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Page: Last modified: 2023-09-26
Code Reference(s):
NFC20 Div.B 4.1.6.3. (first printing)
Subject:
Other — Hazardous Materials and Activities
Title:
Deletion of Reference to Withdrawn Document
Description:
This proposed change deletes the reference to ULC/ORD-C410A-94, “Absorbents for Flammable and Combustible Liquids,” from explanatory Note A-4.1.6.3.(3)(b).
This change could potentially affect the following topic areas:

Problem

ULC/ORD-C410A-94, "Absorbents for Flammable and Combustible Liquids," which is currently referenced in explanatory Note A-4.1.6.3.(3)(b), was withdrawn by ULC Standards in 2018.

The withdrawn other recognized document (ORD) is over 20 years old. Since the industry was not requesting testing or certification to the ORD, ULC decided to withdraw the ORD. It did not receive adverse comments from certification bodies, the industry or others.

Keeping the reference to the ORD in the NFC would not provide any clarification of the Code requirement. Instead, referring to this withdrawn document could create confusion for Code users when they see the document is referenced in the Code but no longer available in practice.

Justification

At the mid-cycle review of updates to referenced documents in the NFC, it was noted that ULC/ORD-C410A-94 was

  • withdrawn in 2018, and 
  • no longer used in practice. 

Therefore, it was agreed to delete the reference to the withdrawn ORD from the NFC to eliminate potential confusion for Code users. 

The ORD was not a consensus-based standard but a document produced as an interim solution until a standard could be developed. ULC withdrew the document because the industry was not asking for certification of products covered by this document, and there was no demand to develop it into a standard. In the absence of the ORD's guidance, Code users would rely on the manufacturer's guidance or on best engineering practice to deal with spilled or leaked flammable or combustible liquids. 

EXISTING PROVISION

4.1.6.3.Spills and Leaks

1)Maintenance and operating procedures shall be established to prevent the escape of flammable liquids or combustible liquids to areas where they could create a fire or explosion hazard.
2)Except as provided in Sentence (3), all reasonable steps shall be taken to recover escaped liquid and to remove or treat contaminated soil.
3)Spilled or leaked flammable liquids or combustible liquids shall be
a)flushed to a location where they will not create a fire or explosion hazard, or any risk to public health or safety, or
b)neutralized or absorbed and cleaned up with the aid of a product that is compatible and non-reactive with the liquid being cleaned up (see Note A-4.1.6.3.(3)(b)EXISTING PROVISION A-4.1.6.3.(3)(b)), and
i)deposited in a receptacle conforming to Article 2.4.1.3., or
ii)disposed of in a manner that does not create a fire or explosion hazard.

Note A-4.1.6.3.(3)(b)

Information on the compatibility and reactivity of liquids can be found in the Safety Data Sheets for each liquid.
An absorbent material conforming to ULC/ORD-C410A, "Absorbents for Flammable and Combustible Liquids", is acceptable.

PROPOSED CHANGE

[4.1.6.3.] 4.1.6.3.Spills and Leaks

Note A-4.1.6.3.(3)(b)

Information on the compatibility and reactivity of liquids can be found in the Safety Data Sheets for each liquid.
An absorbent material conforming to ULC/ORD-C410A, "Absorbents for Flammable and Combustible Liquids", is acceptable.
 

Impact analysis

The proposed change has no associated cost implications because there is no document that replaces the withdrawn ORD and Code users can use the manufacturer's guidance or best engineering practice to deal with spilled or leaked flammable or combustible liquids.

This proposed change would eliminate confusion arising from referencing a withdrawn document, which would facilitate the enforcement of the Code requirement.

Enforcement implications

The proposed change could be enforced by the infrastructure currently available to enforce the Code. Since the withdrawn ORD is not used by the industry, the proposed change would reduce the potential for confusion or misinterpretation for the agencies that enforce the Code requirement.

Who is affected

Builders, consumers, manufacturers, regulators and designers.

OBJECTIVE-BASED ANALYSIS OF NEW OR CHANGED PROVISIONS

[4.1.6.3.] 4.1.6.3. ([1] 1) [F82,F44-OS1.1,OS1.2]
[4.1.6.3.] 4.1.6.3. ([1] 1) [F82,F44-OP1.1,OP1.2]
[4.1.6.3.] 4.1.6.3. ([2] 2) [F44-OP1.1,OP1.2]
[4.1.6.3.] 4.1.6.3. ([2] 2) [F44-OS1.1,OS1.2]
[4.1.6.3.] 4.1.6.3. ([2] 2) [F44-OH5]
[4.1.6.3.] 4.1.6.3. ([3] 3) ([a] a)[F01,F02-OS1.1]([b] b)[F02-OS1.1,OS1.2]
[4.1.6.3.] 4.1.6.3. ([3] 3) ([a] a)[F44-OP1.1,OP1.2]([b] b)[F02-OP1.1,OP1.2]
Date modified: