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Public Input No. 6-NFPA 502-2023 [ 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 E84, Standard Test Method for Surface Burning Characteristics of Building Materials,
2021a 2023 .
ASTM E119, Standard Test Methods for Fire Tests of Building Construction and Materials,
2020 2022 .
ASTM E136, Standard Test Method for Assessing Combustibility of Materials Using a Vertical
Tube Furnace, at 750°C, 2019a 2022 .
ASTM E2652, Standard Test Method for Assessing Combustibility of Materials Using a Tube
Furnace with a Cone-shaped Airflow Stabilizer, at 750°C, 2018 2022 .
ASTM E3134, Standard Specification for Transportation Tunnel Structural Components and
Passive Fire Protection Systems, 2020.

Statement of Problem and Substantiation for Public Input

date updates

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 18 13:37:48 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-27-NFPA 502-2023

Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached word document with track changes shows all the updates.

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Public Input No. 9-NFPA 502-2023 [ Section No. 2.3.2 ]

2.3.2 BSI Publications.

BSI British Standards , 12110 Sunset Hills Road, Suite 200, Reston, VA 20190-5902 Institution,
12950 Worldgate Drive, Suite 800 Herndon, Reston, VA 20190 .
BS 476-4, Fire tests on building materials and structures
— Part 4:
, Non-combustibility test for materials ,
1970
70th Edition ,
corrigendum
October 1 , 2012 , Reaffirmed 2020 .

Statement of Problem and Substantiation for Public Input

update

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 18 14:09:42 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-27-NFPA 502-2023

Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached word document with track changes shows all the updates.

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Public Input No. 23-NFPA 502-2023 [ Section No. 2.3.9 ]

2.3.9 UL Publications.
Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.
UL 263 Fire Tests of Building Construction and Materials 2011, revised 2022.

UL 723, Test for Surface Burning Characteristics of Building Materials, 2018.

UL 1685, Vertical-Tray Fire-Propagation and Smoke-Release Test for Electrical and Optical-
Fiber Cables , 2015.
UL 1724, Outline of Investigation for Fire Tests for Electrical Circuit Protective Systems , 2006.
UL 2024, Cable Routing Assemblies and Communications Raceways, 2014, revised 2021.

UL 2196, Fire Test for Circuit Integrity of Fire-Resistive Power, Instrumentation, Control, and
Data Cables , 2017.
UL 2524, In-building 2-Way Emergency Radio Communication Enhancement Systems, 2019.

Statement of Problem and Substantiation for Public Input

Update UL standards to the current edition and revision. UL 263 UL 2024 and UL 2524 are added as
related to PIs under consideration by the technical committee.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 24-NFPA 502-2023 [Section No. 12.1]
Public Input No. 27-NFPA 502-2023 [Section No. 12.2.1.3]
Public Input No. 28-NFPA 502-2023 [Section No. 4.5]

Submitter Information Verification

Submitter Full Name: Kelly Nicolello

Organization: UL Solutions
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:15:42 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-27-NFPA 502-2023

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Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached word document with track changes shows all the updates.

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Public Input No. 10-NFPA 502-2023 [ New Section after 3.1 ]

SCADA
A system which is a combina�on of hardware and so�ware used to send commands and acquire data for
the purpose of monitoring and controlling.

Additional Proposed Changes

File Name Description Approved

Professional
NFPA_Professional_Backaground_and_Experience_- Background
_Thomas_Kuhn.docx information for
justification

Statement of Problem and Substantiation for Public Input

The ISA-112 SCADA systems committee adopted the definition for SCADA on May 5, 2017 for
inclusion in a new SCADA systems standard. Many industries, vendors, owners, authorities use the
term SCADA to mean many different things that are specific to them and their industry. Each is correct
in how it uses the term within its own context, but the ISA-112 generalized standard definition for
SCADA should be included for this standard for consistency of understanding and use.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn

Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 13:47:50 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: Adding a new definition for SCADA system would cause additional confusion in the
industry. This introduces unnecessary specificity to it's usage.

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Public Input No. 21-NFPA 502-2023 [ New Section after 3.3.15 ]

3.3.16 Cross Passageway

Cross-passageway means a passage connec�ng adjacent tunnels.

Statement of Problem and Substantiation for Public Input

“Cross-passageway” is used throughout the Standard without definition.

Submitter Information Verification

Submitter Full Name: Natasha De Los Rios

Organization: Mott MacDonald
Affiliation: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 01:12:46 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: Using the term "connecting adjacent tunnels" does not only describe cross passageways
but is also used to describe other things that connect adjacent tunnels such as vehicle
crossovers. The term being defined cannot be used in the definition.

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Public Input No. 20-NFPA 502-2023 [ New Section after 3.3.62 ]

3.3.63 Ventilation Zone

Underground segment formed between two points of connec�ons to atmosphere, and which uses the
same set of ven�la�on responses.

Statement of Problem and Substantiation for Public Input

“Ventilation Zone” is used throughout the Standard without definition.

Submitter Information Verification

Submitter Full Name: Natasha De Los Rios

Organization: Mott MacDonald
Affiliation: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 01:09:40 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: The proposed definition is incorrect since ventilation zones don't exclusively connect to
the atmosphere.

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Public Input No. 35-NFPA 502-2023 [ New Section after 4.4.1 ]

TITLE OF NEW CONTENT

Type your content here ...4.4.2 The local responding fire department(s) and other emergency
response agencies which may be expected to respond to a fire or other emergency incidents,
shall be provided opportunities to input on the project design and operational intent during the
design and planning phases to ensure emergency response will be effective and feasible.

Statement of Problem and Substantiation for Public Input

Although emergency response agencies may comment on emergency plans, and may, at the
owner/designer discretion be invited to comment on design and operational intent, there is no
requirement for this to occur. This language makes this a requirement. In some cases lack of early
input results in final design being completed without responder agencies input. Lacking early input the
design and response plans may not allow effective responder actions. This lack of input has resulted in
responder or local AHJ requiring changes to design with resultant unnecessary delays and additional
costs.

Submitter Information Verification

Submitter Full Name: Gary English

Organization: Underground Command and Safety
Affiliation: NFPA 502 Technical Committee alternate
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 15:33:23 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-2-NFPA 502-2023

Statement: Although emergency response agencies may comment on emergency plans, and may, at
the owner/designer discretion be invited to comment on design and operational intent,
there is no requirement for this to occur. This language makes this a requirement. In
some cases, lack of early input results in final design being completed without responder
agencies input. Lacking early input, the design and response plans may not allow
effective responder actions. This lack of input has resulted in responder or local AHJ
requiring changes to design with resultant unnecessary delays and additional costs.
Subsequent sections to be renumbered.

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Public Input No. 28-NFPA 502-2023 [ Section No. 4.5 ]

4.5 Emergency Communications.

4.5.1 Emergency communications, where required by the AHJ, shall be provided by the
installation of outdoor-type telephone boxes, coded alarm telegraph stations, radio transmitters,
or other approved devices that meet the following requirements:
(1) They shall be made conspicuous by means of indicating lights or other approved methods.
(2) They shall be identified by a readily visible number plate or other approved device.
(3) They shall be posted with instructions for use by motorists.
(4) They shall be located in approved locations so that motorists can park vehicles clear of the
travel lanes.
(5) Emergency communication devices shall be protected from physical damage from vehicle
impact.
(6) Emergency communication devices shall be connected to an approved constantly attended
location.
4.5.2 Where installed, emergency responder communication enhancement systems shall be
listed to UL 2524

Statement of Problem and Substantiation for Public Input

In some instances, emergency responder communication enhancement systems may be needed to

boost signals where radio communicators are the means for providing required emergency
communications. This Public Input adds an allowance for the installation of an emergency responder
communication enhancement system (ERCES) to provide emergency communication in road tunnels
where required by the AHJ. Where installed, the performance and reliability of the ERCES should be
confirmed by a listing to the applicable UL Standard.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 23-NFPA 502-2023 [Section No. 2.3.9]

Submitter Information Verification

Submitter Full Name: Kelly Nicolello

Organization: UL Solutions
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:43:13 EDT 2023
Committee: ROA-AAA

Committee Statement

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Resolution: The proposed text is specific to tunnels and chapter 4 is general requirement which is
applicable to all areas of the standard. As such, this is already covered for tunnels in
section 7.5.

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Public Input No. 25-NFPA 502-2023 [ Section No. 4.8 ]

4.8* Noncombustible Material.

A material that complies with any one of the following shall be considered a noncombustible
material:
(1) The material, in the form in which it is used and under the conditions anticipated, will not
ignite, burn, support combustion, or release flammable vapors, when subjected to fire or
heat.
(2) The material is reported as passing ASTM E136, Standard Test Method for Assessing
Combustibility of Materials Using a Vertical Tube Furnace at 750°C.
(3) The material 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, Standard Test Method
for Assessing Combustibility of Materials Using a Tube Furnace with a Cone-shaped
Airflow Stabilizer, at 750°C.
(4) * The material is reported as complying with the pass/fail criteria for Class A1 of either of
the following :
(5) EN 13501-1, Fire classification of construction products and building elements —
Part 1: Classification using data from reaction to fire tests , in relation to ISO 1182,
Reaction to fire tests for products — Non-combustibility test , and ISO 1716, Reaction
to fire tests for products — Determination of the gross heat of combustion (calorific
value)

(6) BS 476-4, Fire tests on building materials and structures — Part 4: Non-combustibility test
for materials

Statement of Problem and Substantiation for Public Input

- BS 476-4 is superseded by BS EN ISO 1182 (ISO 1182 is referenced in EN 13501-1) and as a

consequence should not be applied.
- Application of BS 476-4 cannot lead to an A1 classification.
- Application of BS 476-4 leads to a UK classification for non-combustibility.

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:21:26 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-11-NFPA 502-2023

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Statement: BS 476-4 is superseded by BS EN ISO 1182 (ISO 1182 is referenced in EN 13501-1) and
as a consequence should not be applied. Application of BS 476-4 cannot lead to an A1
classification.

Editorial change to update correct reference for Annex from (3) to (4).

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Public Input No. 4-NFPA 502-2023 [ New Section after 5.3.2 ]

5.3.3 Newly proposed or redesigned limited access highways shall incorporate

into the design considerations for expedited emergency vehicle access.
A.5.3.3 Designers should consider the most expeditious route that fire and emergency service
vehicles will be responding from and the means necessary to accommodate such access
during an emergency response. Roadway designers should be consulting with emergency
services early on in the design process to ensure emergency response needs are incorporated
into the final roadway design.

Statement of Problem and Substantiation for Public Input

Roadway designs that do not incorporate considerations for emergency access can create significant
delays in emergency response vehicles reaching a scene or accessing a scene to provide patient care
or mitigation activities. Designers should consider the most expeditious route that fire and emergency
service vehicles will be responding from and the means necessary to accommodate such access
during an emergency response. Roadway designers should be consulting with emergency services
early on in the design process to ensure emergency response needs are incorporated into the final
roadway design.

Submitter Information Verification

Submitter Full Name: Anthony Apfelbeck

Organization: Altamonte Springs Building and Fire Safety Department
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 12 09:13:02 EST 2023
Committee: ROA-AAA

Committee Statement

Resolution: Text was incorporated into Section 4.4.1 making this proposed text redundant. Section
4.3.1 addresses emergency access.

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Public Input No. 16-NFPA 502-2023 [ Section No. 5.4.1 ]

5.4.1
Acceptable means shall be included within the design of the limited access highway to protect
structures in accordance with this standard to achieve the following:
(1) Support firefighter accessibility activities
(2) Mitigate structural damage from fire to prevent progressive structural collapse
(3) Minimize economic impact

Statement of Problem and Substantiation for Public Input

Accessibility seems to be limited to "entering" the facility or structure. The intend of the change (from
accessibility to activities) is to draw attention also to e.g. safe operations as well as departure of fire
fighters after finishing their operations (in other words: the entire period of time the fire fighters are
active in the facility or structure).
See also 6.3.1.1, 7.3.1.

Submitter Information Verification

Submitter Full Name: Cornelis Both

Organization: ETEX
Street Address:
City:
State:
Zip:
Submittal Date: Wed May 31 11:57:47 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-7-NFPA 502-2023

Statement: Accessibility is limited to "entering" the facility or structure. The terminology was modified
to "operations" instead of "activities" since operations encompasses the entire
emergency response. The intent of the change (from accessibility to operations) is to
draw attention also to safe operations as well as departure of fire fighters after finishing
their operations (in other words: the entire period of time the fire fighters are active in the
facility or structure).

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Public Input No. 3-NFPA 502-2023 [ New Section after 5.6 ]

5.6.2 Standpipes
5.6.2.1 Where standpipes are provided to comply with 5.6.1 or other provisions of this
Standard, standpipes shall be in compliance with NFPA 14, Standard for the Installation of
Standpipe and Hose Systems.

Statement of Problem and Substantiation for Public Input

Provides a reference to NFPA 14 for installation of Standpipes on Limited Access Highways, where
they are required to be installed in order to comply with 5.6.1.

The proponent of this PI realizes that fire hydrants, standpipes and water supplies are a new issue for
NFPA 502 as it related to Limited Access Highways. Therefore, it might be appropriate for the 502 TC
to form a task group to write new language in this area. This PI is submitted to spur the discussion and
ask the TC provide guidance in this area as it is a gap and source of conflict between AHJs and design
professionals in how to address water supplies for fire protection on limited access highways.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 1-NFPA 502-2022 [Section No. 5.6] New content under new chapter title.
Public Input No. 2-NFPA 502-2023 [Section No. 5.6] Similar topic
Public Input No. 2-NFPA 502-2023 [Section No. 5.6]

Submitter Information Verification

Submitter Full Name: Anthony Apfelbeck

Organization: Altamonte Springs Building and Fire Safety
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jan 12 09:03:05 EST 2023
Committee: ROA-AAA

Committee Statement

Resolution: It is rare to see a standpipe on a limited access highway. Installing a standpipe in

accordance with NFPA 14 on a limited access highway is not practical without some
exceptions. For example, NFPA 14 requires manual dry standpipe systems to be
supervised, requiring an air supply and a supervising mechanism connected to a point of
notification.

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Public Input No. 1-NFPA 502-2022 [ Section No. 5.6 ]

5.6* Standpipes, Fire Hydrants . (Reserved) and Water Supplies.

Statement of Problem and Substantiation for Public Input

The title of this chapter should be revised to match to other chapters. Standpipes, water supplies and
hydrants should all be addressed within the content.

Related Public Inputs for This Document

Related Input Relationship

Content matches the new chapter
Public Input No. 2-NFPA 502-2023 [Section No. 5.6]
title
Public Input No. 3-NFPA 502-2023 [New Section after
5.6]

Submitter Information Verification

Submitter Full Name: Anthony Apfelbeck

Organization: Altamonte Springs Building and Fire Safety Department
Street Address:
City:
State:
Zip:
Submittal Date: Wed Dec 28 13:46:41 EST 2022
Committee: ROA-AAA

Committee Statement

Resolution: No new content is being added to this section and therefore, the change in title is not
required.

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Public Input No. 2-NFPA 502-2023 [ Section No. 5.6 ]

5.6* Fire Hydrants. (Reserved)

5.6.1 Where existing fire hydrants are in place along existing water lines within 1,000
feet of a new limited access highway, provisions shall be made to ensure the existing
hydrants can be accessed for fire protection water supplies along the limited access
highway.
A.5.6.1 The intent of this section is not to require new hydrants be installed. It is
intended to ensure that hydrants within 1,000 feet of the limited access highway can be
accessed for fire protection water supplies. This can occur though access ports
through fences or walls, standpipes, or designated access points. This section is
intended to allow flexibility between the design professional and the AHJ to determine
the best method to allow access to existing fire hydrants when a new limited access
roadway is constructed.

Statement of Problem and Substantiation for Public Input

Currently, NFPA 502 does not provide any guidance to the AHJ or design professional on how to
address the need for fire protection water supplies on limited access highways. This proposal
addresses the basic issue of accommodating access to existing fire hydrants when a new limited
access highway is constructed. Those fire hydrants are typically not in the right-of-way of the limited
access highway but are along the right-of-way in adjacent urban or suburban areas.

The proponent of this PI realizes that fire hydrants and water supplies are a new issue for NFPA 502
as it related to Limited Access Highways. Therefore, it might be appropriate for the 502 TC to form a
task group to write new language in this area. This PI is submitted to spur the discussion and ask the
TC provide guidance in this area as it is a gap and source of conflict between AHJs and design
professionals in how to address water supplies for fire protection on limited access highways.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 3-NFPA 502-2023 [New Section after 5.6] Similar topic
Public Input No. 1-NFPA 502-2022 [Section No. 5.6]
Public Input No. 3-NFPA 502-2023 [New Section after 5.6]

Submitter Information Verification

Submitter Full Name: Anthony Apfelbeck

Organization: Altamonte Springs Building and Fire Safety Department
Street Address:
City:
State:
Zip:
Submittal Date: Wed Jan 11 09:24:02 EST 2023
Committee: ROA-AAA

Committee Statement

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Resolution: Limited access highways in NFPA 502 do not require water supplies along the highway.
Therefore, it is impractical to make provisions for accessing a hydrant just because it is
within a 1000 feet of the limited access highway. Limited access highways do not require
the same protection that structures do for bridges, elevated highways and tunnels. The
current Annex provides appropriate guidance where there is a hydrant within a 1000 feet,
leaving access to it optional.

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Public Input No. 26-NFPA 502-2023 [ Section No. 6.2.1 ]

6.2.1
For bridges or elevated highways less than 300 m (1000 ft) in length, the provisions of this
chapter shall not may not apply.

Statement of Problem and Substantiation for Public Input

For bridges of short length - that due to their strategic position in the infrastructure are important - the
AJH, or municipality, should determine the applicability of the standard following section 6.2.
The fire in Rouen (France) on the Pont Mathilde bridge demonstrates that the cost of an uncontrolled
fire can be very high in case of an unusable bridge, both for the local economy and from an
environmental point of view.

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:32:50 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: The proposed language is not enforceable.

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Public Input No. 17-NFPA 502-2023 [ Section No. 6.2.3 ]

6.2.3
In rural areas, Sections 6.4 and 6.7 of this standard shall may not apply.

Statement of Problem and Substantiation for Public Input

The rationale for this proposed change is that it might make sense to add additional safety features,
although the facility is in a rural area. Arguably the definition of rural area is vague, and so there could
be a situation where serious life safety impact can be foreseen, in the absence of measures as
described in 6.4 and 6.7. Alternatively, or in addition to the proposed change, we add similar language
as in 6.2.2., such as the decision on the applicability of (parts of) the sections 6.4 and 6.7 shall be
made by the AHJ.

Submitter Information Verification

Submitter Full Name: Cornelis Both

Organization: ETEX
Street Address:
City:
State:
Zip:
Submittal Date: Wed May 31 12:03:18 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: The proposed language is not enforceable.

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Public Input No. 29-NFPA 502-2023 [ Section No. 6.3.1 [Excluding any Sub-

Sections] ]

Acceptable means shall be included within the design of the bridge or elevated highway to
prevent progressive structural collapse or , collapse of primary structural elements or large
structural damage .

Statement of Problem and Substantiation for Public Input

Large structural damage, as has been observed at the Pont Mathilde bridge fire (Rouen, France), shall
be avoided as to prevent "unacceptable implications" as mentioned in section 6.3.2.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 31-NFPA Both PI emphasize the importance of large structural
502-2023 [Section No. 6.3.3] damage as an unacceptable implication

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:59:42 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: The term "large" is not quantifiable and is unenforceable. This concern is already
addressed in Section 6.3.2.

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Public Input No. 31-NFPA 502-2023 [ Section No. 6.3.3 ]

6.3.3
For through truss bridges, suspension (including cable stay) bridges, or elevated highways, an
engineering analysis shall be prepared to determine acceptable risk due to fire, including
possible collapse scenarios and large structural damage .

Statement of Problem and Substantiation for Public Input

Large structural damage, as has been observed at the Pont Mathilde bridge fire (Rouen, France), shall
be avoided as to prevent "unacceptable implications" as mentioned in section 6.3.2.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 29-NFPA 502-2023 [Section No. 6.3.1 [Excluding any Sub-
Sections]]

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 11:21:30 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: The term "large" is not quantifiable and is unenforceable. This concern is already
addressed in Section 6.3.2.

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Public Input No. 18-NFPA 502-2023 [ Section No. 7.2.1 ]

7.2.1*
Where a roadway or portion of a roadway is not fully enclosed on both sides, is not fully
enclosed on top, or any combination thereof, the decision by the authority having jurisdiction
(AHJ) to consider the roadway, or parts thereof, as a road tunnel shall be made after an
engineering analysis is performed in accordance with 4.3.1.

Statement of Problem and Substantiation for Public Input

The engineering analysis, according to 4.3.1, might lead to conclusions as to whether or not the not
fully enclosed roadway is a tunnel or not, which are different for each of the functional requirements.
An opening might certainly facilitate fire fighter actions, but might increase the heat release rate
(ventilation controlled fire). The aim of the proposed change is to draw attention to that, and avoid a
decision to make a compromise for the entire roadway under consideration, but allow for differentiation
for individual parts of the not fully enclosed roadway.

Submitter Information Verification

Submitter Full Name: Cornelis Both

Organization: ETEX
Street Address:
City:
State:
Zip:
Submittal Date: Wed May 31 12:17:30 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-14-NFPA 502-2023

Statement: The aim of the proposed change is to avoid a compromise for the entire roadway under
consideration, but allow for differentiation for individual segments of the not fully enclosed
roadway.

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Public Input No. 12-NFPA 502-2023 [ New Section after 7.4.7.3 ]

7.4.7.x
For facili�es that u�lize a SCADA system to monitor and control facility subsystems that are part of an integrated emergency resp
7.4.7.2, the SCADA system shall include SIL 2 rated safety func�ons for the ini�a�on of fire protec�on as part of a defined Safety In
accordance with the ANSI ISA-84/IEC 61511, Standard Func�onal safety - Safety instrumented systems for the process industry sec

Additional Proposed Changes

File Name Description Approved

Professional
NFPA_Professional_Backaground_and_Experience_- background
_Thomas_Kuhn.docx information for
Thomas Kuhn

Statement of Problem and Substantiation for Public Input

Most tunnels utilize high availability SCADA systems for tunnel ventilation control and now increasingly
for fire protection as well. Fire alarm systems, which are listed for fire alarm use, generally do not
provide the functionality or controls capability for advanced fire protection functions such as positive
alarm sequencing, operator intervention, remote and automated control and interface with other
systems (e.g., traffic control systems, ITS). The previous inclusion of SIL-2 certified components was
the next logical step for fire protection by SCADA systems. This suggested addition is the next logical
step in tunnel safety for SCADA systems because it requires the process of calculating the SIL rating
based on availability and design of the SCADA system’s fire protection safety function. It limits the
safety function requirements to fire protection only, which is a more discrete and attainable standard for
current technology.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn

Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 15:32:37 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: Section 7.4.7.3 currently requires a minimum integrity level of SIL-2; therefore a new
section does not need to be created to restate current requirements. It is unknown
whether ANSI ISA-84/IEC 61511N would apply to SCADA system utilized in these
facilities at this time and may have unintended consequences. Section 7.4.7.3 clearly
identifies IEC 61508 which does apply to SCADA systems used in this standard.

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Public Input No. 11-NFPA 502-2023 [ Section No. 7.4.7.3 ]

7.4.7.3*
For facili�es that u�lize a nonlisted nonlisted SCADA system to monitor and control facility
subsystems that are a part of an integrated emergency response system described in 7.4.7.2 , the
components of the SCADA system including and between the programmable logic control pla�orm
(logic solver) and the its field level input/output modules , shall a�ain be cer�fied to a minimum
safety integrity level Safety Integrity Level (SIL) of SIL - 2 in accordance with the IEC 61508,
Standard for Func�onal Safety of Electrical/Electronic/Programmable Electronic Safety-Related
Systems .

Additional Proposed Changes

File Name Description Approved

Professional
NFPA_Professional_Backaground_and_Experience_- background
_Thomas_Kuhn.docx information for
Thomas Kuhn

Statement of Problem and Substantiation for Public Input

The IEC standard 61508 is for manufacturers of controls equipment. Leading manufacturers of PLCs
have their equipment certified to a SIL rating by an independent agency such as TÜV Rheinland
according to both 61058 and 61511. It is important to note that the certification is for the equipment
components and systems provided by manufacturers and not the final installed system by the end
users. Understanding then that the intent of this paragraph is to use SIL rated components for PLC
systems used for fire protection such as deluge or high-pressure mist systems in tunnels, then these
minor modifications are intended to clarify the requirement to use SIL-2 certified components.

Secondly, the “and between” language is suggested to be removed and the “logic solver” language
added to be consistent with the terms in the 61508/61511 standards. The logic solver component of a
safety instrumented system (SIS) is typically the PLC (Programmable Logic Controller) and its
input/output (I/O) modules. Most mainstream, commercially off-the-shelf PLCs and their I/O modules
have versions with SIL 2 certification, but it is not clear what “and between” would refer to as the logic
solver definition includes functionality for PLC backplanes, network/communication I/O adapters etc.
Including “and between” may lead to misinterpretations of the 502 standard to include interposing
relays, network switches and other devices which are not part of the SIS or its safety function. By
using “logic solver” the necessary components are implied.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn

Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 14:22:53 EDT 2023
Committee: ROA-AAA

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Committee Statement

Resolution: Using the term Certified might be misinterpreted that the SCADA system would be
required to be listed.

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Public Input No. 13-NFPA 502-2023 [ Section No. 7.4.7.4 ]

7.4.7.4
For facili�es that do not u�lize a nonlisted SCADA system to monitor and control facility subsystems,
the ac�va�on of subsystems in response to a fire emergency shall be directly ini�ated from the FACP
listed fire alarm or emergency response system .

Additional Proposed Changes

File Name Description Approved

Professional
NFPA_Professional_Backaground_and_Experience_- background
_Thomas_Kuhn.docx information for
Thomas Kuhn

Statement of Problem and Substantiation for Public Input

The FACP (Fire Alarm Control Panel) is a component of a fire alarm system. Not all manufacturers
may have FACPs that can include initiation controls. Alternately some fire alarm systems have listed
computer-based interfaces that are either panel mounted or desktop computers. The intent of this
modification is to provide a more general requirement that can be met by multiple listed fire alarm
systems so they may not necessarily be limited to using an FACP for initiation.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn

Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 15:42:52 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: It is unclear what a listed emergency response system is. A FACP is a listed component
which is used to operate the Fire Alarm System.

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Public Input No. 37-NFPA 502-2023 [ New Section after 7.9.1 ]

Lithium-Ion Battery Portable Fire Extinguisher

Portable fire extinguisher with a rating of Class L-Lithium Ion Battery, shall be lacated along
along the roadway in approved wall cabinets at intervals of not more than 90 m (300 ft).

Statement of Problem and Substantiation for Public Input

Lithium-Ion Battery is the #1 growing hazard in the world. LIB is an electrochemical fire involving Class
A, Class B, Class C, and in some cases Class D fires. We know from NFPA Research project that it
takes copious amounts of water. We also know from testing that ABC Dry Powder is ineffective on LIB.
NFPA 18A, Section 7.7 - Encapsulator Agents have been extensively test and are effective on LIB and
stopping thermal runaway propagation. See NFPA 18A, A4.3.

Submitter Information Verification

Submitter Full Name: Michael Greiner

Organization: Hazard Control Technologies, I
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 17:10:35 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: These extinguishers are ineffective on car fires with Lithium-Ion batteries. This may give
occupants a false sense of security in that they could control a fire event involving an
electric vehicle.

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Public Input No. 19-NFPA 502-2023 [ Section No. 7.16.5.5 ]

7.16.5.5*

Emergency exit door assemblies exposed to the incident tunnel shall be 1 1 ⁄ 2 -hour rated rated
for a period of fire exposure as per 7.3.3 , based on the time-temperature curve described in
7.3.2, and shall be installed in accordance with NFPA 80. All other doors in the path of egress
shall comply with NFPA 101.

Statement of Problem and Substantiation for Public Input

Arguably, the rating of the doors and the other parts (compartmentation, walls, ceiling) need to be the
same. With the public input, an attempt has been made to align this, but leave the opening for a
deviation, should the AHJ accept this.

Submitter Information Verification

Submitter Full Name: Cornelis Both

Organization: ETEX
Street Address:
City:
State:
Zip:
Submittal Date: Wed May 31 12:27:32 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-10-NFPA 502-2023

Statement: The proposed text has merit but requires review by a Task Group. Task Group is
reviewing how doors should be rated in a tunnel environment.

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Public Input No. 32-NFPA 502-2023 [ Section No. 7.16.5.5 ]

7.16.5.5*
Emergency exit door assemblies exposed to the incident tunnel shall be 11⁄2-hour rated, based
on a worst-case differential pressure and on the time-temperature curve described in 7.3.2, and
shall be installed in accordance with NFPA 80. All other doors in the path of egress shall comply
with NFPA 101.

Statement of Problem and Substantiation for Public Input

Emergency exit doors usually have quite a lot of intumescent materials for closing the door at fire
conditions. The performance of intumescent material is negatively influenced by a (high) differential
pressure over the door (i,e. they will be blown out if not properly implemented/installed) which will
impact the fire rating of the door. Therefore testing at a worst-case differential pressure is important to
show that an emergency exit door can withstand a tunnel fire. In the Netherlands an overpressure in
the fire resistance furnace of 50 Pa at the top of door is used.

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 12:04:43 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-10-NFPA 502-2023

Statement: The proposed text has merit but requires review by a Task Group. Task Group is
reviewing how doors should be rated in a tunnel environment.

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Public Input No. 15-NFPA 502-2023 [ New Section after 7.17.1 ]

Fire-fighter breathing air replenishment system (FBARS)

Where required, fire-fighter breathing air replenishment systems shall comply with Appendix F
of the Uniform Plumbing Code .

Statement of Problem and Substantiation for Public Input

Cities in at least 21 states and Canada now require Fire-fighter breathing air replenishment systems
(FBARS) – several of which specifically require FBARS to be installed in transportation tunnels. The
following list contains examples of specific cities and projects where FBARS are required in tunnels:

1. The cities of Bellevue, WA and Nashville, TN require FBARS in transportation tunnels exceeding
300 ft in length constructed in accordance with NFPA 502 and 130.
2. The city of San Francisco, CA requires FBARS to be installed in new transportation and
pedestrian tunnels the exceed 300 ft in length.
3. The city of San Jose, CA requires FBARS to be installed in any tunnel over 500 ft in length.
4. The Montreal City Fire Department currently requires FBARS to be included as part of the Mont-
Royal Tunnel refurbishment project.

Fire-fighter breathing air replenishment systems (FBARS) are fixed standpipe systems that deliver
breathing air. They are designed to provide firefighters with a quick, safe, reliable, and constant source
of air. Just as water standpipes replaced hand buckets as a delivery system for water, FBARS
replaces the slow, labor-intensive process of hand-delivering replacement air bottles. The system is
designed to allow firefighters to refill their air bottles in 2 minutes or less under full respiration at fill
stations located throughout the interior of a structure or building.

The purpose of this public input is to provide a basis to include future requirements that to help clarify
where and how FBARS should be applied in tunnels when required by an AHJ. As a starting point the
Uniform Plumbing Code currently provides a comprehensive set of base design, installation,
inspection, testing, and maintenance requirements for FBARS. It’s currently referenced in Annex D of
NFPA 1.

Submitter Information Verification

Submitter Full Name: Zachary Magnone

Organization: Johnson Controls
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 30 15:33:38 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-3-NFPA 502-2023

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Statement: Depending on the length of the tunnel, it may be beneficial for fire fighters to have the
ability to refill their air supply bottles without having to leave the tunnel or have somebody
continually bringing bottles in and out. A task group has been established to determine
what the minimum requirements would be where a FARS (Firefighters Air Replenishment
System) is installed in a tunnel.

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Public Input No. 38-NFPA 502-2023 [ New Section after 9.2.2.1 ]

9.2.2.1.1 Agent-Water Fixed Fire Suppression System

An agent-water fire suppression system utilizing Encapsulator Agent conforming to NFPA 18A,
Section 7.7. Encapsulator Technology - Spherical Micelle Stability Test Protocol have proven to
modify the heat reduction mechnaism of a plain water droplet, resulting in greater heat reduction
than plain water and up to three time greater heat reduction that Water Mist. In addition
Encapsulator Agents have proven to be effective on Lithium-ion Battery hazard as outlined in
NFPA 18A, Setion A4.3.

Statement of Problem and Substantiation for Public Input

Lithium-Ion Battery is the #1 growing hazard in the world. LIB is an electrochemical fire involving Class
A, Class B, Class C, and in some cases Class D fires. We know from NFPA Research project that it
takes copious amounts of water. We also know from testing that ABC Dry Powder is ineffective on LIB.
NFPA 18A, Section 7.7 - Encapsulator Agents have been extensively test and are effective on LIB and
stopping thermal runaway propagation. See NFPA 18A, A4.3. In addition, testing has shown
Encapsulator Agents utilizing regular spray droplet can reduce heat rate over 3 times faster than Water
Mist (i.e., smaller water mist droplet)

Submitter Information Verification

Submitter Full Name: Michael Greiner

Organization: Hazard Control Technologies, I
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 17:26:23 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: Proposed text is not enforceable. No fire test data was provided to support the
encapsulating agent referenced in the proposed text.

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Public Input No. 30-NFPA 502-2023 [ Section No. 11.4 [Excluding any Sub-

Sections] ]

The design of the emergency ventilation system shall be based on a fire scenario having
defined heat release rates (HRR), smoke release rates, and carbon monoxide release rates
and release rates from other toxic gases identified from the fire scenario , all varying as a
function of time. The selection of the fire scenario shall consider the operational risks that are
associated with the types of vehicles expected to use the tunnel. The fire scenario shall consider
fire at a location where the most stringent ventilation system performance requirement is
anticipated by an engineering analysis.

Statement of Problem and Substantiation for Public Input

Since more vehicles are propelled by other (new) energy carriers other toxic gases, such as hydrogen
fluoride, shall be considered in the engineering analysis.

Submitter Information Verification

Submitter Full Name: Jos Bienefelt

Organization: Efectis
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 11:09:37 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-12-NFPA 502-2023

Statement: The proposed text has merit but requires review by a Task Group. Task Group is review
combustible material and constituents in an emergency scenario.

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Public Input No. 24-NFPA 502-2023 [ Section No. 12.1 ]

12.1 General.
12.1.1*
The electrical systems shall support life safety operations, fire emergency operations, and
normal operations.
12.1.2
Emergency circuits installed in a road tunnel and ancillary areas shall remain functional for a
period of not less than 1 hour for the anticipated fire condition by one of the following methods:
(1) * Fire-resistive cables shall be approved or be listed for no less than 2 hours when
tested to the time-temperature curve of ASTM E119, Standard Test Methods for Fire Tests
of Building Construction and Materials , in accordance with UL 2196, Fire Test for Circuit
Integrity of Fire-Resistive Power, Instrumentation, Control, and Data Cables, or other
approved, recognized standards, as follows:
(2) Fire-resistive cables shall be tested as a complete system, in both vertical and
horizontal orientations, on conductors, cables, and raceways as applicable.
(3) Fire-resistive cables intended for installation in a raceway shall be tested in the type of
raceway in which they are intended to be installed.
(4) Each fire-resistive cable system shall have installation instructions that describe the
tested assembly with only the components included in the tested assembly acceptable
for installations.
(5) Fire-resistive cables shall be installed in accordance with their listing and
manufacturer’s instructions.

(6) * Circuits shall be protected by a 2-hour fire barrier system in accordance with UL 1724,
Outline of Investigation for Fire Tests for Electrical Circuit Protective Systems. The cables
or conductors shall maintain functionality at the operating temperature within the fire barrier
system.
(7) They shall remain functional by the routing of the cable system external to the roadway.
(8) They shall remain functional by using diversity in system routing as approved, such as
separate redundant or multiple circuits separated by a 2-hour fire barrier, so that a single
fire or emergency event will not lead to a failure of the system.
12.1.3
The requirement of 12.1.2 shall not apply to bidirectional antennas used for emergency
communication circuits.
12.1.4
The electrical systems shall maintain ventilation, lighting, communications, drainage, a fixed
water-based fire-extinguishing system, fire alarm and fire detection, exit signs, traffic control,
and others for areas of refuge, exits, and exit routes, under all normal and emergency modes
associated with the facility.
12.1.5*
The fire-life safety electrical systems shall be designed and installed to resist lateral forces
induced by earthquakes (seismic forces) in the appropriate seismic zone and to continue to
function after the event.

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12.1.6
An electrical single-line diagram shall be posted within the main electrical room.
12.1.6.1
The diagram shall include utility short-circuit duty, all sources, uninterrupted power supplies
(UPSs), or standby source and interlocking schemes, and other data per IEEE standards for
single-line diagrams.
12.1.7
Labels, nameplates, or tags shall be affixed to switchboards, panelboards, motor controllers,
switches, and breakers that correspond to the single line. The equipment or device operating
instructions shall be available to operating personal.

Statement of Problem and Substantiation for Public Input

This Public Input accomplishes three changes to provide better technical accuracy and guidance
related to the requirements for fire-resistive cables:
1. Fire-resistive cables are required to be listed in Section 728.4 of the NEC, so there is no need to
have this “approved” here. “Tested and listed” would match the current language in the NEC.
2. Deleting reference to the ASTM E119 standard time-temperature curve as that is the referenced
test criteria in UL 2196. That language is redundant and not necessary.
3. Adding a requirement for installation in accordance with the listing and manufacturer’s instructions is
a crucial component to ensure the proper use and installation of the required fire-resistive cable.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 23-NFPA 502-2023 [Section No. 2.3.9]

Submitter Information Verification

Submitter Full Name: Kelly Nicolello

Organization: UL Solutions
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:19:37 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-6-NFPA 502-2023

Statement: The word “approved” was maintained in the requirements to allow flexibility for standards
that may apply outside of the US or other unique situations. Part (d) was added as
installation instructions are part of the requirements of UL 2196. Subsection (3) was
revised to remove requirements for cables run outside the roadway and a new fire test
was introduced (IEEE 2412) providing an alternate means of protecting a circuit within
the roadway.

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Public Input No. 27-NFPA 502-2023 [ Section No. 12.2.1.3 ]

12.2.1.3
All cables and conductors used in road tunnels shall be resistant to the spread of fire and shall
have reduced smoke emissions by one of the following methods:
(1) Wires and cables listed as having fire-resistant and low smoke-producing characteristics,
by having a cable char height of not greater than 1.5 m (4.9 ft) when measured from the
lower edge of the burner face, a total smoke release over the 20-minute test period no
greater than 150 m2, and a peak smoke release rate of no greater than 0.40 m2/sec, when
tested in accordance with either anyone of the following:
(2) IEEE 1202, Standard for Flame-Propagation Testing of Wire and Cable

,
(a)
(b) The method described in
UL 1685, Vertical-Tray Fire-Propagation and Smoke-Release Test for Electrical and
Optical-Fiber Cables , or the
(a) UL 2556 Vertical tray flame tests (Method 1 – Vertical tray and Method 2 – FT4)
(b) CSA FT4 Vertical Flame Test per CSA C22.2 No. 0.3, Test Methods for Electrical
Wires and Cables
(3) Wires and cables listed as having fire-resistant and low smoke-producing characteristics,
by having a flame travel distance that does not exceed 1.5 m (4.9 ft), generating a
maximum peak optical density of smoke of 0.5 and a maximum average optical density of
smoke of 0.15 when tested in accordance with the methods described in NFPA 262 or the
CSA FT6 Horizontal Flame and Smoke Test per CSA C22.2 No. 0.3
(4) Where cables are installed in communications raceways fittings shall be listed as having a
maximum peak optical density of 0.50 or less, an average optical density of 0.15 or less,
and a maximum flame spread distance of 1.5 m (4.9 ft) or less when tested in accordance
with UL 2024, Cable Routing Assemblies and Communications Raceways.
(5) Wires and cables tested to equivalent internationally recognized standards approved by the
authority having jurisdiction (AHJ)

Statement of Problem and Substantiation for Public Input

This Public Input accomplishes several changes to provide better technical accuracy and guidance
related to the requirements for fire-resistive cables:
1. Adds a “pointer” to Section 12.1.2 for cables installed in tunnels; picks up certification requirement to
UL 2196.
2. Replaces UL 1685 with UL 2556, Wire and Cable Test Methods. UL 1685 is being phased out as
per the PrE Susan Stene/Anthony Tassone
3. Add new reference to UL 2024, Cable Routing Assemblies and Communications Raceways
4. The addition of “(3)” aligns these requirements with NFPA 90A Section 4.3.11.2.6.4

Related Public Inputs for This Document

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Related Input Relationship

Public Input No. 23-NFPA 502-2023 [Section No. 2.3.9]

Submitter Information Verification

Submitter Full Name: Kelly Nicolello

Organization: UL Solutions
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 10:33:47 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-4-NFPA 502-2023

Statement: The revision replaces UL 1685 with UL 2556, Wire and Cable Test Methods as UL 1685
is being phased out. Communication raceways are not applicable for installation in
tunnels since tunnels don't have plenums as defined in NFPA 90A.

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Public Input No. 34-NFPA 502-2023 [ Section No. A.4.3.2 ]

A.4.3.2
Fire protection, life safety, or emergency systems are comprised of interdependent mechanical,
electrical, communications, control, fire protection, structural, architectural, and other elements,
all of which must function as a system to achieve the designed result. It is critical that all primary
and supporting elements are protected to produce a similar level of combined system reliability
for the design incident exposure. This does not preclude loss of elements that are compensated
for in the design.

Protecting ceiling or portal mounted fire and other emergency systems, as well as structural elements
from over height collisions may be necessary to ensure reliability. Over height collisions may result in
lengthy functional loss of essential systems, expensive repairs which may result in lengthy tunnel
closures. Over height vehicles height may occur from exceeding height restrictions, or vehicle equipment
not properly secured e.g., dump trucks with beds in open position, etc. In addition to height warning
signs, automatic over height detection and driver warning systems, is used, should occur before last exit
in advance of tunnel, bridge or air rights structures.

Statement of Problem and Substantiation for Public Input

Reliability of fire systems have been eliminated by over height collisions with tunnel systems. Although
existing language in road and bridge design may include maximum allowable vehicle heights, where
these limits have been exceeded fire and other essential systems have been severely damaged. This
annex language identifies a potential preventative measure to improve reliablity.

Submitter Information Verification

Submitter Full Name: Gary English

Organization: Underground Command and Safety
Affiliation: 502 Technical Committee alternate
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 15:22:28 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-15-NFPA 502-2023

Statement: The proposed text has merit but requires review by a Task Group. Task Group is
reviewing over-height protection methods for mounted emergency systems. [MOS
doesn't allow for "may" within the annex text; alternates include "can", "might", and
"should."]

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Public Input No. 36-NFPA 502-2023 [ New Section after A.4.4.1 ]

TITLE OF NEW CONTENT

A. 4.4.2 Historically, where project design and operational intent progressed without responder
input beyond the point where essential changes are readily possible, responders and AHJs
have required changes which could have been resolved with earlier responder input with less
impact to project schedule, and additional costs.

Statement of Problem and Substantiation for Public Input

Clarifies impacts of not requiring responder agencies input early enough to prevent schedule delays
and costs which could have been avoided.

Submitter Information Verification

Submitter Full Name: Gary English

Organization: Underground Command And Safety
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 15:44:31 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-2-NFPA 502-2023

Statement: Although emergency response agencies may comment on emergency plans, and may, at
the owner/designer discretion be invited to comment on design and operational intent,
there is no requirement for this to occur. This language makes this a requirement. In
some cases, lack of early input results in final design being completed without responder
agencies input. Lacking early input, the design and response plans may not allow
effective responder actions. This lack of input has resulted in responder or local AHJ
requiring changes to design with resultant unnecessary delays and additional costs.
Subsequent sections to be renumbered.

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Public Input No. 39-NFPA 502-2023 [ Section No. A.7.2 ]

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A.7.2

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The categorization of road tunnels is also influenced by their level of traffic congestion as
evidenced by the tunnel’s peak hourly traffic count, as shown in Figure A.7.2. These minimum
requirements, which are fully described within this standard, are summarized in Table A.7.2 as
a reference guide to assist in the search for requirements listed elsewhere in this standard.
Figure A.7.2 Urban and Rural Tunnel Categories.

Table A.7.2 Minimum Road Tunnel Fire Protection Reference Guide

Road Tunnel Categories

X A B C
NFPA 502 [See [See [See [See
Fire Protection Systems Sections 7.2(1)] 7.2(2)] 7.2(3)] 7.2(4)]
Engineering Analysis
Engineering analysis 4.3.1 MR MR MR MR
Fire Protection of Structural
Elementsa
Fire protection of structural 7.3 MR MR MR MR
elements
Fire Detection
Detection, identification, and 7.4 — CMR MR MR
location of fire in tunnel
CCTV systemsb 7.4.3 — CMR CMR CMR
Automatic fire detection 7.4.6.7 — CMR CMR CMR
systemsb
Fire alarm control panel 7.4.7 — CMR MR MR
Emergency Communications Systemsc
Emergency communications 4.5/7.5 CMR CMR CMR CMR
systems
Traffic Control
Stop traffic approaching tunnel 7.6.1 MR MR MR MR
portal
Stop traffic from entering tunnel’s 7.6.2 — CMR MR
direct approaches MR
Fire Protection

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Road Tunnel Categories

X A B C
NFPA 502 [See [See [See [See
Fire Protection Systems Sections 7.2(1)] 7.2(2)] 7.2(3)] 7.2(4)]
Fire apparatusd 7.7 — — — —
Fire standpipe 7.8/10.1 — MR MR MR
Water supply 7.8/10.2 — MR MR MR
Fire department connections 10.3 — MR MR MR
Hose connections 10.4 — MR MR MR
Fire pumpse 10.5 — CMR CMR CMR
Portable fire extinguishers 7.9 — MR MR MR
Fixed water-based firefighting 7.10/Chapter 9 — — CMR CMR
systemsf
Emergency ventilation systemg 7.11/Chapter 11 — — CMR MR

Tunnel drainage systemh 7.12 — CMR MR MR

Hydrocarbon detectionh 7.12.7 — CMR MR MR

Flammable and combustible 7.15 — CMR CMR CMR
environmental hazardsi
Means of Egress
Emergency egress 7.16.1.1 — — MR MR
Exit identification 7.16.1.2 — MR MR MR
Tenable environment 7.16.2 — — MR MR
Walking surface 7.16.4 — MR MR MR
Emergency exit doors 7.16.5 — — MR MR
Emergency exits (includes cross- 7.16.6 — — MR MR
passageways)j
Electrical Systemsk
General 12.1 — CMR MR MR
Emergency power 12.4 — CMR MR MR
Emergency lighting 12.6 — CMR MR MR
Exit signs 12.6.8 — CMR MR MR
Security plan 12.7 — CMR MR MR
Emergency Response Plan
Emergency response plan 13.3 MR MR MR MR
MR: Mandatory requirement (3.3.42). CMR: Conditionally mandatory requirement (3.3.42.1).
Note: The purpose of Table A.7.2 is to provide guidance for locating minimum road tunnel fire
protection requirements within this standard. If there is any conflict between the requirements
defined in the standard text and this table, the standard text must always govern.
aDetermination of requirements in accordance with Section 7.3.

bDetermination of requirements in accordance with Section 7.4.

cDetermination of requirements in accordance with Sections 4.5 and 7.5.

dNot mandatory to be at tunnel; however, they should be near to minimize response time.

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eIf required, must follow Section 10.5.

fIf installed, must follow Section 7.10 and Chapter 9.

gSection 11.1 allows engineering analysis to determine requirements.

hIf required, must follow Section 7.12.

iDetermination of requirements in accordance with 7.15.2.

jEmergency exit spacing must be supported by an egress analysis in accordance with 7.16.6.

kIf required, must follow Chapter 12.

Additional Proposed Changes

File Name Description Approved

NFPA_502_2023_-_Table_A.7.2_- Track changes version with comments of
_DBH.docx Table A.7.2

Statement of Problem and Substantiation for Public Input

The table is often used to summarize the required systems. Although the disclaimer is present
regarding conflicts between the main body and the table, the table is sometimes presented by itself
and can be misleading. The table is outdated and many of the references and determination of MR vs
CMR require updates.

Recommend to address updating the table through a working committee as it may have impact on
associated clauses.

The use of CMR needs to be clarified and a coherent methodology for labeling MR vs CMR vs –
should be established throughout the table including how items listed and items not listed in 4.3.1 are
addressed. New systems should be added while outdated ones should be removed and others
modified to reflect the most up to date requirements.

Submitter Information Verification

Submitter Full Name: David Hahm

Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 17:36:21 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-5-NFPA 502-2023

Statement: A Task Group was created to correct any issues found within Table A.7.2 and any
peripheral language attached to the table.

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Public Input No. 33-NFPA 502-2023 [ Section No. B.2.1 ]

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B.2.1 Heat Effects.

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Exposure to heat can lead to life threat in three basic ways:

(1) Hyperthermia
(2) Body surface burns
(3) Respiratory tract burns
For use in the modeling of life threat due to heat exposure in fires, it is necessary to consider
only two criteria — the threshold of burning of the skin and the exposure at which hyperthermia
is sufficient to cause mental deterioration and thereby threaten survival.
Note that thermal burns to the respiratory tract from inhalation of air containing less than
10 percent by volume of water vapor do not occur in the absence of burns to the skin or the
face; thus, tenability limits with regard to skin burns normally are lower than for burns to the
respiratory tract. However, thermal burns to the respiratory tract can occur upon inhalation of air
above 60°C (140°F) that is saturated with water vapor.

The tenability limit for exposure of skin to radiant heat is approximately 2.5 kW/m2. Below this
incident heat flux level, exposure can be tolerated for 30 minutes or longer at least several
minutes without significantly affecting the time available for escape. Above this threshold value,
the time to severe skin pain, burning of skin due , incapacitation, or serious injury due to
radiant heat decreases rapidly according can be calculated according to equation B.2.1a.

[B.2.1a]
where:
tIrad = time to burning of skin due to radiant heat (minutes)
r = radiant heat exposure dose (kW/m 2 ) 4/3 min
q = radiant heat flux (kW/m2)
Radiant heat exposure dose, r Value [ (kW m -2 ) 4/3 min]
Severe skin pain (a tolerance threshold) 1.33
Second-degree burns 4.0
Fatal level for a vulnerable popula�on (over 65 10.0
years of age) or 1 % fatality level for the average
popula�on (a threshold for incapacita�on and
serious injury)
Third degree (full-thickness) burns (50% 16.7
probability lethal level for the average
popula�on)

As with toxic gases, an exposed occupant can be considered to accumulate a dose of radiant
heat over a period of time. The fraction equivalent dose (FED) of radiant heat accumulated per
minute is the reciprocal of tIrad.
Radiant heat tends to be directional, producing localized heating of particular areas of skin even
though the air temperature in contact with other parts of the body might be relatively low. Skin
temperature depends on the balance between the rate of heat applied to the skin surface and
the removal of heat subcutaneously by the blood. Thus, there is a threshold radiant flux below
which significant heating of the skin is prevented but above which rapid heating occurs.
Based on the preceding information, it is estimated that the uncertainty associated with the use
of equation B.2.1a is ±25 percent. Moreover, an irradiance of 2.5 kW/m2 would correspond to a
source surface temperature of approximately 200°C (392°F), which is most likely to be
exceeded near the fire, where conditions are changing rapidly.

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Calculation of the time to incapacitation under condition of exposure to convected heat from air
containing less than 10 percent by volume of water vapor can be made using either equation
B.2.1b or equation B.2.1c.
As with toxic gases, an exposed occupant can be considered to accumulate a dose of
convected heat over a period of time. The FED of convected heat accumulated per minute is
the reciprocal of tIconv.
Convected heat accumulated per minute depends on the extent to which an exposed occupant
is clothed and the nature of the clothing. For fully clothed subjects, equation B.2.1b is
suggested:

[B.2.1b]

where:
tIconv = time (minutes)
T = temperature (°C)
For unclothed or lightly clothed subjects, it might be more appropriate to use equation B.2.1c:

[B.2.1c]

where:
tIconv = time (minutes)
T = temperature (°C)
Equations B.2.1b and B.2.1c are empirical fits to human data. It is estimated that the uncertainty
is ±25 percent.
Thermal tolerance data for unprotected human skin suggest a limit of about 120°C (248°F) for
convected heat, above which there is, within minutes, onset of considerable pain along with the
production of burns. Depending on the length of exposure, convective heat below this
temperature can also cause hyperthermia.
The body of an exposed occupant can be regarded as acquiring a “dose” of heat over a period
of time. A short exposure to a high radiant heat flux or temperature generally is less tolerable
than a longer exposure to a lower temperature or heat flux. A methodology based on additive
FEDs similar to that used with toxic gases can be applied. Providing that the temperature in the
fire is stable or increasing, the total fractional effective dose of heat acquired during an
exposure can be calculated using equation B.2.1d:

[B.2.1d]

where:
FED = fraction equivalent dose
tIrad = time (min)
tIconv = time (min)
= change in time (min)

Note 1: In areas within an occupancy where the radiant flux to the skin is under 2.5 kW/m2, the
first term in equation B.2.1d is to be set at zero.
Note 2: The uncertainty associated with the use of equation B.2.1d would depend on the
uncertainties associated with the use of the three earlier equations.
The time at which the FED accumulated sum exceeds an incapacitating threshold value of 0.3
represents the time available for escape for the chosen radiant and convective heat exposures.

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Consider an example with the following characteristics:

(1) Evacuees are lightly clothed.
(2) There is zero radiant heat flux.
(3) The time to FED is reduced by 25 percent to allow for uncertainties in equations B.2.1b and
B.2.1c.
(4) The exposure temperature is constant.
(5) The FED is not to exceed 0.3.
Equations B.2.1c and B.2.1d can be manipulated to provide the following equation:

[B.2.1e]

where:
texp = time of exposure to reach a FED of 0.3 (minutes)
T = temperature (°C)
This gives the results in Table B.2.1.
Table B.2.1 Exposure Time and Incapacitation

Exposure Temperature Maximum Exposure Time Without Incapacitation

°C °F (min)
80 176 3.8
75 167 4.7
70 158 6.0
65 149 7.7
60 140 10.1
55 131 13.6
50 122 18.8
45 113 26.9
40 104 40.2

Statement of Problem and Substantiation for Public Input

The SFPE Handbook of Fire Protection Engineering, 5th Edition has the power of 1.33, not 1.36.
Suggest using a variable r for the radiant heat exposure dose which has a range between 1.33 to 1.67
for severe skin pain, 4.00 to 12.2 for second degree burns, 16.7 for third degree burns. Pursur and
McAllister also propose “that a figure of 1.33 (kW · m-2)4/3min is used to represent a tolerance
threshold and 10 (kW · m-2)4/3min a threshold for incapacitation and serious injury. For infrared
radiation it is also proposed that 10 (kW · m-2)4/3min represents a fatal level for a vulnerable
population (over 65 years of age) or a 1 % fatality level for the average population, whereas 16.7 (kW ·
m-2)4/3min represents a 50 % probability lethal level for the average population.” If the 4 value is
decided to remain, need to provide a unit, (kW m-2)4/3 min, to the radiant heat exposure dose number
for consistency of units.

Submitter Information Verification

Submitter Full Name: David Hahm

Organization: Mott MacDonald
Street Address:

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City:
State:
Zip:
Submittal Date: Thu Jun 01 12:32:11 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-13-NFPA 502-2023

Statement: The proposed text has merit but requires review by a Task Group. Task Group is going to
review the references and source material against the ISO standard and provide a
working value as basis for design.

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Public Input No. 14-NFPA 502-2023 [ New Section after D.3.1.2 ]

D.3.1.3 Dimensionless HRR update to 2017 variable Critical Froude Number table.
Because NFPA 502 2017 Critical Velocity calculation methodology referenced publications [8],
[9], [10] use dimensionless HRR instead of total HRR, an updated variable Critical Froude
Number table with dependency on dimensionless HRR is shown in Table D.3.1.3. To convert
the dimensionless HRR to total HRR to be used by the equations D3.1.1, equation D.3.1.3 is
provided below.
Table D.3.1.3 Critical Froude Number Factors (based on Dimensionless FHRR, Q*)
Q* K1

>1.608 0.606

1.448 0.62

1.126 0.64

0.804 0.68

0.483 0.74

<0.1608 0.87
[D.3.1.3]

Using the dimensionless FHRR methodology, Figure D.3.1.3 shows the improved applicability to
tunnel with height different than 5 m.
Figure D.3.1.3 Demonstration of dimensionless FHRR variable Critical Froude Number table
applicability on a 3m by 3m tunnel in comparison to 2014 and 2017 methodologies (limitation
from Figure D.3.1.2.1 has been improved).
Figure D.3.1.3 to be attached here
The dimensionless FHRR methodology has improved the 2017 methodology applicability. The
methodology was developed based on scale modeling techniques with limitation of tunnel shape
roughly resemble a square tunnel.
References to be included as part of Annex D:
[8] Oka, Y., and Atkinson, G.T., “Control of smoke flow in tunnel fires,” Fire Safety Journal, vol.
25, no. 4, pp. 305-322, 1995.
[9] Wu, Y., and Bakar, M.Z.A., “Control of smoke flow in tunnel fires using longitudinal ventilation
systems --- a study of the critical velocity,” Fire Safety Journal, vol. 35, no. 4, pp. 363-390,
2000.
[10] Li, Y.Z., Lei, B., and Ingason, H. , “Study of critical velocity and backlayering length in
longitudinally ventilated tunnel fires,” Fire Safety Journal, vol. 45, no. 6-8, pp. 361-370, 2010.

Additional Proposed Changes

File Name Description Approved

D.3.1.3.PNG Figure D.3.1.3

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Statement of Problem and Substantiation for Public Input

This is a continuation from Public Input: Public Input No. 5-NFPA 502-2023 [ Section No. D.3.1.2 ]

The modification PI for section D.3.1.2 pointed out a limitation of the 2017 Critical Velocity calculation
methodology. This additional section is based on the finding documented in the publication
Shi, Y., Bowman, I., De Los Rios, N., Harvey, N., Lopez, K., and Pelessone, L., “NFPA 502 Critical
Velocity Calculation Methodologies and Dimensionless Heat Release Rate,” proceeding of 10th
International Symposium on Tunel Safety and Security, Stavanger, Norway, April 25th – 28th, 2023.

It improves the applicability of variable Froude Number method by using dimensionless FHRR.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 5-NFPA 502-2023 Continuation of the previous PI, to answer the limitation
[Section No. D.3.1.2] found in the previous section

Submitter Information Verification

Submitter Full
Yinan Shi
Name:
Organization: Mott MacDonald
Norris Harvey, Natasha De Los Rios, Iain Bowman, Kyle
Affiliation:
Lopez, Luke Pelessone
Street Address:
City:
State:
Zip:
Submittal Date: Sat May 27 14:01:58 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-1-NFPA 502-2023

Statement: The papers identified in the PI will need to be provided to the Committee for review
before taking a final action on this PI. Task Group was created to review the material and
report back at the Second Draft Meeting. This Task Group will review the cross sectional
area values and referenced height of the tunnel as it relates to the formula for
determining critical velocity.

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Public Input No. 5-NFPA 502-2023 [ Section No. D.3.1.2 ]

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D.3.1.2 2017 Edition of NFPA 502.

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In the 2017 edition of NFPA 502 [2], a variable critical Froude number, K1 (Table D.3.1.2),
dependent on convective FHRR total FHRR , was added to the 2014 edition equations based
on scale model tests. The new formulation addressed an apparent discrepancy between the
experimental data at lower FHRRs (approximately 20 MW) and the critical velocity predicted by
the 2014 edition equations, as shown in Figure D.3.1.2.
Table D.3.1.2 2017 Edition of NFPA 502 Critical Velocity Equation Critical Froude Number
Factors (based on convective total FHRR, Q T )

QT (MW) K1
>100 0.606
90 0.62
70 0.64
50 0.68
30 0.74
<10 0.87

Figure D.3.1.2 provides a plot of the critical velocity predictions using both the 2014 and 2017
edition NFPA 502 equations and the air velocity results from the Memorial Tunnel Fire
Ventilation Test Program. At heat release rates above the range of 10 MW to 20 MW, the 2017
critical velocity equation predicts a higher critical velocity than the available MTFVTP data.
Figure D.3.1.2 Critical Velocity Equation from 2014 and 2017 Editions of
NFPA 502 Versus MTFVTP (Note: the MTFVTP “backlayering controlled” data are
included for indicative purposes only; they may not be the true Critical Velocities, as
explained in Section D .

3.1.1).
Insert replacement Figure D.3.1.2 here
Note: the following parameters were used in the calculations to produce the 2014 edition of
NFPA 502 curve provided in Figure D.3.1.2:
(1) A radiative heat fraction of 30 percent
(2) A height (H) value of 7 m (23 ft)
(3) A tunnel cross-sectional area of 60 m2 (650 ft2) and a free tunnel area of 50 m2 (540 ft2)

The limitations of the 2017 edition equation with the modified Froude number as shown in Table
D.3.1.2 include the following:
(1) The 2017 edition equation’s limitations are identical to the 2014 edition except that it has
introduced a variable critical Froude number (critical Froude factor K1). Mixing conditions
between the incoming airflow and the fire plume were represented with the variable critical
Froude number factors (Table D.3.1.2).
(2) The fixed critical Froude number used in the 2014 edition equations is a simplification that
is dependent on parameters such as FHRR and tunnel geometry. The 2017 edition
equation attempts to address some of this with a critical Froude number factor (K1) that

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varies based on the FHRR. The values determined are based on small-scale tests.
(3) The 2017 variable critical Froude Number table was developed based on a 5m height
tunnel [6]. Tunnels with other heights should not use this methodology. The limitation is
shown in Figure D.3.1.2.1 with a 3m by 3m tunnel without slope, without blockage.
Figure D.3.1.2.1 Demonstration of 2017 variable Critical Froude Number table limitation
on a 3m by 3m tunnel.
Insert Figure D.3.1.2.1 here
As shown in Figure D.3.1.2.1, the NFPA 502 2017 methodology displayed an incorrect trend
where the Critical Velocity was highest at approximately 15 MW total HRR. Mathematically,
and in practical physics, it is unrealistic to predict a higher Critical Velocity value for a small
total HRR fire than a large total HRR fire. [7]
Reference to be added with the rest of the Annex D references:
[6] Shi, Y., Bowman, I., De Los Rios, N., Harvey, N., Lopez, K., and Pelessone, L., “NFPA 502
Critical Velocity Calculation Methodologies and Dimensionless Heat Release Rate,” proceeding
of 10th International Symposium on Tunel Safety and Security, Stavanger, Norway, April 25th –
28th, 2023.
[7] Shi, Y. S., De los Rios, N., & Lopez, K., “The Critical Penalty”, 19th International Symposium
on Aerodynamics, Ventilation & Fires in Tunnels, Brighton, UK, 5-17, 2022

Additional Proposed Changes

File Name Description Approved

D.3.1.2.PNG Replacement Figure D.3.1.2
D.3.1.2.1.PNG New Figure D.3.1.2.1

Statement of Problem and Substantiation for Public Input

According to 2017 NFPA 502 Annex D, the variable Froude Number table is depended on total HRR
not convective HRR
According to 2023 NFPA 502 Annex D Section D.3.1.1, MTFVTP "backlayering controlled" data is
based on observation that doesn't guarantee the critical velocity (zero smoke backlayering) was
achieved due to the limitation of observation methodology and fine control of ventilation devices.
According to the findings from two published papers, the 2017 Variable Froude Number table has
limitations for a certain tunnel size:
Shi, Y. S., De los Rios, N., & Lopez, K., “The Critical Penalty”, 19th International Symposium on
Aerodynamics, Ventilation & Fires in Tunnels, Brighton, UK, 5-17, 2022
Shi, Y., Bowman, I., De Los Rios, N., Harvey, N., Lopez, K., and Pelessone, L., “NFPA 502 Critical
Velocity Calculation Methodologies and Dimensionless Heat Release Rate,” proceeding of 10th
International Symposium on Tunel Safety and Security, Stavanger, Norway, April 25th – 28th, 2023.
This limitation should be disclosed to the users of the standard.

Related Public Inputs for This Document

Related Input Relationship

Public Input No. 14-NFPA 502-2023 [New Section after D.3.1.2]

Submitter Information Verification

Submitter Full
Yinan Shi
Name:
Organization: Mott MacDonald

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Norris Harvey, Natasha De Los Rios, Iain Bowman, Kyle

Affiliation:
Lopez, Luke Pelessone
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 02 05:08:57 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: CI-1-NFPA 502-2023

Statement: The papers identified in the PI will need to be provided to the Committee for review
before taking a final action on this PI. Task Group was created to review the material and
report back at the Second Draft Meeting. This Task Group will review the cross sectional
area values and referenced height of the tunnel as it relates to the formula for
determining critical velocity.

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Public Input No. 40-NFPA 502-2023 [ Section No. G.2.5 ]

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G.2.5 Battery Electric Vehicle (BEV).

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Both battery EVs and gasoline-electric–type hybrid electric vehicles (HEVs) have been
commercially available for a number of years. Their volumes are expected to grow rapidly in the
next years. Due to the introduction of electric drive, energy storage, and conversion systems,
one safety consideration involves the high-voltage system (e.g., 400 VDC) used for the
powertrain, such as electric shock and short-circuit. The other is heat generated during battery
charging and discharging, which can generate toxic fumes.
The main EV and HEV Li-ion battery pack failure mode is thermal runaway. Thermal runaways
in batteries are typically the result of electrical failure, mechanical damage, or excessive
exposure to heat. These events result in venting of flammable gases and could result in
subsequent fires. Venting of these gases can occur before actually going into thermal runaway
but can be difficult to observe visually. If vented gases are accumulated in a confined or
semiconfined space, there is the potential to reach lethal concentrations or for
combustion/explosion in the presence of an ignition source.
Typical cell vent gases consist of a mixture of carbon monoxide, carbon dioxide, hydrogen,
methane, hydrogen fluoride, and a number of heavier hydrocarbons. Testing has confirmed that
the exact composition of vent gases depends on the battery state-of-charge and battery
chemistry [1].
Smoke originating from a lithium-ion battery fire is a severe potential health risk due to
contamination with heavy metals and hazardous gases [2]. Smoke generated by battery fires
can severely damage concrete or steel structures due to the smoke’s corrosive properties.
Related health risks to first responders should be considered in the design of enclosed facilities
for EV such as tunnels and parking garages. Further, the potential presence of high-voltage
areas is a risk to tunnel occupants and rescue services. One concern for first responders is also
the hydrogen fluoride can enter the body through the skin, which increases the requirements
and properties of the protective clothing and equipment used by first responders. NFPA
provides information on most commercially available EVs detailing specific areas of risk [3] in a
database on its public home page. NFPA also provides dedicated online training courses [4].
Contaminated water treatment should also be considered during design.
Water is an effective suppression agent for EV fires. However, the amount of water required for
suppression in performance tests was much higher than for standard IC vehicle fires and as
high as 2600 gal (9850 L) [5]. Testing showed that the most effective way to attack EV and HEV
fires is to concentrate the water flow onto the battery pack in order to reduce the temperature of
the cells, avoiding thermal runaway and fire re-ignition. Encapsulator Agents conforming to
NFPA 18A-Water Additive for Fire and Vapor Mitigation, Section 7.7 - Encapsulator Technology
Spherical Micelle Stability Test Protocol has been proven to be effective on EV fires. Earlier in
this paragraph referece is made to requiring 2600 gals of water. That figure comes from an
NFPA Funded Research Project utilizinf 16 KwH battery. Utilizing a 20.4 KwH battery and like
condition it took only 4 gallons of 3% Encapsulator Solution to extinguishe the fire and stop
thermal runaway propogation. Refer to NFPA 18A, Section A4.3 regarding testing of NFPA
18A, Section 7.7 Encapsulator Agents on Lithium Ion battery.
The risk of thermal runaway during charging and discharging of EV batteries is higher than
during periods of inactivity such as normal parking [6]. Therefore, enclosed spaces intended for
EV charging should be equipped with a fire detection, ventilation, and fixed firefighting systems
depending on the overall safety concept. Battery packs of EVs are typically located underneath
the vehicle or below the trunk area and therefore difficult to be reached by water-based fixed
firefighting systems. Hence, the main purpose of fixed firefighting systems in this case is to cool
the environment near the burning EV and to reduce the smoke’s hazardous content. This action
will limit fire spread and provide better access for fire brigades. Again, the treatment of run-off
water should be considered.
EVs whose batteries have been mechanically damaged, exposed to mechanical impact, or
involved in a fire have a risk for re-activation, even after seemingly stable conditions, and
should be separated from other combustible material by at least 50 ft (15 m) [7]. In some
European countries such as Germany, Austria, and Switzerland, fire brigades submerge EV
cars in water to prevent re-ignition during transport and disassembly. Submersion for larger EVs
such as busses and trucks is not typically practical due to size limitations.
It should be noted that research on EV fires so far has been very limited. Most fire tests have
been performed using a limited number of battery cells, single battery packs, or single EV.

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There is limited information on larger battery installations. Furthermore, no methodical research

is currently available for large size battery packs such as those used in busses or trucks or
those transported in trucks. Neither have fire tests been carried out to examine fire scenarios
involving multiple EVs or combinations of EVs and vehicles powered by other fuel sources such
as diesel, petrol, gas, or hydrogen.

Statement of Problem and Substantiation for Public Input

Lithium-Ion Battery is the #1 growing hazard in the world. LIB is an electrochemical fire involving Class
A, Class B, Class C, and in some cases Class D fires. We know from NFPA Research project that it
takes copious amounts of water. We also know from testing that ABC Dry Powder is ineffective on LIB.
NFPA 18A, Section 7.7 - Encapsulator Agents have been extensively test and are effective on LIB and
stopping thermal runaway propagation. See NFPA 18A, A4.3.

Submitter Information Verification

Submitter Full Name: Michael Greiner

Organization: Hazard Control Technologies, I
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 17:41:51 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: NFPA 18 and 18A is already referenced within Annex A providing guidance based on
Annex added to Section 9.1.2.

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Public Input No. 7-NFPA 502-2023 [ Section No. O.1.2.6 ]

O.1.2.6 ASTM Publications.

ASTM International, 100 Barr Harbor Drive, P.O. Box C700, West Conshohocken, PA
19428-2959.
ASTM C666/C666M, Standard Test Method for Resistance of Concrete to Rapid Freezing and
Thawing, 2015.
ASTM E136, Standard Test Method for Assessing the Combustibility of Materials Using a
Vertical Tube Furnace at 750°C, 2019a 2022 .
ASTM E580/E580M, Standard Practice for Installation of Ceiling Suspension Systems for
Acoustical Tile and Lay-in Panels in Areas Subject to Earthquake Ground Motions, 2020 2022 .
ASTM E2652, Standard Test Method for Assessing the Combustibility of Materials Using a Tube
Furnace with a Cone-shaped Airflow Stabilizer, at 750°C, 2018 2022 .
ASTM E3134, Standard Specification for Transportation Tunnel Structural Components and
Passive Fire Protection Systems, 2020.

Statement of Problem and Substantiation for Public Input

date updates

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 18 13:45:58 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-28-NFPA 502-2023

Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached Word Document with Track Changes contains various updates
to this Chapter.

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Public Input No. 8-NFPA 502-2023 [ Section No. O.1.2.7 ]

O.1.2.7 BSI Publications.

BSI British Standards , 12110 Sunset Hills Road Institution, 12950 Worldgate Drive , Suite
200 800 Herndon , Reston, VA 20190-5902 20170 .
BS 476-4, Fire tests on building materials and structures, Non-combustibility test for materials,
1970 70th Edition , corrigendum, 2014 October 1, 2012, Reaffirmed 2020 .
BS EN 492, Fibre-cement slates and fittings— Product specification and test methods,
2012+A2:2018 .
BS EN 12467, Fibre-cement flat sheets— Product specification and test methods,
2012+A2:2018 .
BS EN 13501-1, Fire classification of construction products and building elements — Part 1:
Classification using data, 2019 2018 .

Statement of Problem and Substantiation for Public Input

updates on standards and address

Submitter Information Verification

Submitter Full Name: Marcelo Hirschler

Organization: GBH International
Street Address:
City:
State:
Zip:
Submittal Date: Thu May 18 13:54:27 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-28-NFPA 502-2023

Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached Word Document with Track Changes contains various updates
to this Chapter.

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Public Input No. 22-NFPA 502-2023 [ Section No. O.1.2.17 ]

O.1.2.17 PIARC Publications.

World Road Association (PIARC), Tour Pascal B 19th floor, 5 Place des Degrés, F-92055 La
Défense CEDEX, France.
Current Practice for Risk Evaluation for Road Tunnels, 2013.
Design Fire Characteristics for Road Tunnels, 2016.
Fire and Smoke Control in Road Tunnels, 1999.
Fixed Fire Fighting Systems in Road Tunnels: Current Practices and Recommendations, 2016.
OECD/PIARC QRA Model, Quantitative Risk Assessment Model for Dangerous Goods
Transport through Road Tunnels.
Road Tunnels: An Assessment of Fixed Fire Fighting Systems, 2008.
Systems and Equipment for Fire and Smoke Control in Road Tunnels, 2007.
Impact of New Propulsion Technologies on Road Tunnel Operations and Safety Case Studies,
2022.

Statement of Problem and Substantiation for Public Input

This is the latest PIARC TC4.4. publication on alternative fuel vehicles / tunnels and should be added
to the reference. Note! There is an additional document coming for same topic from PIARC but
currently it is not yet published by PIARC.

Submitter Information Verification

Submitter Full Name: Max Lakkonen

Organization: IFAB - Institute for Applied Fire Safety Research
Street Address:
City:
State:
Zip:
Submittal Date: Thu Jun 01 05:23:53 EDT 2023
Committee: ROA-AAA

Committee Statement

Resolution: FR-28-NFPA 502-2023

Statement: Updated references to the most current edition. Incorporated reference changes due to
NFPA Emergency Response and Responder Safety (ERRS) Consolidation Project.
Updates to addresses for various Publications. Incorporated reference as per various
First Revisions. Attached Word Document with Track Changes contains various updates
to this Chapter.

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