Building & Fire Codes

Building and fire codes have been developed to preserve life and property. One concept used in the modern era is to separate hazardous chemicals with fire resistive barriers.ⁱ This is known as the ‘Control Area’ for most occupancies and for specifically constructed academic research facilities ‘Lab Suite’.

The building code identifies the construction details of buildings based on the requirements at the time the structures are substantially designed. The fire code applies limits to activities within and adjacent to each building on an on-going basis.

Fire Code Progression

Prior to 1994, states and localities in the U.S. generally followed one of four codes:

• the National Fire Prevention Code
• the Standard Fire Prevention Code
• the Uniform Fire Code 
• National Fire Protection Association (NFPA) 1 – Fire Prevention Code

In 1994, the International Code Council created the International Fire Code (IFC). Today, most governmental agencies’ codes are based upon the IFC.ⁱⁱ  Prior to 2000, the IFC did not include any comprehensive Maximum Allowable Quantity (MAQ) limits.ⁱⁱⁱ  The 2000 IFC, with modifications, became the 2001 California Fire Code (CFC). This code established definitions and limits for 34 physical hazard classes and 6 health hazard classes.  

Starting in 2001, California Fire Codes systematically limited the maximum quantities of chemicals in ’control areas’. Limits are by physical state at ‘normal temperatures and pressures’, hazard type & class, locations in or near a building, type of storage, use and design of the building. There can be up to 4 control areas in a building, not exceeding 10,000 square feet each. The code established 8 high hazard occupancies. ‘B’ for business occupancy can still include laboratories.

In 2015 IFC (2016 CFC), MAQ rules changed again. Now, more control areas (or lab suites) are allowed which vary in allowed number by floor (Table 1 & Table 2). A percentage reduction is imposed by floor (Table 3). The 2001 hazardous hazard classes were also updated and now include 44 physical hazard classes and 3 health hazard classes. 

Applying the Fire Code to MAQs

Enforcement of MAQ limits has been mostly absent. Each municipality or Authority Having Jurisdiction (AHJ) has relied on an analysis of the MAQ limit compliance when a major remodel or with the construction of new building by requiring the creation of a Hazardous Materials Inventory Statement (HMIS). To obtain these statements requires the architect or owner to identify the quantities of chemicals by hazard classes and control areas, projecting their ‘storage’ and ‘in-use’ amounts. This is a complicated task and doing the work manually is time-consuming. Accurate analysis requires a complete, accurate chemical inventory and chemicals hazards being classified using Fire Code definitions. In addition, the building fire control features and control areas must be properly identified.  Where the fire code allows, hazardous chemicals stored in approved containers need to be accounted for so their limit can be adequately calculated. For most hazard classes, placing chemicals in approved storage allows a doubling of the amount stored in the control area.

The relevant building-related criteria that impact MAQ limits are as follows:

1. The fire code year the Authority Having Jurisdiction applies to the hazardous material use.
2. The presence (or absence) of a compliant building-wide automatic fire suppression system.
3. Each floor assigned relative to the ‘grade plane’ as defined in the code.
4. Each control area must have the sufficient fire resistive construction as required by code. This can include periodic inspections of the facility to ensure the fire barriers have not been compromised.
5. All rooms in the control area are identified.
6. The right occupancy for each control area must be selected based upon the occupancies of all the rooms in the control area.

The MAQ codes affect the allowed storage in systematic ways:

• Prohibitions of hazards based on automatic fire suppression & approved storage.
• Reduced allowed amounts above and below grade.
• Reduced allowed numbers of control areas above and below grade.
• Increased allowed amounts based on automatic fire suppression.
• Increased allowed amounts based on approved storage.
• Limits can vary between groups of occupancies.

There are hazard classes only allowed in buildings protected fully by automatic fire suppression systems (fully sprinklered):

• Explosives
• Organic Peroxide Class UD (Unclassified detonable)
• Pyrophorics
• Unstable Reactive Class 4
• Oxidizer Class 4

Likewise, there is one hazard class in two states of matter, that are only allowed in control areas with approved enclosed exhausted storage:

• Highly Toxic Gas
• Highly Toxic Liquified Gas

Fire Code Hazardous Materials Classification

Fire code hazardous classification requires a deep understanding and application of physical, chemical, and epidemiological data. The definitions in the code vary widely in their specificity and so how they are applied is a significant challenge. Some code definitions are clear and quantitative (e.g., flammability), while others are qualitative and not clear (e.g., oxidizers).  Different states in the U.S. vary in their adoption of NFPA standards (e.g., 30, 45, 55, 400). The code often includes non-mandatory examples based on historical events.

One of the primary sources of reliable information about a chemical product is the Safety Data Sheet provided by the supplier to the end user. However, OSHA adopted the Globally Harmonized Standard, resulting in the absence of fire code hazard classes of their products on SDS.

Currently there is an effort to align some of the less clear hazard classes to the GHS Hazard Statements/H codes, however this is in the initial stages. You find the comparison in the 2024 International Fire Code.

The fire code requires an evaluation of the state of matter at normal temperatures and pressures (20 C (68 °F), 1 atm (101.32501 kilopascal, 1.0132501 bar)).  Many chemicals with low melting points, or which are slightly contaminated, may appear as a liquid even though their melting point is above 20 C. As most liquids are subject to more stringent restrictions than are most solids, a practical approach to this determination is required.  
In the category of physical hazards, there are two classes that are gas only (flammable & oxidizing gases); eight classes that include all three states of matter: solid, liquid, and gas; there are eleven classes that are liquid only and there are eighteen classes which are solid & liquid only.

Fire Code Occupancies

Accurate fire code classification of chemical hazards is a challenge. A single chemical can belong to more than one hazard class and the lowest MAQ limit for any of the classifications, take precedence. Table 5003.1.1(1) from the fire code (See Figure 1.) shows how occupancy classifications are applied once MAQs have been exceeded.

Most fire code occupancies use the same MAQ tables. Variations exist based upon occupancy and laboratory suite. M & S occupancies have a different table from ‘B’ and most others. Here’s a list of occupancies:

Assembly Group (A)

• A-1: Theaters and similar spaces with fixed seating for viewing performances.
• A-2: Places where food and drink are consumed, such as restaurants and nightclubs.
• A-3: Spaces for worship, recreation, or other assembly purposes not classified under A-1, A-2, A-4, or A-5, such as libraries and art galleries.
• A-4: Indoor sports facilities with spectator seating.
• A-5: Outdoor sports and entertainment venues.

Business Group (B)

• Office buildings, professional services (e.g., law offices, medical offices), and similar facilities. (Can include labs)

Educational Group (E)

• Schools and day care centers for children up to the 12th grade.
  Factory and Industrial Group (F)
• F-1: Moderate-hazard industrial uses, such as manufacturing and processing operations.
• F-2: Low-hazard industrial uses, such as beverage manufacturing.

High-Hazard Group (H)

• H-1: High hazard materials likely to detonate.
• H-2: High hazard materials posing a deflagration hazard.
• H-3: High hazard materials presenting a physical hazard.
• H-4: High hazard materials presenting a health hazard.
• H-5: Semiconductor fabrication facilities using hazardous production materials (HPM).

Institutional Group (I)

• I-1: Residential care facilities with more than 16 occupants.
• I-2: Medical care facilities with overnight stays, such as hospitals and nursing homes.
• I-3: Detention facilities, such as jails and prisons.
• I-4: Day care facilities for more than five persons of any age.

Mercantile Group (M)

• Retail stores and other facilities for the display and sale of merchandise.

Residential Group (R)

• R-1: Hotels and motels where occupants are primarily transient.
• R-2: Apartments and dormitories where occupants are primarily permanent.
• R-3: Single-family homes and duplexes.
• R-4: Residential care and assisted living facilities for more than five but not more than 16 occupants.

Storage Group (S)

• S-1: Moderate-hazard storage, such as for combustible materials.
• S-2: Low-hazard storage, such as for non-combustible materials.

Utility and Miscellaneous Group (U)

• Buildings and structures not classified under other groups, such as agricultural buildings, sheds, and towers.

Tables

Appendix

Appendix A – List of Historical Fires and Effects

• 64 AD Rome burns, Nero Emperor 
• 1631 Boston 1st Fire Ordinance outlawed building wooden chimneys and thatched roofs
• 1648 New Amsterdam Governor appoints four Fire Wardens to inspect proper cleaning and construction of chimneys.
• 1666 London Great Fire, started in bakery, 80% of the city burned.
• 1871 Chicago Great Fire, started in O’Leary’s barn, 30% of the city burned Commemorated 1st week each October – motivated first fire and building codes.
• 1871 Peshtigo Fire in Wisconsin and Michigan 23 towns, ~1,500 people
• 1872 Boston Great Fire started basement of warehouse prompted more code changes.
• 1812-1890 Automatic Sprinkler Systems developed.
• 1903 Chicago Iroquois Theater Fire, 602 people died, created federal and state standards for exiting pathways, exit doors, exit signs and markings, maximum seating, and the use of the panic bar.
• 1904 Baltimore Fire started in basement, 2500 buildings destroyed, developed standards for fire hose coupling.
• 1904 General Slocum Wheel Boat Fire, 1030 passengers dead, federal and state regulations to test and destroy defective equipment.
• 1909 San Francisco Fire & 7.9 Earthquake, 90% of the city damaged, 450 died, 300,00 homeless.
• 1911 Triangle Shirtwaist Company Fire started in scrap bin by un-extinguished match or cigarette, 164 people died: developed NFPA 101 (Life Safety Code)
• 1929 Cleveland Clinic Hospital Fire, started in x-ray film in basement, 121 people died, caused requirements for film. 
• 1930 Ohio Penitentiary Fire started with candle igniting oily rags, 320 prisoners died; jails and prisons were included in new Life Safety Code
• 1934 SS Morro Castle Fire, Luxury cruise ship, 135 passengers 
  and crew died.
• 1940 Rhythm Club Fire in Natchez, Mississippi, 209 people died.
• 1942 Cocoanut Grove Night Club Fire, Boston, 200 people died, 
  Life Safety Code changes: Outward swinging doors, fire suppression systems and more.
• 1942 Knights of Columbus Hall Fire, Newfoundland Canada, 100 people died.
• 1944 Ringling Brothers Circus Tent Fire, 100 children and 69 
  adults died; NFPA Standard 102 was created; 2000 International Building Code and 2003 NFPA 5000.
• 1946 Winecoff Hotel Fire, Atlanta, 120 guests and staff died.
• 1947 Texas City SS Grandcamp Fire, 2,300 tons of ammonium nitrate ignited; shock wave felt 100 miles away, 567 people died
• 1949 St. Anthony Hospital Fire, 74 people died, changes in code required fire and smoke barriers and fire-resistant stairway enclosures.
• 1958 Our Lady of the Angel’s School Fire 92 children and 3 nuns died, some codes changes were applied. 
• 1961 Los Angeles Wildfire, brush fire in Sherman Oaks, 16,090 acres, 610 houses and structures burned, code requires fire resistant roofs.
• 1967 Apollo 1 Fire, oxygen enriched atmosphere ignited with spark, 3 astronauts died.
• 1977 Beverly Hills Supper Club Fire, South Gate, Kentucky, deficient electrical wiring, inadequate exits and design, 167 people died, changes required sprinklers in nightclubs and large assembly areas.
• 1980 MGM Grand Hotel Fire, Las Vegas caused by electrical wires, 84 people died, mostly from smoke.
• 2003 The Station Nightclub Fire, West Warwick, Rhode Island, sparks from pyrotechnics caught non-fire-resistant soundproof boards, 100 people died.

ⁱ Lessons learned include: Use of fire-resistant materials, clear, safe exit ways, segregation of hazards, decreasing the allowed hazard amounts above and below grade, use of automated fire suppression systems, and control contaminated suppression water.

ⁱⁱ 3/10/2020 Koorsen Fire & Security 

ⁱⁱⁱ M. Hall, personal communication, March 22, 2018

Author

Russ Vernon, Ph.D.
EH&S Business Development Manager
Risk and Safety Solutions