Over 200 pages of NFPA 1 (including Annexes) are dedicated to the storage, use and handling of hazardous materials. We receive many questions asking hazardous materials-related questions from fire inspectors, AHJs, and others, trying to better understand how to apply provisions to help them with their day to day job enforcing Fire Code requirements. Most commonly we hear from users about how to determine the maximum allowable quantity (MAQ) of a hazardous material and how to properly protect a space with hazardous materials.
Inspectors are responsible for enforcing the safe use and presence of hazardous materials, which include aerosols, compressed gases and cryogenic fluids, corrosives, explosives, flammable and combustible liquids and solids, toxic materials, oxidizers and LP Gas. The amount of material in the Code that one needs to understand in order to safely apply it can be complex and even overwhelming. There are several key terms that must be understood first before applying the Code:
- Maximum Allowable Quantity (MAQ). The quantity of hazardous material permitted in a control area. This term is deceiving. NOTE! --> While the term is referred to as "maximum", it really means that the material allowed is the maximum quantity per control area before requiring additional protection. So, its not really a "maximum", rather a threshold before additional requirements kick in.
- Control Area. A building or portion of a building or outdoor area within which hazardous materials are allowed to be stored, dispensed, used, or handled in quantities not exceeding the maximum allowable quantities (MAQ).
- Protection Level. While not an officially defined term in the Code, but, where the quantity of hazardous materials in storage or use exceeds the MAQ for indoor control area the occupancy is required comply with additional protection requirements (referred to as Protection Level 1, 2, 3 or 4.)
Here are the first steps for a fire inspector, facility personnel or designer planning for the presence of these materials in their building:
1. Classify the hazardous material
2.Determine the quantity of hazardous material to be use
3. If the quantity exceeds the MAQ for a single control area, one can either apply the provisions for the various protection levels, or apply provisions for multiple control area
4. If the quantity does not exceed the MAQ for a single control area, no special construction features are required
To apply steps 3 and 4, an inspector needs to know what the permitted MAQ is for the particular occupancy. Table 220.127.116.11.1.3 presents what can be termed the “general” MAQs. These are maximum quantities of hazardous materials that are considered to be appropriate for industrial, mercantile, or storage occupancies without the need for special protective measures. This is used to determine the MAQ for any given material, unless the MAQ for the specific occupancy is different. In that case, the MAQ in the occupancy-specific table applies.
The following steps should be followed when using Table 18.104.22.168.1.3:
- The category of the hazardous material should be determined, based on the classification of the material and the definitions within the Code. Without this basic information, the limits and protection features cannot be identified. All physical and health hazards associated with the hazardous material must be identified and classified so that each risk can be determined and the protection features or limits can be specified.
- The use of the hazardous material in a building must be understood so that appropriate limits can be established. These uses are generally categorized as storage, use-closed, and use-open. The storage category is designed for a hazardous material that is intended to enter a building in a container, cylinder, or tank and is not removed from the original container, cylinder, or tank in the storage room or control area. If the hazardous material is shipped to the site, stored, then shipped off-site, only the storage column of the table is used.
- If the material is used in a process, the process system must be reviewed to determine whether it is classified as use-closed or use-open. Closed use and storage have very similar risks and are treated the same with respect to MAQ. Open use is considered the most hazardous and, therefore, is most restricted with respect to an MAQ 4
- Apply the appropriate footnotes (there are quite a few!) Information in the footnotes may modify the values in the Table so this step cannot be overlooked.
Chapter 61 through 75 then contain requirements to specific types of hazardous materials (for example, Chapter 63 contains requirements for compressed gases and cryogenic fluids.) Most of these provisions are extracted into NFPA 1 from the respective NFPA documents (NFPA 30, Flammable and Combustible Liquids Code; NFPA 58, Liquefied Petroleum Gas Code...)
Understanding how to properly protect areas with the storage, use or handling of hazardous materials benefits both life safety and property protection. In addition to understanding how to properly protect these areas, fire inspectors are required to meet the minimum professional qualifications established in NFPA 1031, Standard for Professional Qualifications for Fire Inspector and Plan Examiner. One way to accomplish this is with a Certified Fire Inspector (CFI) certification, which includes demonstrating knowledge on protecting areas with hazardous materials. These programs were created back in 1998 in response from local jurisdictions for a certification program based on the competencies in NFPA 1031. Starting in NFPA 1, 2018 edition, compliance with NFPA 1031 is mandated for all fire inspectors and plans examiners. The NFPA CFI I and CFI II certification programs are one way to demonstrate compliance with this requirement, promote professionalism in the role of a fire inspector, help demonstrate and understanding of the application and use of codes and standards, and improve job performance. For more information on these programs and how to enroll, visit their page.
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Thanks for reading!