Public comments for: 3 RCNY Section 3004-01 Use of Carbon Dioxide in Beverage Dispensing Systems

Comments

Comment:
Reference materials for the required Certificate of Fitness G-82 are not accurate. - CGA references - add G 6.5 Standard for Small Stationary Insulated Carbon Dioxide Systems - this is the guideline on small bulk beverage CO2 systems - Container is defined as insulated pressure vessel, ASME coded - section 7.9 of G-82 refers to labeling and stamping of DOT cylinders but refers to them as containers. - Design & Installation requirements should include CGA G 6.5 as a reference - Section 7.4 Leak Detection recommends CO2 monitors be installed 4 - 6 feet above the floor. The sensors should be installed 18 inches above the floor due to the density of CO2 gas being 1.5 times heavier than air. - Section 7.6.1 Overfilling Containers - PRD setting is listed as 350 psig, should be 300 psig for these type tanks - Section 7.9 Marking & labeling refers to high pressure DOT cylinders, do not use the word "containers" as they are defined as insulated ASME vessels in the definitions section.
Agency: FDNY
Comment:
Are they going to change any of the cert of fitness cat numbers. Are they going to come out with new test for this requirements.
Agency: FDNY
Comment:
Comments of the New York City Hospitality Alliance on the Fire Department of New York’s proposal to amend e Section 3004-01 of Title 3 of the Rules of the City of New York change fire safety requirements. My name is Andrew Rigie and I am the Executive Director of the New York City Hospitality Alliance (”The Alliance”), a not-for-profit trade association representing thousands of eating-and-drinking establishments throughout the five boroughs. We recently received notice from the FDNY about their proposed rule to comprehensively update Section 3004-01 of Title 3 of the Rules of the City of New York which regulates carbon dioxide installations and to adopt the latest national and industry standards and to eliminate or update New York City-specific fire safety requirements. The Alliance believes that any measure taken by the City of New York to amend current regulations and procedures must be carefully considered by all stakeholders. Therefore, it is our recommendation that before the FDNY proceeds with this proposal, they convene an advisory board of stakeholders to review and determine what, if any, modifications should be made. The Alliance would embrace an opportunity to participate on such an advisory board. We found this process very effective in our work with the city’s Department of Environmental Protection and their proposal to amend requirements relating to wood- and coal-cook stoves. The number of businesses impacted by that proposal was small compared to the majority of the 25,000 eating-and-drinking establishments that would be impacted by this FDNY proposal. This proposal requires equal or greater attention to ensure that it accomplishes its goal, without posing unnecessary financial, administrative and other burdens on our city’s small businesses. We are concerned with our reading of the proposed rules and have many questions. What is the cost of this additional work? Does this Rule apply retroactively to thousands of establishments, many of which are small mom and pop businesses in old buildings? Is this retrofitting possible in some of those locations? Are there an adequate number of private companies that currently perform this work? Is the proposed new equipment readily available on the marketplace? Are the new reporting and paperwork requirements overly burdensome for small businesses? We are interested in learning these answers along with others in order to offer substantive comments on the proposal. Worker and customer safety is of the utmost importance to our organization and our members. We look forward to engaging with the FDNY in a substantive conversation on this matter. Respectfully submitted, ANDREW RIGIE l EXECUTIVE DIRECTOR I NYC HOSPITALITY ALLIANCE 212-582 2506 l ARIGIE@THENYCALLIANCE.ORG I THENYCALLIANCE.ORG 65 WEST 55th ST I SUITE 203A I NYC 10019
Agency: FDNY
Comment:
Hello This is Bo Hansson, I made some small mistakes in my earlier submittal please use this corrected version. Thank you, Best regards, Bo Hansson
Agency: FDNY
Comment:
My Name is Bo Hansson, I have been working over 25 years exclusively with CO2 Safety. I have installed over 40 000 CO2 Safety Systems in the largest fast food chain in the world. I work and am represented in many countries by the largest soft drink company in the world. I train the larger CO2 gas suppliers of CO2 in CO2 Safety. I have my products installed in over 126 countries Last year I won the McD World Innovation Award - first time a safety product has won it. I have made a non commercial short film about working with CO2 Safety: https://www.youtube.com/watch?v=OTanQa9JpoQ Please look at my suggestions and if I can assist in any way do not hesitate to ask, it is free of charge. My experience might avoid making the same mistakes that have been made in other places, It might save a lot of frustration. I will attend the hearing tomorrow. I would be happy to make a presentation at a convenient time - listening doesn´t cost money. Best regards, Bo Hansson
Agency: FDNY
Comment:
Comments & Recommendations to the proposed revision of FDNY Section 3004-01 of Title 3 of the Rules of the City of New York are overlaid in red in the attached document. Hank Moeller Manager Regulatory Compliance
Agency: FDNY