This is topic Xenon Lamps--Toxic? in forum Film Handlers' Forum at Film-Tech Forum ARCHIVE.
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Posted by Michael Elam (Member # 788) on 10-27-2004, 04:49 PM:
I have a city inspector insisting that we move exhaust systems
claiming the Xenon lamps produce toxic chemcials. He's not satisifed with documents that show UL approved and 'ozone-free', does anyone have a document that will clearly state they are NOT toxic?
Posted by Aaron Sisemore (Member # 145) on 10-27-2004, 06:27 PM:
Aside from any ozone and UV radiation produced by operating a xenon lamp, the only other 'toxic' material related to xenons would be the traces of thorium in the electrodes, but that would only apply if the bulb were broken and you tried consuming the electrodes
there is no real threat to the public from proper operation of a xenon lamp.
-Aaron
Posted by Gordon McLeod (Member # 33) on 10-27-2004, 06:37 PM:
technically the UL approval on most xenon lamphouses specifies that they be vented to the outdoors
Posted by Michael Elam (Member # 788) on 10-27-2004, 07:06 PM:
This inspector is wanting us to move the exhaust for 8 consoles,
that have been in place for 15 years, he is claiming that the
exhaust are too close to the HVAC units and that 'toxic' fumes
from the exhausts are being allowed to enter the HVAC units, he wants the exhausts moved 10 feet or 'lifted' two feet above the
height of the HVAC unit.
Posted by Marc Hansen (Member # 705) on 10-27-2004, 08:56 PM:
Ask the inspector(politely)to give you a copy of the regulation he wants you to comply with. Either he won't be able to come up with it (problem solved),or he will and you will know what info you need to counter it, or you'll know there is no way out and you have to change it. I learned this from my fire inspector. A new, young inspector came thru my business and found 16 "violations". I went to the senior inspector, asked him about it(he had inspected my many times before), he just shook his head and said "make him prove it". It came back a few weeks later with just 2 items listed (absolutly valid). The inspectors can't be current on everything, there is just too much. Treat them right, respect them and they can be an asset to your business. The young inspector now comes thru my business points things out and signs off the form. He knows anything valid will be fixed.
Posted by Mark Gulbrandsen (Member # 72) on 10-27-2004, 09:06 PM:
This guy has definately been smoking some of that I-15 stuff!!!
But really, take the advice and ask him, in writing only via certified mail that only he can sign for, for a copy of the regulation so you can study it in great detail. By mailing him the request you have proof that you asked him for it and he must provide it. If they get you on non-compliance and he never provided you with the correct info after wrigint the request you can prove that it was requested.
On a new job in Southern Utah the new local inspector wanted the safety data on every piece of equipment going into the building. Getting it together wasn't that big of deal and we gave him a basket full of info and documents to keep him busy.
Another job in progress is only a half block from the local OSHA office... that ought to be interesting.
Mark
Posted by Michael Elam (Member # 788) on 10-29-2004, 06:35 AM:
Looks as if we are going to move the exhaust, we admitted he was new, as well he admitted the codes are very old and mostly
likely written for the carbon arc days, but he insists as long as it is code then we must move them.
Posted by Frank Angel (Member # 248) on 10-29-2004, 07:05 AM:
If that is the case, and you feel the regulation is outdated and you have been operating for 15yrs with other inspectors not citing you, and especially if other similar regulations are still on the books that pertain to long abandoned methods of operations (such as those relating to nitrate film use), you can present a prima facia case that the regulation is obsolete and you are demanding a variance from the city regulatory agency, whichever it is that administers those codes.
More than likely this same thing has been done for a variety of regs as would have to have been the case when platters came in to use; there were all kinds of regulations governing how much (or rather how little) film was allow exposed to air in the booth, how many total number of feet of film could be contained in the booth at one time....etc. Those regs may never have been revoked but somewhere along the line, some exhibitor or big chain got a variance so they could put in a platter. Same with fire walls, fire shutters, etc. I would guess that most new builds don't have fire shutters and certainly they don't have double fire walls that isolated the booth from the theatre proper. When single screens began to be routinely converted into those hideous multiplexes, all those old regs went bye-bye. The fire regs and building codes that were written to protect theatres from the hellish evils of nitrate stock were either quickly revised or variances were obtained so they could be legally ignored. I am sure you could get the same for this foolish reg about exhaust stacks.
Check out other booths. If a big chain has a similar "violation" that has been ignored by the inspectors, that would be a very good addition to any plea for variance or to actually get the code revised. If say a Sony Theatre booth has the same condition, you might be able to get the big guns to go in on a petition to get the reg altered or completely removed from the code books. And if they are not interested in helping you, you could still name them and claim unfair hardship is being directed only at you which would be a restraint of trade and unfair practice. But usually exhibitors would find it to be in their own best interest to get changed in their favor. You might find yourself standing up there along side a slew of big chain lawyers. And be sure of this....the bigger the cat making the hissing sound, the quicker the bureaucRATs sit up and take notice!
Posted by Darryl Spicer (Member # 711) on 10-29-2004, 08:06 PM:
Hell, I worked in a theater for 7 1/2 years were all the exhaust was emmitted into the projection booth. Four of the projectors were located in the lobby. Hell there is probably more toxic fumes in the actual air it's self than will ever be emitted from a xenon bulb. The codes need to be re-written for non-carbon arc facilities otherwise we are being forced to have to pay for something that is not needed.
It needs to be taken to court or something before one dime is spent on any changes.
Posted by Jason Black (Member # 684) on 10-29-2004, 09:39 PM:
Daryl,
Taking the case to court will require greater expenditures than paying the HVAC crew to extend the vent tubes the extra 2' they need to be moved.
While I agree with your feeling that certain codes should allow for what I call 'common sense' variances, it is often an unwise choice to question a code inspector. I witnessed a pissed off electrical inspector state that a theatre (3 days from opening) would require further inspection after a frosty machine (of all things) was found with no UL label. At that point, he demanded to see UL labels on ALL electrical equipment in the building. He wanted to see it immediately, or he would be back for further inspection "when he could get to it". This is the same A-hole who took out a neutral screw from the main breaker panel, looked at it, then measured it to see if it was the proper length. Thank God it was at least green, as code required.
Bottom line, as someone else already stated, treat the person with soem respect, not with an attitude, and you'll generally be ok. I had a friend who owns a restaurant (among many other things)... The health dept. came around for routine inspection. Just so happened that my friend knew that the inspector was recently 'estranged' from his wife... so what does he do? Asks how the wife is.... LOL... Needless to say, 6 years later, he STILL catches grief on all his inspections...
Posted by Steve Kraus (Member # 476) on 10-29-2004, 09:52 PM:
What is the legality of requiring anything from UL, a private company?
Posted by Darryl Spicer (Member # 711) on 10-29-2004, 11:05 PM:
True it would problaby cost more to get the code changed but if more than one location ends up having the same issues then what happens with the cost.
Posted by Jon Miller (Member # 163) on 10-30-2004, 09:15 AM:
quote: Jason Black
...he demanded to see UL labels on ALL electrical equipment...
What about "ETL" certification, which some manufacturers obtain as an alternative to UL certification? That inspector could be excessively anal...
Posted by Dominic Espinosa (Member # 2122) on 10-30-2004, 11:23 AM:
How was the conclusion reached that there's toxic fumes being vented into the building via the HVAC units from the xenon exhausts?
Could he show that there were fumes coming from the vents?
Moreover, if there isn't, what proof does he have that nothing but hot air is escaping from there?
Posted by Gordon McLeod (Member # 33) on 10-30-2004, 01:02 PM:
Actually part of the issue isn't that it is the projector exhaust but probably an exhaust from the buiding and there is codes regarding the distance between a fresh air intake and any form of exhaust vent from within the building
Posted by Michael Wilkinson (Member # 2389) on 10-31-2004, 04:56 AM:
I just happened to be thumbing through an old ORC 1000B lamp manual which stated that exhaust to the outside was not necessary.
The manual's as old as I am, but thought that was an interesting note given your situation. Although I've never seen it except in those got to figure out something quick box fan jobs
...Can you simply exhaust into the booth???
Posted by Frank Angel (Member # 248) on 10-31-2004, 08:55 AM:
I am not sure the cost of making a plea for a variance would be that prohibitive. You don't need a lawyer to present a request for a variance to the regulatory agency, at least not here in New York, and even if you do, it shouldn't be too expensive just to have a lawyer write up a position paper. Whoever does write the paper, it will need to be succinct, it will need to be written in a way a review board can easily understand; you have to make it sound reasonable with a good dose of common sense. You also need to stress the fact (if you can provide it) that other businesses also have this same issue which has been ignored, also that no other inspector has cited you in 15 years.
This might not be as costly as you think.
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