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for Flammable and Combustible Liquids," which is currently referenced in explanatory Note A-4.1.6.3.(3)(b), was withdrawn by ULC Standards in 2018.
The withdrawn other recognized document (ORD) is over 20 years old.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 Instead, referring to this withdrawn document could create confusion for Code users when they see the document is referenced in the Code but no longer available in practice.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- withdrawn in 2018, and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Therefore, it was agreed to delete the reference to the withdrawn ORD from the NFC to eliminate potential confusion for Code users.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
Note A-4.1.6.3.(3)(b)
PROPOSED CHANGE
[4.1.6.3.] 4.1.6.3.Spills and Leaks
Note A-4.1.6.3.(3)(b)
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The proposed change has no associated cost implications because there is no document that replaces the withdrawn ORD and Code users can use the manufacturer's guidance or best engineering practice to deal with spilled or leaked flammable or combustible liquids.
This proposed change would eliminate confusion arising from referencing a withdrawn document, which would facilitate the enforcement of the Code requirement.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 Since the withdrawn ORD is not used by the industry, the proposed change would reduce the potential for confusion or misinterpretation for the agencies that enforce the Code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
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