By Andrew L. Shakely, PE, LEED AP BD+C
Even with the trend towards environmentally-friendly processes and products, almost every manufacturer utilizes some hazardous materials that are a necessary part of their manufacturing or maintenance operations. If this applies to your company, do you know if you are storing and using these items safely and in compliance with the National Fire Protection Association (NFPA), International Fire Code (IFC) and the International Building Code (IBC)?
It all starts with understanding what hazardous materials you have and knowing their MAQs – or Maximum Allowable Quantities – for each type of hazardous material used in your facility. Storing or using quantities of material in amounts greater than their MAQ will require additional safeguards to be installed in your facility. It may even require that a portion of your facility be categorized as a Hazardous Occupancy.
What is a MAQ and what are Control Areas?
The Code defines the MAQ – Maximum Allowable Quantity – of a hazardous material as the amount of the material that can be stored, used, dispensed, or handled within a Control Area. A Control Area is a defined area of a facility that allows for limited amounts of hazardous materials to be stored or used without classifying the entire facility as a High Hazard H Occupancy. A Control Area can be either an interior or exterior space within a facility or even the entire facility if the hazardous materials are below their MAQs. Most often, a Control Area is an enclosed room within a facility with a minimum 1-hour fire separation from the remaining facility. The Control Area may have special safety systems such as continuous ventilation systems, emergency power, alarms, and secondary containment of the sprinkler system discharge, depending on the type of product in the room. Buildings can have multiple Control Areas based on their size and number of stories.
To begin evaluating your Control Area needs, you must first categorize and quantify the amount of hazardous materials in your facility. This will allow you to identify whether you are exceeding your MAQs for any of the hazardous materials.
Categorize Your Materials
The IBC and IFC categorize hazardous materials into two main categories: Physical Hazards that pose a safety hazard, such as risk for explosion or flammability, and Health Hazards, such as toxicity or corrosiveness. It is possible for a material to be classified in multiple hazard categories. The IBC and IFC Hazard Categories are:
- Combustible DustFlammable Liquids- Combined
- Combustible FibersFlammable Solid
- Combustible LiquidsInert Gasses
- Consumer FireworksOrganic Peroxides
- Cryogenics, FlammableOxidizer Gasses
- Cryogenics, OxidizingOxidizers
- ExplosivesPyrophoric Materials
- Flammable GassesUnstable (reactive)
- Flammable LiquidsWater Reactive
- Highly Toxic
There are numerous categories to be considered, with many of the categories listed above being further divided into classes based on their risk within a particular category. For example, Oxidizers, which promote growth of fire, are further classified H-1, H-2, H-3, H-4 based on how strongly they feed fire growth. H-1 mildly increases the burning rate of materials, while H-4 can cause an explosive reaction.
To determine the classification of a given material, you must start with the product’s Material Safety Data Sheet or MSDS. The MSDS will provide the specific properties or hazard risks of the material. By comparing its physical properties, such as flashpoints and corrisivity, you can determine if the material falls within an IBC hazard category.
Understand how the hazardous material is used
Once you have identified which hazardous materials you possess, you must next understand how they are being used. The IBC and IFC MAQ for each material is determined by whether the material is simply being stored, or if it’s being used in an open or closed process system. An open system is a process where the material is handled in such a way that it is exposed to the atmosphere in the building. This could be a mixer station or a liquid transfer point where the process is vented inside the building.
A closed system is one where the materials are fully contained inside a sealed process. This could be a sealed blending system that has all tank vents extended to the exterior of the building.
Generally, the MAQ for a material is the highest for an item that is only stored and not used in a process. MAQs are most restrictive for hazardous materials that are used in open systems, which potentially creates a risk of worker exposure to hazardous materials, or the risk of exposing the surrounding building systems to the materials. Common examples of problem areas include open transfer locations for flammable liquids or blending areas of combustible dusts. At these locations, properly rated electrical devices and adequate ventilation must be provided to reduce the risk of fire or explosion.
Know what quantity increases you are allowed
In most cases, the MAQ for a material can be increased via safety features within the facility. The most common of these are whether the building is equipped with a sprinkler system or if the hazardous material is stored in an approved safety cabinet. Depending on the material, these can double the allowed quantity in a building.
Develop a compliance strategy
Once you’ve identified your hazardous materials, determined their use, and reviewed facility safety features, you can identify if you are compliance with the MAQs or if you have conditions that need to be addressed. Nutec works with owners to evaluate their processes and uses of materials to develop the most effective strategy for compliance. This could be simple quantity control within individual batches of hazardous materials, or segregation of the materials into separate control areas in the facility. Understanding the options for compliance and the many implications they can have on the use of a facility is critical. If the wrong compliance approach is taken, it can lead to excessive and unnecessary construction costs, or even the imposing of operating procedures that can hamper production and efficiency.
Just like knowing the ABCs are a necessary first step in learning to read and write, knowing your MAQs are the first step to compliance with the IBC, IFC and NFPA. By properly categorizing and quantifying the hazardous materials you use, and knowing the maximum quantities that you are allowed, you can develop the methods needed to provide a safe, code-compliant work place that protects both your employees and your facility.
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