Re: Definition of Non-Combustible for hydraulic fluid

[BRUCE VERHEI via Sprinklerforum]

The code change that allowed elimination of heads is a couple decades old.

We were confused about meaning. I’d like to say I can remember who I talked 
with or have notes. I don’t. I know the re-emphasis by FM concerning both 
heated and unheated combustible liquids being aerosolized by high pressure 
leaks had made everyone vigilant about that concern. So we did some phoning. I 
talked with the actual person who wrote the code change and one of the 13 
committee members, as well as the Chief Elevator Inspector with WA State L 
WA State had also implemented an elevator standard code change about the same 
time that was pertinent. The State amendment was requiring secondary 
containment around the portion of the system extending below the pit or use of 
then-newer fluids. The containment requirement was driven by ground water 
pollution concerns. I guess the old fluids had quite detrimental effects to 
drinking water. The result was virtually all hydraulic elevator systems in WA 
State were converted to newer liquids. These newer fluids all complied with the 
proponents’ original intent. At least in our state all systems were expected to 
be compliant. So the requirement for head in the pit was gone, at least for us. 

Sorry I can’t remember more details. It’s been a long time ago.

Best.

Bruce.

> On 07/12/2020 8:57 PM å...  via Sprinklerforum 
>  wrote:
> 
> Ed 
> 
> 1.  FM has Approval Standard 693 wherein some non-water based 
> fire-resistant hydraulic fluids are certified.
> 
> 2.  There are tests for noncombustibility,  from ASTM, and they are cited 
> in NFPA 130 and NFPA 101.
> 
> 3.  Approval using interpretation from the AHJ, which takes into 
> consideration occupancy and use.  Consider a long analogy and seque below, 
> which I apologize to the Forum in advance for.  
> 
> 
> The "Metro" standard deals with noncombustibility, because 'Metro 
> occupancies'  allow themselves in a non-simple, non-clear way to be 
> non-sprinklered, according to the NFPA committee members who do write to me.
> 
> 
> We probably find such an admirable treatment of " noncombustibility"  
> within the covers of NFPA 130, the rail and rail / train station fire design 
> guide from NFPA, because they has such a miserable treatment of sprinkler 
> design and incongruency with their objective statement at Section 4.2.2.
> Take a look at the admirable treatment of combustibility prescriptions 
> copy-pasted from the 2017 edition.
> 
> 4.6* Noncombustible Material.
> 4.6.1* A material that complies with any of the following shall be 
> considered a noncombustible material: [ 101: 4.6.13.1]
> (1) A material that, in the form in which it is used and under the 
> conditions anticipated, will not ignite, burn, support combustion, or release 
> …ammable vapors, when subjected to ‚re or heat. [ 101: 4.6.13.1(1)]
> (2) A material that is reported as passing ASTM E136. [ 101: 4.6.13.1(2]
> (3) A material that is reported as complying with the pass/fail criteria 
> of ASTM E136 when tested in accordance with the test method and procedure in 
> ASTM E2652. [ 101: 4.6.13.1(3)]
> 
> More on judgment-with-uncertainty by fire plan reviewers.
> 
> The IBC and its handbook, quite emphatically writes,  "if you are an AHJ, 
> you are paid to render expert judgment.  There will be times this is 
> difficult and you will have to interpret the intent of the Building Code.  
> This is why we (insert your version of the Building Code here: IBC/California 
> Building Code/ Texas Building Code, etc.)  authorize the Building Code 
> Official and their duly appointed deputes with the trust and expectation to 
> interpret the intention of the Building Code.   
> 
> I add to the above, for those AHJ that are paid civil servants, they are 
> government employees.  As far as I can recall, government is elected to serve 
> the people.  The definition of what is ' service' changes with the times 
> and conditions, but service should be to ' the will of the people'  in the 
> instances of elected governments.  As such, it is the duty of the AHJ to 
> educate themselves, learn the intent of the Code, seek advice, and then stand 
> up and earn their money by making interpretations that are open, honest and 
> simple-as-possible.  It takes courage.  There will be mistakes.  I don't know 
> of any AHJ's being legally punished for making mistakes, and there have been 
> some deadly ones made in past, repeatedly.  I know plenty of AHJ's that have 
> been indirectly punished for not serving the will of well-healed corporations 
> whom financed the building infrastructures.  That is the politics of plan 
> review.
> 
> I have developed a tool that helps plan reviewers make 
> judgments-with-uncertainties, as all judgments involving safety measured 
> against Mother Nature, unavoidably involve uncertainty.  The burden of 
> uncertainty comes inherently with the territory of being a 

Definition of Non-Combustible for hydraulic fluid

[å . . . . . . . via Sprinklerforum]

1.  FM has Approval Standard 693 wherein some non-water based
fire-resistant hydraulic fluids are certified.

2.  There are tests for noncombustibility,  from ASTM, and they are cited
in NFPA 130 and NFPA 101.

3.  Approval using interpretation from the AHJ, which takes into
consideration occupancy and use.  Consider a long analogy and seque below,
which I apologize to the Forum in advance for.


The "Metro" standard deals with noncombustibility, because 'Metro
occupancies'  allow themselves in a non-simple, non-clear way to be
non-sprinklered, according to the NFPA committee members who do write to me.

We probably find such an admirable treatment of " noncombustibility"
within the covers of NFPA 130, the rail and rail / train station fire
design guide from NFPA, because they has such a miserable treatment of
sprinkler design and incongruency with their objective statement at Section
4.2.2.Take a look at the admirable treatment of combustibility
prescriptions copy-pasted from the 2017 edition.

4.6* Noncombustible Material.
4.6.1* A material that complies with any of the following shall be
considered a noncombustible material: [ 101: 4.6.13.1]
(1) A material that, in the form in which it is used and under the
conditions anticipated, will not ignite, burn, support combustion, or
release …ammable vapors, when subjected to ‚re or heat. [ 101: 4.6.13.1(1)]
(2) A material that is reported as passing ASTM E136. [ 101: 4.6.13.1(2]
(3) A material that is reported as complying with the pass/fail criteria of
ASTM E136 when tested in accordance with the test method and procedure in
ASTM E2652. [ 101:4.6.13.1(3)]

More on judgment-with-uncertainty by fire plan reviewers.

The IBC and its handbook, quite emphatically writes,  "if you are an AHJ,
you are paid to render expert judgment.  There will be times this is
difficult and you will have to interpret the intent of the Building Code.
This is why we (insert your version of the Building Code here:
IBC/California Building Code/ Texas Building Code, etc.)  authorize the
Building Code Official and their duly appointed deputes with the trust and
expectation to interpret the intention of the Building Code.

I add to the above, for those AHJ that are paid civil servants, they are
government employees.  As far as I can recall, government is elected to
serve the people.  The definition of what is ' service' changes with
the times and conditions, but service should be to ' the will of the
people'  in the instances of elected governments.  As such, it is the duty
of the AHJ to educate themselves, learn the intent of the Code, seek
advice, and then stand up and earn their money by making interpretations
that are open, honest and simple-as-possible.  It takes courage.  There
will be mistakes.  I don't know of any AHJ's being legally punished for
making mistakes, and there have been some deadly ones made in past,
repeatedly.  I know plenty of AHJ's that have been indirectly punished for
not serving the will of well-healed corporations whom financed the building
infrastructures.  That is the politics of plan review.

I have developed a tool that helps plan reviewers make
judgments-with-uncertainties, as all judgments involving safety measured
against Mother Nature, unavoidably involve uncertainty.  The burden of
uncertainty comes inherently with the territory of being a safety
professional.  If a plan reviewer wants to be 100% prescriptive... there is
AI coming.  As stated previously, AI already is replacing para-legals and
junior lawyers who pour over volumes of codes and records searchnig for
legal precedence.  When you think about it, a prescriptive design guide is
not much more than a big series of coded 'if - then ' statements.   AI can
search through all of our building safety references, standards and
Building Codes and come back with a prescriptive judgment  (if that is all
we are offering) before we can boot up our computer.  The future in plan
check, is executing judgment-with-uncertainty and field inspections.  Rote
reading of the Code and standards is not only a *DIS*service to the public,
and an indication that you may be overpaid as a safety professional  (or
overpaid as an entire organization, if that organization embraces a
structure too prescriptively oriented).  Being overly prescriptive is
setting oneself up for obsolescence and eventual replacement by
silicon-based neural networks.

I offer training to plan reviewers, with a tool I have developed, for
free.  It is numeric, falsifiable, open, honest, and somewhat simple (a
little bit of multiplication and addition involved). No jurisdiction on the
planet has expressed any interest in it.  Most fire plan reviewers are not
known for being 'overly curious' personalities.   And not too many people
are able to recognize something of value when they have not seen it
before... (how many of us bought into Microsoft, UPS or Amazon when we
first heard about them)?  Many in Code enforcement are anathema to

RE: Definition of Non-Combustible for hydraulic fluid

[Prahl, Craig/GVL via Sprinklerforum]

See related forum post for additional info:

NFPA 30- 2015:
4.2.2 Combustible Liquid. Any liquid that has a closed-cup flash point at or 
above 100°F (37.8°C), as determined by the test procedures and apparatus set 
forth in Section 4.4. Combustible liquids are classified according to Section 
4.3.

4.3.1 Flammable liquids, as defined in 3.3.33.2 and 4.2.3, shall be classified 
as Class I liquids and shall be further subclassified in accordance with the 
following:
(1) Class IA Liquid -Any liquid that has a flash point below 73°F (22.8°C) and 
a boiling point below 100°F (37.8°C)
(2) Class IB Liquid -Any liquid that has a flash point below 73°F (22.8°C) and 
a boiling point at or above 100°F (37.8°C)
(3) Class IC Liquid - Any liquid that has a flash point at or above 73°F 
(22.8°C), but below 100°F (37.8°C)

4.3.2 Combustible liquids, as defined in 3.3.33.1 and 4.2.2, shall be 
classified in accordance with the following:
(1) Class II Liquid - Any liquid that has a flash point at or above 100°F 
(37.8°C) and below 140°F (60°C)
(2) Class III Liquid - Any liquid that has a flash point at or above 140°F 
(60°C)
(a) Class IIIA Liquid-Any liquid that has a flash point at or above 140°F 
(60°C), but below 200°F (93°C)
(b) Class IIIB Liquid-Any liquid that has a flash point at or above 200°F (93°C)

IBC - 2015
[F] COMBUSTIBLE LIQUID. A liquid having a closed cup flash point at or above 
100°F (38°C). Combustible liquids shall be subdivided as follows:
Class II. Liquids having a closed cup flash point at or above 100°F (38°C) and 
below 140°F (60°C).
Class IIIA. Liquids having a closed cup flash point at or above 140°F (60°C) 
and below 200°F (93°C).
Class IIIB. Liquids having a closed cup flash point at or above 200°F (93°C).

The category of combustible liquids does not include compressed gases or 
cryogenic fluids.

Craig Prahl | Jacobs | Group Lead/SME - Fire Protection | 864.676.5252 | 
craig.pr...@jacobs.com | 
www.jacobs.com
1041 East Butler Road   Greenville, South Carolina  29606

From: Sprinklerforum  On Behalf 
Of Steve Leyton via Sprinklerforum
Sent: Friday, July 10, 2020 1:34 PM
To: sprinklerforum@lists.firesprinkler.org
Cc: Steve Leyton 
Subject: [EXTERNAL] Definition of Non-Combustible for hydraulic fluid

A client is wrestling with an AHJ regarding sprinkler exceptions in elevator 
pits on a multi-building project.  The issue is whether or not the hydraulic 
fluid is noncombustible and the MSDS sheet from Chevron states, "Not classified 
by OSHA as flammable or combustible."   It's NFPA rated 1 for flammability 
(it's basically mineral oil) with a flashpoint of 356°F and no Autoignition 
value is proffered.   NFPA 220 §4.1.5.1 has a definition but it's for building 
materials - does anyone know if there's an overarching ("preferred") definition 
in the NFPA code set for "Noncombustible" as it applies to hydraulic elevator 
fluid?


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RE: Definition of Non-Combustible for hydraulic fluid

[Prahl, Craig/GVL via Sprinklerforum]

The old "lesser combustible" or "less combustible" definitions are of no value. 
 Look at the SDS for the material. If there is a flashpoint, it is categorized 
within the IBC and NFPA 30.  A liquid with a flashpoint of over 200°F is a 
class IIIB combustible.  While IIIB liquids pose the least hazard when it comes 
to ignition, it is still a combustible.  Autoignition temperatures for IIIB 
liquids can be quite high, making them essentially impossible to ignite by just 
heating under most conditions and nearly impossible to ignite by a spark alone 
while in their liquid state at ambient temperature and at atmospheric pressure. 
 So from an elevator pit standpoint, the presence of this fluid requires 
sprinklers.

The characteristics of a combustible liquid released under pressure can mimic a 
flammable liquid due to the liquid becoming an aerosol which takes far less 
energy to ignite.

This same conversation comes up with regard to oil cooled electrical equipment.

Craig Prahl | Jacobs | Group Lead/SME - Fire Protection | 864.676.5252 | 
craig.pr...@jacobs.com | 
www.jacobs.com
1041 East Butler Road   Greenville, South Carolina  29606

From: Sprinklerforum  On Behalf 
Of Steve Leyton via Sprinklerforum
Sent: Friday, July 10, 2020 1:34 PM
To: sprinklerforum@lists.firesprinkler.org
Cc: Steve Leyton 
Subject: [EXTERNAL] Definition of Non-Combustible for hydraulic fluid

A client is wrestling with an AHJ regarding sprinkler exceptions in elevator 
pits on a multi-building project.  The issue is whether or not the hydraulic 
fluid is noncombustible and the MSDS sheet from Chevron states, "Not classified 
by OSHA as flammable or combustible."   It's NFPA rated 1 for flammability 
(it's basically mineral oil) with a flashpoint of 356°F and no Autoignition 
value is proffered.   NFPA 220 §4.1.5.1 has a definition but it's for building 
materials - does anyone know if there's an overarching ("preferred") definition 
in the NFPA code set for "Noncombustible" as it applies to hydraulic elevator 
fluid?


[cid:image002.jpg@01D65871.6C2919F0]





NOTICE - This communication may contain confidential and privileged information 
that is for the sole use of the intended recipient. Any viewing, copying or 
distribution of, or reliance on this message by unintended recipients is 
strictly prohibited. If you have received this message in error, please notify 
us immediately by replying to the message and deleting it from your computer.
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