fd tc circulation cover memo

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M TO: NFPA Technical Committee on Electrical Equipment of Industrial Machinery FROM: Mark Cloutier, Staff Liaison DATE: October 31, 2012 SUBJECT: NFPA 79 First Draft TC Circulation Ballot (A2014)

The October 26, 2012 date for receipt of the NFPA 79 First Draft letter ballot has passed. The preliminary First Draft ballot results are as follows: 23 Members Eligible to Vote 4 Not Returned (M. Gililland, D. Mariuz, J. Sroczynski, and E. Watson) In accordance with the NFPA Regulations Governing Committee Projects, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received on or before Wednesday, November 7, 2012. Members who have not returned a ballot may do so now. Please note that the return of ballots is required by the Regulations Governing Committee Projects. Attachment: Circulation Report

NFPA 79 First Draft Ballot Circulation (A2014)

Election:79_A2014_EEI‐AAA_FD_ballot

Results by Question

FR‐50, Global Input, See FR‐50Total Eligible to Vote: 23h

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Choice: Comments VotesAffirmative with Comment 1Mark R. Hilbert Continue to create the revision as recommended by the meeting actions. Relocating the parenthetical terms to a new

annex and creating a cross reference for the US and IEC terms along with additional explanatory material will benefit all readers of the Standard as well as the harmonization process. The Grounding and Bonding Task Group is continuing to work on comments for the development of the new Annex. There is an opportunity for the public as well as committeework on comments for the development of the new Annex. There is an opportunity for the public as well as committee members to provide comments that will help explain the similarities and differences between the US and the IEC grounding and bonding terms and applications. Recommendations in comments would be appreciated.

Negative 1David R. Carpenter I certainly agree with the submitter concerning the nomenclature of understanding between the IEC and NFPA standards.

I also agree that the NFPA 70 is the base standard for NFPA 79. However,that does not negate the need for understanding the IEC terms which are needed to properly install, maintain and troubleshoot industrial machines located in the US and are designed based on the IEC standards. Electricians, engineers and inspectors are increasingly faced with Industrial Machines which are designed based on IEC standards. It is imperative that they have guidance to prevent potential hazards which can, and has resulted in shock hazards, fire hazards and the destruction of equipment. A few examples of past problems: color codes difference between IEC and NFPA concerning neutral applications schematicexamples of past problems: color codes difference between IEC and NFPA concerning neutral applications, schematic difference concerning interlocks, and transformer characteristics that change grounding techniques and overcurrent protection application. This is especially troublesome when troubleshooting and installation. Most often seen when an IEC design is feed by a US system. The aforementioned is similar discussion to why IEC clarification terms were put in this standard. Industrial Machines have certain nuances which are not germane to facilities and should have some application difference as is needed. See my comments FR‐15y

Abstain 0Affirmative 17

FR‐97, Section No. 1.3.1.1, See FR‐97Total Eligible to Vote: 23Choice: Comments Votes

1


Affirmative with Comment 1David R. Carpenter comply with the NFPA Manual of StyleNegative 0Abstain 0Affirmative 18

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FR‐98, Section No. 1.3.2, See FR‐98Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter comply with the NFPA Manual of Stylep p y yNegative 0Abstain 0Affirmative 18

FR‐38, Section No. 2.3.6, See FR‐38T t l Eli ibl t V t 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter reference updateNegative 0Abstain 0Abstain 0Affirmative 18

FR‐39, Section No. 3.1, See FR‐39Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter Reference updateNegative 0Abstain 0Affirmative 18

FR‐99, Section No. 3.3.3.1, See FR‐99Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter comply with the NFPA Manual of Style

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Negative 0Abstain 0Affirmative 18

FR 54 Section No 3 3 9 See FR 54

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FR‐54, Section No. 3.3.9, See FR‐54Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 0Negative 1David R. Carpenter Bonding ‐ the asterisk should not be removed because it leaves the reader with less information to determine how to p g

correlate with IEC designed systems using the term "protective bonding circuit" definition ..See my comments FR‐50... the asterisk does not complicate the standard but gives needed information with out complicating the flow of sentence structure.

Abstain 0Affirmative 18Affirmative 18

FR‐5, Section No. 3.3.34, See FR‐5Total Eligible to Vote: 23Choice: Comments VotesChoice: Comments VotesAffirmative with Comment 1David R. Carpenter Change neededNegative 0Abstain 0Affirmative 18

FR‐3, Section No. 3.3.50, See FR‐3Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R Carpenter Agree in principleDavid R. Carpenter Agree in principleNegative 0Abstain 0Affirmative 18

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FR‐40, New Section after 3.3.55, See FR‐40Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 4Palmer L. Hickman This term should apply globally throughout the document. This is a recommendation to do so and have it included in the

First Draft for public review and comment

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First Draft for public review and comment.

David R. Carpenter Agree to be consistent with acceptably definition to all NFPA standards

Daniel R. Neeser The term should be consistent throughout the document. In some cases the term that is used is “control panel” and these should be changed to “industrial control panel”.g p

Jay Tamblingson While it is useful to add the definition of industrial control panel, there are a number of uses of similar terms within the standard (control panel, control enclosure, main enclosure, etc) which should either be included as reference within this definition or those sections revised to use the defined term as appropriate.

Negative 0Abstain 0Affi ti 15Affirmative 15

FR‐15, New Section after 3.3.71, See FR‐15Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Affirmative with Comment 1David R. Carpenter The term needs constancy but clarification in relation to Industrial Machines. Branch Circuits have certain nuances

indigenous to industrial machines which are not to facilitiesNegative 0Abstain 0Affirmative 18

FR‐41, Section No. 3.3.74, See FR‐41Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 0Affirmative with Comment 0Negative 0Abstain 1David R. Carpenter Not sure I fully understand the reasoning behind this changeAffirmative 18

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FR‐51, Section No. 3.3.77, See FR‐51Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Mark R. Hilbert Continue to accept the revision. See my ballot comment on FR 50.Negative 1

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Negative 1David R. Carpenter See comments on FR‐50Abstain 0Affirmative 17

FR‐53, Section No. 3.3.78, See FR‐53, ,Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Mark R. Hilbert Continue to accept the revision. See my ballot comment on FR 50.Negative 1D id R C t S t FR 50David R. Carpenter See comments on FR‐50Abstain 0Affirmative 17

FR‐44, Section No. 3.3.98, See FR‐44Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter Not neededNegative 0Abstain 0Affirmative 18

FR‐21, Section No. 3.3.100, See FR‐21Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter much needed and should be in other NFPA standardsNegative 0Abstain 0

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Affirmative 18

FR‐19, New Section after 3.3.101, See FR‐19Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1

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Affirmative with Comment 1David R. Carpenter needed for clairificationNegative 0Abstain 0Affirmative 18

FR‐85, Section No. 4.4.2.1, See FR‐85Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3P l D b k Th ti ti b t b t k th h th b ll t Th b itt did t t ik th h th tiPaul Dobrowsky The entire section number appears to be struck through on the ballot. The submitter did not strike through the entire

number and I believe intended the section be numbered 4.4.2.

David R. Carpenter comply with the NFPA Manual of Style

Jay Tamblingson The existing requirements of 4.4.2 for providing EMC mitigation are likely unenforceable as they give no specific guidance Jay Tamblingson The existing requirements of 4.4.2 for providing EMC mitigation are likely unenforceable as they give no specific guidance regarding electrical noise and transient levels permitted and when suppression must be provided. This section should be revised to reference appropriate standards, manufacturer requirements, and application considerations.


FR‐45, Section No. 5.3.1.3, See FR‐45Total Eligible to Vote: 23Choice: Comments VotesChoice: Comments VotesAffirmative with Comment 4David R. Carpenter needed

Jay Tamblingson The requirements in 5.3.1.4 need to be revised to align with the new permitted use of separately mounted disconnecting means and asscociated interlocking requirements contained in the revised text.

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Mark R. Hilbert Continue to accept the revision. With the increasing awareness of electrical hazards in the workplace and the desire to create safe work practices for electrical workers in the United States it is common to locate the supply circuit disconnecting means in a separate enclosure. This new exception maintains the interlocking requirements of 6.2.3 while allowing the electrical hazard reduction strategies formally limited to machines totaling 2 hp or less.

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J. B. Titus The new text from the committee action does not take into account random events such as material handling, staged tooling and other situations that could temporarily block immediate access to the disconnecting means. I suggest inserting..... "and always readily accessible to the operator."

N i 0Negative 0Abstain 0Affirmative 15

FR‐23, Section No. 5.3.2, See FR‐23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Paul Dobrowsky The committee statement indicates that the term "rated" was deleted elsewhere therefore should be deleted here but it

appears in underlined format in (2). I believe it needs to be removed.

David R. Carpenter clarificationNegative 0Abstain 0Affirmative 17Affirmative 17

FR‐100, Section No. 5.3.3.2.1, See FR‐100Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter comply with the NFPA Manual of StyleNegative 0Abstain 0

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Affirmative 18

FR‐46, Section No. 6.1, See FR‐46Total Eligible to Vote: 23Choice: Comments Votes

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Choice: Comments VotesAffirmative with Comment 2David R. Carpenter needed information which does not need to be in the body of the text

Mark R. Hilbert Continue to accept the revision. The requirements of Chapter 6 are intended to warn a worker of a potential arc‐flash hazard. The requirement in 6.1 mirrors the National Electrical Code which already requires control cabinets to be field q y qlabeled to warn workers of a potential arc‐flash hazard. Keeping this requirement in NFPA 79 will be a benefit those working on electrical equipment of industrial machinery in cases where NFPA 79 is the only document used.

Negative 3Paul Dobrowsky This change should not be made. Placing live parts in an enclosure inherently reduces the likelihood of an arc flash event

occurring. An indirect contact electric shock incident can occur as a result of an insulation failure if the enclosure integrity th ff ti f lt t th i i d El t i l i t d t f t ti l fl h h d dor the effective fault current path is compromised. Electrical equipment does not warn of potential arc‐flash hazards and

marking requirements seem to belong in Chapter 16. First Revision No. 47‐added Annex material to .6.2 that supports this concept.

Palmer L. Hickman The submitter of the Public Input has recommended a significant reduction in personnel protection without technical substantiation. The assertion is made that "Current language could be interpreted to require that the equipment must be substantiation. The assertion is made that Current language could be interpreted to require that the equipment must be designed to protect person(s) from arc flash hazards." The present requirements are clear. They do require protection against arc flash hazards. See present requirements below: Electrical equipment shall provide protection of persons from electric shock, from direct and indirect contact, and from arc‐flash hazards.

Daniel R Neeser Providing protection from direct contact or indirect contact does provide a degree of protection from arc flash hazardsDaniel R. Neeser Providing protection from direct contact or indirect contact does provide a degree of protection from arc flash hazards, and as such it is more than just “warn of potential” of arc flash hazards, as indicated in the new annex A.6.1. Therefore the change would reduce the level of safety.


FR‐101, Section No. 6.2.2.1, See FR‐101Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of Style

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FR‐74, Section No. 6.4.1.1, See FR‐74Total Eligible to Vote: 23

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0Affirmative 18

FR‐48, Section No. 6.6, See FR‐48Total Eligible to Vote: 23Choice: Comments VotesAffi ti ith C t 3Affirmative with Comment 3David R. Carpenter needed to be consistant concerning arc flash with other NFPA standards

Jay Tamblingson The reference here to 16.2.3 is too limiting. Subsection 16.2.7 also references the requirement for warning against arc flash hazards. Should not 16.2.7 be also referenced in 6 6? What is missing is some lower limit of the arc flash hazard which could exclude those devices or assemblies for which the warning is not needed. As of now the only exclusion is which could exclude those devices or assemblies for which the warning is not needed. As of now the only exclusion is found in 16.2.3.2 which excludes items too small to place a label on.

Mark R. Hilbert Continue to accept the revision. See my ballot statement on FR 46.Negative 0Abstain 0Affirmative 16

FR‐20, Section No. 7.2.1.2, See FR‐20Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R Carpenter correct wording for applicationDavid R. Carpenter correct wording for applicationNegative 0Abstain 0Affirmative 18

FR‐13, Section No. 7.2.4.2.5, See FR‐13

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter correlation with NEC and style manualNegative 0Abstain 0

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Abstain 0Affirmative 18FR‐103, Section No. 7.2.7.1, See FR‐103Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Paul Dobrowsky Transformers and overload device requirements are provided with references to the NEC. A similar requirement should

be included for motor controllers possibly as part of 7.2.10. Motor controllers shall be provided in accordance with Article 430, Part VII of NFPA 70.

David R. Carpenter comply with the NFPA Manual of StyleN ti 0Negative 0Abstain 0Affirmative 17

FR‐14, Section No. 7.2.8, See FR‐14FR 14, Section No. 7.2.8, See FR 14Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter clarifies applicationNegative 0Abstain 0Affirmative 18

FR‐2, Section No. 7.2.10.1.1, See FR‐2Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0

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Affirmative 18

FR‐17, Section No. 7.2.10.2, See FR‐17Total Eligible to Vote: 23

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3David R. Carpenter consistancy and clarification of other articles/sections

Daniel R. Neeser Recommend deleting "ground fault" since this is redundant ‐ a ground fault is a type of short‐circuit.g g g yp

Jay Tamblingson It would be better, structure wise, if the added sentence was inserted as a new listed item. If not, an "and" should be inserted before the two clauses so the listed item (2) would be one sentence.

Negative 0Abstain 0Affi ti 16Affirmative 16

FR‐16, Section No. 7.2.10.3, See FR‐16Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3Affirmative with Comment 3David R. Carpenter consistancy and clarification of other articles/sections

Daniel R. Neeser Recommend deleting "ground fault" since this is redundant ‐ a ground fault is a type of short‐circuit.

Jay Tamblingson The "is" in the last sentence should be "shall be"Negative 0Abstain 0Affirmative 16

FR‐22 Section No 7 2 11 3 See FR‐22FR‐22, Section No. 7.2.11.3, See FR‐22Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2

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Paul Dobrowsky The opening phase should be improved for clarity such as "shall meet all the following requirements" or "shall be:"

David R. Carpenter clarificationNegative 0Abstain 0

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Affirmative 17

FR‐84, Section No. 7.3.1, See FR‐84Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Affirmative with Comment 2David R. Carpenter compliance with the NFPA Manual of Style

Stephen W. Douglas Is it necessary to include “motor controller”? Some may read this to mean the overlaod protection needs to be installed ahead of the motor controller. I recommend we remove “motor controller” from this requirement.

Negative 0gAbstain 0Affirmative 17

FR‐18, Section No. 7.8, See FR‐18Total Eligible to Vote: 23Choice: Comments VotesChoice: Comments VotesAffirmative with Comment 3Paul Dobrowsky Delete new 7.8.3 Where provided, SPDs shall be connected across the terminals of all equipment requiring such

protection. I understand this is an existing requirement but SPD's are installed by Choice: so why shouldn't the designer or installer be permitted to decide where to connect them.

David R. Carpenter Needed information to properly install, inspect or troubleshoot

Jay Tamblingson The new language appears to mandate that only devices classified as SPD's can be used for surge suppression of switching transients, but does not differentiate between transients in power circuits vs. control circuits. It is common practice to use diodes on dc inductive loads to suppress switching transients, but it is unclear if these are classified under

SPD' I dditi i f i d t i l t th t id i t li t d SPD' b t tas SPD's. In addition, accessories for industrial components that provide suppression are not listed as SPD's but as motor controller accessories.


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FR‐86, Section No. 7.9, See FR‐86Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter needed information and clarificationNegative 0

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FR‐57, Section No. 8.1, See FR‐57Total Eligible to Vote: 23gChoice: Comments VotesAffirmative with Comment 2Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase

"equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding jumper" might be more appropriate.

Jay Tamblingson Rather than deleting the the annex note reference under 8.1, it should be retained and the annex note changed to refer to the new annex J on grounding and bonding terminology.

Negative 1David R. Carpenter See FR‐50 comments ‐ This especially applies to industrial machines and should not be treated as facilities type language.

There are times when the two do overlap.Abstain 0Abstain 0Affirmative 16

FR‐75, Section No. 8.2, See FR‐75Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase


Negative 3

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Mike Soter Exception allows the use of machine members for establishing the continuity of a ground path. This is not an acceptable practice(regardless of machine member size)for multiple reasons: 1. The resistivity of that path (based on the number of bolted connections)may not be the least resistive path to the source. 2. The path then becomes a "function" of non‐qualified individuals. ie. Personnel familiar with electrical installations lose "functional" control of the ground path integrity. 3. Non‐Electrical maintenance personnel may inadvertantley break, or add resistance to that unlabeled/unidentified path during the course of the machine's life expectancy

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unlabeled/unidentified path during the course of the machine's life expectancy.

David R. Carpenter See comments FR‐50 and FR‐57

Jay Tamblingson The permission of the exception to 8.2.2.1 was removed from the 2007 NFPA 79 for reasons that included alignment with IEC 60204‐1 in accordance with the July 23, 1998 letter from the Standards Council which read in part: "Concur with the y , pefforts of the NFPA 79 Committee to harmonize the technical requirements of NFPA 79 and IEC 204, where feasible and where in concert with the NEC and its related codes and standards." Further, the "in concert with the NEC and its related codes and standards" part of the permission from the Standards Council was then deemed to be met, as cited by Lynn Saunders in his Comment, in that the removal of the allowance to substitute machine members for an equipment grounding conductor met the requirements of Article 300.3(B) of the NEC. It required that the equipment grounding

d t b t i d i th ith th th d t f th i it Th d ti i iconductor be contained in the same raceway with the other conductors of the same circuit. The proposed exception is, in effect, ignoring the agreement to align with IEC 60204‐1 and the NEC 300.3(B) requirement. It has been proposed on the basis of Article 250.136(A) which permits a grounded metal rack or structure provided for the support of electrical equipment to, in turn, ground the electrical equipment that is securely mechanically and electrically connected thereto. This negates the need for a separate equipment grounding conductor for the thus mounted electrical equipment. The interpretation is that if it is OK for a metal rack or structure with the sole purpose of supporting electrical equipment to interpretation is that if it is OK for a metal rack or structure with the sole purpose of supporting electrical equipment to substitute for an equipment grounding conductor, then it’s OK for machine members to be used for the same purpose, notwithstanding the very significant functional roles and mechanical differences. The permission in 250.136(A) is for electrical equipment supported by grounded metal racks or structures. This permission is far from allowing machine members to have the same role. For instance, there are implicitly more connections when machine member(s) are used to substitute for an equipment grounding conductor. Further, even where machine members might be so used, they are often not contiguous pieces of metal which begs the question of integrity of continuity over the years since machines are continually stressed and subject to the possibility of exposure to corrosive materials. Simply put, it cannot be claimed that the proposed substitution of machine members for equipment grounding conductor elements is “in concert with the NEC and its related codes and standards.”


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FR‐96, Section No. 8.3, See FR‐96Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter needed changeNegative 0

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FR‐107, Section No. 8.4.2, See FR‐107Total Eligible to Vote: 23gChoice: Comments VotesAffirmative with Comment 1Paul Dobrowsky NFPA Staff's name incorrectly appears as the submitter. Removing the parenthetical terms is a good change and should

improve clarity. In addition replacing the phrase "equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding jumper" might be more appropriate.

N ti 1Negative 1David R. Carpenter See comments FR‐50 and FR‐57Abstain 0Affirmative 17

FR‐76, Section No. 9.1.1.2, See FR‐76Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase


Negative 1David R. Carpenter See comments FR‐50 and FR‐57Abstain 0Affirmative 17Affirmative 17

FR‐63, Section No. 9.1.4.2, See FR‐63Total Eligible to Vote: 23Choice: Comments Votes

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Affirmative with Comment 1David R. Carpenter correction neededNegative 0Abstain 0Affirmative 18

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FR‐24, Section No. 9.2.2, See FR‐24Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter correction neededpNegative 0Abstain 0Affirmative 18

FR‐59, Sections 9.2.5.3.1, 9.2.5.3.2, See FR‐59T t l Eli ibl t V t 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter correction neededNegative 1Mark R. Hilbert I agree with the recommendation to change the word “where” to “as” however, no action should be taken on the Mark R. Hilbert I agree with the recommendation to change the word where to as however, no action should be taken on the

remainder of the proposed revisions. By removing 9.2.5.3.1 there is no longer a mandatory requirement to provide a Category 0 stop. I do not agree that 9.2.5.3 is redundant with 9.2.5.3.2. Section 9.2.5.3.2 only requires the Category 0, 1, or 2 stop(s) to be provided and located as required by the risk assessment. There is no mandatory requirement for a Category 0 stop to be provided. That requirement is in 9.2.5.3.1.

Abstain 0Affirmative 17FR‐25, Section No. 9.2.5.4.2.1, See FR‐25Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R Carpenter gives needed guidanceDavid R. Carpenter gives needed guidanceNegative 0Abstain 0Affirmative 18

FR‐42, Section No. 9.3.6, See FR‐42

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter different nomenclature is used to be consistantNegative 0Abstain 0

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FR‐67, Section No. 9.4.1, See FR‐67Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0Affirmative 18

FR‐26, Section No. 9.4.3.2, See FR‐26Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter improper annex noteDavid R. Carpenter improper annex noteNegative 0Abstain 0Affirmative 18FR‐66, Section No. 9.4.3.4, See FR‐66Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3Paul Dobrowsky During the meeting there was considerable discussion about the necessary provisions for software and firmware based

controllers used in safety related functions. Some indicated that the existing conditions cannot be met. Listed products are available that supposedly meet these provisions. If the provisions are not accurate they need to be modified but they need to remain in the standard and not only determined by anyone's risk assessment with no specific stated methodneed to remain in the standard and not only determined by anyone s risk assessment with no specific stated method.

David R. Carpenter annex note which was incorrectly referenced has now been corrected

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Jay Tamblingson The annex note revision was correct, but the committee action to reject the changes proposed in Public Input 47 by the NFPA 79 Control and Technology Task Force was not. Most of today's safety relays and controllers use software or firmware, and the existing language essentially prescribes a level of safety control system performance that may not be appropriate or achievable for the level of risk identified. Functional safety solutions are given in probabilistic terms. They are based on the theory that any electronic component can fail at any time. This is quite different from the deterministic approach used for electromechanical devices that have B10 life characterizations where it is very improbable that a well

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approach used for electromechanical devices that have B10 life characterizations where it is very improbable that a well‐designed redundant system will fail during the derated B10 life of the devices. In addition, the committee discussed the listing requirements in 9.4.3.4.1 for software and firmware controllers. As it is not clear at this time if NRTL's are


FR‐1, Section No. 10.3.1.1, See FR‐1Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1D id R C t li ith th NFPA M l f St lDavid R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0Affirmative 18

FR‐62, Section No. 10.7.4.1, See FR‐62Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1

id d li bl fDavid R. Carpenter removed non‐applicable referenceNegative 0Abstain 0Affirmative 18

FR‐34, Section No. 11.2.1.5.1, See FR‐34Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1

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David R. Carpenter This guidance is neededNegative 0Abstain 0Affirmative 18

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FR‐32, Section No. 11.3.2, See FR‐32Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Paul Dobrowsky The term "NEMA" should be removed from this section. The NEC simply uses the term "Type". leaving the term "NEMA"

can infer that something different than the NEC Type rations are intended.

David R. Carpenter clarification makes the principle easier to applyNegative 0Ab t i 0Abstain 0Affirmative 17

FR‐33, Section No. 11.4.2, See FR‐33Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter needed referenceNegative 0Abstain 0Affirmative 18

FR‐35, Section No. 11.5, See FR‐35Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3Affirmative with Comment 3Paul Dobrowsky The additional text submitted in PI ? Log 114 needs to be added to this section. It is my understanding that the NEC

working spaces requirements are applicable for the enclosure that contains the supply conductor. This is supported by NEC 670.1, Informational Note 2. During the meeting there was considerable discussion and disagreement about this issue. Clear direction needs to be provided regarding which working space requirements are applicable.

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Drake A. Drobnick I agree with the submitter's substantiation (PI#96). Required equipment working spaces shall be flat in both the entire depth and width dimentions.

David R. Carpenter This clarification needed

Negative 1Mark R Hilbert I voted negative as I do not agree with all the proposed changes I agree with the recommendations in PIs 104 & 56 to

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Mark R. Hilbert I voted negative as I do not agree with all the proposed changes. I agree with the recommendations in PIs 104 & 56 to revise the metric measurement, the recommendation in PI 55 to clarify Exception No. 4 by changing “and” to “where” and the recommendation in PI 10 to relocate 11.5.1 to a new 11.5.1.4. I do not agree with the recommendation in PI 56 to add “opening into the” in front of the words “control cabinet” in 11.5.1.2. The requirements of this section are necessary to provide adequate space for personnel to perform adjustment, examination, maintenance and servicing tasks on the outside of enclosures as well as the inside. The proposed changes only consider tasks that are performed p p g y pinside of the enclosure when in fact there are tasks performed on the outside of enclosures as well. For example repair or replacement of the operating handle for a disconnecting means mounted on the outside flange of a control cabinet. As revised adjacent machine equipment could be placed in front of a control cabinet as long as the cabinet opening is clear and I can operate the disconnecting means operator. This will compromise the access to components mounted on the outside of equipment and will significantly reduce the likelihood of door swings beyond the point of 90 degrees. U f t t l b ti t k PI 94 it d t th b ll t PI 94 d d l bUnfortunately because no action was taken on PI 94 it does not appear on the ballot. PI 94 recommended language be added to 11.5 to clarify the working space requirements of the NEC apply where the enclosure contained the supply conductors. Although I agree with the submitter there is a need to clarify coverage of the working space requirements for enclosures containing the supply conductors I also agree with the Committee discussion that as NFPA 79 is currently worded the working space for an enclosure containing the “supply conductor terminals” is covered by NFPA 79. Further clarification is necessary as there are cases when an enclosure may contain the “supply conductors” and “supply clarification is necessary as there are cases when an enclosure may contain the supply conductors and supply


FR‐11, Section No. 12.5.5, See FR‐11Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2

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Paul Dobrowsky The term " derating" should be replaced with "adjustment" related to "numbers of conductors" and "correction" relating to ambient temperature. This cange has been made in the NEC and NFPA 79 should be consistent to avoid confusion.

Jay Tamblingson Given that 4.4.3 states that the ambient operating temperature of the equipment shall be betweeen 5c and 40C, it would be useful to update the correction factors and ampacity tables based on 40C rather than requiring users to always adjust from 30C ambient values and would improve harmonization with IEC 60204‐1.

Negative 0

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FR‐10, Section No. 12.6.1.1, See FR‐10, ,Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2David R. Carpenter Difference between ampacity and current in the sentence structure is needed to keep definitions consist to

application...Ampacity defines the capability of a circuit to handle current.. Current Rating is the ability to produce... This t i i t t ith th t l t d t d d h th DOEterm is now consistent with other motor related standards such as the DOE..

Daniel R. Neeser Class CF fuses which have the same performance requirements as Class J fuses should be added to the list of acceptable fuses in 1(c)iii, 2(c)iii, and 3(c)iii. In addition, Class CF fuses should be added to Table 7.2.10.1. So it should say "Class J or CF".

Negative 0Negative 0Abstain 0Affirmative 17

FR‐9, Section No. 12.6.1.2, See FR‐9Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2David R. Carpenter see FR‐10 comments

Daniel R Neeser Class CF fuses which have the same performance requirements as Class J fuses should be added to the list of acceptableDaniel R. Neeser Class CF fuses which have the same performance requirements as Class J fuses should be added to the list of acceptable fuses in 1(c)iii, 2(c)iii, and 3(c)iii. In addition, Class CF fuses should be added to Table 7.2.10.1. So it should say "Class J or CF".


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FR‐73, Section No. 12.9.2, See FR‐73

Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2David R. Carpenter revised language clarifies the intent

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Mark R. Hilbert This revision also meets the intent of PI 103, Log #59.Negative 0Abstain 0Affirmative 17

FR‐90, Section No. 13.1.4, See FR‐90Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3David R. Carpenter revised language clarificaton is needed

Daniel R. Neeser The term "supply circuits" should be better defined in the standard. Is it for the supply to the main industrial control panel of a machine? Does it also apply to industrial control panels downstream of the main industrial control panel? I would think the requirements for downstream industrial control panels, may not necessarily have the same

Stephen W Douglas Is it the intent of the committee to prevent these supplies to be installed in separate cables? Provide each supply isStephen W. Douglas Is it the intent of the committee to prevent these supplies to be installed in separate cables? Provide each supply is installed in a separate cable I believe the intent of this requirement will be met. I recommend we add “or cables” after the word raceway to read: Where the equipment is supplied from two or more sources of power or from two or more independent disconnecting means, the power wiring from each supply source or from each disconnecting means shall be run in raceways, or cables and shall not terminate in or pass through common junction boxes.

Negative 0gAbstain 0Affirmative 16

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FR‐77, Section No. 13.2.2.1, See FR‐77Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 0Negative 1David R Carpenter See comment FR 50

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David R. Carpenter See comment FR‐50Abstain 0Affirmative 18

FR‐78, Section No. 13.4.5.3, See FR‐78, ,Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase

"equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding j " i ht b i tjumper" might be more appropriate.

Negative 1David R. Carpenter See comment FR‐50Abstain 0Affirmative 17

FR‐105, Section No. 13.5.10.1, See FR‐105Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0Affirmative 18

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FR‐106, Section No. 14.1.1, See FR‐106Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3David R. Carpenter compliance with the NFPA Manual of Style

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Paul R. Warndorf This item should be harmonized with FR‐90‐NFPA 79‐2012 and delete the word "separate" from "separate raceway".Stephen W. Douglas Is it the intent of the committee to prevent these supplies to be installed in separate cables? Provide each supply is

installed in a separate cable I believe the intent of this requirement will be met. I recommend we add “or cables” after the word raceway to read: Where the equipment has two or more sources of power or two or more independent disconnecting means, power wiring from each disconnecting means shall be run in separate raceways or cables and shall g , p g g p ynot terminate in or pass through common junction boxes.

Negative 1Jay Tamblingson This section should have been deleted as it is redundant with 13.1.4 which applies to all conductors, including motor

circuits.Abstain 0Affi ti 15Affirmative 15

FR‐79, Section No. 15.1.1, See FR‐79Total Eligible to Vote: 23Choice: Comments VotesChoice: Comments VotesAffirmative with Comment 1Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase

"equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding jumper" might be more appropriate. The parenthetical terms (plug/sockets) should also be deleted.

Negative 2Drake A. Drobnick I agree with the submitter's substantiation (PI#1) for removing 20 ampere receptacles.

David R. Carpenter See comment FR‐50

Abstain 0Affirmative 16Affirmative 16

FR‐88, Section No. 16.2.3 [Excluding any Sub‐Sections], See FR‐88Total Eligible to Vote: 23Choice: Comments Votes

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Affirmative with Comment 1David R. Carpenter Sign must be durableNegative 0Abstain 0Affirmative 18

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FR‐89, Section No. 16.4.1, See FR‐89Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter needed to stop confusionNegative 0Abstain 0Affirmative 18

FR 80 S ti N 18 1 S FR 80FR‐80, Section No. 18.1, See FR‐80Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase

"equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding equipment grounding circuit with equipment grounding conductor , bonding conductor or equipment bonding jumper" might be more appropriate.

Negative 1David R. Carpenter This change does not stop or clear up confusion when Industrial Machine design is based on IEC standards. See FR‐50..

Removing the term "protective ground" does not explain how it (the term "Protective Ground")is to be applied when referred to within specifications and wiring diagrams of IEC based equipment. When the engineer or installer encounters the IEC Wirng Diagram they are not aware that this in reference to the US equivalent of the equipment ground... some think it is referring to the neutral....

Abstain 0Affirmative 17FR‐81, Section No. 18.2, See FR‐81Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1

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Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase "equipment grounding circuit" with "equipment grounding conductor", "bonding conductor" or "equipment bonding jumper" might be more appropriate.

Negative 1David R. Carpenter See comments FR ‐50 & FR ‐ 80

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N i 1Negative 1David R. Carpenter See comments FR ‐50 & FR ‐ 80



"equipment grounding circuit" with "equipment grounding conductor" "bonding conductor" or "equipment bondingequipment grounding circuit with equipment grounding conductor , bonding conductor or equipment bonding jumper" might be more appropriate.

Negative 1David R. Carpenter See comments FR ‐50 & FR ‐ 80


FR‐87, Section No. 19.1, See FR‐87Total Eligible to Vote: 23g

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Choice: Comments VotesAffirmative with Comment 2David R. Carpenter This clarification is long over due. However, there is still work needed for this section concerning existing applications

with no manufactures guidance concerning SCCR. This must be compliant with the manufactures testing results for Daniel R. Neeser It would be beneficial to clarify that the branch circuit overcurrent protective device is really only providing short‐circuit

protection Recommend the standard refer to the branch circuit short circuit and ground fault protection be changed to

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protection. Recommend the standard refer to the branch‐circuit short‐circuit and ground fault protection be changed to branch‐circuit short‐circuit protection. In addition, it would be beneficial to define the term in Chapter 3, such as Short‐circuit (fault). A short‐circuit is a type of overcurrent condition where current flows outside of the normal path. The fault can be line‐line, line‐ground (ground fault), line‐neutral or combination.


FR‐55, Section No. A.3.3.9, See FR‐55T t l Eli ibl t V t 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 0Negative 1David R. Carpenter See comments FR ‐50 & FR ‐ 80Abstain 0Abstain 0Affirmative 18

FR‐95, Section No. A.3.3.32, See FR‐95Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Palmer L. Hickman Delete the parenthetical references: Conduits, cable trunking systems (see 3.3.15), and underfloor channels are types of

duct (See also 3 3 80 Raceway )duct. (See also 3.3.80, Raceway.)

David R. Carpenter needed editorial change

Negative 1

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Paul Dobrowsky This section and the definition of "Duct" in Chapter 3 should be deleted. The term "Raceway" is defined and is the correct term. Adding information in the proposed annex related to the term "duct" is appropriate.


FR 52 Section No A 3 3 77 See FR 52

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FR‐52, Section No. A.3.3.77, See FR‐52Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter See comments FR ‐50 & FR ‐ 80Negative 0gAbstain 0Affirmative 18

FR‐69, Section No. A.3.3.85, See FR‐69Total Eligible to Vote: 23Ch i C t V tChoice: Comments VotesAffirmative with Comment 1David R. Carpenter needed changeNegative 0Abstain 0Affirmative 18Affirmative 18

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FR‐8, Section No. A.4.1, See FR‐8Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Palmer L. Hickman The Correlating Committee should review this action. It may be beyond the scope of NFPA 79 to address static electricity.David R Carpenter needed reference

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David R. Carpenter needed reference

Negative 1Daniel R. Neeser Adding this standard is not appropriate since the text does not address static electricity (only in the annex material).Abstain 0Affirmative 16Affirmative 16

FR‐70, Section No. A.5.4.3, See FR‐70Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Palmer L. Hickman Recommend removal of the parenthetical reference: The selection of other means is dependent on many factors, taking

into account those persons for whom its use is intended. (See ANSI B11.0 and ISO 12100.)David R. Carpenter Needed ReferenceNegative 0Abstain 0Affirmative 17Affirmative 17

FR‐47, New Section after A.6.2, See FR‐47Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2David R. Carpenter best language for intent

Mark R. Hilbert Continue to accept the revisions. See my ballot comment on FR 46.

Negative 1Daniel R. Neeser There are not currently UL 50E enclosures that are available as arc resistant, only some low‐voltage and medium voltage

equipment (switchgear and motor control centers) is currently available.

Abstain 0Affirmative 16FR‐56, Section No. A.6.3.1.1, See FR‐56Total Eligible to Vote: 23

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Choice: Comments VotesAffirmative with Comment 2Paul Dobrowsky Removing the parenthetical terms is a good change and should improve clarity. In addition replacing the phrase


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Jay Tamblingson This is the only place where the term "equipment grounding system" is used. The term "equipment grounding circuit" is used in Chapter 8 and elsewhere.

Negative 1David R. Carpenter See comments FR ‐50 & FR ‐ 80Abstain 0Affirmative 16

FR‐58, Section No. A.8.1, See FR‐58Total Eligible to Vote: 23Choice: Comments VotesChoice: Comments VotesAffirmative with Comment 0Negative 2David R. Carpenter See comments FR ‐50 & FR ‐ 80

Jay Tamblingson The annex note should be retained but revised to point to the new Annex J containing details on grounding and bonding terminologyterminology.


FR‐61, New Section after A.9.2, See FR‐61Total Eligible to Vote: 23gChoice: Comments VotesAffirmative with Comment 2Palmer L. Hickman The first sentence does not appear to read correctly. Also, it is recommended to remove the parenthetical reference: For

removal of power it can be sufficient to remove the power needed to generate a torque or force. This can be achieved by declutching, disconnecting, switching off, or by electronic means (see 9.2.5.4.1.4). When stop functions are initiated it

b t di ti hi f ti th th tican be necessary to discontinue machine functions other than motion.David R. Carpenter annex needed


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FR‐64, Section No. A.9.2, See FR‐64Total Eligible to Vote: 23Choice: Comments Votes

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Choice: Comments VotesAffirmative with Comment 2David R. Carpenter See comments FR ‐50 & FR ‐ 80Jay Tamblingson The term "emergency stopping" should be changed to "stopping" as it generically applies with the other items listed. As

described in A9.2.5.4, "emergency stop" is a complementary protective measure.

Negative 0Negative 0Abstain 0Affirmative 17

FR‐60, New Section after A.9.2.3.3, See FR‐60Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Palmer L. Hickman This sentence does not appear to read correctly: The supply circuit disconnecting means when opened achieves a

Cate or 0 stopCategory 0 stop.

David R. Carpenter nedded

Negative 0Abstain 0Abstain 0Affirmative 17

FR‐68, Section No. A.9.4.1.1, See FR‐68T t l Eli ibl t V t 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter corrected referenceNegative 0

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FR‐65, Section No. A.9.4.3.2, See FR‐65Total Eligible to Vote: 23

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter corrected referenceNegative 0Abstain 0Affirmative 18

FR‐71, Section No. A.14.1, See FR‐71Total Eligible to Vote: 23Choice: Comments VotesAffi ti ith C t 1Affirmative with Comment 1David R. Carpenter corrected referenceNegative 0Abstain 0Affirmative 18

FR‐72, Section No. C.5, See FR‐72Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter clarification

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Negative 1Mark R. Hilbert Adding “conveyors and conveying machines” to the examples of industrial machines is not necessary and will likely add

more confusion than clarification from an inspection standpoint. For example would a conveyor with a manual start/stop arrangement and loading that is permanently installed between grade level or the 1st floor and the 2nd floor storage area of an industrial or commercial facility be an considered an industrial machine? The large complex types of “conveying machines” recommended in the recommendation can be considered under C 5 (2) and (3) transfer and

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“conveying machines” recommended in the recommendation can be considered under C.5 (2) and (3) transfer and sortation machines.


FR‐91, Section No. D.1, See FR‐91Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2P l L Hi k It i t d t th th ti l i f ti Fi D 1( ) th h Fi D 1( ) t i t d d t bPalmer L. Hickman It is suggested to remove the parenthetical information: Figure D.1(a) through Figure D.1(q) are not intended to be

(design) guidelines. They are included only to illustrate documentation methods.

David R. Carpenter Agree that output and input are wrong in existing textNegative 0Abstain 0Affi i 17Affirmative 17

FR‐92, Section No. F.2, See FR‐92Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance and clarityNegative 0Abstain 0Affirmative 18

FR‐104, Section No. F.5.3.1, See FR‐104

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Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1David R. Carpenter compliance with the NFPA Manual of StyleNegative 0Abstain 0

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FR‐31, New Section after F.5.4, See FR‐31, ,Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 0Negative 0Abstain 0Affi ti 19Affirmative 19

FR‐43, Section No. H.2, See FR‐43Total Eligible to Vote: 23Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Palmer L. Hickman It is suggested to remove the parentheical references.

David R. Carpenter consistent terminology


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FR‐49, New Section after H.5, See FR‐49Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 1Mark R. Hilbert Continue to develop this Annex. See my ballot statement on FR 50.Negative 1

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Negative 1David R. Carpenter The IEC terms and definition should be compared to NFPA to help the reader understand how to apply.Abstain 0Affirmative 17

FR‐7, Section No. J.1.1, See FR‐7Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2P l L Hi k Th C l ti C itt h ld i thi ti It b b d th f NFPA 79 t dd t ti l t i itPalmer L. Hickman The Correlating Committee should review this action. It may be beyond the scope of NFPA 79 to address static electricity.David R. Carpenter Needed referenceNegative 2Drake A. Drobnick If we didn't accept any public inputs concerning static electricity there is no need to reference this publication.Daniel R. Neeser Adding this standard is not appropriate since the text does not address static electricity (only in the annex material).Abstain 0Abstain 0Affirmative 15

FR‐30, Section No. J.1.2, See FR‐30Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 3Drake A. Drobnick I agree with the submitter of PI#60. The dates for ISO 12100 and 13849‐1 should be updated.

David R. Carpenter ISO information neededDavid R. Carpenter ISO information needed

J. B. Titus According to the PI 60 and FR 30 statements for my submittal on J.1.2.5, the recommended action was approved. Yet, the date for ISO 12100 was not changed from 2003 to 2010 and likewise the date for ISO 13849‐1 was not changed from 1990 to 2006.

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FR‐94, Section No. J.1.2.8, See FR‐94Total Eligible to Vote: 23Choice: Comments VotesAffirmative with Comment 2Drake A. Drobnick The UL publication dates within this FR do not agree with dates for the same publications found in FR#30.p g pDavid R. Carpenter the best reference available


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fd tc circulation cover memo

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