DSP site requirements

[OldFriend]

Hello,
I'm trying to locate a comprehensive list of DSP site requirements. Most notably I can't find information about whether the DSP, which in our case will not be operating any mashing/fermenting/distilling equipment, has any liquid drain requirements.
Cheers!

[Thatch]

The only one who can tell you what you need is the AHJ (authority having jurisdication)  Once you present to the building inspector and/or fire inspector what you intend to do, they will tell you what you need to meet code.  This is neither a TTB nor State requirement, this has to do with building codes and fire codes and the AHJ's interpretation.

 

[Patio29Dadio]

Agree with Thatch.  However, depending on the level of distillery experience with you local building official and fire marshal, you might be better off driving this by telling them what you think is required and providing them the CYA materials they can use.   Buy the DISCUS distillery code manual and read it top to bottom, and then give them your plan and a copy of the manual (I think the Copyright permissions allow you to provide copies to people involved in your project... check it out though).   Your plan should include things like the MAQ you intend to support.   For example, if you are making something with GNS and your operation is large enough to require in excess of the MAQ allowed given your sprinklered and/or non-sprinklered control rooms, then you would be pushed into a Class-1 / Division-2 fire code classification for flammable materials and you will need a lot of things including a floor with containment gutters and a drain and might require special fire prevention.  You want to stay in Class-1 / Division-1 if at all possible.

One thing that can help is that spirits stored in barrels are arguably not included in the MAQ calculation.   But I know of some distilleries where the local officials still required sprinklers and a floor drain in the barrel storage area.  I hear that in Kentucky due to the recent barrel rickhouse collapses where whisky went into the local streams and rivers and destroyed fish and other wildlife, and made a mess out of the environment, that there is talk of requiring containment drainage ponds for any new rickhouses.

The last point I would make to anyone starting a DSP... put in floor drains.   You will regret it later if you don't.  

[Thatch]

1 hour ago, Patio29Dadio said:

One thing that can help is that spirits stored in barrels are arguably not included in the MAQ calculation.

Respectfully disagree - Spirits in a barrel are included in the MAQ per zone.  In other words, if you are F-1 the most you can have is 960 gallons MAXIMUM not in bottles.  The 960 comes from 4 x 240 (4 control areas sprinkled - your distillery and 3 others).  There may be no maximums in the fire code but there are in the building code.  If you are H-3, there is no MAQ. 

[bluestar]

On 1/2/2020 at 7:01 PM, Thatch said:

Respectfully disagree - Spirits in a barrel are included in the MAQ per zone.  In other words, if you are F-1 the most you can have is 960 gallons MAXIMUM not in bottles.  The 960 comes from 4 x 240 (4 control areas sprinkled - your distillery and 3 others).  There may be no maximums in the fire code but there are in the building code.  If you are H-3, there is no MAQ. 

There is a good ACSA safety presentation that goes through the current code, and establishes that the barrel exclusion would count in an H3 with appropriate ventilation and such. Not the F-1. Also, bottle spirits in the F-1 may count as part of the total if over 100 proof, you can get an exclusion for all bottle spirits for higher proof kept in an M occupancy, for example.

NB: corrected this last statement that previously indicated bottle spirits count toward MAQ in F-1 irrespective of alcohol concentration. As pointed out to me by @Thatch, there is an exception for product bottled below 50% ABV.

[Thatch]

On 1/2/2020 at 9:09 PM, bluestar said:

bottle spirits in the F-1 may count as part of the total if over 100 proof

Agree, the code says:  c. The quantities of alcoholic beverages in retail and wholesale sales occupancies shall not be limited provided the liquids are packaged in individual containers not exceeding 1.3 gallons. In retail and wholesale sales occupancies, the quantities of medicines, foodstuffs or consumer products, and cosmetics containing not more than 50 percent by volume of water-miscible liquids with the remainder of the solutions not being flammable, shall not be limited, provided that such materials are packaged in individual containers not exceeding 1.3 gallons.

[Patio29Dadio]

22 hours ago, Thatch said:

There may be no maximums in the fire code but there are in the building code. 

This gets back to my point that it depends on your local building official as most will gladly turn over all fire hazard code compliance decision to the fire authority.   The fire code is at worst ambiguous about alcohol storage in wooden vessels.   In my visits to most craft distilleries around the nation, I would say that most have barrel storage in their bonded space excess of the MAQ and with C1-D1/F1 occupancy compliance only.   If you consider a barrel room a control room where the contents apply to the MAQ, then you could store about 5 full sized barrels before being put into H3.  This business is already expensive enough without going to extremes in code compliance over things that can be interpreted away.  I would always point to the fire code over the building code in this case.  Let the building official lead the push to H3, but don't offer up that advice.  The move up from C1-D1 can add several tens, if not hundreds, of thousands to the build cost.  For example, it might require ripping out the existing sprinkler system and replacing it for the higher capacity required. 

My experience is that fire will be more concerned about high-stacking of barrels.... depending on your ceiling height and classification of your building sprinklers. 

But I am sure that everyone will have a difference experience with their local building official.  These guys are generally CYA professionals... so your best approach is to convince them that their A will not be in hot water for what you are doing. 

[Thatch]

On 1/2/2020 at 4:21 PM, OldFriend said:

liquid drain requirements.

Back to the OP's post, spill control, drainage, and containment all refer to the International Fire Code where barrels are exempt.  So, if you are storing in barrels, you should not be mandated to have any of the listed safeguards.  But, as it has been said many times before, this is up to your AHJ.  If he thinks you need them, you need them.  

With regards to your question on a list of site requirements, this code review document should be helpful,

This is a code review for a classification change from F-1 to H-3.  Although this references mostly Ohio Building Code the numbers should correspond directly to IBC and your local code.  

Preliminary Code Review to Convert Existing Malt House F-1/S-1 to H-3

Existing Building

Use Group H-3 - Distillery and spirit storage

Table 307.1(1) – Spirits at 50% alcohol or less is a 1C flammable liquid and requires an H-3 use group when the MAQ of 120 gal x 2 = 240 gal is in use or storage is exceeded.

OBC 414 – Hazardous Materials

414.1.3 – Report required to be submitted to AHJ describing max quantities and types of hazardous materials to be in-use or stored

414.3 Ventilation – Mechanical ventilation required. 1 CFM/SF continuous in areas or spaces where flammable vapors may be emitted due to processing, use, handling or storage. Make up air likely required.

414.5.1 – Explosion control is not required per OBC Table 414.5.1 – 1C not listed.

414.5.2 – Standby power may be required for the continuous ventilation. This would be exempt if the 1C flammable liquid is stored in containers not exceeding 6.5 gal.

IFC 2704.2.1 – Spill control needed if storage is in individual vessels of more than 55 gals. The barrels are smaller than 55 gal so no spill control needed.

IFC 2704.2.2 – Secondary containment is not required.

OBC – 415 Detailed requirements for H Groups

415.3 – Fire Alarm monitoring of sprinkler riser. Existing, complies.

415.4 – Automatic sprinkler. Design should be review for the change of use/occupancy.

415.5.1 – Emergency alarm. Local manual alarm outside of egress from a storage area is required.

415.6 – Greater than 25% of the perimeter wall is exterior wall, Complies.

415.6.1 – Group H minimum fire separation distance.

OBC Table 602 – Exterior wall fire-resistance rating based on fire separation distance. 26’ separation distance to the east and west property lines requires a 1 HR exterior wall rating for an H use group.

OBC CH 5 – Building area. Existing building area is 13,246SF is less than Table 506.2 14,000SF for a IIB, H-3. Complies without open perimeter or sprinkler area increases.

OBC 706 – Fire walls. A 2 HR rated fire wall exists between the 5B (combustible) B-use office and the 2B (non-combustible) F-1/S-1 to separate building construction type. Table 706.4 requires a 3 HR rated fire wall for an H-3 use group.

[OldFriend]

On 1/2/2020 at 5:13 PM, Patio29Dadio said:

Agree with Thatch.  However, depending on the level of distillery experience with you local building official and fire marshal, you might be better off driving this by telling them what you think is required and providing them the CYA materials they can use.   Buy the DISCUS distillery code manual and read it top to bottom, and then give them your plan and a copy of the manual (I think the Copyright permissions allow you to provide copies to people involved in your project... check it out though).   Your plan should include things like the MAQ you intend to support.   For example, if you are making something with GNS and your operation is large enough to require in excess of the MAQ allowed given your sprinklered and/or non-sprinklered control rooms, then you would be pushed into a Class-1 / Division-2 fire code classification for flammable materials and you will need a lot of things including a floor with containment gutters and a drain and might require special fire prevention.  You want to stay in Class-1 / Division-1 if at all possible.

One thing that can help is that spirits stored in barrels are arguably not included in the MAQ calculation.   But I know of some distilleries where the local officials still required sprinklers and a floor drain in the barrel storage area.  I hear that in Kentucky due to the recent barrel rickhouse collapses where whisky went into the local streams and rivers and destroyed fish and other wildlife, and made a mess out of the environment, that there is talk of requiring containment drainage ponds for any new rickhouses.

The last point I would make to anyone starting a DSP... put in floor drains.   You will regret it later if you don't.  

Thank you for this reply. We're looking at a setup right now where the whiskey barrels (sourced) would be stored in a very secure ex-grain silo, and we would have an adjacent blending/bottling room. The Bottling room would be much easier to install a drain and sprinklers than the silo. But it sounds like in some cases the storage area would need a sprinkler system and maybe drainage. Probably best for us to contact local officials?

[Patio29Dadio]

1 hour ago, OldFriend said:

Probably best for us to contact local officials?

My opinion here is that you educate yourself and develop your own basis.  A basis is an opinion based on fact, evidence, documentation, etc..   Then you go to your officials and provide them with your plans including everything you think you need for compliance.  In my opinion I would use the fire code for the barrel storage to make the case that you don't need sprinklers there, and you don't need floor drain.  As Thatch points out, the building code seems to say that barrels are included in the Maximum Allowed Quantity (MAQ) calculation and thus it would easily push you requirements to nasty land.

Show the sombrero of death requirement 10 ft from all stills and below 36" from the floor for needing explosion proof electrical.  That will impress them.  It will cost you a bit more, but should not break the bank... and you will more likely not blow up your distillery.  Also make sure you talk about keep the barrels stacked no more than 2 high.  That will prevent the high-stacking concern that some fire officials are trained to light up on.  After the CofO you can certainly decide to go higher.

In the end you are at the mercy of your local officials.  If they are ignorant to the code, they can make your life miserable.  If they are knowledgeable of the code they can make your life miserable.  In my experience, if they are short men they will make your life miserable.   

[OldFriend]

1 hour ago, Patio29Dadio said:

Show the sombrero of death requirement 10 ft from all stills and below 36" from the floor for needing explosion proof electrical.  That will impress them.  It will cost you a bit more, but should not break the bank... and you will more likely not blow up your distillery. 

No stills in our business model, just sourcing barrels of whiskey. Which hopefully simplifies things with fire code.
Thanks for the good info!

[Patio29Dadio]

That should simplify things substantially!

[bluestar]

Since the original question pertained to drains, also note that a DSP is considered a food process plant by the federal government, and you must be registered as such. Generally, the inspection of such plants is delegated by the federal government to the state governments, sometimes the agriculture departments. So, the issue of drains might be a requirement set by the state for that reason, too. In this case, if no production or processing is going to occur, and the space will ONLY be used as storage of barrels, you might be able to treat it as warehouse only space, and avoid any food or sanitation requirements. Again, local authority will apply. By the way, this does not change the requirements for fire code, etc.

[starcat]

The AHJ can tell you what they want to see for sure, but both they and the GC are going to tell you you need an Engineers stamp to proceed. Getting a really good set of architectural drawings which include all aspects of the build out for this craft can be challenging. In order to get the best possible result, you need some expertise in your camp that ideally is very well versed in Industrial Electrical-Mechanical systems. This will help both raise the correct questions and get you the system that is going to work the best for your needs. For sure it will be helpful to visit working production facilities of a similar size and scope that are well done.