A Code-Path for Non-Combustible Rack Storage?

4/3/2023

This feels like a silly question, but we have high-piled, non-combustible storage, with open-grate or solid level single/double row permanent racks with Extra Hazard Group 2 overhead system.

I'm trying to identify the actual code verbiage that says nothing is required from an code/NFPA standpoint.

The product is metallic car parts with no added materials, just exposed solid metal, no plastic gaskets or spacers, etc.

The 2015 IFC is the highest code in my jurisdiction, so starting with that, Chapter 32 is for High-Piled "Combustible" Storage and provides no avenue for code justification.

NFPA 13-2013 defines "Noncombustible Material & Automotive Components on Portable Racks" but also gives no criteria for non-combustible storage.

FM Global Data Sheet 8-1 actually lists noncombustible as a commodity classification, unlike NFPA 13, but does not provide a criteria stating no coverage.

Is this just the simple scenario where code or NFPA standards don't list a requirement or criteria because it just doesn't require anything?

Again I feel like it's a silly question given the commodity but I believe the only rules to follow would be obstruction rules and distance from deflector to storage.

Thoughts?

Thanks in advance.

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12 Comments

Matt

4/3/2023 08:14:25 am

First thing, classify the occupancy using the adopted IBC (Maybe Group S-2).

Next, go to §903.2 and see if a sprinkler system is required for that occupancy.

Todd E Wyatt

4/3/2023 10:35:16 am

SUMMARY
If the entire building meets the Occupancy Classification (OC) of a Group S-2 Low-Hazard Storage, it may NOT be required to be protected by an automatic sprinkler system (ASPS) per the scoping code (e.g. 2021 IBC).

EXPLANATION
The scoping Code (e.g. 2021 IBC) determines “WHERE REQUIRED” an ASPS based on the building’s Occupancy Classifications (OC) and/or its inclusion of “specific building areas and hazards.” Once the scoping Code has determined if the entire building or portions of a building requires protection by an ASPS or not, it references the applicable ASPS standard (NFPA 13, NFPA 13R or NFPA 13D) for HOW the ASPS is to be “designed and installed”.

Depending on the combustibility of the item(s) stored, the building would be classified as either a “Group S-2 Low-Hazard Storage” OR as a “Group S-1 Moderate-Hazard Storage” ... see REFERENCES below.

S-1 buildings require an ASPS throughout if it meets any of the (4) prescriptive requirements of “2021 IBC 903.2.9 Group S-1.”
S-2 buildings do NOT require an ASPS throughout per “2021 IBC 903.2 Where Required.”

4/3/2023 10:35:37 am

REFERENCES
2021 IBC
Chapter 3 Occupancy Classification and Use
Section 311 Storage Group S
Storage Group S occupancy includes, among others, the use of a building or structure, or a portion thereof, for storage that is not classified as a hazardous occupancy.
311.2 Moderate-Hazard Storage, Group S-1
Storage Group S-1 occupancies are buildings occupied for storage uses that are not classified as Group S-2, including, but not limited to, storage of the following:
311.3 Low-Hazard Storage, Group S-2
Storage Group S-2 occupancies include, among others, buildings used for the storage of noncombustible materials such as products on wood pallets or in paper cartons with or without single thickness divisions; or in paper wrappings. Such products are permitted to have a negligible amount of plastic trim, such as knobs, handles or film wrapping. Group S-2 storage uses shall include, but not be limited to, storage of the following:
Electrical motors
Metal parts

Chapter 9 Fire Protection and Life Safety Systems
903.1 General
Automatic sprinkler systems shall comply with this section.
903.2 Where Required
Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.
Exception: Spaces or areas in telecommunications buildings used exclusively for telecommunications equipment, associated electrical power distribution equipment, batteries and standby engines, provided that those spaces or areas are equipped throughout with an automatic smoke detection system in accordance with Section 907.2 and are separated from the remainder of the building by not less than 1-hour fire barriers constructed in accordance with Section 707 or not less than 2-hour horizontal assemblies constructed in accordance with Section 711, or both.

903.2.9 Group S-1
An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists:
1. A Group S-1 fire area exceeds 12,000 square feet (1115 m2).
2. A Group S-1 fire area is located more than three stories above grade plane.
3. The combined area of all Group S-1 fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).
4. A Group S-1 fire area used for the storage of commercial motor vehicles where the fire area exceeds 5,000 square feet (464 m2).
903.2.10 Group S-2 Parking Garages

903.2.11 Specific Building Areas and Hazards

Bobby V

4/3/2023 08:47:43 am

First off, l'm not sure what you mean by " nothing is required from an code/NFPA standpoint." Do you mean leave the existing OH2 as is, or are you trying to justify a sprinkler system is not required?

I would start by going to 2013 NFPA 13, chapter 16 for rack storage of class I-IV commodities. Since you have a non-ESFR system, use sections for CMDA sprinkler protection to figure if OH2 is acceptable for your storage height. You may also have to know your aisle widths, and temperature ratings of the existing sprinklers to pinpoint your design. You will basically be “reverse engineering” this design.

Dan Wilder

4/3/2023 08:53:49 am

So the commodity is non-combustible (Class I, maybe a II), what about the pallets? Reinforced plastic pallets would drive you into a Class III/IV automatically. standard plastic or wood pallets would push you to a Class II/III (again depending on where you start for the commodity itself). Anything about idle pallet storage within the racking as well?

Make sure the overhead sprinklers are listed for storage occupancies as well including verification of the overhead K-Factor meeting the minimum required for the final density.

Franck

4/3/2023 09:52:03 am

I saw your configuration sometimes in the automotive industry, as well as in steel plants.
If there is nothing else than the metal parts(no pallet, no packaging, no wrapping), then you’re right and it is a non combustible storage.
You don’t need a sprinkler protection for it.
The only reason for sprinkler protection would be if there was something else that needs to be protected (charging station for forklifts, for example). But in that case your OH gr 2 is more than sufficient.

Nfpa (or FM or any sprinkler protection standard) gives guidance to protect a fire hazard (occupancy or combustible load with commodity). No hazard, no need for protection, no guidance.

So you don’t even need to care for clearance or obstruction, as long as you keep only metallic parts. Just avoid mechanical damages to sprinklers…

Anthony

4/3/2023 11:14:57 am

This (good work Franck), Also check IBC for S-2 and F occupancy over 12K sqft requirements.

Make sure you also consider the life cycle of building with the customer. they may want flexibility to store different goods in the future without the 6 month wait time installing an ESFR system would take.

Jesse

4/3/2023 10:14:06 am

Linke Frank, I've seen this too in automotive mfg. You stated no packaging, but I'm wondering if there are pallets.

If strictly, metal parts on metal racks, its effectively a Class 0 commodity. With the presence of pallets, this will increase the commodity class.

Sundance Bob

4/3/2023 10:55:39 am

Non-combustible is Class 1 commodities per NFPA-13.
You can see if the entire building can be unsprinklered or deal with class 1 requirements.

In high piled storage you have another issue if the load footprint exceeds 20 sf in you then have to view it as solid shelving and deal with possible in-rack requirements even if is steel pipe on steel cantilever racks for example.

Can anyone cite Code that works around these issues?

4/3/2023 03:15:56 pm

“HIGH-PILED” is referenced per the scoping Code (e.g. 2021 IBC) (9) time in “Chapter 9 Fire Protection and Life Safety Systems” :

1. 903.2.7.1 HIGH-PILED Storage. An automatic sprinkler system shall be provided in accordance with the International Fire Code in all buildings of Group M where storage of merchandise is in HIGH-PILED or rack storage arrays.
2. 905.1 General. Standpipe systems shall be provided in new buildings and structures in accordance with Sections 905.2 through 905.11. In buildings used for HIGH-PILED combustible storage, fire protection shall be in accordance with the International Fire Code.
3. TABLE 906.1 IFC SECTION / SUBJECT ... 3206.10 / HIGH-PILED storage
4. 907.2.15 HIGH-PILED Combustible Storage Areas. An automatic smoke detection system shall be installed throughout HIGH-PILED combustible storage areas where required by Section 3206.5 of the International Fire Code.
5. 910.2.2 HIGH-PILED Combustible Storage. Smoke and heat removal required by Table 3206.2 of the International Fire Code for buildings and portions thereof containing HIGH-PILED combustible storage shall be installed in accordance with Section 910.3 in unsprinklered buildings. In buildings and portions thereof containing HIGH-PILED combustible storage equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1, a smoke and heat removal system shall be installed in accordance with Section 910.3 or 910.4. In occupied portions of a building equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1, where the upper surface of the story is not a roof assembly, a mechanical smoke removal system in accordance with Section 910.4 shall be installed.

None of these HIGH-PILED references are applicable to the conditions described per the submitter.

The 2021 IFC includes an entire chapter (Ch 32) on “High-Piled Combustible Storage” ... it contains (14) references to “NONCOMBUSTIBLE”.

Section 3203 Commodity Classification
3203.1 Classification of Commodities
Commodities shall be classified as Class I, II, III, IV or high hazard in accordance with Sections 3203.2 through 3203.10.3. Materials listed within each commodity classification are assumed to be unmodified for improved combustibility characteristics. Use of flame-retarding modifiers or the physical form of the material could change the classification.
3203.2 Class I Commodities
Class I commodities are NONCOMBUSTIBLE products in ordinary corrugated cartons with or without single-thickness dividers, or in ordinary paper wrappings with or without wood pallets. The amount of Group A plastics shall be limited in accordance with Section 3203.9.

4/4/2023 11:22:16 pm

Class I means something to burn, i.e. pallets or packaging.
Empty metallic drums on pallets is class I and need to be protected because of the pallets they sit on.
Empty metallic drums on the ground (no pallet, no packaging) is pure non combustible and does not need to be protected.

Mike Wells link

8/4/2023 07:52:14 pm

I have a related situation.

Our customer stores pieces of metal U-channel strut and all thread rod that are stacked on steel cantilever racks. There are no pallets. Packaging is by wrapping of steel bands. Everything is non-combustible.

Since the commodity is non-combustible, Table 435.5.1 for high piled racking does not apply, correct? It seems to apply only to combustible commodities. Therefore the 12 foot high limitation triggering high-pile storage requirements would not apply, right?

We hope to avoid the requirements of Table 435.5.1 since the building does not meet the fire department access door requirements even though it does meet the requirements for automatic sprinklers as well as smoke and heat removal.

I can't find a code section I can point to for what is not required on non-combustible commodities. Like proving a negative.

A Code-Path for Non-Combustible Rack Storage?

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