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Carbon Dioxide Reporting Exemption

Note: This exemption has been eliminated effective 7/24/2015. All carbon dioxide is now HMBP-reportable when handled at or above the reporting thresholds specified in Article 1 of Chapter 6.95 of California Health and Safety Code.

Originally Posted October 18, 2004.

Pursuant to California Health and Safety Code section 25503.5(c)(2), Unified Program agencies in Santa Clara County, consisting of the Santa Clara county fire department hazardous materials programs and the County Environmental Health Department (also defined as Administering Agencies) have determined that carbon dioxide, used for the dispensing of food or beverage, is exempt from reporting on a Hazardous Materials Business Plan in quantities less than 6,000 cubic feet. This statement constitutes the required public notice.

Rationale: Establishments that dispense food and beverages are known by the public and by emergency response personnel to routinely have sources of carbon dioxide for the dispensing of food and beverages. Preparation of a Hazardous Materials Business Plan to alert the community or emergency responders is unnecessary and would not significantly enhance emergency response activities. The California Fire Code permit threshold for carbon dioxide is 6,000 cubic feet, thirty times greater than the reporting threshold for a Hazardous Materials Business Plan. The primary hazard of carbon dioxide is as a simple asphyxiant. With respect to carbon dioxide dewars, a catastrophic release from a dewar is unlikely as the sudden

release of the gas would result in condensation freezing and restricting the rate of release.

Note:   This exemption applies to Hazardous Materials Business Plan reporting only.   Requirements for storage and use still apply. Below is a summary of these requirements.

Storage and Use Requirements

REQUIREMENT

CODE REFERNCE

CO 2 containers, cylinders and tanks shall be secured to prevent falling due to contact, vibration or seismic activity.

CFC 7401.6.4

CO 2 containers, cylinders and tanks designed for protective caps, collars or other protective devices shall have the caps or devices in place except when in use or being serviced or filled.

CFC 7401.7.2

Storage areas for CO 2 containers, cylinders or tanks shall be secured against unauthorized entry and safeguarded with such protective facilities as public safety requires,

CFC 8001.11.2

CO 2   cylinders or tanks shall be marked in accordance with CFC Standard 79-3.   Markings shall be visible from any direction of approach

CFC 7401.5.2

CO 2   piping shall be marked at intervals no greater than every 20 feet with the name “Carbon Dioxide” and the direction of flow. Piping shall also be labeled at each point where changes in direction occur and where wall, ceiling or floor penetrations occur.

CFC 7401.5.3, 8001.4.3.2

CO 2 containers, cylinders and tanks shall not be placed near elevators, unprotected platform ledges or other areas where falling would result in the container dropping a distance exceeding half the height of the container.

CFC 7401.8.4

REQUIREMENT

CODE REFERNCE

CO 2 containers, cylinders and tanks shall not be heated by devices which could raise the surface temperature of the containers, cylinders or tank above 125 F.

CFC 7401.8.7

CO 2 containers, cylinders and tanks shall not be located where they could become part of an electrical circuit.   CO 2 containers, cylinders and tanks shall not be used for electrical grounding.

CFC 7401.9

Service, repair, modification or removal of valves, pressure-relief devices or other appurtenances shall be performed by trained personnel in accordance with nationally recognized standards.   See Article 90 standard u.3.3 of the 2000 CFC.

CFC 7401.10

CO 2 containers, cylinders and tanks shall not be used for any purpose other than to serve as a vessel for containing CO 2.

CFC 7401.11

Leaking, damaged or corroded CO 2 containers, cylinders and tanks shall be removed from service.

CFC 7401.13