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NFPA 502 - Publ

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National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPa...

Public Input No. 12-NFPA 502-2023 [ New Section after 7.4.7.3 ]

7.4.7.x
For facili es that u lize a SCADA system to monitor and control facility subsystems that are part of an integ
7.4.7.2, the SCADA system shall include SIL 2 rated safety func ons for the ini a on of re protec on as par
accordance with the ANSI ISA 84/IEC 61511, Standard Func onal safety Safety instrumented systems for th

Additional Proposed Changes

File Name Description Approved


Professional
NFPA_Professional_Backaground_and_Experience_- background
_Thomas_Kuhn.docx information for
Thomas Kuhn

Statement of Problem and Substantiation for Public Input

Most tunnels utilize high availability SCADA systems for tunnel ventilation control and now increasingly
for fire protection as well. Fire alarm systems, which are listed for fire alarm use, generally do not
provide the functionality or controls capability for advanced fire protection functions such as positive
alarm sequencing, operator intervention, remote and automated control and interface with other
systems (e.g., traffic control systems, ITS). The previous inclusion of SIL-2 certified components was
the next logical step for fire protection by SCADA systems. This suggested addition is the next logical
step in tunnel safety for SCADA systems because it requires the process of calculating the SIL rating
based on availability and design of the SCADA system’s fire protection safety function. It limits the
safety function requirements to fire protection only, which is a more discrete and attainable standard for
current technology.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn


Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 15:32:37 EDT 2023
Committee: ROA-AAA

20 of 60 9/12/2023, 2:10 PM
National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPa...

Public Input No. 11-NFPA 502-2023 [ Section No. 7.4.7.3 ]

7.4.7.3*
For facili es that u lize a nonlisted nonlisted SCADA system to monitor and control facility
subsystems that are a part of an integrated emergency response system described in 7.4.7.2 , the
components of the SCADA system including and between the programmable logic control pla orm
(logic solver) and the its eld level input/output modules , shall a ain be cer ed to a minimum
safety integrity level Safety Integrity Level (SIL) of SIL - 2 in accordance with the IEC 61508,
Standard for Func onal Safety of Electrical/Electronic/Programmable Electronic Safety Related
Systems .

Additional Proposed Changes

File Name Description Approved


Professional
NFPA_Professional_Backaground_and_Experience_- background
_Thomas_Kuhn.docx information for
Thomas Kuhn

Statement of Problem and Substantiation for Public Input

The IEC standard 61508 is for manufacturers of controls equipment. Leading manufacturers of PLCs
have their equipment certified to a SIL rating by an independent agency such as TÜV Rheinland
according to both 61058 and 61511. It is important to note that the certification is for the equipment
components and systems provided by manufacturers and not the final installed system by the end
users. Understanding then that the intent of this paragraph is to use SIL rated components for PLC
systems used for fire protection such as deluge or high-pressure mist systems in tunnels, then these
minor modifications are intended to clarify the requirement to use SIL-2 certified components.

Secondly, the “and between” language is suggested to be removed and the “logic solver” language
added to be consistent with the terms in the 61508/61511 standards. The logic solver component of a
safety instrumented system (SIS) is typically the PLC (Programmable Logic Controller) and its
input/output (I/O) modules. Most mainstream, commercially off-the-shelf PLCs and their I/O modules
have versions with SIL 2 certification, but it is not clear what “and between” would refer to as the logic
solver definition includes functionality for PLC backplanes, network/communication I/O adapters etc.
Including “and between” may lead to misinterpretations of the 502 standard to include interposing
relays, network switches and other devices which are not part of the SIS or its safety function. By
using “logic solver” the necessary components are implied.

Submitter Information Verification

Submitter Full Name: Thomas Kuhn


Organization: Mott MacDonald
Street Address:
City:
State:
Zip:
Submittal Date: Tue May 23 14:22:53 EDT 2023
Committee: ROA-AAA

21 of 60 9/12/2023, 2:10 PM

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