Jay

NFPA Barrel storage exception

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Does anyone know what section of the NFPA addresses the barrel storage exception from contributing to MAQ's?

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NFPA 30:

Chapter 6 Container and Portable Tank Storage

6.1 Scope.

6.1.1 This chapter shall apply to the storage of liquids in drums or other containers that do not exceed 450 L (119 gal) individual capacity, in portable tanks that do not exceed 2500 L (660 gal) individual capacity, and in intermediate bulk containers that do not exceed 3000 L (793 gal) and to limited transfers incidental thereto. This chapter shall also apply to overpack drums when used for temporary containment of containers that do not exceed 230 L (60 gal) capacity. Such overpack containers shall be treated as containers as defined in 3.3.7.

6.1.2 This chapter shall not apply to the following:

  1. Containers, intermediate bulk containers, and portable tanks that are used in process areas, as covered by Chapter 5
  2. Liquids in the fuel tanks of motor vehicles, aircraft, boats, or portable or stationary engines
  3. Beverages, where packaged in individual containers that do not exceed 5 L (1.3 gal) capacity
  4. Medicines, foodstuffs, cosmetics, and other consumer products that contain not more than 50 percent by volume of water-miscible liquids, with the remainder of the solution not being flammable where packaged in individual containers that do not exceed 5 L (1.3 gal) capacity
  5. Liquids that have no fire point when tested by ASTM D 92, Standard Test Method for Flash and Fire Points by Cleveland Open Cup, up to the boiling point of the liquid or up to a temperature at which the sample being tested shows an obvious physical change
  6. Liquids with a flash point greater than 35°C (95°F) in a water-miscible solution or in dispersion with a water and inert (noncombustible) solids content of more than 80 percent by weight, which do not sustain combustion when tested using the “Method of Testing for Sustained Combustibility,” per 49 CFR 173, Appendix H, or the UN Recommendations on the Transport of Dangerous Goods
  7. Distilled spirits and wines in wooden barrels or casks

source: https://law.resource.org/pub/us/cfr/ibr/004/nfpa.30.2003.html

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Thanks Guys, local fire is reinspecting based on recent accidents(KY). I attended the House Spirits seminar @ ADI and it looks like it's only a matter of time until this effects more of us.

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I know there's a proposal to remove the barrel exemption from the next IFC revision.

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Existing would certainly be grandfathered, I'm sure. Under the proposal, sprinklers would be required for distilled spirit storage quantities over the Class 1C flammable liquid MAQ, up to 10 feet in height, 2 racks (flu space) with 3 barrels per row in each rack, or single rack with 4 barrels per row.

Here's the link to the full proposal (search for F127 – 13): http://www.iccsafe.org/wp-content/uploads/00-CompleteGroupB-MonographUpdates.pdf

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It's only a matter of time. The frequency and severity of accidents is clearly increasing. With the recent explosive growth of the industry, this will reach critical mass, and if the authorities don't cry uncle, the insurers will. Then everyone is going to feel the pain. You better take your insurance guy out to a nice dinner, and make a donation to your local fire district.

While DISCUS clearly is an attempt at the larger commercial industry self-regulating. It's clear that the smaller craft producers have no appetite to attempt the same kind of self-regulation and policing. If the current flow of conversation on the interwebs is indicative, there is about a 100 to 1 ratio of "How cheaply can I start a distillery" to "What's the safest way" conversations, and this points to problems. Avoidance topics outnumber compliance topics just the same.

The few folks that have tried to start the conversation haven't really been successful. I really wish there were more conversations here about how to cost effectively meet the spirit and letter of the regulation, versus trying to sidestep it.

Most of us here want to invest, and invest in safety specifically - but want to do it in a way that makes sense. That's the information I'd love to have access to.

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Barrel exemption does not exempt barrels from sprinklers, alarms, or 1 hour separation, it does exempt them from ventilation, spill control, and explosion control...

This is due to the Building Code and Fire Code inter-relationship more than just the fire code alone... it is not something you can determine from one paragraph in one code. Hire a fire code consultant if you want to get the least effort and cost to be legal....

Now... we have all seen places in excess of the MAQ with and without lots of barrels, without sprinklers... that is 100% on the AHJ, so don't expect a distillery in or not in your same jurisdiction to go to bat for you when you want a lax interpretation of the codes...

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Has anyone had to deal with this in California? We are being told by our local fire marshal that this would apply if the CA Fire Code points to this NFPA section as reference. If it does not, then it was not adopted by CA as approved.

UPDATE = Chapter 57 of the Calif. Fire Code states the same statement about wooden barrels or casks.

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The trouble with most codes is they are not written for craft distillers. The other trouble is most people (inspectors) do not know the code and due to some incidents like the JB fire and Heaven Hill and Wild Turkey they look at alcohol like it is gasoline! It is NOT. I had the fire dept come out and they said they tried to light a barrel on fire and poured diesel on it and it still would not burn! Now lightning...that is a different animal. 

If you find an intelligent and sensible inspector they will know that ethanol does not burn even close to gasoline. But even in Kentucky there are no sensible inspectors! The thing is the test for flammability is "closed cup" meaning if a vapor forms and is ignitable then the liquid is flammable. Well your distillery is NOT a closed cup and as long as you have air circulation you will not accumulate enough vapor to ignite. The insurance industry states that within 1 meter of a vapor source the vapor is no longer ignitable. And the vapor is heavier than air so the source of ignition must be below 18 inches from the floor.

And just to be clear water does not put out an ethanol fire UNLESS the water entirely covers the fire. So if you have a fire about 6 feet in diameter and spray with water hose it will most likely not go out. The water provides a medium for the alcohol to "move" with the water meaning the fire will spread with the water. 

And do not confuse the story of distillery explosion in KY with this issue. The cause there was completely different. And by the way wood and paper and other things burn too.

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