Furniture Stores & Furniture Warehouses. Guidance for Code Officials

Furniture Stores & Furniture Warehouses Assessing the Hazard Guidance for Code Officials Prepared by Robert J. Davidson Fire & Life Safety Consultan...
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Furniture Stores & Furniture Warehouses Assessing the Hazard

Guidance for Code Officials

Prepared by Robert J. Davidson Fire & Life Safety Consultant

August 28, 2007

T A B L E O F C O N T E N T

S

Table of Contents Page 1.

Introduction

1

2.

The High Hazard Group

4

3.

How Much Furniture Equals 125 or 250 lbs.

8

4.

NFPA Correlation

25

5.

Enforcement Action

31

6.

Summary

33

Appendices A. IBC H Group Decision Matrix B. NFPA 5000 High Hazard Decision Matrix C. VTECH Poly Foam Analysis Report D. Internet article, “How is Plastic Made”, “Flexible Polyurethane Foam Glossary”,; and reference to “Polyurethanes” as a “urethane chemical” by “BASF The Chemical Company” E. NBSIR 82-2604, “Upholstered Furniture Heat Release Rates Measured with a Furniture Calorimeter” F. NBS Special Publication 749, “Fire Hazard Comparison of Fire-Retarded and Non-Fire-Retarded Products” G. “Products – Fire Safety – Material Safety Data Sheet” H. Resume of Robert J Davidson, Fire & Life Safety Consultant

Introduction

S E C T I O N 1

1.

Introduction

Historically a furniture store has been classified as an M - Mercantile occupancy under the model codes and the storage of furniture has been classified as an S - Storage 1 occupancy. These classifications were based upon the common understanding of fire loads presented by the materials. Recent testing has identified that those classifications have been in error for numerous occupancies. The polyurethane foam utilized for cushions and other upholstery associated with furniture pieces has been tested in accordance with the test method of CPSC 16 CFR, Part 1500.44 and has been documented to burn with a self sustained flame rate greater than 0.1 inch per second along its major access. 1 Based upon this testing polyurethane foam has been identified as a “Flammable Solid” which is regulated as a hazardous material by the International Building Code and the International Fire Code. 2 “FLAMMABLE SOLID. A solid, other than a blasting agent or explosive, that is capable of causing fire through friction, absorption or moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which has an ignition temperature below 212°F (100°C) or which burns so vigorously and persistently when ignited as to create a serious hazard. A chemical shall be considered a flammable solid as determined in accordance with the test method of CPSC 16 CFR; Part 1500.44, if it ignites and burns with a self-sustained flame at a rate greater than 0.1 inch (2.5 mm) per second along its major axis.” (Emphasis added) 3 Some may question this determination because of the use of the term “chemical” in the sentence referring to the CPSC test method. The term “chemical” is not defined in the International Building Code or the International Fire Code. However, the fire code directs the user to “Webster’s Third New International Dictionary of the English Language, Unabridged,” to determine the ordinarily accepted meanings of undefined terms. “201.4 Terms not defined. Where terms are not defined through the methods authorized by this section, such terms shall have ordinarily accepted meanings such as the context implies. Webster’s Third New International Dictionary of the English Language, Unabridged, shall be considered as providing ordinarily accepted meanings.” Webster’s Third New International Dictionary of the English Language, Unabridged, defines “chemical” as follows: 2 Main Entry: chemical Function: noun “: a substance (as an acid, alkali, salt, synthetic organic compound) (emphasis added) obtained by a chemical process, prepared for use in chemical manufacture, or used for producing a chemical effect see FINE CHEMICAL, HEAVY CHEMICAL” 1

See test report dated November 2, 2006 prepared by VTech Laboratories, Inc. See Section 307.1 of the 2006 International Building Code and Section 2703.1 of the 2006 International Fire Code. 3 See Section 307.2, 2006 International Building Code. 2

1

Polyurethane is a synthetic organic compound 4 , i.e., a chemical. The CPSC test method referenced supports the application of this concept by providing a test method for “Rigid and pliable solids”. “TITLE 16--COMMERCIAL PRACTICES CHAPTER II--CONSUMER PRODUCT SAFETY COMMISSION PART 1500_HAZARDOUS SUBSTANCES AND ARTICLES; ADMINISTRATION AND ENFORCEMENT REGULATIONS Sec. 1500.44 Method for determining extremely flammable and flammable solids. (a) Preparation of samples— (1) Granules, powders, and pastes. Pack the sample into a flat, rectangular metal boat with inner dimensions 6 inches long x 1 inch wide x one-fourth inch deep. (2) Rigid and pliable solids. Measure the dimensions of the sample and support it by means of metal ringstands, clamps, rings, or other suitable devices as needed, so that the major axis is oriented horizontally and the maximum surface is freely exposed to the atmosphere. (b) Procedure. Place the prepared sample in a draft-free area that can be ventilated and cleared after each test. The temperature of the sample at the time of testing shall be between 68 [deg]F. and 86 [deg]F. Hold a burning paraffin candle whose diameter is at least 1 inch, so that the flame is in contact with the surface of the sample at the end of the major axis for 5 seconds or until the sample ignites, whichever is less. Remove the candle. By means of a stopwatch, determine the time of combustion with self-sustained flame. Do not exceed 60 seconds. Extinguish flame with a CO2 or similar nondestructive type extinguisher. Measure the dimensions of the burnt area and calculate the rate of burning along the major axis of the sample.” Even without the reference to the CPSC test method in the last sentence, the definition also includes the phrase, “or which burns so vigorously and persistently when ignited as to create a serious hazard.“ Clearly polyurethane foam products meet this characterization. This determination, (characterization as a flammable solid), should not be a surprise. The hazards of polyurethane foam related to its burning characteristics have long been recognized through scientific testing. 5

4

See Internet article, “How is Plastic Made”, published by PlasticResource.org; Definitions of “Polymer” and “Polyurethane” listed in an Internet based “Flexible Polyurethane Foam Glossary”, published by the Polyurethane Foam Insulation”; and reference to “Polyurethanes” as a “urethane chemical” by “BASF The Chemical Company” at http://www.basf.com/urethanechemicals/”. 5 See NBSIR 82-2604, “Upholstered Furniture Heat Release Rates Measured with a Furniture Calorimeter”, published by the U.S. Department of Commerce, National Bureau of Standards, December 1982; and NBS Special

2

The hazards are also clearly recognized by industry. In the MSDS for their poly foam products the Penn Foam Corporation lists the following hazard information 6 : Section I - Identification Name: Chemical Type: Trade names & Synonyms

Flexible Polyurethane Foam Polyether based urethane polymer Flexible polyurethane foams, PUR foams, flexible foam, foam rubber, CAL 117 foams, high comfort foams, HR foams, Rebond foam, ether foam

Section IV - Fire and Explosion Hazard Data Unusual Fire Hazards: Rapid flame spread, intense heat, dense smoke, toxic gases. Can turn into a burning liquid. Section V - Reactivity Data Conditions to Avoid: Open flame, ignition source. Section VII - Precautions for Safe Handling & Use Waste Disposal Method: …NEVER smoke, use naked lights, open flames, exposed electrical elements or other ignition sources near stored foam. Do not allow cuttings or foam scrap to accumulate. Handling: Precautions: WARNING - terms such as "fire-retardant" and "flame resistant" are used only to describe flammability properties, they do not mean or imply fire safety under all conditions. Small scale fire tests are NOT INTENDED TO REFLECT HAZARDS PRESENTED BY THESE OR ANY OTHER MATERIALS UNDER ACTUAL FIRE CONDITIONS. Storage: Precautions: Store buns, blocks, sheets, and fabricated items indoors under the appropriate sprinkler protection. Storage should be in accordance with your particular sprinkler system's recommendations for this type of material. Make sure heights and aisle ways are kept in accordance with your sprinkler systems requirements. Check with your local fire department or your insurance company for specific details and recommendations. Section IX - General Warning Statement: If ignited in an enclosed space, polyurethane foam will burn rapidly, release great heat, produce dense toxic smoke and consume great amounts of oxygen, which can result in suffocation and death.

Publication 749, “Fire Hazard Comparison of Fire-Retarded and Non-Fire-Retarded Products”, published by the U.S. Department of Commerce, National Bureau of Standards, July 1988. 6 See “Products – Fire Safety – Material Safety Data Sheet”, published by the Penn Foam Corporation at “http://www.pennfoam.com/products/products05.html”.

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The High Hazard Group

S E C T I O N 2

2.

The High Hazard Group

Once we acknowledge that polyurethane foam products are classified as a “flammable solid” the “High Hazard Group H” section of the International Building Code must be reviewed for compliance for any occupancy containing the foam product. In reviewing Section 307.1 of the International Building Code the only exceptions that would be applicable to “flammable solids” would be items 1 and 2, both of which require a limitation of the amount of flammable solids present in accordance with the Maximum Allowable Quantity permitted by Table 307.1(1), or the occupancy is designated as an H Group.

SECTION 307 HIGH-HAZARD GROUP H [F] 307.1 High-hazard Group H. High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard in quantities in excess of those allowed in control areas constructed and located as required in Section 414. Hazardous uses are classified in Groups H-1, H-2, H-3, H-4 and H-5 and shall be in accordance with this section, the requirements of Section 415 and the International Fire Code. Exceptions: The following shall not be classified in Group H, but shall be classified in the occupancy that they most nearly resemble: 1.

2.

3.

4.

5. 6.

Buildings and structures that contain not more than the maximum allowable quantities per control area of hazardous materials as shown in Tables 307.1(1) and 307.1(2), provided that such buildings are maintained in accordance with the International Fire Code. Buildings utilizing control areas in accordance with Section 414.2 that contain not more than the maximum allowable quantities per control area of hazardous materials as shown in Tables 307.1(1) and 307.1(2). Buildings and structures occupied for the application of flammable finishes, provided that such buildings or areas conform to the requirements of Section 416 and the International Fire Code. Wholesale and retail sales and storage of flammable and combustible liquids in mercantile occupancies conforming to the International Fire Code. Closed piping containing flammable or combustible liquids or gases utilized for the operation of machinery or equipment. Cleaning establishments that utilize combustible liquid solvents having a flash point of 140°F (60°C) or higher in closed systems employing equipment listed by an approved testing agency, provided that this occupancy is separated from all other areas of the building by 1-hour fire barriers or 1-hour horizontal assemblies or both. 4

7. 8. 9. 10. 11.

12.

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14.

15.

Cleaning establishments that utilize a liquid solvent having a flash point at or above 200°F (93°C). Liquor stores and distributors without bulk storage. Refrigeration systems. The storage or utilization of materials for agricultural purposes on the premises. Stationary batteries utilized for facility emergency power, uninterrupted power supply or telecommunication facilities, provided that the batteries are provided with safety venting caps and ventilation is provided in accordance with the International Mechanical Code. Corrosives shall not include personal or household products in their original packaging used in retail display or commonly used building materials. Buildings and structures occupied for aerosol storage shall be classified as Group S-1, provided that such buildings conform to the requirements of the International Fire Code. Display and storage of nonflammable solid and nonflammable or noncombustible liquid hazardous materials in quantities not exceeding the maximum allowable quantity per control area in Group M or S occupancies complying with Section 414.2.5. The storage of black powder, smokeless propellant and small arms primers in Groups M and R-3 and special industrial explosive devices in Groups B, F, M and S, provided such storage conforms to the quantity limits and requirements prescribed in the International Fire Code.

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[F] TABLE 307.1(1) MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A PHYSICAL HAZARDa, j, m, n, p

MATERIAL Flammable solid

CLASS N/A

GROUP WHEN THE MAXIMUM ALLOWABLE QUANTITY IS EXCEEDED H-3

STORAGEb Solid pounds (cubic feet) 125d, e

Liquid gallons (pounds) N/A

USE-CLOSED SYSTEMSb Gas (cubic feet at NTP) N/A

Solid pounds (cubic feet) 125d

Liquid gallons (pounds) N/A

Gas (cubic feet at NTP) N/A

USE-OPEN SYSTEMSb Solid Liquid pounds gallons (cubic (pounds) feet) d 25 N/A

For SI: 1 cubic foot = 0.023 m3, 1 pound = 0.454 kg, 1 gallon = 3.785 L. NL = Not Limited; N/A = Not Applicable; UD = Unclassified Detonable a. For use of control areas, see Section 414.2. b. The aggregate quantity in use and storage shall not exceed the quantity listed for storage. c. The quantities of alcoholic beverages in retail and wholesale sales occupancies shall not be limited providing the liquids are packaged in individual containers not exceeding 1.3 gallons. In retail and wholesale sales occupancies, the quantities of medicines, foodstuffs, consumer or industrial 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. d. Maximum allowable quantities shall be increased 100 percent in buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1. Where Note e also applies, the increase for both notes shall be applied accumulatively. e. Maximum allowable quantities shall be increased 100 percent when stored in approved storage cabinets, day boxes, gas cabinets, exhausted enclosures or safety cans. Where Note d also applies, the increase for both notes shall be applied accumulatively. f. The permitted quantities shall not be limited in a building equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1. g. Permitted only in buildings equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1. h. Containing not more than the maximum allowable quantity per control area of Class IA, IB or IC flammable liquids. i. Inside a building, the maximum capacity of a combustible liquid storage system that is connected to a fuel-oil piping system shall be 660 gallons provided such system complies with the International Fire Code. j. Quantities in parenthesis indicate quantity units in parenthesis at the head of each column. k. A maximum quantity of 200 pounds of solid or 20 gallons of liquid Class 3 oxidizers is allowed when such materials are necessary for maintenance purposes, operation or sanitation of equipment. Storage containers and the manner of storage shall be approved. l. Net weight of the pyrotechnic composition of the fireworks. Where the net weight of the pyrotechnic composition of the fireworks is not known, 25 percent of the gross weight of the fireworks, including packaging, shall be used. m. For gallons of liquids, divide the amount in pounds by 10 in accordance with Section 2703.1.2 of the International Fire Code. n. For storage and display quantities in Group M and storage quantities in Group S occupancies complying with Section 414.2.4, see Tables 414.2.5(1) and 414.2.5(2). o. Densely packed baled cotton that complies with the packing requirements of ISO 8115 shall not be included in this material class. p. The following shall not be included in determining the maximum allowable quantities: 1. Liquid or gaseous fuel in fuel tanks on vehicles. 2. Liquid or gaseous fuel in fuel tanks on motorized equipment operated in accordance with this code. 3. Gaseous fuels in piping systems and fixed appliances regulated by the International Fuel Gas Code. 4. Liquid fuels in piping systems and fixed appliances regulated by the International Mechanical Code.

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307.1.1 Hazardous materials. Hazardous materials in any quantity shall conform to the requirements of this code, including Section 414, and the International Fire Code. [F] 307.2 Definitions. The following words and terms shall, for the purposes of this section and as used elsewhere in this code, have the meanings shown herein. FLAMMABLE SOLID. A solid, other than a blasting agent or explosive, that is capable of causing fire through friction, absorption or moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which has an ignition temperature below 212°F (100°C) or which burns so vigorously and persistently when ignited as to create a serious hazard. A chemical shall be considered a flammable solid as determined in accordance with the test method of CPSC 16 CFR; Part 1500.44, if it ignites and burns with a self-sustained flame at a rate greater than 0.1 inch (2.5 mm) per second along its major axis. [F] 307.5 High-hazard Group H-3. Buildings and structures containing materials that readily support combustion or that pose a physical hazard shall be classified as Group H-3. Such materials shall include, but not be limited to, the following: Class I, II or IIIA flammable or combustible liquids that are used or stored in normally closed containers or systems pressurized at 15 pounds per square inch gauge (103.4 kPa) or less Combustible fibers, other than densely packed baled cotton Consumer fireworks, 1.4G (Class C, Common) Cryogenic fluids, oxidizing Flammable solids Organic peroxides, Class II and III Oxidizers, Class 2 Oxidizers, Class 3, that are used or stored in normally closed containers or systems pressurized at 15 pounds per square inch gauge (103 kPa) or less Oxidizing gases Unstable (reactive) materials, Class 2 Water-reactive materials, Class 2

A review of Table 307.1(1) along with note d identifies that buildings or structures that are not protected by an automatic sprinkler system are limited to no more than 125 lbs. of flammable solids per control area. If the building or structure is protected by an automatic sprinkler system the allowable amount is increased by 100% to 250 lbs. of flammable solid materials per control area.

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How Much Furniture Equals 125 or 250 lbs.

S E C T I O N 3

3.

How Much Furniture Equals 125 or 250 lbs?

To properly apply the International Building Code as it applies to the presence of flammable solids the code official needs to know how many pounds of the materials are or will be present in the building or structure. Though it is the building owner/occupants responsibility to supply that information, the code official should have the ability to judge the information provided as compared to the conditions present. The amount of polyurethane foam present in furniture will be as varied as the types and designs of furniture are. To assist the code official in understanding how quickly the amount of flammable solids adds up, two sets of living room/family room furniture were utilized for comparison purposes. The cushions on the couches, loveseats and a chair were measured and weighed. The weights noted per cushion ranged from a low of 6 lbs. to a high of 9.5 lbs. It must be remembered that there is additional polyurethane foam cushioning in the furniture other than the cushions, whether in the arms, pillow backs or other portions. As you review the pictures it will be easily recognized that as few as seven or eight couches will contain more than 125 lbs. of flammable solid material. An amount that if located in a single control area would be a high hazard Group H occupancy requiring automatic fire suppression to be present. If a fire suppression system is present the limitation will be increased to 250 lbs. per control area. A level that an average furniture store will quickly surpass.

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The weights provided do not include foam padding on the couch or loveseat itself or in detachable pillows.

9

The weights provided do not include foam padding on the loveseat itself or in detachable pillows.

10

The weights provided do not include foam padding on the couch itself or in detachable pillows.

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The weights provided do not include foam padding on the chair itself or in detachable pillows.

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Furniture Store Example Pictures

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Once you know that the individual cushions may have weights of approximately 6 to 9.5 lbs. each it is easy to visualize that the typical furniture store or a furniture warehouse with furnishings containing polyurethane foam padding or cushions will readily contain flammable solids in amounts greater than the MAQ permitted before going over the threshold and becoming an H Group occupancy.

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NFPA Correlation

S E C T I O N 4

6.3 Hazard of Contents. 6.3.1 General. 6.3.1.1 For the purpose of this Code, the hazard of contents shall be the relative danger of the start and spread of fire, the danger of smoke or gases generated, and the potential of an explosion or other occurrence to endanger the lives and safety of the occupants of the building or structure or to cause damage to the building or its contents. 6.3.1.2 Hazard of contents shall be classified by the registered design professional (RDP) or owner and submitted to the authority having jurisdiction for review and approval on the basis of the character of the contents and the processes or operations conducted in the building or structure. 6.3.1.3 For the purpose of this Code, where different degrees of hazard of contents exist in different parts of a building or structure, the most hazardous shall govern the classification, unless hazardous areas are separated or protected as specified in the applicable sections of Chapters 16 through 31.

6.3.2* Classification of Hazard of Contents. 6.3.2.1* General. The hazard of contents of any building or structure shall be classified as low, ordinary, or high in accordance with 6.3.2.2 through 6.3.2.4. 6.3.2.2* Low Hazard. Low hazard contents shall be classified as those of such low combustibility that no self-propagating fire therein can occur. 6.3.2.3* Ordinary Hazard. Ordinary hazard contents shall be classified as those that are likely to burn with moderate rapidity or to give off a considerable volume of smoke. 6.3.2.4 High Hazard. 6.3.2.4.1 General. 6.3.2.4.1.1 High hazard contents shall include materials defined as “hazardous material” in Chapter 3, whether stored, used, or handled. 6.3.2.4.1.2 High hazard contents shall be classified in accordance with 6.3.2.4.2 through 6.3.2.4.6, whether stored, used, or handled. 6.3.2.4.1.3* Occupancies in which high hazard contents are stored, used, or handled shall also comply with Chapter 34. 6.3.2.4.4 High Hazard Level 3 Contents. High hazard Level 3 contents shall include materials that readily support combustion or present a physical hazard including, but not limited to, the following: (1) Level 2 and Level 3 aerosols

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(2)

(3) (4) (5) (6) (7) (8) (9) (10)

Class I, Class II, or Class III-A flammable or combustible liquids that are used or stored in normally closed containers or systems at gauge pressures of less than 15 psi (103 kPa) Consumer fireworks, 1.4 G Flammable solids, other than dusts classified as high hazard Level 2, stored, used, or generated in a manner creating a high fire hazard Class II and Class III organic peroxides Class 2 solid or liquid oxidizers Class 3 solid or liquid oxidizers that are used or stored in normally closed containers or systems at gauge pressures of less than 15 psi (103 kPa) Oxidizing gases and oxidizing cryogenic liquids Class 2 unstable (reactive) materials Class 2 water-reactive materials

Chapter 34 High Hazard Contents 34.1 General Requirements. 34.1.1* Applicability. 34.1.1.1 Occupancies containing high hazard contents shall comply with this chapter in addition to other applicable requirements of this Code. 34.1.3 Quantity Limits. 34.1.3.1 General. Maximum allowable quantities of hazardous materials per control area shall be as specified in Table 34.1.3.1, except as modified by 34.1.3.2 and 34.1.3.3. 34.2 Requirements for All Occupancies Containing High Hazard Contents. 34.2.1 Applicability. Buildings, and portions thereof, containing hazardous materials regulated by this Code shall comply with Section 34.2. 34.2.2 Fire Prevention Code. Buildings, and portions thereof, where hazardous materials are stored, used, or handled shall also comply with NFPA 1. 34.3 Requirements for Occupancies Exceeding the Maximum Allowable Quantities per Control Area for High Hazard Contents. 34.3.2 General Requirements. The requirements set forth in 34.3.2 shall apply to buildings, or portions thereof, that are required to comply with Protection Level 1 through Protection Level 5 where required by 34.3.1.1 through 34.3.1.5. 34.3.2.1 Fire Protection Systems. Buildings, or portions thereof, required to comply with Protection Level 1 through Protection Level 5 shall be protected by an approved automatic fire sprinkler system complying with Section 55.3.

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Table 34.1.3.1 Maximum Allowable Quantity (MAQ) of Hazardous Materials per Control Areaa STORAGE

MATERIAL

CLASS

High Hazard Contents Level

Flammable solid

N/A

3

Solid Liquid Gasb pounds gallons (ft3) (ft3) (lb) Physical Hazard Materials 125g,h N/A N/A

USE-CLOSED SYSTEMS Solid pounds (ft3)

Liquid gallons (lb)

Gasb (ft3)

125h

N/A

N/A

USE-OPEN SYSTEMS Solid Liquid pounds gallons (ft3) (lb) 25g,h

N/A

For SI units, 1 lb = 0.454 kg; 1 ft3 = 0.0283 m3; 1 gal = 3.785 L. NA: Not applicable. NL: Not limited. a See 34.1.3.2 for exceptions to tabular amounts. For use of control areas, see 34.2.4. Table values in parentheses correspond to the unit name in parentheses at the top of the column. The aggregate quantity in use and storage is not permitted to exceed the quantity listed for storage. In addition, quantities in specific occupancies are not permitted to exceed the limits in 34.1.3.2. b Measured at 70°F (21°C) and 14.7 psi (30 kPa). c Inside a building, the maximum capacity of a combustible liquid storage system that is connected to a fuel oil piping system is permitted to be 660 gal (2,500 L), provided that such system conforms to NFPA 31, Standard for the Installation of Oil-Burning Equipment. d Flammable and combustible liquids and flammable gases in the fuel tanks of mobile equipment or vehicles are permitted to exceed the MAQ where the equipment is stored and operated in accordance with the fire code. e In storage, low, and ordinary hazard occupancies, the storage of Class II combustible liquids is required to be limited to a maximum quantity of 1,375 gal (5204 L); Class IIIA combustible liquids are required to be limited to a maximum quantity of 2,750 gal (10,409 L); and Class IIIB combustible liquids are required to be limited to a maximum quantity of 13,750 gal (52,044 L) where stored in accordance with all the requirements in NFPA 30 for general-purpose warehouses. f The quantity of fuel in aircraft in hangars is required to be in accordance with NFPA 409, Standard on Aircraft Hangars. g Quantities are permitted to be increased 100 percent where stored in approved cabinets, gas cabinets, exhausted enclosures, explosives magazines, or safety cans, as appropriate for the material stored, in accordance with NFPA 1. Where footnote h also applies, the increase for both footnotes is permitted to be applied accumulatively. h Maximum quantities are permitted to be increased 100 percent in buildings equipped throughout with an automatic sprinkler system in accordance with NFPA 13, Standard for the Installation of Sprinkler Systems. Where footnote g also applies, the increase for both footnotes is permitted to be applied accumulatively. i The permitted quantities are not limited in a building equipped throughout with an automatic sprinkler system in accordance with NFPA 13. j A maximum quantity of 200 lb (91 kg) of solid or 20 gal (76 L) of liquid Class 3 oxidizers is permitted where such materials are necessary for maintenance purposes, operation, or sanitation of equipment. Storage containers and the manner of storage are required to be approved. k Unless the actual weight of the pyrotechnic composition of the consumer fireworks, 1.4G, is known, 25 percent of the gross weight of the fireworks, including packaging, is permitted to be used to determine the weight of the fireworks for the purpose of this table. l Permitted only in buildings equipped throughout with an automatic sprinkler system in accordance with NFPA 13. m Maximum quantities of black powder, smokeless propellant, and small arms primers stored or displayed in mercantile occupancies or stored in one- or two-family dwellings are permitted to exceed the amount specified by this table where such storage complies with the requirements of NFPA 495, Explosive Materials Code, Chapter 13. n In lieu of the maximum allowable quantity limit per control area, the maximum aggregate quantity per building of special explosive devices in industrial, mercantile, and storage occupancies is required to be 50 lb (23 kg). o Additional storage locations are required to be separated by a minimum of 300 ft (92 m). p In mercantile occupancies, storage of LP-Gas is limited to a maximum of 200 lb (91 kg) in nominal 1 lb (0.45 kg) LP-Gas containers. q In storage, low, and ordinary hazard occupancies, the storage of Class IA flammable liquids is not permitted, and the combination storage of Class IB and Class IC flammable liquids is required to be limited to a maximum quantity of 660 gal (2,500 L) where stored in accordance with all the requirements in NFPA 30 for general-purpose warehouses. r Containing not more than the maximum allowable quantity per control area of Class IA, Class IB, or Class IC flammable liquids. s A single cylinder containing 150 lb (68 kg) or less of anhydrous ammonia in a single control area in a nonsprinklered building is considered to be the maximum allowable quantity. Two cylinders, each containing 150 lb (68 kg) or less, in a single control area is considered to be the maximum allowable quantity, provided that the building is equipped throughout with an automatic sprinkler system in accordance with NFPA 13. t Allowed only where stored in approved, exhausted gas cabinets or exhausted enclosures, as specified in NFPA 1.

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6.1.10 Mercantile. For requirements, see Chapter 27. 6.1.10.1* Definition - Mercantile Occupancy. An occupancy used for the display and sale of merchandise. Chapter 27 Mercantile Occupancies 27.3.5 Extinguishment Requirements. 27.3.5.1 Mercantile occupancies shall be protected by an approved, supervised automatic sprinkler system in accordance with NFPA 13 and 55.3.2 as follows: (1) Throughout all mercantile occupancies three or more stories in height (2) Throughout all mercantile occupancies exceeding 12,000 ft 2(1115 m2) in gross area (3) Throughout stories below the level of exit discharge where such stories have an area exceeding 2500 ft2 (232 m2) and are used for the sale, storage, or handling of combustible goods and merchandise (4) Throughout mixed occupancies in accordance with 6.2.2 where the conditions of 27.3.5.1(1), (2), or (3) apply to the mercantile occupancy

6.1.13 Storage. For requirements, see Chapter 30. 6.1.13.1* Definition - Storage Occupancy. An occupancy used primarily for the storage or sheltering of goods, merchandise, products, vehicles, or animals.

Chapter 30 Storage Occupancies 30.3.5* Extinguishment Requirements. 30.3.5.1 Fire Sprinklers. 30.3.5.1.1 Storage occupancies, other than low hazard storage occupancies, shall be protected by an approved, supervised automatic sprinkler system in accordance with NFPA 13 as follows: (1) Throughout all storage occupancies three or more stories in height (2) Throughout all storage occupancies exceeding 12,000 ft2 (1115 m2) in fire area (3) Where the total area of all floors, including mezzanines, exceeds 24,000 ft2 (2230 m2)

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Two items of note for those jurisdictions that have adopted NFPA 1 as their fire code and as a result use a combination of the International Building Code with references to the NFPA standards directly in place of those that reference the International Fire Code. Below is cross references from four sections found in the International Building Code dealing with hazardous materials. In each case there is a corresponding requirement in NFPA 1 to match the requirement that would have been covered by the reference to the International Fire Code. The other item to note is that NFPA 1, The Uniform Fire Code requires all high hazard uses covered by Protection Levels 1 through 5 to be protected with an automatic fire sprinkler system.

NFPA 1 Correlation IBC 307.1.1 reference to IFC

NFPA 1 - 60.1.1

IBC 413.1 High piled storage reference to IFC

NFPA 1 - 20.15.7.1

IBC 414.1.1 reference to IFC

NFPA 1 - 60.1.1

IBC 414.2 Control Areas

NFPA 5000 - 34.1.3.1 NFPA 1 - 60.1.3.1

60.3.2 General Requirements. The requirements set forth in 60.3.2 shall apply to buildings, or portions thereof, that are required to comply with Protection Level 1 through Protection Level 5 where required by 60.3.1.1 through 60.3.1.5. [5000:34.3.2] 60.3.2.1 Fire Protection Systems. Buildings, or portions thereof, required to comply with Protection Level 1 through Protection Level 5 shall be protected by an approved automatic fire sprinkler system complying with Section 13.3. [5000:34.3.2.1]

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Enforcement Action

S E C T I O N 5

5.

Enforcement Action

As noted in the introduction section of this guidance document occupancies containing large amounts of polyurethane foam products as part of finished furniture pieces may have been incorrectly identified as mercantile and/or storage occupancies when the amounts of flammable solids present exceed the threshold for qualification as an H Group occupancy. Now that testing has identified the correct characterization of the polyurethane foam products a course of action needs to be undertaken. As indicated in literature published by a polyurethane manufacturing firm, the polyurethane foam product If ignited in an enclosed space, will burn rapidly, release great heat, produce dense toxic smoke and consume great amounts of oxygen, which can result in suffocation and death. Based upon that industry characterization, (which matches testing results for the product), the only solution to protect occupants, the buildings and firefighters from the hazards presented by polyurethane foam products is to require the installation of automatic fire sprinkler systems with the proper water flow density needed to handle fires should they occur. If an automatic fire sprinkler system is already installed it should be checked to insure it has the appropriate water flow capabilities needed to suppress a fire that occurs in the polyurethane foam product. If a building or structure is already provided with an automatic fire sprinkler system checking the ability of the system to protect the polyurethane hazard should be a simple manner since maintenance of the system requires that it be able to handle the hazard it is protecting. It is a straight forward fire code or building code enforcement action. If the occupancy exists now as a mercantile or storage occupancy without automatic fire suppression protection, the enforcement action available depends on your enabling legislation and policies on enforcement of the building or fire codes. In a jurisdiction that has adopted NFPA 1 as the fire code all hazardous occupancies are required to be protected by an automatic fire sprinkler system. 7 If your jurisdiction has adopted the International Fire Code there is no similar requirement for existing buildings. Your jurisdiction may have its own retroactive regulations that apply and require all high hazard uses to be protected with an automatic fire sprinkler system. If your jurisdiction has enacted NFPA Life Safety Code 101, mercantile occupancies with high hazard contents areas must be protected by an automatic extinguishing system. 8 Another option available is to determine if the existing facility has a valid certificate of occupancy based upon the knowledge that the previous designation as a mercantile or storage occupancy was incorrect. In other words, if you determine that the use was 7 8

See NFPA 1, Section 60.3.2.1 Fire Protection Systems. SEE NFPA 101, Section 37.3.2.2 High Hazard Contents Areas.

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incorrectly characterized at the initial plan review and construction stage, the Certificate of Occupancy may be considered invalid or void since it was based upon incorrect assumptions or facts. In many jurisdictions, a Certificate of Occupancy is issued based upon compliance with the code in effect at the time the Certificate of Occupancy is issued and for continued compliance with any of the code requirements in effect at that time. If the information the Certificate of Occupancy was based upon was incorrect, than the Certificate is not valid. Regardless of when the error in characterization of the use was discovered. That would require that the code be properly applied, in this case the requirements for a high hazard occupancy in order for the building to be brought into compliance with the code and receive a new Certificate of Occupancy. A quick research of the legacy codes identifies that the BOCA National Building Code began using the current definition for “flammable solid” as early as the 1993 edition 9 and utilized the same threshold for amounts permitted to be present for storage of the material, i.e., 125 lbs. if not protected with an automatic fire sprinkler system. The SBCCI Standard Building Code utilized a definition for “flammable Solid” that included the characterization, “..or which burns so vigorously or persistently when ignited so as to create a serious hazard.”, along with the same thresholds for amounts permitted to be present for storage of the material, i.e., 125 lbs. if not protected with an automatic fire sprinkler system in the 1997 edition of that code. 10 The ICBO Uniform Building Code utilized a definition for “flammable solid” that included the characterization “…or which burns so vigorously or persistently when ignited that it creates a serious hazard.”, along with the same thresholds for amounts permitted to be present for storage of the material, i.e., 125 lbs. if not protected with an automatic fire sprinkler system in the 1997 edition of that code. 11 If the research is taken back early enough you will find that hazardous materials were broadly defined in a manner that a flammable solid such as polyurethane foam product easily qualifies as a high hazard occupancy. This would mean that in many jurisdictions it would be possible to have furniture stores and warehouses that stock furnishings composed of polyurethane foam products retroactively install automatic fire sprinkler systems by determining the initial use assigned was incorrect pursuant to the code in effect at that time and ordering the occupancy to meet the high hazard construction requirements. It is recommended that code officials research which avenue of requiring adequate automatic fire sprinkler protection is available for use in their jurisdiction.

9

See Section 307.2 and Table 307.8(1) of the BOCA National Building Code, 1993 edition. See Section 202 and Table 308.2C of the SBCCI Standard Building Code, 1997 edition. 11 See Section 207-F and Table 3-D of the ICBO Uniform Building Code, 1997 edition. 10

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Summary

S E C T I O N 6

6.

Summary

The presence of polyurethane foam products increases the fire hazard potential within any occupancy. The impact of that fire hazard is even greater in mercantile and storage occupancies handling furnishings composed of polyurethane foam products because of the increased density of the fuel load per square foot. The polyurethane manufacturing industry warns that “If ignited in an enclosed space, polyurethane foam will burn rapidly, release great heat, produce dense toxic smoke and consume great amounts of oxygen, which can result in suffocation and death.” The industry itself has identified the serious hazard these materials present to the occupants, the building and to responding firefighters. From a fire protection standpoint the only protective method suitable to control the hazard presented is a properly engineered and installed automatic fire sprinkler system. Now that laboratory testing has documented that polyurethane foam products are classified as a flammable solid most if not all furniture stores and warehouses should be correctly identified as High Hazard occupancies and those that are not currently protected by automatic fire sprinkler systems must be ordered to have such systems installed immediately to eliminate the recognized, and well documented hazards presented by the polyurethane products.

Robert J Davidson Fire & Life Safety Consultant

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