NC During IATF Audit

[mmkraftwerk]

Hello all,
I'm going to try to lay this out as methodically as possible.
So at my current place of employment, we have a small laboratory where we recently started conducting FMVSS 302 testing (Flammability of Interior Materials). I pushed for developing this project as a QC and the responsibility of it has fallen solely on to me. So as part of the development of the lab, I had the following items calibrated:

• 18" Steel Rule
• Stopwatch
• Environmental Chamber (For testing such as GMW3232 which requires cycle aging)
• Thermometer / Hygrometer

Before I started here, the environmental chamber, laboratory fume hood, and FMVSS 302 flammability chamber had already been purchased.
During our audit (and of course the last stop for the auditor) we were found to have a minor non-conformance due to the fume hood having never been calibrated for the correct amount of CFM evacuation for noxious fumes. I told the auditor that we do not run the fume hood fan during testing, due to the concern that it would interfere with the testing, and that it only runs after the test completes in order to evacuate the smoke. She accepted this as fine, and lowered the NC to a minor NC, and stated that our previous testing did not need to be scrapped.
My issue is that in a previous life, this issue never was brought up during IATF audits, and frankly I've never heard of someone having a fan calibrated for testing. Which I guess is besides the point. We have an anemometer, and I ran some testing with it and found that the pull from the fan at the back of the chamber where airflow should be the highest was at 439CFM, which brings me to the following point.
I've collected some information. The FMVSS 302 lab testing procedure document (1991) states:
"It should be noted that certain samples may produce noxious gases during combustion. For this reason it is strongly suggested that these tests be conducted under a fume hood or similar facility. Air turbulence around the burn cabinet (produced by the exhaust system) must be low level and MUST NOT, IN ANYWAY, EFFECT THE OUTCOME OF A TEST."
I'm a little miffed that the language in this is so nonspecific. What is "low level"? Air turbulence surrounding the burn cabinet is also not generally where you test CFM, and the meter I'm using is not sensitive enough to detect any airflow "around the burn cabinet" so it is below 400CFM, but I'm not sure how low.
The only reference points I have, are that generally, air flow under laminar flow hoods should be anywhere between 75 and 125 CFM and that OSHA recommends 100CFM in environments where noxious chemicals are released during the combustion of materials.
Which brings me to my question for you guys: How would you go about certifying a fan that has an adjustable speed, is it necessary? How would you go about measuring the proper level of air flow for testing in this environment? I would prefer not to breathe in these chemicals, so not running the fume hood is not a good long term solution. Would purchasing a more sensitive anemometer help in this situation? Where is the proper location to check for the level of CFM?
Thanks for the help all. Happy Friday!

 

[Johnny Quality]

Can you share the statement of the nonconformity and the clause?

What does the fan do? Is it purely a H&S device to evacuate smoke?

 

[Ashland78]

I worked with a company that had gases involved, if I recall 3.5% HEL something.
We had the manufacturer of the equipment provide training of what needs to be done, how often, etc. We then put it in a procedure within calibration, and only the engineers that were trained could perform, this task.

It was over 5 years ago when I managed a lab that had some very unique calibration that I never saw in 16 years. I can't quite recall the exact details.

 

[Golfman25]

So let me see if I understand. You have an evacuation fan/hood, that you don't turn on during testing so as not to affect the test results. Then when the test is complete, you run the fan and clear the area. On what basis is the auditor requiring calibration of the fan? Is the auditor some type of testing expert now?

As to your other question, can you use a respiratory device to not breath the fumes? They other specifics may be better answered by the manufacturer. Good luck.

 

[Johnnymo62]

Do any of your documents specify the CFM stting to use when testing? If not, it shouldn't be a NC.
Any negative pressure should pull gasses out, especially from teh chamber.

 

[ChrisM]

"a minor non-conformance due to the fume hood having never been calibrated for the correct amount of CFM evacuation for noxious fumes."
But if there is no CFM specified or required for the evacuation then how can this be a nonconformance? As has been said, we need to see the wording used in the NCR to be able to give specific advice on how to respond to it