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High-voltage transformer ballistic fire barriers

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Asymmetrical transformer fire barrier[1], subject of ripoffreport.com Report #1465535[2], with ”durabarrier” public domain test reports[3] purchased by Horizon Utilities, located between Parkdale Substation and Hamilton Hyundai in Hamilton, ON, Canada.

High-voltage transformer ballistic firewalls, or transformer firewalls, transformer ballistic firewalls, transformer blast walls, are outdoor countermeasures against cascading failures in a national electrical grid, as well as wildfires (where electrical substations are located near forested areas). The purpose of these barriers, like common fire barriers in building construction, is compartmentalisation, in this case, of transformer fires[4], as well as transformer and bushing explosions where the fuel source of both fires and explosions is the petroleum-based transformer oil. Without compartmentalisation, one ruptured transformer could start its neighbouring transformer on fire[5] and thus create a domino effect accident that can affect the surrounding electric grid, causing a cascading failure, particularly during peak demand times. High-voltage transformer fire barriers, (ballistic-resistant, or not) are typically located in electrical substations, but may also be attached to buildings, such as valve halls or factories with large electrical distribution systems, such as pulp and paper mills. Outdoor transformer fire barriers, that are attached, at least on one side, to a building, are referred to as wing walls. At times, high-voltage transformers[6]

Attacks upon electrical substations and high-voltage transformers targets[edit]

As early as World War II, electrical substations have been military targets, as they have been again[7], during Russia’s invasion of Ukraine. During WW2, Operation Joséphine B, the British Special Operations Executive successfully targeted a French substation with high-voltage transformers[8] in order to disrupt the German war effort there. There have been a number of incidents of reports of shots fired on transformers, for example, in Nova Scotia[9], Saskatchewan[10], Alberta[11], and the Metcalf sniper attack. Shooting at an operating transformer could cause a fire and explosion. It is possible, and has happened, that one ruptured transformer can ignite a neighbouring transformer, increasing the likelihood of a cascading failure, such as the Northeast blackout of 2003, as well a wildfire, if the electrical substation that contains the ruptured transformer is in proximity to woodlands. There is history with regards to wildfires beginning with outdoor electrical equipment[12], of which petroleum-based transformer oil filled high-voltage transformers form a part. This scenario can be tested, for qualification purposes, exposing the test sample to shots fired[13] before or after a fire test.

Code requirements and liability[edit]

High-voltage transformers with bushings on top, separated by a fire barrier
Transformer[14] inside an electrical service building, behind an external damper at the (now defunct) St. Mary's Paper. When inside a building, the room containing the transformer is referred to as a transformer vault[15], for example in NFPA 5000 Building Construction and Safety Code[16] - 2015's Service Equipment, Hazardous Operations or Processes, and Storage Facilities, whereby the walls containing such equipment have unique requirements, separate and apart from outdoor transformer fire walls, which are not subject to building codes. In this case, a firestop mortar is being installed in an exterior electrical cable through-penetration.
Time/Temperature curves used in North America and Europe. The hydrocarbon [17] curve is also used internationally, particularly to qualify fireproofing systems for oil refineries and offshore platforms, due to the faster heat rise when burning oil, whereas ASTM E119[18], ISO 834[19], DIN 4102[20] and BS476[21] are based on burning timber and thus form the basis of fire testing for buildings.
Comparison of French hydrocarbon and other time/temperature curves used inside of tunnels. Still the internationally most cited time/temperature curve for hydrocarbon applications is UL 1709[22], which reaches ca. 1,100°C in minutes and then flatlines until the end of the test.
This is a full-scale wall furnace of [23], which is now (the furnace, that is) defunct. Notice the black tubes that project into the fire test chamber, before which a wall test sample would be clamped. These black tubes are made of Inconel. These tubes are used to shield standard thermocouples inside. It is a requirement in North American test standards for walls and floor/ceiling and/or roof/ceiling assemblies that the thermocouples used to collect furnace temperatures, in order to enter the test record, calculate a furnace average temperature for comparison against the stipulated time/temperature curve and its tolerance as well as to regulate the gas flow fuel into the fire chamber such that the heat exposure conforms to the standard being tested against. Importantly, the use of shielded thermocouples[24].
This is the now defunct ULC “4x9” medium scale fire test furnace. Inconel tubes used to shield the furnace thermocouples are visible at mid-height. Below, one can see the gas pipes with holes to fuel the fire in accordance with the time/temperature curve, from temperature input from the shielded thermocouples. Notice the one small, black tube near the top, in the centre. This is where furnace pressure is sensed. Furnace pressure must also be regulated via calibrated equipment in order to conform to North American fire test standards.
Furnace pressure is mandated by test standards to be within given tolerances, further negating the use of ad hoc outdoor testing as a means to qualify fire barriers.
Mandatory hose stream test [25], of a wall system, containing a fire door. Up to and including 3 hours of fire endurance, the pressure at the base of the nozzle is 2.1 bars or 30 PSI. From 4 hours on, the pressure must be 3.1 bars or 45 PSI. The duration of the hose stream test depends on the test sample size and the length of the fire endurance period: 1 minute per 100 ft² (9.3 m²) up to 1 hour of fire testing. 1.5 minutes per 100ft² (9.3m²) up to 1.5 hours of fire testing. 2.5 minutes per 100ft² (9.3m²) up to 3 hours of fire testing. 5 minutes per 100ft² (9.3m²) from 4 hours to less than 8 hours of fire testing. Therefore, a 6-hour fire-resistance test sample would have to undergo 45PSI (3.1bar), at 5 minutes per 100ft² or 9.3m² in order to qualify. 6 minutes for 8 hours of fire-resistance and above per 100ft² or 9.3m².
High strength low alloy steel armour, exhibiting plastic deformation as a result of projectile impacts in UL 752 testing. Plastic deformation as a result of impact can knock loose, tear or squish passive fire protection (PFP) materials, particularly once the passive fire protection (PFP) materials are stressed by heat. Some passive fire protection (PFP) materials can, at times, be very resilient, impact resistant and ductile at ambient. Once stressed by fire, that can change as free water dissipates at 100°C (212°F), and hydrates can be spent near 300°C (572°F), all of which is reached within minutes of a design basis fire. Construction level binders, unlike certain refractories, can also degrade with heat, thus changing the physical properties of many passive fire protection (PFP) materials across different temperature ranges. None of that is, normally, a problem. In fact, it is part of some passive fire protection (PFP) designs for various reasons. But, when combining passive fire protection (PFP) with ballistics or fragmentation, it is prudent to consider all relevant stresses in designing barriers that must (or may be presumed or advertised to) simultaneously defeat fire, followed by hose stream and impacts that come during a fire-event. For example, if a passive fire protection (PFP) material failed the hose stream test after only 1 hour of fire endurance, this could be an indicator of loss of ductility as a result of heat exposure.

Outdoor structures, such as the transformers and fire barriers that separate them, do not constitute buildings, as defined by building codes. Building codes, therefore, do not typically apply to them, unless buildings are in close proximity and may be adversely affected by transformer ruptures. Where building code issues are inapplicable, no typical building permit[26] is required, as would be the case for a house or office buildings. If no building code applies, then also no fire code[27] applies, as fire codes presume construction and approval per the local building code[28] This is a crucial factor in terms of regulatory or judicial oversight concerning the construction and maintenance of transformer fire barriers, especially since utility deregulation. Building construction and maintenance have the benefit of a defined Authority Having Jurisdiction (AHJ)[29]. When a building is designed, the architect submits drawings and specifications to the municipal or regional building department, such as the New York City Department of Buildings, along with a fee, which covers plans examinations and inspections. The building department then has a plans examiner[30] check construction documents for compliance with the applicable building code. He or she may require changes before construction can proceed. Once construction is underway, the building department typically has a building inspector checking on progress and compliance. Once a building, or occupancy, is completed and in use, the Authority Having Jurisdiction (AHJ)[31] typically changes from the building department, enforcing the version of the building code that was in effect on the date of the building permit application, over to the fire department, and, specifically the local fire prevention officer, who is tasked to enforce the local fire code, which is based upon the building code. A fire prevention officer is actually a law enforcement official, who can criminally charge violators of the fire code, such as home owners or office building or plant owners. While North American outdoor transformer fire barriers use identical fire test standards to qualify fire barriers as are used in buildings ASTM E119[32], UL 263[33], CAN/ULCS101[34], and, formerly, NFPA 251[35], and, despite the fact that the national electric grid is considered critical national infrastructure (CNI), there is only sporadic governmental oversight, particularly since utility deregulation, such as exists for any buildings. For example, in buildings, it is customary for building component vendors to have to prove compliance with codes by means of certification listings, bounding and certification marks. This is the easiest way to communicate to an Authority Having Jurisdiction (AHJ)[36], that the item tested is identical to the item being sold and installed as intended and within the tolerances indicated in the certification listing, which summarises the test report. However, in the absence of a mandatory code for such outdoor installations, as is the case in North America, there is also no AHJ to make sure that what is being installed is verified by a third party to be fit for purpose[37], which leaves the property owners to perform this task. If an owner, and/or his or her consultant, chooses to accept a test report, without its interpretation and evidence of current validity (bearing in mind that test standards, codes and regulations are subject to revision, which affects due diligence by means of an active certification listing, this inherently relies upon the ethics of the successful vendor, in the event that vendor is still in business at the time of a failure and/or claim. Complying with the latest version of a standard, forms part of due diligence, and is the reason for UL file reviews[38]. In the absence of certification listings that bound the installed configuration, complete with certification marks on the installed fire barrier, which points to the certification listing number, the end-user must also interpret the test report to resolve bounding issues, which requires actual test experience, check whether the test standard used in the report is up to date for current use, and if not, what changes took place and whether the old work still constitutes due diligence that is defensible in the event of a claim, knowledge, comprehension of, and hands-on experience with applied test standards, and the corresponding conditions of acceptance, as well as the raw data provided by the vendor to prove compliance. Laboratories who perform fire tests pay closer attention (to counteract both oversights and deliberate deception on the part of a vendor) to the construction of test samples and the manufacture of its components when the test is intended to earn a certification listing, due to liability concerns. Testing for the purpose of producing a test report places more liability on the test sponsor than testing for and maintaining active certification listings subject to UL fire review, or equivalent. When a utility, or any consumer of safety products, is satisfied with test reports, only, and does not require the use of certification listings and bounding of field configurations by listings, with visible certification marks on the installed configuration in practice, whereby the certification listing not only interprets and summarises test reports, but also assists in ensuring current compliance with standards that constantly change, this may produce a lower initial cost, but at the expense of due diligence in the event of a claim. In large claims, and damages, for critical national infrastructure, this can affect taxpayer-funded governmental assistance as well as ratepayer-funded insurance rates predicated upon risk factors, as determined by insurance providers and funded by paid utility bills. A private sector firm that provides a safety product may be an exporter outside of the jurisdiction of the installed configuration, out of business by the time a claim occurs, close the company and re-open under a new name, or not be financially able to pay all the damages, in the event claim proceedings find such a vendor liable in criminal and/or civil proceedings. Another legal aspect, in the event of a claim, can include attempts by all sides, owner, consultant, AHJ, vendor and contractor, to deflect liability, whereby purchasing and sales conditions may be referred to, which are contradictory. As an example, found in the PD folder[39] for one of the vendors, the, certain contract drawings have a notation on the bottom left-hand side, indicating that the installed configuration was constructed as per a certain test report (contained in that folder), which is “available on request” [40]. Personnel familiar with electrical matters, such as high-voltage direct current, electric power transmission and transformers, who may be expected to decide on a tender for transformer fire barriers, can thus benefit from training concerning fire-resistance ratings and fire testing, which are completely different fields, that do not cross over into the electrical realm, particularly for outdoor installations.

Voluntary recommendations (due diligence) by NFPA 850[edit]

The primary North American due diligence document that deals with outdoor high-voltage transformer fire barriers is NFPA 850 Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations[41]. NFPA 850 – 2015 defines the term “Fire-Resistance Rating” as the time, in minutes or hours, that materials or assemblies have withstood a fire exposure as determined by the tests, or methodology based on testing, as mandated in NFPA 5000 Building Construction and Safety Code[42]. NFPA 5000 is a model building code. It indicates states that the fire-resistance ratings of structural elements and building assemblies are determined in accordance with the prescriptive requirements based on the test procedures set forth in ASTM E 119, Standard Test Methods for Fire Tests of Building Construction and Materials[43], or UL 263, Standard for Fire Tests of Building Construction and Materials[44], or other approved (meaning acceptable to the Authority Having Jurisdiction)] test methodology or analytical methods, which refer to the use of ASCE/SFPE 29, Standard Calculation Methods for Structural Fire Protection[45]. NFPA 850 further outlines that outdoor oil-insulated transformers should be separated from adjacent structures and from each other by firewalls, spatial separation[46], or other approved (meaning acceptable to the Authority Having Jurisdiction) means for the purpose of limiting the damage and potential spread of fire from a transformer failure[47]. Unless indicated otherwise by an analysis, whose factors are listed in the document, it is recommended that any oil-insulated transformer containing 500 US gallons (1,893 L), or more, of oil, be separated from adjacent structures by a 2-hour–rated firewall or by spatial separation in accordance with the table entitled “Outdoor Oil-Insulated Transformer Separation Criteria”. Where a firewall is provided between structures and a transformer, it should extend vertically and horizontally as the document indicates, beyond the equipment itself. NFPA 850 states that unless an analysis considering the equipment and surroundings indicates otherwise, it is recommended that adjacent oil-insulated transformers containing 500 US gallons (1,893 litres), or more, of oil be separated from each other by a 2 hour–rated fire separation or by spatial separation. When the oil containment consists of a large, flat concrete containment area that holds several transformers and other equipment in it without the typical pit containment areas, specific containment features to keep the oil in one transformer from migrating to any other transformer or equipment should be provided. Where a firewall is provided between transformers, it should extend at least 30cm (12") above the top of the transformer casing and oil conservator tank and at least 61cm or 24" beyond the width of the transformer and radiators, or to the edge of the containment area, whichever is greater. Importantly: Where a firewall is provided, it should be designed to resist projectiles from exploding transformer bushings or lightning arresters. The above results in the following checklist for compliance against NFPA 850 and its subordinate documents (NFPA 5000[48], ASTM E119, UL 263, as well as NFPA 251 and CAN/ULC S101[49], all of which are identical for non-loadbearing wall fire tests, and represent the sum of North American wall fire testing standards).

Compliance checklist for transformer firewalls (non-loadbearing)[edit]

  • 1.) Minimum wall fire test sample size:100ft² or 9.3m², restrained on all four edges of the wall fire test sample restraint frame, per §8.3.1 of ASTM E119. NOTE: For systems not subject to certification listing, this may not be covered. As an indicative example, per Ripoff Report #1465535[50] and the Mega public domain evidence folder[51] test A41 by UL of Canada, Page T1-1 of 4, file SV16502 indicates one of several example where the sides of the undersized test sample was not fastened to the two vertical sides of the restraint frame, as the test standard requires, thus free to deflect without rupture during the test, contrary to standard requirements.
  • 2.) Asymmetrical firewall qualifying fire test samples must be tested from both sides in order to satisfy the conditions of acceptance of all 4 aforementioned North American fire test standards, for non-loadbearing walls, meaning a minimum of two identical (and inverted) test samples to get a fire-resistance ratings, such that each of the two different sides of the wall design are exposed to the same fire endurance and mandatory hose stream tests to take place within 10 minutes of the end of the fire endurance. The lowest result, if a certification listing is earned, and/or fire-resistance achieved, of the two identical (and inverted) samples, is the overall rating of the wall system. The results of both tests must form part of the report. Neither test sponsor, nor laboratory, get to decide beforehand, let alone afterwards, which side is more or less critical or more or less likely to succeed and then only test one side. Also, BS476 (which does NOT meet North American standards) PERMITS the use of single side testing of asymmetrical fire separations (used in the UK in “cavity barriers” that sub-divide rated plenums and outdoor extensions of egress routes), provided the laboratory, not the test sponsor, states a rationale for doing so, which is not permissible in North America. If a United Kingdom Accreditation Service (UKAS) accredited laboratory permits single side testing of an asymmetrical fire separation, such a British lab is then accountable to audit by UKAS. In the aforementioned Ripoff Report #1465535[52], specifically in the case of the A40 test[53] the use of the term “ad hoc” was used to claim exemption from audit by UKAS.
  • 3.) Independent test laboratory: By precedent referring back to the Thermo-lag scandal indicated by United States Nuclear Regulatory Commission Generic Letter 92-08[54] and the Federal Register Volume 64, Number 90 (Tuesday, May 11, 1999 (Notices) [55], on the subject matter of claiming that the ITL Laboratory, which had fiduciary ties to Thermal Science Inc.[56], acted as an independent laboratory, resulted in the following statement by USNRC: This is a Severity Level I violation (Supplement VII) Civil Penalty--$100,000[57]. UL1709 is designed to test structural steel fireproofing for use in hydrocarbon fires. By default, in North America, walls, of any type, that are required to have a fire-resistance rating, are fire tested to ASTM E119, CAN/ULC-S101, NFPA 251 or UL 263, as all the provisions of those standards are identical for qualifying the fire-resistance ratings of walls. However, by citing UL 1709, or even mentioning “hydrocarbon” in product literature or other official writings or certificates, whereby UL1709 does NOT address testing walls, the concept is to use one of the aforementioned wall test standards but substitute the time/temperature curve for hydrocarbon UL 1709 fire exposures. The furnace instrumentation[58], and, specifically, whether the furnace thermocouples are shielded, has an influence upon the severity of the initial thermal shock upon any fire test sample, whereby shielded thermocouple experience a time lag, during the first half hour of a fire test, until the heat has sufficiently soaked into the Inconel thermocouple shielding tubes, to be responsive to changes in the average furnace temperature. This means that North American furnaces can run ca. 200°C (392°F) hotter (early in the test, inflicting greater thermal shock) than European furnaces equipped with fast response thermocouples (using bare copper plates). In the aforementioned Thermo-Lag Scandal, it was determined and entered into the record of the Library of Congress] in the case against Thermal Science Inc. (TSI)[59], that the Industrial Testing Laboratories, Inc. (ITL) [60] Industrial Testing Laboratories, Inc. (ITL) fire test furnace used to qualify Thermo-Lag 330-1[61] circuit integrity fireproofing, was equipped with fast response thermocouples, in contravention of all applicable North American fire test standards (ASTM E119, CAN/ULC-S101, NFPA 251 and UL 263, all of which are equivalent/identical for qualifying fire resistive assemblies). Using a fire test furnace to qualify a fire-resistive product or system, whereby the furnace was equipped with fast response thermocouples, unlike the shielded furnace thermocouples, which take longer to heat up, compared to fast response thermocouples, meaning that North American tests run hotter at the initial thermal shock during the first ca. 20 minutes of a fire test, mandated for use in North America, the Thermo-lag 330-1 test samples passed, but identical test samples failed when tested in accordance with the same ASTM E119 time/temperature curve, when the furnace was instrumented per North American standards, using shielded thermocouples, at Omega Point Laboratories[62] Fire Test Research Engineer Mr. Herbert Stansberry[63], in Elmendorf, Texas, in support of the government’ s case against Thermal Science Inc, (TSI), then owned by Mr. Rubin Feldman. The effect of the difference between instrumenting furnaces with shielded versus fast response thermocouples was the subject of a study by Dr. Mohamed A. Sultan[64] of the National Research Council (Canada), which corroborates test results achieved by Engineer Herbert Stansberry (then) of Omega Point Laboratories (now Intertek).
  • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[65], U.S.C. Title 18, §47[66], U.S.C. Title 18, §1002[67], U.S.C. Title 18, §1018[68], U.S.C. title 18, §1031[69], U.S.C. Title 18, §1343[70], U.S.C. Title 31, §3729[71], Competition Act of Canada, Section VII.1[72], Canada’s Criminal Code Section 380 (1) Fraud[73], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[74]
  • 4.) Testing shall be run in a calibrated full scale wall furnace as per test standard (ASTM E119, CAN/ULC-S101, NFPA 251, and/or UL 263 cited, time/temperature curves, including the hydrocarbon fire test time/temperature curve of the standard UL 1709, in the event that the vendor claims to have run a hydrocarbon test[75]. UL1709 is designed to test structural steel fireproofing for use in hydrocarbon fires. By default, in North America, walls, of any type, that are required to have a fire-resistance rating, are fire tested to ASTM E119, CAN/ULC-S101, NFPA 251 or UL 263, as all the provisions of those standards are identical for qualifying the fire-resistance ratings of walls. However, by citing UL 1709, or even mentioning “hydrocarbon” in product literature or other official writings or certificates, whereby UL1709 does NOT address testing walls, the concept is to use one of the aforementioned wall test standards but substitute the time/temperature curve for hydrocarbon UL 1709 fire exposures. The furnace instrumentation[76], and, specifically, whether the furnace thermocouples are shielded, has an influence upon the severity of the initial thermal shock upon any fire test sample, whereby shielded thermocouple experience a time lag, during the first half hour of a fire test, until the heat has sufficiently soaked into the Inconel thermocouple shielding tubes, to be responsive to changes in the average furnace temperature. This means that North American furnaces can run ca. 200°C (392°F) hotter (early in the test, inflicting greater thermal shock) than European furnaces equipped with fast response thermocouples (using bare copper plates). In the aforementioned Thermo-Lag Scandal, it was determined and entered into the record of the Library of Congress] in the case against Thermal Science Inc. (TSI)[77], that the Industrial Testing Laboratories, Inc. (ITL) [78] Industrial Testing Laboratories, Inc. (ITL) fire test furnace used to qualify Thermo-Lag 330-1[79] circuit integrity fireproofing, was equipped with fast response thermocouples, in contravention of all applicable North American fire test standards (ASTM E119, CAN/ULC-S101, NFPA 251 and UL 263, all of which are equivalent/identical for qualifying fire resistive assemblies). Using a fire test furnace to qualify a fire-resistive product or system, whereby the furnace was equipped with fast response thermocouples, unlike the shielded furnace thermocouples, which take longer to heat up, compared to fast response thermocouples, meaning that North American tests run hotter at the initial thermal shock during the first ca. 20 minutes of a fire test, mandated for use in North America, the Thermo-lag 330-1 test samples passed, but identical test samples failed when tested in accordance with the same ASTM E119 time/temperature curve, when the furnace was instrumented per North American standards, using shielded thermocouples, at Omega Point Laboratories[80] Fire Test Research Engineer Mr. Herbert Stansberry[81], in Elmendorf, Texas, in support of the government’ s case against Thermal Science Inc, (TSI), then owned by Mr. Rubin Feldman. The effect of the difference between instrumenting furnaces with shielded versus fast response thermocouples was the subject of a study by Dr. Mohamed A. Sultan[82] of the National Research Council (Canada), which corroborates test results achieved by Engineer Herbert Stansberry (then) of Omega Point Laboratories (now Intertek).
    • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[83], *U.S.C. Title 18, §47[84], U.S.C. Title 18, §1002[85], *U.S.C. Title 18, §1018[86], U.S.C. title 18, §1031[87], U.S.C. Title 18, §1343[88], *U.S.C. Title 31, §3729[89], Competition Act of Canada, Section VII.1[90], Canada’s Criminal Code Section 380 (1) Fraud[91], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[92]
  • 5.) Mandatory hose stream testing, following the end of the fire endurance test within 10 minutes of gas shut-off. ASTM E119 now refers to a separate document, ASTM E2226 Standard Practice for Application of Hose Stream, for the hose stream test, in order to avoid duplication, as the hose stream test procedure is used in other fire-resistive assemblies in addition to those tested under ASTM E119. Testing outside of North America typically excludes hose stream testing, unless witnessed by North American authorities for the purpose of obtaining ratings (certification listings) inside of North America. In order to qualify for a rating or to be able to use the term fire-resistance, fire-resistive, fire barrier, and/or firewall, for a wall system in North America, in addition to all other requirements, there can be no through-projection of water from the exposed side (the side of the wall test sample, during the qualifying fire test) to the unexposed side of the test sample (the side facing the laboratory, with its back to the furnace), as a result of the hose stream test. The foregoing definition of exposed versus unexposed side, is meant to address flat wall test specimens, not 3D fireproofing shapes, such as rated ductwork or circuit integrity fireproofing, whereby the inside of such assemblies, located inside of the qualifying fire-resistance test, may include the inside of enclosures, located inside of the furnace. NOTE: One cannot “frankenstein” tests, or portions of tests together, for interpretations favourable to vendors. As an example, in public domain evidence[93] on the “durabarrier scam”[94], results in the A41 test report[95] therein, apart from other test standard discrepancies cited by UL of Canada in the aforementioned A41 report, it is not possible to assume the hose stream result in this test can be attributed to other tests cited in the public domain folder on the subject. Each test must stand on its own, particularly when the A41 test is the only one that used extra 22-gauge sheet metal flashing whose use is exclusively in evidence in that one test report, as opposed to advertising or installed configurations.
  • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[96], U.S.C. Title 18, §47[97], U.S.C. Title 18, §1002[98], *U.S.C. Title 18, §1018[99], U.S.C. title 18, §1031[100], U.S.C. Title 18, §1343[101], U.S.C. Title 31, §3729[102], Competition Act of Canada, Section VII.1[103], Canada’s Criminal Code Section 380 (1) Fraud[104], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[105].
  • 6.) The temperature on the unexposed side of the wall sample must be equipped with a minimum of 9 (nine) thermocouples, which are covered with defined ceramic fibre[106] (1 of 3 man-made-mineral fibres or MMMFs) pads, sized 6" x 6" x 3/8" or 15 x 15 x 0.95 cm, density 18.7lbs/ft³ or 300kg/m³. The temperature rise on the unexposed side on the average of the minimum 9 thermocouples on a wall sample shall not exceed 139°C (250°F) and no single hot spot is permitted in excess of a heat rise above 181°C (325°F). The nearly identical Canadian test standard CAN/ULC-S101 (metric) (ISO 834 mirrors this) states 140°C and 180°C for average, versus single point hot spot maximum heat rise on the unexposed side of test samples during qualifying fire tests. The point in time at which either or both of those maximum heat rises, above the starting temperature before the fire has begun, is exceeded, that period of time, from the start of the test, to the point in time of thermal failure determines the overall rating of the assembly, unless fire breaks through first, or, deflection exceeds the limit, or unless the hose stream fails, in which case all is null and void. Example: If a wall test sample in a 2-hour fire endurance test, were to have a thermal failure at the 10 or 21-minute point[107], or any point in time less than the overall intended fire-resistance rating, particularly less than the 2 hour recommended rating per NFPA 850 transformer firewalls, there would be no legitimate use in continuing the test once the limiting temperature were reached, even if the sample could, after the fire endurance period, pass the hose stream test, as any single, mandatory criterion amongst the conditions of acceptance for non-loadbearing walls, listed in ASTM E119, CAN/ULC-S101, UL263 and/or NFPA 251, can fail the sample altogether, whereby vendor assertions to the contrary are at odds with standard requirements. NOTE: Temperatures radiated from a test sample to a subjective distance away from the unexposed side, into the laboratory (This has been claimed by vendors using British cavity barriers[108].), are immaterial (though they have been used for promotional purposes, in order to attempt to qualify “cavity barriers” for use in fire-resistance, as defined by the conditions of acceptance per ASTM E119, CAN/ULC-S101, UL 263 and/or NFPA 251.), as the test standards all mandate the temperature be used that is measured by the unexposed side thermocouple, under the thermocouple pad. NOTE: Product testing of British ”cavity barriers” [109] have been used to justify[110] BS476 qualified barriers (using undersized test samples, without mandatory “insulation rating”, without mandatory hose stream test, using more favourable fast response furnace thermocouples, as transformer firewalls, contrary to recommendations in NFPA 850. This is inappropriate for use in this application, including, but not limited to, North America, as BS476 does not have the mandatory hose stream test, the maximum test sample is 9m², which is inadequate (less than the North American minimum of 9.3m² or 100ft², which is important, as test samples typically experience deflection and/or bowing towards the centre of the fire test furnace), and the fast response furnace thermocoupling results in a less severe fire exposure than is mandatory in North America. Further, British ”cavity barriers”, used to separate rated plenums, or outdoor │egress route] egress route extensions[111] not only do not exist in North America, but, in fact, have very limited use in the United Kingdom building construction. NFPA 850] By comparison, transformer firewalls complying with the recommendations of NFPA 850, could be used in place of common, non-loadbearing fire separations in North American building construction, such as a party wall, between apartments or hotel rooms in a high-rise building, with the added benefit of impact resistance. But “cavity barriers” could not be used as common fire barriers in the UK, for example, to separate apartments or different occupancies from one another, without the “insulation rating”. Even outside of North America, neither having a mandatory hose stream test, nor allowing enough heat to penetrate a barrier to risk igniting combustibles on the unexposed side, and running a furnace with fast response thermocouples, resulting in a lower initial thermal shock, are adequate to the task of resisting the extreme oil fires and explosions that can occur with ruptured transformers.
  • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[112], U.S.C. Title 18, §47[113], U.S.C. Title 18, §1002[114], U.S.C. Title 18, §1018[115], U.S.C. title 18, §1031[116], U.S.C. Title 18, §1343[117], U.S.C. Title 31, §3729[118], Competition Act of Canada, Section VII.1[119], Canada’s Criminal Code Section 380 (1) Fraud[120], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[121].

Fragmentation resistance per NFPA 850, in addition to standard fire-resistance ratings for transformer firewalls[edit]

NFPA 850 recommends the following additional test criterion to qualify transformer firewalls for use during a fire event: Where a firewall is provided, it should be designed to withstand the effects of projectiles from exploding transformer bushings and/or lightning arresters].

  • NFPA 850 does not provide a test procedure for this fragmentation of electrical equipment as a result of a transformer explosion, be it protrusions from a transformer, the transformer itself or any permanent or transient materiel, let alone ballistic projectiles. It would stand to reason that fragmentation is a fire event, since there is no explosion without sufficient heat to ignite the transformer oil. Explosions, by definition, involve high heat and flying matter. However, added fragmentation exposures, as well as ballistics, during standardised fire testing is outside of fire test standards as well as fire test laboratory workplace safety requirements. Therefore, the application of fragmentation following the mandatory hose stream test would leave the fire test procedure unaltered and still compliant with this recommendation. Using the wording provided in NFPA 850, the test sample has to resist the effects of the fragmentation, meaning that the fragmentation should not permit the creation of see-through openings in the sample, which would during the course of a fire, permit heat and fire-event projectiles to traverse the barrier. What is missing, however, is data on the size, shape, momentum and number of projectiles to be employed in any qualifying tests, leaving that consideration to the end user, particularly in the absence of a code or Authority Having Jurisdiction (AHJ)].
  • Anecdotal evidence from a transformer fire and explosion at Sinatra station[122], on the Las Vegas strip, indicates flying shrapnel, causing bodily injury[123] as well as debris being thrown onto nearby Interstate 15 freeway, as well as porcelain shards being embedded in a fire barrier[124], which would support the NFPA 850 recommendation above via anecdotal evidence.

Hydrocarbon fire testing[edit]

Why test high-voltage transformer fire barriers to the hydrocarbon UL 1709 time/temperature curve?[edit]

NFPA 850 recommends the use of the cellulosic time/temperature curve, which is over 100 years old, and is based upon burning wood, as that was a predominant building furniture material in buildings, at the time. It is, subjectively, a severe fire test, judging by the looks of many test samples[125] [126]. However, the fuel in transformer fires and explosions, is petroleum-based transformer oil, which is a hydrocarbon. Hydrocarbon fires[127] burn more rapidly and release more heat faster than the same mass of wood. Therefore, a comparison of the ASTM E119 and UL 1709 time/temperature curves suggests the continued use of standard wall fire test procedures in ASTM E119, as recommended in NFPA 850, as this applies to non-loadbearing walls, regardless of which time/temperature curve is employed, but to substitute a hydrocarbon time/temperature curve, because transformers are filled with petroleum-based oil, not wood, which explains the different heat rises for each curve, resulting in a more severe shock on anything in the way of a hydrocarbon fire, including, but not limited to, transformer firewalls.

Nomenclature clarification[edit]

Any reference to hydrocarbon fire testing, particularly in North America, implies the use of the UL 1709 time/temperature curve, which inherently also implies the use of UL 1709’s provisions or furnace instrumentation, which mirrors that of ASTM E119. In France, and French-influenced countries, it could also mean the use of the modified French hydrocarbon curveCite error: Closing </ref> missing for <ref> tag</ref>, using fast response furnace thermocouples. A compensatory laboratory measure for the use of slower, shielded thermocouples, with rapid heat rise time/temperature curves, can be to use garbage bags filled with fuel-soaked rags, inside the furnace chamber, in order for the furnace to perform as per standard, particularly early in the test, when a very high temperature must be reached very quickly, in an ambient temperature furnace. Where any walls are concerned, including high-voltage transformer fire barrier walls (ballistic and explosion resistant or not), particularly with the use of the terms “fire-resistance or “fire-resistant”, what is inherently impliedCite error: Closing </ref> missing for <ref> tag</ref> in North America, is the use of one of the identical fire test standards that are used to evaluate non-loadbearing-wall assemblies, including and limited to NFPA 251, ASTM E119, UL 263, and/or CAN/ULCS101. European standards, such as ISO 834, DIN 4102, BS476, that exclude the (mandatory in North America) hose stream test and rely on fast response thermocouples (not permissible in North America) for furnace instrumentation, cannot be implied under the terminology of “fire-resistance” or “fire-resistant” for North America, and would have to be very explicitly outlined in order to comply with Canada’s Competition Act, Section VII.1, Deceptive Marketing PracticesCite error: Closing </ref> missing for <ref> tag</ref>, whereby Part VII.1 (sections 74.01 to 74.19) of the Competition Act deals with deceptive marketing practices, and 15 U.S. Code § 45 - Unfair methods of competitionCite error: Closing </ref> missing for <ref> tag</ref>, which states ’“Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful”. Specifically, BS476, Part 20, 1987 makes the “insulation rating” optional (which is never the case in North American wall fire test standards, and is also not permitted in the UK outside of “cavity barriers”, which do not exist in North America. By comparison, an ASTM E119 2-hour rated non-loadbearing wall complying with the recommendations of NFPA 850 would also qualify for use as an apartment party or a corridor wall in a high-rise in North America. But, a BS476 qualified cavity barrier, without the “insulation rating”, would NOT be permitted for use in indoor corridors or to separate apartments or occupancies in the UK.). BS476 also permits the lab’s use of “depth gauges” to measure maximum gaps in a fire barrier that may develop as a result of fire test exposure. Such practices are not permitted in any North American wall fire test standards. Obviously, a gap would fail the mandatory hose stream test and could let fire and products of combustion through. Therefore, a North American high-voltage transformer fire barrier, advertised as a hydrocarbon firewall or hydrocarbon fire barrier, implies the use of a North American wall fire test standard, whereby the test sample is exposed to the UL 1709 time/temperature curve, substituting the cellulosic curve, using shielded furnace thermocouples, in a calibrated furnace, and satisfying the conditions of acceptance in ASTM E119, NFPA 251, UL 263, and/or CAN/ULCS101 for non-loadbearing walls, which includes mandatory “insulation” (in British parlance, no heat rise above 139/181°C above ambient at the start of the test) and hose stream test passing performance.

Running a test per cellulosic curve, but calling it hydrocarbon, or running an outdoor test, where the heat can vent to the atmosphere, instead of being trapped in a calibrated furnace, per standard, or any other combination/deviation from an accredited standard test protocol, particularly when citing standards, even when using the term “ad hoc”, for later use as a legal defence, or, in other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §47Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1002Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1018Cite error: Closing </ref> missing for <ref> tag, U.S.C. title 18, §1031Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1343Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 31, §3729Cite error: Closing </ref> missing for <ref> tag, Competition Act of Canada, Section VII.1Cite error: Closing </ref> missing for <ref> tag, Canada’s Criminal Code Section 380 (1) FraudCite error: Closing </ref> missing for <ref> tag, and Canada’s Criminal Code, Section 436 (1) Arson by negligenceCite error: Closing </ref> missing for <ref> tag.

Concrete used as transformer fire barrier[edit]

Cast concrete is an effective fire barrier in building construction, whose fire exposure is, primarily, limited to cellulosic design fire time/temperature curve (ASTM E119, ULC-S101, UL 263, NFPA 251, ISO 834, BS476, DIN 4102 are all based on burning wood)] exposures. Evidence of this is plentifulCite error: Closing </ref> missing for <ref> tag. This does not mean that concrete of any mix design inherently achieves unlimited fire-resistance, in all situations without careful consideration of multiple factors. Expert help is available from the Portland Cement Association. For example, polypropylene fibresCite error: Closing </ref> missing for <ref> tag have been proven to mitigate heat (including hydrocarbonCite error: Closing </ref> missing for <ref> tag) induced concrete spallingCite error: Closing </ref> missing for <ref> tag. The types of aggregate used in concrete can affect fire-resistanceCite error: Closing </ref> missing for <ref> tag. The amount of moisture in concrete is known to affect fire-resistanceCite error: Closing </ref> missing for <ref> tag. Also, typically, cementitious products, including, but not limited to, concrete slabs, as test samples, in fire test laboratories, are equipped with moisture probes and ordinarily not subjected to fire testing unless the test sample’s relative humidity is at or below 75%, due to the potential effects of explosive spallingCite error: Closing </ref> missing for <ref> tag inside an operating laboratory. Further, ASTM E119 indicates, that, prior to fire-resistance testing, test specimensCite error: Closing </ref> missing for <ref> tag are to be conditioned with the objective of providing a moisture condition, within the test specimen, representative of that in similar construction in buildings, whereas transformer fire barriers are outdoors and subject to the weather, where internal moisture rises and falls with the surrounding environment. Consequently, the moisture condition at the time of the qualifying test may be at cross-purpose with concrete used outdoors for fire-resistance reasons, particularly if explosive spalling, which can come about as a result of moisture within the wall, can defeat that wall. This phenomenon is not unique to concrete products in buildings. Even cementitious refractory castablesCite error: Closing </ref> missing for <ref> tag require countermeasures to prevent explosive spallingCite error: Closing </ref> missing for <ref> tag. Why does this comparison between common concrete and refractory castables matter? (1.) A more heat-resistant cement is used in refractories, compared against common construction, using concrete bound by Portland cement, obviously, to line the inside of commercial furnaces. (2.) Probability matters: The probability of fire exposure with commercial furnaces is 100%. The probability of a transformer fire/explosion/ballistic attack, is certainly below 100%. In furnace lining, the luxury to disregard a self-defeating moisture level inside of refractory castables that is known, when excessive, to cause explosive spalling does not exist. Consequently, a whole sub-industry exists to safely dry out cast refractory concretesCite error: Closing </ref> missing for <ref> tag. Technically, the need to dry cast concrete, regardless of whether it is bound by Portland cement, or, the more heat-resistant, calcium aluminate cement, to lower the moisture level, to prevent explosive spalling, is known and well established. Practically, it is something that needs to be taken into account for design purposes, so as to avoid catastrophic errors, made inevitable by high humidity or rain, in the case of outdoor transformer firewalls made of concrete. Expert advice is available from the Portland Cement Association. For purposes of standardisation, in fire testing, the following condition is established at equilibrium resulting from conditioning in an ambient atmosphere of 50 % relative humidity at 22.8°C or 73°F. There is public domain video evidence on concrete spalling when exposed to high temperatures, which happens when the moisture level is correct. When the moisture is too high, where a laboratory declines to run the test, on account of workplace safety regulations and procedures, spalling is more likely. Both the amount of free water, which could evaporate out, in hot and dry conditions, and/or from the heat of hydrationCite error: Closing </ref> missing for <ref> tag, and the concentration of hydrates play a role in concrete's reaction to fireCite error: Closing </ref> missing for <ref> tag whereby hydrates, which form part of the cement stoneCite error: Closing </ref> missing for <ref> tag, can break down beginning at 300°C or 572°F. The binder used also makes a difference, whereby calcium aluminate cements are, broadly, used in refractory castables. Just because a calcium aluminate cement is used in a concrete mix design, however, does not mean that there aren't important design considerations, as free water (not bound as hydrates in the cement stone) and hydrates are considered here too, to prevent spalling. In fact, it is customary for freshly placed castables to be subjected to a certain heating regime, which can come in the form of sub-contractors, blowing heat into the furnace, separate and apart from the inherent heating system routinely employed in operating commercial furnaces, in order to prevent explosive spalling as a result of heat exposure. Apart from moisture-based spalling, there is also the process of "conversion", whereby concrete made with calcium aluminate cement first gains significant strengthCite error: Closing </ref> missing for <ref> tag, but then loses some of it in the conversion processCite error: Closing </ref> missing for <ref> tag. Specific to qualifying transformer fire barriers, it is prudent for the designer/end-user/consultant in charge to be aware whether the inevitable reduction of strength that results from conversion of calcium aluminate cement bound concrete was taken into account during qualifying tests. The aforementioned fire test standards do not take a conversion process into account, presuming that full strength of cementitious products is reached within 30 days of placement. It is, therefore, possible, in qualifying a transformer fire barrier wall system, bound with calcium aluminate cement, to be in compliance with applicable fire test standards, and if the moisture comes down sufficiently, before conversion (strength reduction) has set in, the test sample being tested may be tougher than what is installed in the field, post-conversion, meaning the qualifying test would be compliant with standards, and, at the same time, unfairly favourable to the product being tested, at the same time. Incorrect use of calcium aluminate cements (typically based on the flaw of presuming the pre-conversion compression strength remains) in construction has led to widespread problems, especially during the third quarter of the 20th century when this type of cement was used because of its faster hardening properties. The problem here was the false assumption that the pre-conversion strength was the final compression or "cold crushing" strength. After several years, some of the buildings and structures collapsed due to degradation (conversion) of the cement and many had to be torn down or reinforced. Heat and humidity accelerate the conversion processCite error: Closing </ref> missing for <ref> tag. In Madrid, Spain, a large housing block nicknamed Korea (because it was built to house Americans during the Korean War), built 1951~1954 was affected and had to be torn down in 2006Cite error: Closing </ref> missing for <ref> tag. Also, in Madrid, the Vicente Calderón Stadium was affected and had to be partially rebuilt and reinforced. While NFPA 850 refers to analytical methods used to determine fire-resistance ratings of concrete structures, one must bear in mind that this refers back to building codes, which are based upon fires in relatively dry buildings. Outdoor transformer fire barrier design based on concrete, regardless whether the binder is Portland or calcium aluminate cement, must take into account moisture conditions both in terms of free moisture and hydrates. In other word, could a full-scale test sample pass dry, as well as wet? Simply substituting binders to refractory binders, does not eliminate the ASTM E119 requirements concerning sample conditioning. This means that one rainfall or high humidity, even with post cure heat treatment of calcium aluminate cement bound concrete, can affect fire-resistance. Painting the concrete does not eliminate the moisture vapour transmission rate (or steam diffusion) and may just lock in moisture that can exacerbate spalling. As an example, a 4-1/2" or 114mm thickness of cast concrete, with siliceous aggregate, with low moisture, complying with ASTM E119 sample conditioning provisions, is known to defeat a 2-hour ASTM E119 fire testCite error: Closing </ref> missing for <ref> tag. However, any spalling can reduce thickness and thus negate the fire-resistance rating. Spalling can also lead to catastrophic failure, as opposed to being limited to a reduction in thickness. Further, there is still the fire-event fragmentation, as well as ballistic resistance and timing, to be considered as well, as its test sequencing. It is possible to overcome the technical challenges. In order to do so, one must take all factors into account, or use a certification listed system, that can be verified to have taken the aforementioned factors into account.

Ballistic resistance[edit]

Increasingly, since widely publicised ballistic attacks on electrical substations containing petroleum-based transformer oil and polychlorinated biphenyl (PCB) filled high-voltage transformers, utilities, require ballistic protection of their high-voltage transformer fire barriers. This can have two reasons. First, as mentioned above, there is public domain record of physical (not limited to cyber) attacks upon substations. Secondly, since NFPA 850 indicates, and anecdotal evidence in the public domain supports the possibility of fragmentation from bushings and lightning arresters, which form part of the transformer, one could argue that a ballistic test, when combined with a fire test upon the same sample, or a component thereof, could simulate fire-event fragmentation. Both scenarios have validity, at least until NFPA adds a specific test regime or performance requirement for firewall resistance to fragmentation. Whether to defeat ballistic sabotage or transformer fragmentation, either the fire barrier has inherent ballistic resistance properties, or it is added on by means of armour, whose addition to a fire barrier must be included at the time of the qualifying fire test, as all wall fire test standards require (for example §5 of ASTM E119) that test samples resemble the end-use configuration, as any additions or deletions can alter test results. For example, lightweight armour, such as Kevlar may not be able to pass (and thus require test evidence to prove non-combustibility) ASTM E136 Standard Test Method for Assessing Combustibility of Materials Using a Vertical Tube Furnace at 750 °C[128], or CAN/ULC-S114 Standard Method of Test for Determination of Non-Combustibility in Building Materials[129] (which, along with similar standards in industry and building code use) defines the term “non-combustible”), using covalently bound materials and fibres, which can add fuel and heat to a fire (bearing in mind that wall fire tests are not based on direct flame impingement, but, instead heat from the fire that stops short of the test sample), whereas steel armour, when exposed to heat, will first expand[130] and then collapse[131], is fireproofed in building and maritime construction, in order to comply with building codes and regulations. Vehicle armour, traditionally, has to consider trade-offs between resistance and weight. For a static wall, keeping the weight low, is less important than for armoured fighting vehicles, where every pound of added weight affects range and cargo carrying capacity. Also, a transformer fire barrier is not ordinarily designed to defeat artillery, let alone missile attacks[132], whereas a main battle tank or a bomb shelter would be. However, particularly in subsequent installations, where adding the protection is an afterthought, rather than forming part of the original design, there is an incentive to keep barriers as small and modular as possible whilst defeating the given requirements of fire, fragmentation and ballistics, simply due to spatial geometry and the need to perform electrical installation and maintenance work in confined spaces. Particularly for added (to fire barriers) armour, as opposed to inherent impact resistance, as a characteristic of a fire-resistive wall system, such as high strength low alloy steel, or rolled homogeneous armour (RHA), or even combustible armour materials, such as composite materials including, but not limited to, Kevlar, it is important not only to include such components in qualifying fire tests, as they can fundamentally alter fire-resistance performance, but to consider the test sequencing (Which comes first? Bullet/explosion/shock-wave/shrapnel/fire?). In the case of steel armour, this would need to be fireproofed, like all structural steel is for fire-resistant applications. If not, when exposed to fire, steel first expands and then loses its strength, which can cause damage. In the case of combustible materials added for ballistic resistance, meaning materials that do not pass ASTM E136[133] these can add fuel to a fire, which increases the likelihood of failure, as part of a fire-resistant assembly, that should not burn from the inside or on the unexposed side, due to heat transfer and autoignition/spontaneous combustion. Therefore, added ballistic resistance without being included in the qualifying fire and hose-stream testing, can have a deleterious effect, defeating the purpose of the barrier.

  • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[134], U.S.C. Title 18, §47[135], U.S.C. Title 18, §1002[136], U.S.C. Title 18, §1018[137], U.S.C. title 18, §1031[138], U.S.C. Title 18, §1343[139], U.S.C. Title 31, §3729[140], Competition Act of Canada, Section VII.1[141], Canada’s Criminal Code Section 380 (1) Fraud[142], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[143] .

Ballistic testing[edit]

Internationally, there is a variety of ballistic resistance test standards. For North America, product certification is available from the two primary fire testing and certification organisations using the ballistic resistance test standard UL 752 Standard for Bullet Resisting EquipmentCite error: Closing </ref> missing for <ref> tag. Another popular North American standard in the realm is NIJ 0108.1Cite error: Closing </ref> missing for <ref> tag</ref>. Those two organisations are UL LLC and Intertek, who are both accredited, meaning both UL LLC and Intertek are subject to audit by the American National Standards Institute (ANSI) and the Standards Council of Canada (SCC). This combination of organisations that perform both fire testing and ballistic testing is desirable, simply because the certification mark on the product (in the event the test sponsor/manufacturer has elected to engage and has earned and maintains certification, meaning that he or she is under regular audit to ensure what is made for sale is identical to that which is sold and installed, provided the certification mark is visible on the product) indicates compliance. No certification organisation can guarantee these procedures to be followed 100% at all times by a listee or client. Theoretically, it is possible to game the system. However, there are significant negative consequences to getting caught, such as the forced removal of labels, public notification and legal exposure. Both the Thermo-lag scandal and durabarrier scam are examples where certification was not mandatory, and utilities relied on the use of test reports on the installed configuration, which entailed customer judgements of test reports for bounding purposes (making sure the installed configuration fell within the evidentiary limits of each test report. When there is no certification mark on the product installed in the field, visible upon inspection of the installed configuration, there is no third-party evidence that what is installed is identical to that which passed testing. UL 752 Standard for Bullet Resisting Equipment requires ballistic testing in a calibrated shooting range, with samples measuring 12” x 12” or 30 x 30cm, as well as the use of a calibrated gun chronograph and a firearms test receiver that different rifles, or tubes, can be mounted to, in order for one device to be able to simulate all weapons listed in a standard such as UL 752. UL publishes such certification listings via Guide CNEX, which is accessible once logged in to UL’s website. Intertek describes its UL 752 Standard work onlineCite error: Closing </ref> missing for <ref> tag</ref>, as performed by its ballistic laboratory in York, Pennsylvania. Legitimate testing per UL 752 Standard for Bullet Resisting Equipment requires the use of test samples conforming to the standard, sized correctly and, where necessary, tested at three different temperatures, in a calibrated shooting range by a qualified ballistic technician. Certification mark use on the product installed in the field enables inspectors and end-users to have verification that the item tested was identical to the item being sold and used. Outdoor test samples shown in advertising, outside of the normal shot pattern shown inside of the test standards, with ballistic resistance testing samples outside of the parameters dictated by the test standard, particularly without the use of the certification mark, visible on the product on the installed configuration, may be indicative.

*In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §47Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1002Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1018Cite error: Closing </ref> missing for <ref> tag, U.S.C. title 18, §1031Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1343Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 31, §3729Cite error: Closing </ref> missing for <ref> tag, Competition Act of Canada, Section VII.1Cite error: Closing </ref> missing for <ref> tag, Canada’s Criminal Code Section 380 (1) FraudCite error: Closing </ref> missing for <ref> tag, and Canada’s Criminal Code, Section 436 (1) Arson by negligenceCite error: Closing </ref> missing for <ref> tag.

Testing sequence[edit]

Since UL 752 ballistic test samples measure 12" x 12" (=1 ft²) or 304.8mm x 306.8 mm (=0.0929m²), and any legitimate wall fire-resistance test sample is minimum 100ft² or 9.3m², and since legitimate, compliant, ballistic testing must occur in a calibrated shooting range, into which one cannot fit a full scale wall fire test sample, and fire test laboratories cannot, for occupational safety and health reasons, permit gunfire, testing of fire-resistance and ballistic resistance must occur on separate samples, or be out of compliance with something. Alternatively, a section of one sample can be incorporated in the other, such as a ballistic sample can be used inside of the fire test sample, or a piece of fire test sample can be cut out after the fire test and be subjected to ballistic testing, or both, subject to laboratory consent with a laboratory rationale for the sample integration and sequencing stated in the report and/or listing. For the combination between fire-resistance materials with ballistic resistance materials to be meaningful, whereby one must not defeat the other, common sense dictates that adding fire-resistive materials to a ballistic resistive material can only improve ballistic resistance, since there would be more material in the way of projectiles. The opposite, however, is not necessarily true. Lightweight, covalently bonded armour composite materials can add fuel to a fire. This is important, because qualifying wall fire tests do not permit the fire to touch the sample. In ASTM E119, NFPA 251, CAN/ULC-S101 and/or UL 263 testing of nonloadbearing walls, the fire stops short of the sample by design. Therefore, fuel (in the form of added covalently bound armour) used in, or on, a rated assembly without having been included, at the time of the qualifying test, negates results, as does any change from the tested configuration. Rolled homogenous armour (RHA), or high strength low alloy steel, both require fireproofing in order to retain original load carrying capacity and shape, when exposed to the heat of a cellulosic or hydrocarbon fire. In fact, the expansion of heated steel armour, while attached to a weaker fire-resistive material, or system, can tear its attached fire barrier apart, unless a test bounding the final configuration resulted in a positive outcome, ideally backed by a certification listing and certification marks on the installed configuration in the field, enabling inspectors to ascertain compliance immediately, simply by checking the active listing online. Therefore, any armour materials, both combustible and non-combustible (preferably determined by ASTM E136Cite error: Closing </ref> missing for <ref> tag</ref>, added to a fire-resistive assembly must be included at the time of the qualifying fire test, pursuant to ASTM E119, UL263, CAN/ULCS101 and/or NFPA 251, in order to provide evidence that the complete system meets the conditions of acceptance for nonloadbearing walls. One may also, subsequently, expose 12" x 12" or 30 x 30 cm samples of the combined ballistic and fire-resistive layers in order to take advantage of the added ballistic resistance offered by the fire-resistive materials. If the fire barrier material itself were used to defeat ballistic threats and were reduced in thicknessCite error: Closing </ref> missing for <ref> tag (and that whole thickness were required to pass the fire test) at the point of projectile impact, then, due diligence requires that the overall thickness and/or configuration needs to be considered if the barrier must simultaneously defeat fire, fragmentation (fragmentation may occur as a result of projectile impact both from a bullet as well as porcelain shards or other shrapnel originating from exploding transformers) and ballistics (if a defined ballistic resistance forms part of a contract requirement). As an example, if a 2" or 5cm thick precast concrete panel passed a UL 752 ballistic resistance test, but were reduced in thickness below the thickness necessary to achieve the mandated fire-resistance ratings, then the projectile impact reduced thickness of that barrier must be evaluated to simultaneously defeat all threats.

*In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §47Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1002Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1018Cite error: Closing </ref> missing for <ref> tag, U.S.C. title 18, §1031Cite error: Closing </ref> missing for <ref> tag, U.S.C. Title 18, §1343Cite error: Closing </ref> missing for <ref> tag, *U.S.C. Title 31, §3729Cite error: Closing </ref> missing for <ref> tag, Competition Act of Canada, Section VII.1Cite error: Closing </ref> missing for <ref> tag, Canada’s Criminal Code Section 380 (1) FraudCite error: Closing </ref> missing for <ref> tag, and Canada’s Criminal Code, Section 436 (1) Arson by negligenceCite error: Closing </ref> missing for <ref> tag.

Fragmentation, shock wave and ballistic resistance testing[edit]

STANAG 4569, level 1, may be used on a full-scale wall sample in advance of fire testing, depending upon access to the test range, which may require some disassembly and re-assembly of wall modules. Importantly, shock tubes only test the shock wave impact, but no heat, or shrapnel impact, both of which ordinarily result from a fire or explosion, whereby either one can cause the other.

Test sequencing[edit]

There are arguments for and against performing a qualifying fragmentation test before or after the fire test. This is similar to fire testing asymmetrical wall assemblies: It is next to impossible to guarantee which side a fire will come from, much later, in practical use, as conditions change. Consequently, both sides are tested. Whether the threats in addition to fire are fragmentation (recommended to be included by NFPA 850), shock waves or ballistics, due diligence would consider any of the threats to precede another, since one threat can cause another and it is difficult to predict which will come first in practical use. It is prudent to look at all product testing, and, preferably, the certification listings earned, to see the synergistic effects. For example, a steel armour plate may pass a ballistic test but may exhibit plastic deformation at the point of projectile impact[144]. While that plate may pass the ballistic test, the plastic deformation could knock loose fire-resistive material (particularly, though not exclusively, once stressed by fire, regardless how tough it seems at room temperature) it is in contact with and thus degrade or delete the overall system’s fire-resistance rating, thus defeating the entire point of the exercise. One of the considerations must be whether the fire-resistive barrier exhibits inherently sufficient fire-event fragmentation resistance without requiring an added layer for resisting airborne fragments or projectiles, or whether the fragmentation resistance is added on to a fire-resistive material. Either way, both must be included in fire testing, for the same reasons to do this with ballistic resistance materials, which may be one and the same, such as covalently or ionically bonded impact-resistance products. If a barrier is first exposed to fire, which has a deleterious effect, especially when combined with the mandatory hose stream testing, a metallic armour plate may have lost its strength, if it was not sufficiently fireproofed, meaning that its ballistic resistance rating, once exposed to elevated temperatures, may be seriously degraded and will at the very least be outside of its ballistic resistance certification listing bounding, which only covers temperature ranges, per UL 752 Standard for Bullet Resisting Equipment, of -32°C (-25.6°F), +20°C (68°F) and + 49°C (120.2°F) (compared to fire testing, which goes up to ca. 1100°C, depending on the duration of the test, maximum 1,350°C for tunnels). A covalently bound armour material may in fact melt and/or burn as a result of exposure in an ASTM E119 fire test, which could have a disastrous effect on a fire barrier not listed as such in the installed configuration. Combining materials, just because they can individually pass testing to one standard, does not necessarily mean, that, when combined with another material, that has passed a different standard, that the sum of the parts will defeat testing to both standards simultaneously. The conservative approach would be to require a combined ballistic/fragmentation and fire-resistive barrier to undergo fire and hose stream testing first, and then to also defeat bullets and/or flying debris. If materials that are only individually tested, separately, concerning fragmentation, ballistics, fire and hose stream, the combination would violate individual certification listings and claims or implications for such systems to meet all sets of requirements without having been tested together may be subject to interpretation in terms of the Competition Act Part VII.1, Deceptive Marketing Practices and/or Title 15 of the U.S. Code §45, which states "Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful.” Concerning the use of structural steel, which is identical to armour plating made of rolled homogenous armour (RHA) or high strength low alloy steel, in terms of fire-resistance, it is in consideration of the reaction of unprotected steel to fire that ASTM E119 requires the instrumentation of structural steel components in fire-resistive fire test sample assemblies, to determine the point in time, at which such steel components exceed a heat rise above 538°C or 1,000°F[145], above ambient, before the fire test has begun, as this has an effect upon the overall system. Consequently, the point that such temperatures upon steel have been exceeded, which is minutes into a fire test, if there is no fireproofing of the steel, be it armour, or otherwise, is the point in time when loaded assemblies have failed. On the way towards reaching this fire test failure point, steel expands, which can cause damage to items attached to it, such as passive fire protection materials. Such a measurement is not required for non-bearing assemblies, such as transformer fire barriers. But that does not mean that steel added on without fire testing the field-installed configuration can be done without affecting the validity of the qualifying testing, let alone certification listings. For that reason, ASTM E119 states (as do NFPA 251, UL 263 and CAN/ULC-S101), that the test specimen must be identical to the installed configurations, with every aspect of it recorded in the test report.

  • In other words, “frankensteining” installed configurations by adding or deleting, without appropriate test back-up, outside of certification listed bounding of the installed configuration, and implying non-existent compliance, risks inviting legal exposure to violating U.S.C. Title 15, §45[146], U.S.C. Title 18, §47[147], U.S.C. Title 18, §1002[148], U.S.C. Title 18, §1018[149], U.S.C. title 18, §1031[150], U.S.C. Title 18, §1343[151], U.S.C. Title 31, §3729[152], Competition Act of Canada, Section VII.1[153], Canada’s Criminal Code Section 380 (1) Fraud[154], and Canada’s Criminal Code, Section 436 (1) Arson by negligence[155].

Modularity[edit]

Modularity is offered by some of the North American transformer firewall product vendors in the realm. Modularity enables changes, for example, when one transformer ruptures, damaged wall segments can be replaced, presuming the original equipment vendor is still in business, work can proceed without complete destruction, or, if a transformer were equipped with sensors to enable a monitoring programme to judge the fitness of the transformer and/or its bushings, and the maintenance decision were to replace the transformer, then room can be made for such work by temporarily removing wall segments that are in the way of work, during an outage. As with all such changes, similar to firestops or any passive fire protection systems, it is prudent to be able to demonstrate in advance of the qualifying fire/blast/fragmentation/ballistics and fire testing, that initially installed segments can be demounted and then re-installed, following the manufacturer's instructions and then still pass the required qualifying tests. Typically, manufacturer's instructions accompany test reports and technicians' notes, at laboratories nationally accredited for fire testing and product certification, such as UL LLC, Intertek and Southwest Research Institute, before public domain certification listings are issued. If the intention of proving modularity exists in advance of the fire test, the instructions for de-mounting and re-assembly are typically followed through before the fire test, particularly if the test is intended to result in a certification listing, which results in the ability to use the laboratory's certification mark on the product, as opposed to testing for information purposes only, which does not entail third party assurance that the item tested is identical to the item sold and installed, in the absence of the certification label's being visible on the installed configuration as verifiable proof of compliance, pointing to the certification listing upon which the installation and local approval is based. Not using listed and labelled safety products results in reliance on vendor ethics, and, in the event of a claim, and that this vendor is still in business, civil remedies, considering higher due diligence is possible by means of ensuring listing bounded installed configurations.

Alternatives or enhancements to transformer fire barriers[edit]

The following may be used in place of or in addition to transformer fire barriers, depending on the design goals. They are not necessarily, however, compensatory measures against ballistic attacks or other sabotage.

Spatial separation[edit]

Transformers may be placed far enough apart, given available space, such that the rupture of one may not affect its neighbouring transformer(s).

Automatic fire suppression[edit]

Fire sprinklers may be used to cool a transformer prior to a rupture[156], if set off by a fire. One design consideration is that the causal event of a transformer rupture lies within the equipment, meaning the outer walls of a transformer are in the way of water or other extinguishing media, whereas the sprinkler piping may be in the way of an explosion. There is also the consideration of any potential spread of toxins, such as polychlorinated biphenyl (PCB), with added water spray, under high pressure.

Alternatives to petroleum-based transformer oil[edit]

Transformer oil is available in different levels of ignitability, including those approved by FM Global. FM Data Sheet 5-4[157] indicates different levels of protection depending on the type of fluid used. Less flammable alternatives include, but are not limited to, esters (vegetable oil)[158] and silicone oil[159].

Automatic transformer and bushing monitoring and instrumentation[edit]

Electronic measures by means of strategic instrumentation[160] may be used to detect and prevent surges leading to fires. This simulates information relayed about automotive brakes to drivers by sound and vibration. In the case of automotive brakes, it becomes clear, simply by driving, when automotive brake repairs are necessary. In the case of outdoor, unmanned transformers, there is nobody who can hear or feel when a transformer is in need of maintenance. Consequently, transformer vendors typically offer optional instrumentation packages including sensors mounted at locations inside transformers and bushings, complete with software, which can be used to inform preventive maintenance.

The Cavity Barrier Trick – and its use in rated pressurisation ductwork, as well as transformer fire barriers[edit]

British cavity barriers[161] are intended, under British building regulations, for specific purposes, including sub-dividing rated plenum spaces and outdoor extensions of egress routes. This is a very limited field of use, compared against common walls or floors required to have a fire-resistance rating, whereby the British standard BS476 used to sub-divide ratings into “stability”, “integrity” and “insulation”, whereby stability and integrity were combined, only singling out “insulation”, meaning, that, for cavity barriers only, it was permissible for the heat of a fire to transmit through to the unexposed side without restriction. A party wall, for example, separating 2 apartments, or hotel rooms, or occupancies (meaning types of building use, such as a nursery on one side and a retail shop on the other), in the UK, would not be allowed to be accomplished by means of using a cavity barrier without the “insulation” portion of the rating. There are no cavity barriers in North American building regulations. Thermal performance cannot be separated from other aspects of a rating per ASTM E119, NFPA 251, UL 263 or CAN/ULC-S101 (all of which have the same provisions for non-loadbearing walls, such as transformer firewalls). Also, the hose stream test is mandatory per the aforementioned North American standard, and cannot, identically to other portions of the conditions of acceptance, be “frankensteined” from one test to another. BS476 permits the use of 9m² sample size, which is less than the 9.3m² or 100ft² minimum in North America. Additionally, BS476 permits the use of fast response furnace thermocouples, which demonstrably results in a lesser thermal shock, compared against North American testing to its domestic standards. BS476 permits the use of “depth gauges”, which are used in the event a gap develops in the test sample, through which depth gauges can be inserted up to a maximum dimension. Any such gaps, forming within a wall fire test sample, as a result of fire exposure, would defeat fire test samples in North America. Still, this British nomenclature of “stability”, “integrity” and “insulation”, have been central to efforts to sell not only transformer fire barriers, but, also, to advocating the use of 3D version of cavity barriers in pressurisation ductwork[162], which neglects to protect critical life safety pressurisation fans, whose function, under fire conditions, is the purpose of pressurisation ductwork.

Definitions and External links[edit]

Category:Passive fire protection

Category:Fraud

Category:Electricity

Category:Infrastructure

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  12. "Over 1,500 California fires in the past 6 years — including the deadliest ever — were caused by one company: PG&E. Here's what it could have done but didn't".
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  16. "NFPA 5000 Building Construction and Safety Code".
  17. "UL 1709 Standard for Rapid Rise Fire Tests of Protection Materials for Structural Steel".
  18. "YouTube video on ASTM E119 Fire Tests of Building Construction and Materials".
  19. "ISO 834 Part 8 Fire-resistance tests — Elements of building construction — Part 8: Specific requirements for non-loadbearing vertical separating elements".
  20. "DIN 4102 Brandverhalten von Baustoffen und Bauteilen".
  21. "BS476 Fire tests on building materials and structures".
  22. "UL 1709 Standard for Rapid Rise Fire Tests of Protection Materials for Structural Steel".
  23. "Underwriters' Laboratories of Canada".
  24. "Heat exposure in fire resistance test furnaces controlled by plate thermometers and by shielded thermocouples Sultan, Mohamed A. – The use of shielded furnace thermocouples results in a more severe heat exposure at the beginning of the test, compared to using plate thermometers".
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  34. "CAN/ULCS101 Standard Methods of Fire Endurance Tests of Building Construction And Materials, Fifth Edition".
  35. "NFPA 251 Standard Methods of Tests of Fire Resistance of Building Construction and Materials".
  36. "Authority Having Jurisdiction (AHJ)".
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  63. "Fire Test Research Engineer Mr. Herbert Stansberry".
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  71. "U.S.C. Title 31, §3729 False claims".
  72. "Canada's Competition Act VII.1" (PDF).
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  74. "Canada's Criminal Code, Section 436 (1) Arson by negligence".
  75. "UL 1709 Standard for Rapid Rise Fire Tests of Protection Materials for Structural Steel".
  76. "Heat exposure in fire resistance test furnaces controlled by plate thermometers and by shielded thermocouples, Sultan, Mohamed A."
  77. "Thermal Science Inc. (TSI)".
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  80. "Bloomberg listing of Omega Point Laboratories, now Intertek".
  81. "Fire Test Research Engineer Mr. Herbert Stansberry".
  82. "Dr. Mohamed A. Sultan, of the National Research Council of Canada, published a study on the use of shielded versus plate furnace thermometers, confirming the findings of Engineer Herbert Stansberry in the US Government's case against Thermal Science Inc.(TSI), in the Thermo-Lag Scandal, brought to light by whistle blower Gerald W. Brown".
  83. "U.S.C. Title 15, §45 Unfair methods of competition unlawful; prevention by Commission".
  84. "U.S.C. Title 18, §47 Fraud and False Statements".
  85. "U.S.C. Title 18, §1002 Possession of false papers to defraud the United States".
  86. "U.S.C. Title 18, §1018 Official certificates or writings".
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  95. "A41 test report".
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  98. "U.S.C. Title 18, §1002 Possession of false papers to defraud the United States".
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  102. "U.S.C. Title 31, §3729 False claims".
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  123. "Sinatra station fire article: Transformer explosion injures 2 in Las Vegas. Two people on the street were taken to a local medical centre with shrapnel wounds and smoke inhalation".
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  142. "Canada's Criminal Code Section 380 (1) Fraud".
  143. "Canada's Criminal Code, Section 436 (1) Arson by negligence".
  144. "Wikimedia commons image showing plastic deformation of a high strength low alloy steel UL 752 test sample. The point here, is that plastic deformation of a ballistic material while in direct contact with a passive fire protection material may have an effect upon fire-resistance of the overall configuration".
  145. "American Institute of Steel Construction, 11.4 Fire Ratings".
  146. "U.S.C. Title 15, §45 Unfair methods of competition unlawful; prevention by Commission".
  147. "U.S.C. Title 18, §47 Fraud and False Statements".
  148. "U.S.C. Title 18, §1002 Possession of false papers to defraud the United States".
  149. "U.S.C. Title 18, §1018 Official certificates or writings".
  150. "U.S.C. title 18, §1031, Major fraud against the United States".
  151. "U.S.C. Title 18, §1343, Fraud by radio, wire or television".
  152. "U.S.C. Title 31, §3729 False claims".
  153. "Canada's Competition Act VII.1" (PDF).
  154. "Canada's Criminal Code Section 380 (1) Fraud".
  155. "Canada's Criminal Code, Section 436 (1) Arson by negligence".
  156. "LinkedIn article: Transformer fire suppression systems, oil and water don't mix".
  157. "FM Property Loss Prevention Data Sheet 5-4" (PDF).
  158. "International Research Journal of Engineering and Technology (IRJET); A Review on Utilization of Vegetable Oils as Transformer Oils. Authors: Ritu Patel, Anil Brahmin, Simardeep Kaur" (PDF).
  159. "End of an Era for Silicone Transformer Fluids? Author: Darrell Proctor, from powermag.com".
  160. "Design and implementation of real time transformer health monitoring system using GSM technology, from IEEE".
  161. ""Cavity barriers", per Lawinsider.com".
  162. "YouTube video entitled: Debunking ISO 6944 and ASTM E2816 - Considerations for AHJs in permitting shaft alternates per IBC. Duct fireproofing to ISO 6944 & ASTM E2816 has been used in buildings under the "alternates" process - alternates to systems tested to ASTM E119, UL263, CAN/ULC-S101 & NFPA 251. The actual use is for pressurisation ductwork. This actual use for pressurisation ductwork is not always clearly identified in the standards themselves or in marketing information. But it is on construction sites. Since smoke exhaust ductwork is typically return air ductwork, which has no requirement for fireproofing, that leaves pressurisation. There are no thermocouples inside of the duct, in the engulfment test samples in ISO6944/ASTM E2816. Therefore, it can get hot enough inside the ductwork, in the furnace, which represents an engaged compartment, to short out the pressurisation fans sitting inside, & yet still get a rating under ISO6944 and/or ASTM E2816-2020a and prior versions. Also, ISO6944 is criticised in ASTM E2816 and some marketing materials. But ISO 6944 versions after 1985 include for duct expansion, causing penetrant growth pressure towards the firestop, which is not tested under ASTM E2816. E2816 does not mention this with its criticisms of ISO6944. Also, neither E2816, not ISO6944 test a level change with a connection between vertical and horizontal ductwork - this despite the known fact, codified in ISO 6944, and high school level physics, that steel elements first expand under heat, before they reach critical temperature and can collapse once the critical temperature is reached, all of which is known. This is why we have been fireproofing structural steel for many decades. There are software programs in the public domain for predicting steel element expansion as a function of heat exposure. But still, E2816 does not test a level change from horizontal to vertical - only a "T-connection-to-nowhere" in the vertical engulfment test sample. So, a first year construction worker ought reasonably to know that steel expands as a result of heat exposure, but E2816 doesn't test a level change connection known to exist in the field, while criticising ISO6944, which has, by now included a test provision for duct expansion. This video is intended to be viewed by buidling officials & fire prevention officers asked to permit duct fireproofing or fire-resistive ductwork qualified to ISO6944/ASTM E2816, as an alternate shaft. The code requires that shafts are qualified to ASTM E119 / CAN/ULC-S101 / UL263. AHJs are encouraged to obtain their own copies & compare the Conditions of Acceptance per E119/UL263/S101 for non-loadbearing walls (fire, heat and hose stream must not get through), to the contents of ISO 6944-1985 and ISO 6944-2008 and ASTM E2816, up to and including the 2020a version, all of which were rejected at the Committee Level of the April 2021 ICC Code Hearings. If the intended use of the duct fireproofing is pressurisation, then, it follows, that the pressurisation, which is a sealed unit, and is electrical equipment, must be kept from shorting out. How do we keep electrical equipment from shorting out behind fireproofing? We keep the maximum temperature rise below 140°C - which is code intent currently by setting E119 and UL 263 as the baseline of fire protection performance, specifically, the Conditions of Acceptance for non-loadbearing walls. Also there is UL1724, ASTM E1725 and USNRC GL8610-Supplement 1, all of which are used for electrical fireproofing - See Circuit Integrity on Wikipedia, for example. All of these have the same thermal requirements as E119/S101/UL263.) ISO6944 and ASTM E2816 put the burden of the hose stream and the thermal performance on the FIRESTOP PORTION of the test (a small portion of the ductwork in a building). That means the fan can short out in minutes and the test still passes. If the fan is inoperable in minutes, the duct system is absolutely useless because no cool air is being sent to the protected area without an operable fan. But the systems are rated for 2 hours.... This video examines the public domain UL listing categories/preambles, some public domain special interest marketing information and comparative fire testing information, as well as legal statutes found in a Google search, which may or may not be applicable. If you are an AHJ, compare the test standards themselves, and their contents, and see what the thermal and hose stream data actually comes from, and whether this can be judged to represent code intent for shaft alternatives. The presenter is not a lawyer, not giving legal advice & is encouraging viewers to presume the contents 2 be complete & utter nonsense. Just compare the actual test standard contents against code intent & think about the purpose of the pressurisation fan & what such electrical equipment needs to function as intended, & how code intent relates in terms of the Conditions of Acceptance for non-loadbearing walls per ASTM E119, UL 263, NFPA 251, CAN/ULC-S101 (which are all the same for non-loadbearing walls). ASTM E119 is over 100 years old".