In the spring issue of Composites Manufacturing, I described how fire codes are developed and enforced. In this column, we’ll look at specific codes that may be important to composites manufacturers.
NFPA 33, the Standard for Spray Application Using Flammable and Combustible Materials, is likely the most important code for composites manufacturers using open molding. Chapter 17 of this code, on Styrene Cross-Linked Composites Manufacturing (Glass Fiber–Reinforced Plastics), is the result of decades of work by the industry, led by Lowell Miles of Miles Fiberglass and Composites, to get approval for a code that protects open molding shops against fire risks while recognizing that composite resin spray operations are less hazardous than spray painting.
Before this chapter was adopted into NFPA 33, OSHA routinely enforced the spray finishing fire safety requirements at 29 CFR 1910.107, which was a problem especially for the fabrication of large parts that could not fit in traditional spray booths. Since then, it has been OSHA policy that composites open molding operations not in compliance with the 1910.107 standard, but meeting the requirements of NPFA 33, will receive no more than a de minimis citation without fine or other penalty.
Chapter 17 contains provisions for fire protection, resin storage, electrical hazards, ventilation, handling of excess catalyzed resin and the use of paper or plastic film in spray booths to collect overspray. In addition, Chapter 16 of NFPA 33 has important requirements for spray application operations involving organic peroxides.
Industry compliance experts often recommend that composites manufacturers purchase a copy of NFPA 33, make sure they are the following relevant provisions, and have the document on hand for reference when the facility is visited by OSHA, local fire code officials or insurance company representatives.
The second most relevant fire code is NFPA 30, the Flammable and Combustible Liquids code. When they inspect industry operations, local code officials often question the amount of resin, gel coat and other flammable liquids stored in or near resin application areas. These questions can be resolved by reference to NFPA 30.
Some composites manufacturers might find that this code places significant restrictions on the amount, package type, or stacking of resin or gel coat permitted to be stored inside a manufacturing or warehouse building, which in some cases has been resolved by moving some storage to approved facilities outside the building. In other cases, it has been necessary to retain a fire safety engineer to conduct a fire hazards analysis that considers the actual hazards of the facility’s resin storage operations. Recall from my previous column that fire codes are written to provide adequate protections for a wide range of operations and might over- or under-protect any individual facility.
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