u.s. regulatory codes affecting beverage carbonation ... · pdf fileu.s. regulatory codes...

A Game-Changing Solution

IBDEA 2016 September

U.S. Regulatory Codes Affecting Beverage Carbonation System

Installation September 15, 2016

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A Game-Changing Solution Regulations Are Rapidly Changing

• This information presented here is based on the status of regulations as of the date of this presentation.

• The industry standards and government regulations discussed in this presentation are in a constant state of flux with states and local municipalities adopting or enacting new regulations.

• Because so much regulation is now local, there may be multiple requirements to review to assure compliance.

• This makes it even more important to monitor for developments in regulations and industry standards.

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A Game-Changing Solution Regulatory Standards and Events:

A Brief History

Liquid Carbon Dioxide vacuum insulated pressure vessels introduced. Must be ASME Certified and have National Board “NB” Stamp . Inspection req’mts specific to CO2 pressure vessels does not exist

1980’s

CGA publishes G-6.5 Standard For Small, Stationary, Insulated Carbon Dioxide Systems. Intended for distributors and restaurants to install, operate and maintain CO2 beverage systems recommending safe practices. As CGA is non-regulatory, industry is responsible for implementation. Revised in ‘01 , ’07 & ‘13

1992

NFPA 55 Compressed Gases and Cryogenic Fluids Code published. Originally for portable non-insulated cylinders only. Revised in ‘98, ‘03, ’05, ’10, ‘13 and ‘16

1993

NFPA adds new Chapter 13: Insulated Liquid Carbon Dioxide Systems defining requirements. This includes parts of CGA G-6.5, adds req’mts for CO2 Monitors, and defines “Enclosed and Unenclosed Spaces” and when auxiliary Mechanical Ventilation is req’d

2010

May: three people hospitalized including two firefighters related to CO2 beverage system in Phoenix, AZ. September: one fatality, and others hospitalized related to CO2 beverage system in Pooler, GA

2011

CGA G-6.5 NFPA 55 IFC

New ASME Pressure Vessel inspection code: NBIC Part 1 Supplement 3 “Installation Of Liquid Carbon Dioxide Storage Vessels” (LCDSV’s) defines new requirements

2013

NBIC

International Fire Code adds new Section 5307 “ Carbon Dioxide (CO2) Systems Used In Beverage Dispensing Applications” and defines requirements including reference to NFPA 55

2015

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What Codes Apply to Beverage Carbonation Systems?

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A Game-Changing Solution Reference Documents

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The basis for State and/or Local Codes usually are derived from one or all of three sources:

1. International Fire Code (IFC) 2. National Fire Protection Association 55, Compressed

Gases and Cryogenic Fluids Code (NFPA 55) 3. National Board Inspection Code Part 1 Supplement 3,

Installation of Liquid Carbon Dioxide Storage Vessels (NBIC)

Code Sources for Bev Carb Systems

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The Compressed Gas Association (CGA)

CGA document G-6.5 Standard For Small Stationary Insulated Carbon Dioxide Supply Systems:

• Applies to CO2 systems with less than 1000 lbs

• Although non-Regulatory, is used as basis in conjunction with IFC and NFPA for some municipal codes

• CGA is viewed as a subject-matter-expert and is highly influential

Non-Regulatory But Influential for Bev Carb Systems Codes

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• Code groups generally are cognizant of each other and attempt to harmonize requirements, so there are many similarities

• Differences do exist because of either governing bodies perspectives, or code document revision cycle timing

Requirements Are Similar But Differ

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• Special Hazardous Materials reporting requirements – can vary somewhat depending on jurisdiction

• Can have associated permit fees and can vary depending on jurisdiction

• The State of California has a centralized system for businesses to report storage of hazardous materials. The system is called CUPA (Certified Unified Program Agency)

• The CUPA reporting threshold for storage of compressed gases is 200 cubic feet of gas (carbon dioxide) – have seen reference to 1000 CF

California – Hazardous Materials Reporting

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• The reporting portion of CUPA is called CERS (California Environmental Reporting System)

• A HMBEP (Hazardous Materials Business Emergency Plan) is required to be filed by the operating business and is site specific

• Jurisdictional variation in HMBEP requirements also have been noted

California – Hazardous Materials Reporting

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The Authority Having Jurisdiction (AHJ) varies:

“Where public safety is primary, the AHJ may be a federal, state, local or other regional department or individual such as a fire chief, fire marshal, chief of a fire prevention bureau, labor department, health department, building official, electrical inspector or others having statutory authority. For insurance purposes, an insurance inspection department, rating bureau, or other insurance company representative may be the AHJ.”

“AHJ’s” – Who Has Enforcement Authority?

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A Game-Changing Solution Specific Local Requirements

• Consensus estimates : there exists 3,033 counties or county equivalents, 35,000 towns and cities and 19,429 municipal governments in the United States. While there are often similarities in terms of followed guidelines established in IFC, NFPA and/or NBIC standards, each county/city/municipality has jurisdictional power and oversight to set their own specific and unique guidelines.

• Specific locations must be verified to assure compliance with all Codes and Regulations and any Permit requirements within that jurisdiction.

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International Fire Code

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• IFC may serve as the basis for State or Municipal Fire Code – the current edition is 2015

• IFC is revised every three years: there is not universal enforcement nationally of a specific year edition

• IFC references NFPA

• 24 States have adopted IFC in its entirety

• 10 States have adopted IFC with limitations

• 22 States have local governments which have adopted IFC

International Fire Code

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IFC 2015 Edition added a new Section, 5307: Carbon Dioxide Systems Used In Beverage Dispensing Applications with the following :

Carbon Dioxide Systems with more than 100 lbs shall be permitted

Storage, use and handling shall comply with NFPA 55

Installations shall be protected from damage from occupants or equipment

during facility operations

If located indoors or other areas where leakage can collect Mechanical Ventilation or CO2 Monitor must be provided . (multiple CO2 Sensors may be required to fulfill this requirement)

CO2 Monitor alarm shall activate at threshold not exceeding 5000 ppm

International Fire Code - Highlights

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National Fire Protection Association

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• NFPA 55 may be included in State or Municipal Fire Code either in conjunction with IFC or standalone – current edition is 2016

• Note that IFC Section 5307 references NFPA 55, “The storage, use, and

handling of liquid CO2 shall be in accordance with …and applicable requirements of NFPA 55, Chapter 13.” IFC requirements therefore, also mandate compliance to NFPA 55.

National Fire Protection Association

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ENFORCEMENT of VENTILATION 2016 edition NFPA 55 allows for either mechanical ventilation or CO2 gas detection as does IFC 2015. Previous NFPA 55 editions (2010 and 2013) mandated continuous ventilation and this requirement is enforced in these jurisdictions: • Known enforcement in Montgomery, AL, Gilbert, AZ, Phoenix, AZ, Colorado Springs,

CO, and Wisconsin

CO2 MONITORS • NFPA 55 requires PEL plus STEL 30000 ppm (Permissible Exposure Limit 5000 ppm 8-

hour Time Weighted Average; Short-Term Exposure Limit 30,000 ppm 15-minute TWA) vs IFC requirement of only 5000 ppm (instantaneous)

National Fire Protection Association: Some Differences compared to IFC

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Where Unique Jurisdictional Requirements Exist (unrelated to Pressure Vessel

permitting)

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National Board Inspection Code

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Revised 2015: NBIC Part 1 Supplement 3 Installation of Liquid Carbon Dioxide Storage Vessels

• addresses pressure vessel installation parameters • is enforced at State level or through third-party inspections • is basis for pressure vessel code, but only in “Pressure Vessel Law States” and

is applicable statewide

• Changed CO2 Monitor requirements in 2015 from 2013 version, to 5000 ppm (instantaneous, not PEL) and STEL 30000 ppm (Permissible Exposure Limit 5000 ppm 8-hour Time Weighted Average). 2013 was previously (15000 ppm + 30000 ppm).

National Board Inspection Code: Pressure Vessels

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A Game-Changing Solution Where NBIC is Applicable: States With Pressure Vessel Laws and Regulations

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A Game-Changing Solution Where Pressure Vessel State and City

Requirements Can Be Found

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Carbon Dioxide: Characteristics and Safety

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A Game-Changing Solution Carbon Dioxide - CO2

Carbon Dioxide Is Both Naturally Occurring & a By-product of

Industrial Processes

• Makes up 0.03% to 0.04% of the earth’s atmosphere. (300 to 400 ppm)

• Non-flammable and non-reactive with many materials

• As a gas, CO2 is colorless, odorless and is 1.5 times heavier than air

• Can be a solid (“Dry Ice”), liquid or gas

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A Game-Changing Solution CO2 Monitors

• It is recommended that any installation where the CO2 storage container is located in an Enclosed Space (this includes indoors AND outdoors) have a Carbon Dioxide Monitor whether local codes require or not

• Carbon Dioxide is categorized as an asphyxiate and employing a CO2 Monitor is relatively inexpensive to assure safety

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A Game-Changing Solution Where CO2 Monitors are Code Required – Number of Locations Continue To Grow

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A Game-Changing Solution CO2 Risks

* NuCO2 Business Confidential * 28

A Game-Changing Solution CO2 Monitor Code : Three Different

Standards in the U.S.

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A Game-Changing Solution CO2 Monitor Suppliers (alphabetical)

Be sure to verify the model chosen complies with jurisdictional code where installation will occur

Analox Sensor Technology 5981 Engineer Drive Huntington Beach California, 92649 (877) SAFE AIR (714) 891 4478

CO2 Meter, Inc.

131 Business Center Drive

Ormond Beach, FL 32174

877-678-4259

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A Game-Changing Solution CO2 Monitor Suppliers

LogiCO2 International:

Lancer Direct Harvey Page, Installations Service Manager 100 N Gary Avenue, Suite C Roselle, IL 60172 877-814-2271 or 270-779-9722 270-392-8986 (cell)

Ken’s Beverage 10015 Mandel Street Plainfield, IL 60585 800-285-2292 630- 904-1555

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A Game-Changing Solution

Disclaimer and Qualification

Although the information contained in this slide presentation is believed to be reliable and accurate as of the date it was prepared, the presentation and all material set forth within are provided without warranties of any kind, either express or implied, including but not

limited to warranties of the accuracy or completeness of information contained in the presentation or the suitability of the information contained in the presentation for any

particular purpose. The technical implications of any information or guidance contained in this presentation may vary widely based on the specific facts involved and should not be

used as a substitute for consultation with professional and competent advisors. This presentation is not intended to be an exhaustive treatise on the subject. Interested parties

should do their own research. Consequently, the authors recommend also consulting applicable standards, laws, regulations, suppliers of materials, and material safety data

sheets for information concerning safety and health risks and precautions and compliance with then-applicable laws and regulations. This presentation does not constitute legal

advice and a competent legal professional should be consulted to obtain advise on compliance issues. The use of the materials set forth herein is at the user’s own risk. The authors shall not be liable for any direct, indirect, incidental, special, consequential, or

punitive damages arising out of the use of any information contained in this presentation.

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