Comment from Anicello, John; Airgas Inc.

Many acetylene plants were sited, designed and constructed in the first half of the twentieth century, and certainly before the CGA G-1.4 document was initially adopted in 29 CFR 1910. The same will be true with the adoption of NFPA 51A, versions 2001 and 2006. In response to the point made “has no effective-date provision and applies retroactively”, in regards to NFPA 51A version 2001, whether there is a retroactive provision within the NFPA documents or not, the issues related to building siting, design and materials of construction should not be applied retroactively where the facility was compliant at the time of construction. The effect to comply for example would be move the building or demolish and rebuild causing great economic hardship, or even worse the decision to discontinue operating. This comment is submitted on behalf of Airgas Inc. and it subsidiary companies.