Understanding the change process for NFPA 58: Part II

Photo: iStock.com/Sezeryadigar

My previous article on understanding the change process for the NFPA 58: Liquefied Petroleum Gas Code was published in June 2018, just after I submitted my public comments (PC) on actions taken on public inputs (PI).

The PIs were considered at the first-draft meeting for the 2020 LP-Gas Code. I had to wait until the second-draft meeting, held in October 2018 in Baltimore, to consider how the PCs would determine the direction of some of the topics.

We considered the PCs received, thought back on some of the committee inputs we set as placeholders at the first meeting, considered some task group reports on a few topics and discussed some tentative interim amendments to be voted on outside of the meeting.

The National Fire Protection Association (NFPA) has defined the change process for standards, codes and guidelines to be as open as possible to anyone who wants to have input. It announces when certain documents are available for input or for review of actions taken. Those interested must take some initiative. NFPA doesn’t reach out and contact individuals. Instead, someone interested must either check at the NFPA website for activity or place themselves on an alert list to receive an email notice that activity has been posted for a certain document.

We received 102 PCs. The rules state that all of them had to have some relationship to a PI or an action taken at the first meeting. This is protection for the public against introduction of a new topic they may not get a chance to review easily before the action-taking deadline passes. However, NFPA does not screen PCs for adhering to that rule. It’s the committee’s responsibility to screen for new topics or to allow a topic for safety reasons. There were a couple of PCs the committee determined were new material and rejected for that reason, with hardly any discussion of their merits.

I listed several topics in the earlier article that I considered significant changes. Some of them were complete, as in there were no PCs on the topic. That list of topics is below. Those that had suggestions for further work are underlined:

• Completely rewriting “Chapter 15: Operations and Maintenance Procedures” to make it more user-friendly.
• Allowing other volumetric devices for determining the fill level of tanks.
• Specifically allowing use of stainless steel for piping and fittings.
• Allowing groups of 120s to have smaller separation distances when they are beside buildings.
• Changes to the rules for enclosures around/over tanks and for relief valve discharge.
• A requirement that all gates be unlocked when there is activity inside a fenced bulk plant or dispenser area.
• Allowing reduced separation requirements for filling cylinders using low-emission transfer concepts.
• New valve gasket inspection requirements for filling cylinders.
• Clarification of railcar loading/unloading requirements.
• Clarification of wheel–stop requirements.
• Several changes to “Chapter 12: Over-the-road vehicles using propane for engine fuel.”
• Editorial changes and housekeeping on reference updates.

An underlined topic doesn’t mean that it was significantly changed, but it was at least challenged, or better wording was suggested. Also, some topics that were rejected at the first meeting were resubmitted, though they were usually rejected again. A few topics not reported last time that received significant attention at the second meeting are:

• Fire resistance ratings and noncombustible material description;
• A better listing of some valve requirements;
• Changes to the venting section, 7.3.

The next step was the letter ballot, where we officially voted on the action taken at the meeting. We were not voting on the PCs, but on what the committee decided was the proper action to take in order to incorporate what was suggested in the PCs. These actions, called second revisions, will result in a change to the code if not challenged. In other words, we cannot vote in the letter ballot to accept what a PC proposed if the committee rejected it. Voting was completed in mid-January 2019.

There are a couple of other less-known steps in the process. Notice of intent to make a motion (NITMAM) is a way to let it be known you felt your subject was not treated fairly. You take it to the NFPA Conference & Expo, present your case and the general membership votes. There is also an appeals process. See pages 28 and 29 of the NFPA Standards Directory for details.

The 2020 edition of the Liquefied Petroleum Gas Code should be issued in mid- to late-August 2019, with a PDF version available in August and the printed version available in September. Then the cycle begins again. PIs for the 2023 edition will be due in June 2020.

Richard Fredenburg is an LP gas engineer at the North Carolina Department of Agriculture and Consumer Services, Standards Division.