An FSCI update from Keith Frangiamore, FSCI President
Back to Work in the Summertime
As the temperatures rise, and many people are vaccinated, we have finally moved back into a “normal” business environment with the hope that the economy will recover quickly.
With the Illinois move to Phase 5 on June 11, 2021, fully lifting the COVID-19 restrictions and Michigan heading in the same direction soon, we are excited to finally be back in the office without face coverings and social distancing. Some FSCI and PSI managers recently visited the Michigan office in May and again in June for the first time in nearly a year. Prior to the pandemic, managers visited the Michigan office regularly to coordinate and promote our seamless office environment and show support for our great Michigan office team.
In June, the Illinois office enjoyed an outside “game” day where we spent an afternoon together along with enjoyable team building activities. A big thank you to the team members for organizing this very entertaining (and hot) day! Also, congratulations to the winners of the bags tournament!
As we grow to serve all our clients more effectively, we have realigned some of our staff duties to meet the high demand for these consulting services. To strengthen our consulting services, Senior Fire Protection Consultant Brent Gooden has begun taking on some of the consulting division responsibilities while still maintaining his involvement in the fire protection plan review and field services division. Brent has successfully managed the Illinois fire protection field services group for the past few years and has already begun sharing some of the field services duties with other team members. Look for more team member updates coming in the next newsletter! Please stay safe, support each other, and help us all move toward a healthy future!
The COVID-19 Effect on the Logistics Industry
COVID-19 has made a lasting impact on us and businesses worldwide. Throughout the world and highlighted in the US, we’ve all read about the difficulty in finding and buying “normal goods” like toilet paper and hand sanitizer. Often these supply shortages are due to a lack of production and are related to supply chain issues. The supply chain issues have several root causes can include insufficient raw materials and finished product delivery due to the lack of storage space and transportation capacity.
How do supply chain issues effect the local fire service and the fire safety of occupants and buildings in their jurisdiction? In general terms, fire safety in warehouse occupancies may be compromised because of overstocking or a change in commodities being stored which may include hazardous materials.
When FSCI engages in a warehouse storage fire consulting project, the first aspect we evaluate is overstocking in a warehouse. Overstocking can be caused by companies increasing production to meet demand, an inability to ship product once manufactured, or a combination of both. This issue can create fire and life safety conditions that increase risk to the occupants and fire service alike.
Overstocking can comprise the means of egress as well as the commodity storage arrangement. Too much stock can reduce available egress capacity by blocking doors and can increase travel distances. Narrowed aisle widths can reduce required fire separation of storage areas, increasing the likelihood for fire spread and restricting firefighting access. In addition, overstocking can increase the potential for industrial accidents and employee injuries.
The more serious fire safety impact is a change in the product storage arrangements making it difficult for the existing fire sprinkler system to control a fire should it occur. Most people wrongly assume that as long as the building is protected with an automatic fire sprinkler system it does not matter what and how you store commodities. However
In a building with 15-foot ceiling heights, and limited floor space, you can imagine that the easy solution to an excess storage problem would be to get the product off of the floor and onto racks or into a high-piled pallet storage arrangement. Higher-piled storage can easily produce fires that the existing fire sprinkler system cannot control. Historically, this type of storage practice has led to the loss of entire buildings. Fire sprinkler design must take into account the height of the storage, in addition to other factors.
Another key issue is the practice of hazardous material use and storage in buildings that are not necessarily designed with the proper features of fire protection. The ICC’s, International Fire Code (IFC) as well as NFPA 1, Fire Code, specifically address fire safety requirements based on various hazardous chemicals and processes.
Hazardous materials are defined as products that pose an unreasonable risk to the health and safety of operating or emergency responders, the public, and the environment if not properly controlled during handling, storage, manufacture, processing, packaging, use, disposal, or transportation. The codes and referenced address the dangerous conditions related to their storage, dispensing, and handling, and requirements needed to mitigate the hazards associated with the products or processes.
In the IFC and NFPA 1 there are several hazardous materials chapters that address specific products and safety requirements related to the products. Here is a list of those hazardous materials addressed in both codes and included in the Hazardous Materials – General Provisions chapter.
- Explosives and blasting agents.
- Combustible liquids.
- Flammable solids, liquids and gases.
- Organic peroxide solids or liquids.
- Oxidizer, solids or liquids.
- Oxidizing gases.
- Pyrophoric solids, liquids or gases.
- Unstable (reactive) solids, liquids or gases.
- Water-reactive materials solids or liquids.
- Cryogenic fluids.
- Highly toxic and toxic materials.
- Corrosive materials.
In addition, both codes address occupancies that involve hazardous materials and processes, and related safety requirements necessary to operate safely.
Manufacturing and Related Storage Hazards
Fire Safety Consultants, Inc., regularly provides to our clients, a detailed analysis of the hazards related to the manufacturing and storage of many types of products. This portion of the article focuses on the effect that the pandemic has had on our analysis of the use and storage of hazardous materials, and how it has created an enforcement challenge for local fire code officials.
A good first example of the challenges being faced is the dramatic increase in the manufacturing of hand sanitizers that use ethanol (alcohol), which is flammable, raw material, and it’s finished product being the hand sanitizer product which is +/-70% by volume. While some manufacturing operations have safety converted from the manufacture of a similar product, others are quickly modified installations that have not been reviewed or permitted by the fire code official. Many manufacturers attempted to take advantage of the need to fill the hand sanitizer void, at times without fully thinking through the associated hazards and fire safety requirements.
While working on several consulting projects since the pandemic began, FSCI’s team observed the following problems related to operations involving hazardous materials:
- Dispensing of flammable liquids – for I-B flammable liquids the MAQ (maximum allowable quantities) is only 60 gallons but was often exceeded
- Use of flammable liquids in open processing systems – for I-B flammable liquids the MAQ is only 60 gallons but also was often exceeded
- Bulk storage of flammables and associated connections to blending and filling operations was not code compliant
- Storage of flammable liquids (raw material) in excess of the MAQ per control area – for I-B flammable liquids the MAQ is only 240 gallons and was often exceeded
- Storage of flammable finished product at 70% alcohol content was not in compliance with the code
The FSCI team noted large containers, such as 275-gallon totes and even tanks up to 3000 gallons, that were transferred to mixing vats, and subsequently filling stations for the finished product containers. In some cases, the products were transferred using hoses by gravity or non-approved pumps where vapors were regularly being released. Non-compliance issues included no spot ventilation or required room ventilation beyond that which would normally be provided and a lack of fire rated separations.
The following is a list of standard items that need to be addressed when processes involve flammable liquids:
- Separation from the remainder of the building with one-, or two-hour fire rated construction – high hazard H-2 classification if use and dispensing occurs and flammable vapors are present, and H-3 classification in storage areas were no use or dispensing takes place and flammable vapors are not normally present
- Ventilation for removal of exposed flammable vapors
- Electrical classification of the room or area and related electrical equipment installation requirements
- Explosion control – deflagration venting or concentration reduction system
- Fire protection based on use, containers and storage arrangement including aisles
- Spill control and secondary containment to protect against flammable products mixed with sprinkler water flowing into other areas of the building
- Tank storage and piping
- Fire extinguishers
- Means of egress in high-hazard areas based on storage arrangement
- Identification and warning signs
The current challenge for the storage of flammable liquids, without related manufacturing, is mostly related to supply chain issues. Again, this related to an increased demand for flammable raw materials, the increased demand for storage and delivery of finished materials, and a reduction in supply chain capacity. The confluence of these issues has created the need for more storage space in warehouses across the country that are either not designed for flammable liquid storage or the increase in the amount of storage exceeds the fire protection systems within the building.
The FSCI team has found issues that are similar in nature to those storage issues listed in the section above that require attention.
- There was no previous storage of flammable liquids so the area or room was never properly designed for flammable storage
- Storage of combustible and/or incompatible products such as oxidizers was not considered
- Amounts of flammable liquid storage has increased dramatically without changing the areas used for storage – the storage arrangement has changed – manner, height, piles, etc.
- Egress requirements are compromised by storage arrangements
- Fire suppression is inadequate based on the addition of flammable liquids, increased amounts of stored flammable liquids, or changes in their storage arrangement
- Proper separation of hazardous storage areas from general warehouse areas not was not provided when flammable liquids were in excess of the MAQ – Required fire rated construction missing and building code occupancy classification upgrade to high hazard H-3 not taken into account
- Secondary containment was not provided where flammable liquids were in excess of MAQ based on the size of containers or overall amount in storage – Codes require secondary containment based on the largest vessel plus at least 20 minutes of sprinkler flow
- The minimum amount of ventilation required based on the MAQ and other factors can be .25cfm or 1cfm per square foot of floor area but was not provided
Many of the storage practice issues described in this article are challenging and often require an in-depth analysis and code study before comprehensive solutions can be reached.
There are many requirements related to flammable liquids and related processes contained in the 2018 IFC, Chapters 50 and 57, and the 2018 NFPA 1, Chapters 60 and 66. Both codes reference NFPA 30, Flammable and Combustible Liquids Code, for compliance requirements as well as other codes and standards that may apply in specific instances.
Two tools that local fire code officials have in each code are the requirements identifying a HMMP (Hazardous Materials Management Plan) and HMIS (Hazardous Materials Inventory Statement). These simple requirements can provide product information that may have changed related to hazardous materials in an occupancy during the pandemic. Finally, when the local code official encounters these types of situations, he or she can review the requirements listed in the codes above or can require a technical opinion and report.
International Fire Code:
IFC Section 104.7.2 Technical assistance.
To determine the acceptability of technologies, processes, products, facilities, materials and uses attending the design, operation or use of a building or premises subject to inspection by the fire code official, the fire code official is authorized to require the owner or agent to provide, without charge to the jurisdiction, a technical opinion and report. The opinion and report shall be prepared by a qualified engineer, specialist, laboratory or fire safety specialty organization acceptable to the fire code official and shall analyze the fire safety properties of the design, operation or use of the building or premises and the facilities and appurtenances situated thereon, to recommend necessary changes. The fire code official is authorized to require design submittals to be prepared by, and bear the stamp of, a registered design professional.
NFPA 1 Fire Code:
1.15 Technical Assistance.
The AHJ shall be permitted to require a review by an approved independent third party with expertise in the matter to be reviewed at the submitter’s expense.
The independent reviewer shall provide an evaluation and recommend necessary changes of the proposed design, operation, process, or new technology to the AHJ.
-Keith Frangiamore CFPS, President FSCI
Hetul joined Fire Safety Consultants, Inc. in March of 2020 and he could not have come to us at a more uncertain time in the world. However, he did not let that stop him and he jumped right in. Hetul is one of the plan reviewers in our corporate office and he started off his training by learning all about automatic sprinkler systems and soon after, kitchen wet chemical extinguishing systems. Now that he has completed his training in both areas, if you have submitted either of these types of reviews to our office, Hetul may have in fact completed the review for your project.
Before Hetul switched career paths and joined FSCI, he was a pharmacy claims auditor. He has enjoyed the transition to being a fire protection plan reviewer and within his 1st year with us, he has achieved his NICET Level I certification for Water-Based Systems Layout.
Little Known Facts
Hydraulically Calculated Design Areas – NFPA 13
As an FSCI plan reviewer, I constantly see issues come up with hydraulic calculations during the plan review. Chapters 19 and 27 within the 2019 edition of NFPA 13 provide the sprinkler system designer with options and requirements for hydraulically calculated systems. One common issue is figuring out the design area square footage when using the area/density method. To properly figure this out we first look at Figure 18.104.22.168.1 which calls for the area of sprinkler operation. This is not the maximum possible sprinkler spacing but the actual floor area over which the sprinklers will operate. If you are uncertain what the area per sprinkler is please see section 22.214.171.124. Sprinkler spacing is determined by discerning the larger of either the distance to the next sprinkler or twice the dimension to the wall in both directions and multiplying the two numbers together. For additional visuals on how to figure out sprinkler spacing see Exhibit 9.17 and 9.18 in the NFPA 13 Handbook. As far as spacing for extended coverage sprinklers remember, the coverage per sprinkler is based on what it is calculated for, i.e., 16′ by 16′ spacing calculated and not the maximum coverage area allowed for the sprinkler of 20′ by 20′. When locating the boundaries of the design area, the sprinkler operation only goes to the centerline between it and the adjacent sprinkler or to the wall. If you are designing a system, remember these guidelines for a successful design area calculation.
-Hannah Rodriquez, Fire Protection Consultant
NFPA 13 – 2019 Edition – Listing of FDCs
Recently, I received a phone call from a longstanding client that wanted to “ask a simple question”. The fact that they were chuckling indicated to me that it was not going to be a “simple question” and I would need to crack open the code book to answer it. As it turns out, the question was very simple and the reason he was laughing was because he had never been asked it before. “Are Fire Department Connections required to be listed?” I had to take a moment to respond, because I also had never been asked that question.
The client had been on a job site doing a final inspection and was trying to connect to the FDC to verify it was the proper size and type but could not get the connection to fit properly. Being a 4-inch Storz connection this should not have been a problem. After inspecting the connection for damage and finding none, the AHJ asked the contractor to provide documentation for the FDC to show its listing. The contractor could not provide the proper paperwork and indicated the FDC did not need to be listed.
The 2019 edition of NFPA 13, in Section 126.96.36.199, addresses the listing of equipment stating, “Unless the requirements of 188.8.131.52, 184.108.40.206, or 220.127.116.11 are met, all materials and devices essential to successful system operation shall be listed.” Section 18.104.22.168 deals with specific piping, such as copper tubing, that is not required to be listed. Section 22.214.171.124 deals with parts of the sprinkler pipe hangers, such as the threaded rod, that do not need to be specifically listed. Section 126.96.36.199 simply states “Components that do not affect system performance shall not be required to be listed.”. This would seem straight forward, until you read the annex material of this section that states “Certain components installed in sprinkler systems are not required to be listed as their improper operation will not detrimentally affect the automatic system performance. Examples include but are not limited to drain valves, drain piping, signs, gauges, automated inspection and test devices, distance monitoring devices, fire department connections that do not use threadless couplings, and so forth.”
So, like everything else in the code, the answer to the question is “it depends”. If it is a standard Siamese connection it is not required to be listed. But, if it is a Storz connection, yes, it is required to be listed.
-Matt Davis, Senior Fire Protection Consultant
Standpipe Requirements for Roofs
Standpipe systems are a necessity when fighting fires on upper floors of taller buildings such as high-rise structures. The design of these systems must be carefully planned out and be provided in locations that are the most beneficial to responding firefighters. One of the locations that can be confusing for contractors and AHJ’s are roof-top connections. Fires involving equipment commonly found on the roof, such as HAVC units and photovoltaic equipment, can be difficult to extinguish without a reliable means of getting a water stream to the roof. This is especially true when the building exceeds the reach of fire department aerial apparatus.
The wording in NFPA 14 (2013) can be a bit misleading if not read correctly. Section 7.3.2 requires that a 2 ½” hose connection be located at the highest landing of stairways with access to a roof. When the stairway does not have access to the roof, a 2 ½” hose connection needs to be provided on the roof. If the roof has a slope of 4 in 12 or greater, the hose connection is not required as the pitch makes it unsafe for firefighters to operate a fire hose line. Many people take this to mean that if the stairs do not terminate at the roof level, then the roof hose connection is required. The annex of NFPA 14 provides clarification that “access to the roof” can be defined as a permanent ladder, ladder rungs, or a pull-down stair with a roof hatch. This access to the roof must be inside the stairway with a hose connection at the highest landing in order to avoid placing a hose connection on the roof. This is so that the hose line can easily be stretched up to the roof without having to travel through other parts of the building. If the access to the roof is in another area other than within the stairway, the hose connection on the roof would be required.
-Michael Gross, Fire Protection Consultant
Keep you and your staff up to date on the latest Fire, Building and Life Safety code changes and equipment by attending one of our seminars. Fire Safety Consultants, Inc. teaches seminars all over the United States, led by our experienced staff of Matt Davis, Keith Frangiamore, Brent Gooden & Warren Olsen. Whether you are a Contractor, Architect, Technician, Engineer or an Authority Having Jurisdiction, each seminar is full of practical insight and first-hand experiences to help you comply with applicable codes and standards. Fire Safety Consultants, Inc. can also provide custom seminars at your location. Be sure to check out our website to view our listing of available seminars or to check the schedule to see what we are teaching next! Contact us to learn more by emailing email@example.com or by calling our corporate office at (847) 697-1300 x223.