Eye of the Storm
How a Florida marina landed at the center of the NFPA 33 discussion
IN NOVEMBER 2010, the fire marshal in Fort Lauderdale, Florida, issued a cease and desist order to Lauderdale Marine Center (LMC) to stop all spray-painting operations. LMC had developed enclosures, constructed of scaffolding and shrink-wrap, with which to surround vessels that were undergoing prep and painting work. The enclosures were intended to protect the environment from dust and grit produced during surface preparation, and to prevent the release of overspray. Portable systems had been developed to filter and exhaust spray vapors from the tents, with components rated for service with flammable vapors.
The fire marshal, however, determined the enclosures were outside the scope of NFPA 33, Spray Application Using Flammable or Combustible Materials. Some of the enclosures were erected inside LMC sheds, and among the fire marshal’s concerns was that water from ceiling sprinklers would be unable to reach a fire inside an enclosure. LMC is located in the midst of a residential neighborhood, and according to Jim Parks, LMC’s operations manager, the fire marshal was concerned over the possibility of a conflagration that could destroy not only LMC, but also a good part of the surrounding neighborhood.
As Parks put it, the fire marshal’s actions left LMC staffers “gobsmacked.” LMC is a large refit and repair yard that could accommodate nearly 40 vessels up to 150 feet long in its onshore facilities, roughly half of them in sheds, and the cease and desist order came during the home stretch of a busy fall season—it was a twist that held potentially devastating consequences for the marina, Parks said. LMC contacted the NFPA 33 committee chairman, who recommended an experienced fire engineer and code expert who, Parks hoped, could help the marina reach an accord with the fire marshal. As Parks put it, LMC “began a very tense week filled with sometimes contentious negotiations” with the fire marshal on one side, and concerned captains, owners, and vessel managers on the other.
Despite the acrimony, a temporary procedure was hammered out that satisfied the fire marshal and allowed LMC to resume spraying operations. The new procedure included monitoring vapor levels within the tents to help minimize combustible fumes, and establishing higher standards for electrical components. For the first several weeks, LMC employed marine chemists to measure the lower explosive limit (LEL) of the atmosphere within the tents and at the exhaust filters while spraying. Under the Occupational Safety and Health Administration’s rules for confined and enclosed spaces in shipyards, the maximum allowable LEL is 10 percent for workers to be present; the general industry limit is 25 percent. According to Parks, over the first two and a half years that LMC performed the testing—conducted by in-house shipyard competent persons on nearly 3,000 separate paint shoots—LMC did not reach a reading of even 1 percent using the same type of meter utilized by marine chemists around the country.
In 2011, Parks attended the NFPA 33 committee meeting in Fort Lauderdale, which was held to address, among other issues, the topic of temporary membrane enclosures. Committee members toured LMC and other marine facilities, and decided to look at the issue for possible inclusion in the standard. A task group was launched that included Parks, the LMC fire engineer, and the fire marshal for Broward County, Florida (who was not the same fire marshal who had ordered the original cease and desist). As a first step, a revision was crafted to allow spray tents outside of buildings. The problem of enclosures located in interior spaces was resolved by the development of a shrink-wrap material engineered with seams designed to split when subjected to heat, allowing water from sprinklers to reach a fire. Following UL testing, NFPA 13, Installation of Sprinkler Systems, was revised to allow the use of such material in interior spaces, and NFPA 33 was revised accordingly, with the change taking effect in the 2016 edition of the standard.