Second Revision No. 1-NFPA 40-2014 [ Section No. 2.2 ]...Second Revision No. 2-NFPA 40-2014 [...

Second Revision No. 1-NFPA 40-2014 [ Section No. 2.2 ]

2.2 NFPA Publications.

National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 10, Standard for Portable Fire Extinguishers, 2013 edition.

NFPA 13, Standard for the Installation of Sprinkler Systems, 2013 2016 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, 2013 2016 edition.

NFPA 80, Standard for Fire Doors and Other Opening Protectives, 2013 2016 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.

Submitter Information Verification

Submitter Full Name: [ Not Specified ]

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Submittal Date: Tue Jul 29 16:07:09 EDT 2014

Committee Statement

CommitteeStatement:

Update referenced standards, which are in the same revision cycle as NFPA 40, to mostrecent edition.

Response Message:

National Fire Protection Association Report http://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPara...

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Second Revision No. 2-NFPA 40-2014 [ 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 84 E84 , Standard Test Method for Surface Burning Characteristics of Building Materials,2013a 2014 edition.




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Submittal Date: Tue Aug 05 11:00:26 EDT 2014

Committee Statement

CommitteeStatement:

This revision updates the standard to the most recent edition. Public Comments 3 and 8were both accepted.

Response Message:

Public Comment No. 3-NFPA 40-2014 [Section No. 2.3.1]



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Second Revision No. 3-NFPA 40-2014 [ Sections 3.3.10.1, 3.3.10.2 ]

3.3.10.1 Decomposition Vent.

A vent to permit the escape of gases resulting from partial burning or decomposition of decomposition orfrom incomplete combustion of nitrate film.




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Committee Statement

CommitteeStatement:

The committee agrees that revisions to 3.3.10.1 provide clarity to the document, but 3.3.10.2should remain as written. The ignition materials are decomposition gases.

ResponseMessage:

Public Comment No. 11-NFPA 40-2014 [Sections 3.3.10.1, 3.3.10.2]


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6.1 General.

Nitrate film that is not in process or being worked on shall be stored as follows:

(1)

(2)

(3) Extended term storage film shall be stored in extended term storage cabinets or extended termstorage vaults, which are subject to the limitations of Section 6.1(1) and 6.1(2). (See Sections 6.4and 6.5.)

Supplemental Information

File Name Description

A.6.1.1_and_.2_lm_edit.docx




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Committee Statement

CommitteeStatement:

The committee agrees with the Public Comment but moved some unenforceable, explanatory textto Annex A.

This change incorporates approximate equivalencies into the body of the code, where they are morelikely to be recognized by archivists and AHJs. At the time of this writing, few institutions with flat filmholdings are in compliance with NFPA 40. One reason for this lack of compliance appears to be ageneral understanding that NFPA 40 applies to motion picture film alone--an understanding that issomewhat encouraged by the text of the code.

This change also incorporates an equivalency based upon volume. The task force convened byNFPA 40 weighed sheet film stored in individual sleeves in a storage container measuring 4” x 9” x10.5” (0.22 cubic feet). The total mass of cellulose nitrate in the box was 1.642 kg. We thereforeestimate 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 preservationpractice calls for the storage of negatives in individual sleeves, usually constructed of paper or inertplastic. Due to the sheer quantity of this content in a typical flat film storage container, the task forcebelieves 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.

* Amounts exceeding 11 kg (25 lb), or 5 standard rolls, but not exceeding 340 kg (750 lb), or 150standard 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 Section6.3.)


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ResponseMessage:

Public Comment No. 14-NFPA 40-2014 [Section No. 6.1]

Public Comment No. 15-NFPA 40-2014 [Section No. A.6.1]


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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 650 8 × 10 in. negatives, or approximately 1300 5 × 7 in. negatives. 11 kg (25 lb)

also corresponds to approximately 0.5 ft3 of motion picture film, or 1.5 ft3 of individually sleeved, flat

film negatives.

A.6.1 (2)

For reference, 340 kg (750 lb) corresponds to approximately 150 1000 ft rolls of 35 mm motion picture

film, or approximately 45 ft3 of individually sleeved flat film negatives. 340 kg (750 lb) also corresponds

to approximately 15 ft3 of motion picture film, or 45 ft3 of individually sleeved, flat film negatives.


6.4* Extended Term Storage Cabinets.

6.4.1

Extended term storage cabinets shall be provided with individual drawers or compartments, each holdingnot more than 610 m (2000 ft) of film. Individual compartments shall be separated by 9.5 mm (3⁄8 in.) ofnoncombustible insulating material. Each compartment shall be provided with a hinged damper or similardevice to allow release of decomposition gases into the cabinet vent.

6.4.2

Extended term storage cabinets shall be provided with automatic sprinklers when holding more than 23 kg(51 lb) of nitrate film.

6.4.3*

Each extended term storage cabinet having a capacity of more than 23 kg (51 lb), or 10 standard rolls, offilm shall be provided with a vent to the outside of the building. The vent shall have a minimum cross-

sectional area of 90 cm2 per 45 kg (14 in.2 per 100 lb), or 200 standard rolls of film capacity.

6.4.3.1

Decomposition vent pipes shall be of No. 18 U.S. gauge riveted steel or equivalent. Where located withinthe building, decomposition vent pipes shall be covered with 25 mm (1 in.) of noncombustible insulatingmaterial.



A.6.4_lm._edited.docx




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Committee Statement

CommitteeStatement:

This revision adds Annex A material to section 6.4. The committee agrees with Public Comment 17but 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 specialextended term storage requirements under NFPA 40 already use some sort of freezer storage fortheir 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 haltingthe secondary autocatalytic mechanisms of decay. (Heckman 2010, p. 500 citing Bigourdan,”Fromthe Nitrate Experience” p 61.)

This revision covers configurations for varying quantities.

Note: Supporting documentation was provided in the first round of public input.


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ResponseMessage:

Public Comment No. 17-NFPA 40-2014 [New Section after A.6.4.3]


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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 6.4.1 through 6.4.3.1 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 6.5.1

through 6.5.9 for amounts exceeding 340 kg (750 lb).


7.2 Containers Required.

All nitrate film shall be kept in closed , individual metal cans or DOT- approved containers unless inuse .

7.2.1*

Nitrate motion picture film shall be stored in closed metal cans or DOT-authorized containers.

7.2.2*

Nitrate flat film shall be stored in DOT-authorized containers.



A.7.2.1_and_7.2.2_edited.docx




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Committee Statement

CommitteeStatement:

DOT-authorized containers may be used in place of metal cans for motion picture film. This revisionalso 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 flatfilm.

The word “individual” is ambiguous in the current code. Its meaning is not clear to the members ofthe task force, and the task force recommends that it be removed. Multiple rolls might be stored in asingle 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 storemore than a single roll of approximately 1,000 feet.

Annex: Annex material proposed by Public Comment 20 has been attached to section 7.2.2 inSecond Revision 5. Section 7.2 is now a heading, and A.7.2 is to be deleted.

ResponseMessage:

Public Comment No. 19-NFPA 40-2014 [Section No. 7.2]

Public Comment No. 20-NFPA 40-2014 [Section No. A.7.2]


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A.7.2.1 Examples of DOT-authorized containers are in 49 CFR 173.183.

A.7.2.2

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 173.183.

Second Revision No. 6-NFPA 40-2014 [ Section No. 8.1.2 ]

8.1.2*

No more than 34 kg (75 lb) of nitrate film shall be allowed in the projection booth unless stored in anapproved cabinet in accordance with Chapter 6.



A.8.1.2_lm._edited.docx




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Committee Statement

CommitteeStatement:

Projectionists are accustomed to length, rather than weight, measurements. This additionallanguage will help to clarify the amounts allowed. The typical reel size in a modern projectionbooth is 2,000 feet.

The committee moved the explanatory material converting the mass of film to length of film to theannex.

ResponseMessage:



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A.8.1.2

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

Second Revision No. 10-NFPA 40-2014 [ Section No. B.1 ]

B.1 Hazards.

The most dangerous aspects of cellulose nitrate motion picture film are its ease of ignition, its very highrate of combustion, and its extremely poisonous combustion gases.

Cellulose nitrate film decomposes readily when heated to temperatures above ambient but below itsignition temperature. The decomposition is both exothermic and autocatalytic. The quantity of heatproduced by decomposition is such that, if not dissipated, it can rapidly raises the temperature of the filmto the ignition point. Even local heating can raise the temperature of the film to a dangerous level, initiatingdecomposition in the entire mass. Cellulose nitrate also contains enough oxygen within its molecule sothat decomposition or combustion proceeds rapidly, even in a limited air supply. A fire in cellulose nitratefilm, 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 theduration of exposure, size and purity of film, and other factors. For example, in a laboratory test a sampleof fresh nitrate film base ignited in air at 163°C (325°F) within 80 seconds; at 204°C (400°F), ignitionoccurred 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 ClevelandClinic fire of 1929 showed that temperatures above 93°C (200°F) were unsafe for nitrate film and thatexposed 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 as49°C (120°F). Also, spontaneous ignition is believed to have been responsible for a number of nitrate filmfires 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 13,944–18,592 6000–8000

Wood 16,268–18,592 7000–8000

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 woodin any form so that the heat evolved per minute is initially much greater. This rate results in a rapidtemperature increase and a very intense fire. A nitrate film fire burns so fiercely and spreads so quicklythat it is virtually impossible to control or extinguish it except by automatic sprinklers.




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Committee Statement


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Committee Statement: This revision aligns with the rejected definition of decomposition.

Response Message:

Public Comment No. 13-NFPA 40-2014 [Section No. B.1]


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Second Revision No. 11-NFPA 40-2014 [ 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 40years old regardless of age , still appear to be in reasonably good condition. However, allnitrate cellulose-based film deteriorates with age, and the deterioration can be increased by chemicalcontamination and improper storage conditions. Nitrate film in advanced stages of deterioration can beless stable and can ignite at lower temperatures than nitrate film in good condition. All nitrate films thatare to be saved for future reprocessing or for extended term storage purposes should be examinedcarefully throughout their length prior to being stored in a vault. Further, they should be re-examinedperiodically. 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, examinationsshould be made every six months. In tropical climates, inspection intervals might have to be decreased totwo 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 safetyfilm reformatted as soon as practical possible . Any films in cans that are corroded on the inside should berecanned. Such corrosion can indicate an imminent deterioration problem. Films that have degraded tothe 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 ashazardous waste in accordance with local, state, and federal regulations . Nitrate film should not be mixedwith ordinary rubbish. Such film should be kept under water in a steel drum until disposal can bearranged. Safe disposal should be arranged through proper authorities.




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Committee Statement

CommitteeStatement:

The changes to this section more accurately reflect the observed and measured variable nature ofnitrate decay. In accelerated aging trials and archival observations, many nitrate pieces--some morethan 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 heightenedfire risk is mixed at best.

The committee believed that including local, state, and federal regulations removed the need for anapproved container.

They also remove language suggesting that annual inspections are mandatory. Archivists and AHJsdo not always understand that the annex is for informational purposes only. Removing the sectionabout annual inspections allows more flexibility, especially for large institutions. Nitrate holdings areincreasingly centralized at a handful of institutions, many of which have such vast holdings thatannual inspections are simply not feasible.

Finally, the task force recommends removing the phrase “steel drum,” and replacing it with the moreflexible “approved container” to accommodate a wider range of equally safe practices.


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ResponseMessage:

Public Comment No. 18-NFPA 40-2014 [Section No. B.3]


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Second Revision No. 14-NFPA 40-2014 [ Section No. D.1.2.2 ]

D.1.2.2 U.S. Government Publications.

U.S. Government Printing Office, Washington, DC 20402.

Baker, Lt. Col. Walter C. “Proceedings of a Board of the Chemical Warfare Service Appointed for thePurpose of Investigating Conditions Incident to the Disaster at the Cleveland Hospital Clinic, Cleveland,OH, on May 15, 1929.”

Title 49, Code of Federal Regulations, Part 173.183.




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Committee Statement

CommitteeStatement:

49 CFR 173.183 is referenced in sections A.7.2.1 and A.7.2.2, created by SecondRevision 5.

Response Message:


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Second Revision No. 1-NFPA 40-2014 [ Section No. 2.2 ]...Second Revision No. 2-NFPA 40-2014 [...

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