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Changes to the 2014 IFC?


WanderNorth

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I make no claims to be the smartest guy in the world. I've read every post on ADI about this, and in talking to my architect, as well as the city inspectors, it appears that the exemption for quantities over MAQ in an F1 space have disappeared. I did some more digging around, and found this from 2013, on page 473 http://www.iccsafe.org/cs/codes/Documents/2012-2014Cycle/Proposed-B/05-IFC.pdf

Has anyone else heard about this change?

" There is confusion about the applicability of flammable liquid (Chapter 57) hazardous materials (Chapter 50) provisions to

distilled spirits because of the exceptions for distilled spirits and wines stored in wooden barrels and casks in IFC Chapters 50 and
57 (and NFPA 30). The issue arises because of the growing popularity of “boutique” or “craft” distillers locating their operations in
urban areas. The proposed language clarifies bulk storage provisions for distilled spirits but does not alter the intent. The proposed
language does not affect provisions applicable to use, nor those applicable to liquor storage in retail or wholesale establishments.
ICC COMMITTEE ACTION HEARINGS ::: April, 2013 F473First, note distilled spirits are Class 1C and Class 1B flammable liquids.... If a quantity of a Class 1B or Class 1C flammable liquid exceeding the MAQ, the room in which it is located is an H3 Occupancy. Please remember this applies to bulk storage (casks, barrels, metal containers, etc. exceeding 1.3 gallon capacities) and not to liquor stores and wholesale distributors for which there are several exceptions.
H occupancies have to be sprinklered. This is the primary provision overlooked because of the confusion noted above. This is not because wood is inherently safer than metal, plastic or glass – it is not. It was probably inserted in the legacy code(s) back when casks were stored in liquid storage warehouses separated by hundreds of feet from one another and urban distilleries weren’t contemplated...
applicable code requirements have not been changed. The UBC legacy code excepted distilled spirits stored in wooden barrels and casks from the secondary containment and ventilation requirements normally mandated for flammable liquids. The exception was often misinterpreted even then to extend to the entire range of code provisions. When flammable liquids requirements were brought into the IFC, the exception was moved to the scoping provisions which created the confusion recurring today. The deletion of the exception in Section 5001.1 removes the confusion associated with the applicable requirements. The modifications to Sections 5004.2.2 and 5004.3 reestablish the exceptions to secondary containment and ventilation contained in the legacy code.
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That's interesting - on page F582 of the same document, a different person (this time from Seattle) is recommending that "The storage of distilled spirits and wines in wooden barrels and casks" be added as an exception to High-hazard group H classifications. So that seems like it's inconsistent with the reason given in the section you quoted (from a Colorado fire marshal), that would make bulk storage (even in casks, over 1.3 gallon capacity) over the MAQ necessarily qualify for H occupancy, and then sprinkler requirements. He still says in his reasoning that "The Nonapplicability of Chapter 57 to distilled spirits is retained."

In any case, this document is just a proposed list of changes. I haven't seen any evidence that these changes were accepted.

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We are dealing with this exact issue with our city officials right now! They want to limit us to having no more than 480 gallons of alcohol on the premises at any time which creates a huge issue for us and they are ignoring the 1.3 gallon exception which we have already pointed out to them and trying to claim bottled product in that. Basically they've never done a distillery before so they want us to do all the work for them that they should be doing. It's extremely frustrating, does anyone have any suggestions?

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  • 1 month later...

Any update? Our fire protection engineer (required by the sprinkler company) tells us that commentary to the 2013 IFC provides that barrel storage should be counted against MAQ, despite the plain language of the exceptions. The result is an H classification instead of F1. Expensive!

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to wit:

"Exception 10 covers the storage of distilled spirits and wines in wooden barrels and casks. This statement may appear to exempt all requirements for these products from being a Group H occupancy. However, the IBC will still classify the storage area as a Group H occupancy if the amounts exceed the maximum allowable quantities (MAQs) per control area listed in Table 307.1(1) of that code for flammable or combustible liquids. All requirements for a Group H occupancy in the IBC are still applicable; however, any requirements from the code are not."

If this language is universally applied, it would force all distilleries aging in barrels to meet H occupancy requirements (which are much more stringent as far as sprinklering goes, and therefore much more expensive). The language is not very well written, so if anyone has received professional input reaching a different conclusion, I'd love to hear about it!

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Sam,

In my experience, most municipalities look to the regulations not because they want you to comply with every little detail OR because they don't want you to be in business...but simply because they are liable (in a monetary fashion) if an accident happens. You need to give them an out...usually a written document from an engineer or other professional that absolves them of liability in the case of an accident.

I was once contracted to design and install a chimney for a coffee roaster. The local guy wanted double-wall stainless on the entire run (80 feet, with a cost of nearly $10k just for the pipe) when every other roaster was using Nordfab pipe. No amount of explaining would convince him otherwise, until I had a Nordfab engineer write a letter for me...and local guy signed off on it immediately!

Maybe we collectively need to fund a short study by a fire marshall or engineer that looks at liability and danger of ethanol-water blends in the proof range that we generally store them...just so we can have a document to help us with misunderstandings on this very common DSP sticking point.

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Hey Sandy,

Where are you pulling that quote from? I can't find it in the document linked above. In any case, what is New Columbia classified as, H or F1?

PM me if you wanna chat. I'm in Takoma Park, and am working through this stuff myself too.

-Jeff

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Jeff - New Columbia are F1. Their sprinkler sub did not ask for an FPE report, and they passed city inspections. They are sprinklered, but to F1 standards. Who you talk to makes a difference, but I'm concerned that the commentary language is out there and, on the face of it, directs people to H1 conclusions....

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