorrosive as defined under this subchapter.
(2) Each fire extinguisher must be shipped as an inner packaging.
(3) Nonspecification cylinders are authorized subject to the following conditions:...

Key Points

1. When required, fire extinguishers that are not shipped as an inner packaging (not in a box or 6-sided enclosure) must be marked and labeled as " Fire Extinguishers, UN 1044" and shall not be marked or labeled as "Nitrogen, Compressed."
2. Shipping paper entries must identify the extinguishers as "UN1044, Fire Extinguishers, 2.2."
3. Fire extinguishers that are shipped as an inner packaging (in a six-sided enclosure) meet the requirements for limited quantity and therefore the weight of those extinguishers does not apply to placarding considerations. However, you must also change the shipping paper entry to read: UN1044, Fire Extinguishers Limited Quantity, 2.2. You are allowed to abbreviate "Limited Quantity" to "Ltd Qty". (*See note.)
4. Shipping papers are required for fire extinguishers that are transported as Limited Quantity regardless of the exception allowed in CFR 49 Section 177.200 (b)(3).
5. Only fire extinguishers that are being used for training purposes or as "loaners" can be transported as a Material of Trade (MOT) in accordance with CFR 49 Sections 171.8
   and 173.6.
6. All fire extinguishers that are not transported as inner packaging must be properly secured and must be marked as "Fire Extinguisher, UN1044" and labeled with a Division 2.2 label.

*Note: A change last year in the regulations requires that the packaging containing a Limited Quantity Material must be marked with both the proper shipping name and the UN identification number. This means that any box, crate, etc., that is used to contain fire extinguishers needs to be marked "Fire Extinguisher, UN1044."

Don't be surprised if during a DOT facility inspection they ask to review your shipping methods and paperwork related to the transportation of fire extinguishers. NAFED recommends that when you bring in any fire extinguishers that are labeled as "Nitrogen, Compressed" or "Air, Compressed" you remove or cover that label until you replace it with a "Fire Extinguisher, UN1044" label.