Hazard Classification for Whiskey Distillery?

2/20/2024

I am in the process of designing a fire protection system for a whiskey distillery (making of, bottling, shipping & receiving). This project is a full blown distillery with fermenting tanks, barrel filling room, barrel storage etc.

I've looked at NFPA 13 & NFPA 30 as well as some FM Global Data Sheets (7-29 & 7-74) and cannot locate the correct hazard and commodity class to use. I have high piled storage and the storage of flammable liquids.

What is the appropriate commodity classification and hazard to use for whiskey barrel storage?

Maybe I'm in information overload at this point and looking to deep into it. Any suggestions or advice would be greatly appreciated!

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13 Comments

Dan Wilder

2/20/2024 07:14:59 am

NFPA 30 24' (New Section) - 16.10 Distilled Spirits in Wooden Barrels specific to 20%-75% in wooden barrels not exceeding 130 gallons. Mostly follows FM Global paths.

FM 7-74 Chapter 2.4.1.1
FM 7-29 Chapter 2.4.8.4, 2.4.9.4

Both cover barrels.

Other sections within 7-29 cover glass bottle storage based on volume, configuration, height, flash point....

From some previous posts - quick summarized

Credit: Anthony Crispo
http://www.klausbruckner.com/blog/distillery-storage-dilemmas/

Credit: Frank
Using the DISCUSS documentation and research
https://www.distilledspirits.org/wp-content/uploads/2020/03/2020_DISCUS-Recommended-Fire-Protection-Practices-Foreword-and-Table-of-Contents.pdf

Anthony

2/20/2024 07:29:18 am

The alcohol industry has had success in self regulating fire protection since the end of prohibition. There is a design manual out by "The Distilled Spirits Council of the United States, Inc. (DISCUS)" - link below- that has good guidance on ' industry best practices.'

This is a guide and not code. It's not enforceable by a code official but can be a great start for a conversation with an AHJ. They do get into fixed water spray systems and deluge called out in there, so its not a 'OH2 over the whole facility" white wash document. Definitely a good place to start.

https://www.distilledspirits.org/wp-content/uploads/2021/01/2020_DISCUS-Recommended-Fire-Protection-Practices-Manual.pdf

Franck

2/20/2024 08:12:45 am

As highlighted by Anthony, DISCUS is THE standard to follow for distilles spirits.

Information for activities (including distilling and bottling) as well as for storage (in drums, tanks or bottles)

Jesse

2/20/2024 08:50:29 am

Anthony has it with DISCUS. Neither 13 nor 30 have clear guidance, at least until the 2024 revision of 30 like Dan pointed out.

I know one insurer I was doing Loss Control work for a gazillion years ago treated rack storage of finished product liquor in glass bottles and single thickness corrugated boxes as a Class-IV Commodity and then the actual distillation and bottling as OH2 or EH2 depending on the ETOH content.

Dean Melanson

2/20/2024 09:22:06 am

The IFC and NFPA 1 in the general storage chapter assign commodity classifications to alcohol products based on the percentage of alcohol in the product

Todd E Wyatt

2/20/2024 10:17:17 am

The whiskey’s “% alcohol”, the quantities stored, if sold, and if consumed all determine WHERE an automatic sprinkler system (ASPS) is to be installed based on the building’s Occupancy Classification (OC).

Based on your descriptions ( … whiskey distillery (making of, bottling, shipping & receiving …), this building includes the following OCs :

Moderate-Hazard Factory Industrial, Group F-1 & Moderate-Hazard Storage, Group S-1 … for “Beverages: up to and including 16-percent alcohol content”.
Low-Hazard Factory Industrial, Group F-2 & Low-Hazard Storage, Group S-2 … for “Beverages: over 16-percent alcohol content”.

Depending on IF the whisky will be for sale to the public, it may also include a Group M Mercantile OC :

Section 309 Mercantile Group M … use of a building or structure or a portion thereof for the display and sale of merchandise, and involves stocks of goods, wares or merchandise incidental to such purposes and where the public has access

IF the distillery offers space (>750 sf & an occupant load of >50) for the consumption of the whiskey, the building also includes Group A-2 Assembly.

The building probably includes “business areas” which would be Group B Business.

Lastly, depending on how the ALCOHOLIC BEVERAGES are stored ( … liquids are packaged in individual containers not exceeding 1.3 gallons …) will determine IF the building is to be classified as a High-Hazard Group H OC. (see REFERENCES TABLE 307.1(1) below).

Review of IBC-2021 Chapter 9 Fire Protection and Life Safety Systems determines WHERE an ASPS is required based on the building’s OC(s) :

Group F-1 : 903.2.4
Group S-1 : 903.2.9
Group F-2 : No requirements
Group S-2 : No requirements
Group M : 903.2.7
Group A-2 : 903.2.1.2
Group B : No requirements

Additionally, “high-piled storage” is referenced in Group M (903.2.7.1).

The storage of “DISTILLED SPIRITS” is regulated by the adopted IFC Chapter 40 Storage of Distilled Spirits and Wines. The IFC also includes a chapter regarding “High-Piled Combustible Storage” (Chapter 32).

Todd E Wyatt

2/20/2024 10:17:49 am

REFERENCES
IBC-2021

Section 306 Factory Group F
306.2 Moderate-Hazard Factory Industrial, Group F-1
Factory industrial uses that are not classified as Factory Industrial F-2 Low Hazard shall be classified as F-1 Moderate Hazard and shall include, but not be limited to, the following:
Beverages: over 16-percent alcohol content
306.3 Low-Hazard Factory Industrial, Group F-2
Factory industrial uses that involve the fabrication or manufacturing of noncombustible materials that during finishing, packing or processing do not involve a significant fire hazard shall be classified as F-2 occupancies and shall include, but not be limited to, the following:
Beverages: up to and including 16-percent alcohol content

311.2
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:
Beverages over 16-percent alcohol content
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:
Beverages up to and including 16-percent alcohol

309.1 Mercantile Group M
Mercantile Group M occupancy includes, among others, the use of a building or structure or a portion thereof for the display and sale of merchandise, and involves stocks of goods, wares or merchandise incidental to such purposes and where the public has access. Mercantile occupancies shall include, but not be limited to, the following: Retail or wholesale stores, Sales rooms
309.2 Quantity of Hazardous Materials
The aggregate quantity of nonflammable solid and nonflammable or noncombustible liquid hazardous materials stored or displayed in a single control area of a Group M occupancy shall not exceed the quantities in Table 414.2.5(1).

303.3 Assembly Group A-2
Group A-2 occupancy includes assembly uses intended for food and/or drink consumption including, but not limited to: Taverns and bars

Section 307 High-Hazard Group H
307.1 High-Hazard Group H
TABLE 307.1(1) MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A PHYSICAL HAZARD
MATERIAL : Combustible liquid (C)
Keynote C
The quantities of ALCOHLIC BEVERAGES in retail and wholesale sales occupancies shall not be limited provided the liquids are packaged in individual containers not exceeding 1.3 gallons. In retail and wholesale sales occupancies, the quantities of medicines, foodstuffs or consumer 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.

307.1.1 Uses Other Than Group H
An occupancy that stores, uses or handles hazardous materials as described in one or more of the following items shall not be classified as Group H, but shall be classified as the occupancy that it most nearly resembles.
18. DISTILLED or brewing of beverages conforming to the requirements of the International Fire Code.
19. The storage of beer, DISTILLED SPIRITS and wines in barrels and casks conforming to the requirements of the International Fire Code.

Chapter 9 Fire Protection and Life Safety Systems
Section 903 Automatic Sprinkler Systems
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.

903.2.1 Group A
An automatic sprinkler system shall be provided throughout buildings and portions thereof used as Group A occupancies as provided in this section.
903.2.1.2 Group A-2
An automatic sprinkler system shall be provided throughout stories containing Group A-2 occupancies and throughout all stories from the Group A-2 occupancy to and including the levels of exit discharge serving that occupancy where one of the following conditions exists:
1. The fire area exceeds 5,000 square feet (464 m2).
2. The fire area has an occupant load of 100 or more.
3. The fire area is located on a floor other than a level of exit discharge serving such occupancies.

903.2.4 Group F-1
An automatic sprinkler system shall be provided throughout all buildings containing a Group F-1 occupancy where one of the following conditions exists:
1. A Group F-1 fire area exceeds 12,000 square feet (1115 m2).
2. A Group F-1 fire area is located more than three stories above grade plane.
3. The combined area of all Group F-1 fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).
903.2.4.2 Group F-1 DISTILLED SPIRITS
An automatic sprinkler system shall be provided throughout a Gro

Todd E Wyatt

2/20/2024 10:18:41 am

REFERENCES ... continued
IBC-2021

903.2.4.2 Group F-1 DISTILLED SPIRITS
An automatic sprinkler system shall be provided throughout a Group F-1 fire area used for the manufacture of distilled spirits.

903.2.7 Group M
An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115 m2).
2. A Group M fire area is located more than three stories above grade plane.
3. The combined area of all Group M fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).
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.

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).
903.2.9.3 Group S-1 Distilled Spirits or Wine
An automatic sprinkler system shall be provided throughout a Group S-1 fire area used for the bulk storage of distilled spirits or wine.

IFC-2021
Chapter 40 Storage of Distilled Spirits and Wines
User note:
About this chapter: Chapter 40 provides specific requirements for the storage of distilled spirits and wines. In accordance with Section 307.1.1 of the International Building Code®, these occupancies are not classified as a Group H occupancy. Instead, as listed in Sections 311.2 and 311.3 of the International Building Code, the storage of beverages that contain up to and including 16-percent alcohol are classified as a Group S-2 occupancy, and those that contain over 16-percent alcohol content are classified as a Group S-1 occupancy. Note that those that are classified as a Group S-1 occupancy are required to be provided with an automatic sprinkler system throughout the Group S-1 fire area, regardless of size, in accordance with Section 903.

Section 4005 Fire Protection
4005.1 Automatic Sprinkler System
The storage of distilled spirits and wines shall be protected by an approved automatic sprinkler system as required by Chapter 9.
Chapter 9 Fire Protection and Life Safety Systems
Chapter 32 High-Piled Combustible Storage
User note:
About this chapter: Chapter 32 provides guidance for reasonable protection of life from hazards associated with the storage of combustible materials in closely packed piles or on pallets, in racks or on shelves where the top of storage is greater than 12 feet in height, or 6 feet for high-hazard commodities. It provides requirements for identifying various classes of commodities; and general fire and life safety features including storage arrangements, smoke and heat venting, fire department access and housekeeping and maintenance. This chapter attempts to define the potential fire severity and, in turn, determine fire and life safety protection measures needed to control and in some cases suppress a potential fire. This chapter does not cover miscellaneous combustible material storage as regulated in Section 315.

Glenn Berger

2/20/2024 12:41:00 pm

Break down the facility by the specific hazard / event / occupancy in each portion of the facility. The DISCUS document looks very applicable for SOME areas of the facility and I doubt a code official would disagree when presented with this information.

Franck

2/20/2024 01:31:22 pm

The good news is that whisky mix very well with water (well, ethanol mix well with water, not only whisky, but also cognac, vodka…). Sprinkler protection will help dilute the alcohol percentage. This is why whisky bottles are considered as a class IV commodity as indicated by Jess per NFPA and not a flammable liquid.
But if not sprinkler protected, then it burns like any flammable liquid with additional spill fire…
Beer can go down to class I (II if in cardboxes).

Franck

2/20/2024 01:33:03 pm

Cask storage in racks is the big issue.
To my knowledge, only well addressed by FM Global and DISCUS.

Franck

2/20/2024 01:42:47 pm

About 25 years ago we were insuring alcohol facilities and I was one of the Insurance Loss Prevention Engineer.
I saw some pictures of a fire in large warehouse filled with casks of Cognac in the South of France (unprotected) and that was pretty impressive. Buildings were more than 40 ft high and the flammes were about 100 ft from the ground. Just like flaming rum in a pan.
At that time we had an “interesting” loss in Scotland where one warehouse (unprotected) caught fire at the top of the hill. Other warehouses were more than 100 ft apart… but downhill. The spill fire went down the hill and finally burnt several warehouses… That was a big loss !

Megan Asbrock

3/21/2024 06:55:43 pm

you should download FM Globals Data sheet for commodity classification. to determine protection you need to take a look at your fuel load package...a pallet size of material. if different areas deal with different mixtures (different levels of alcohol content) and different container types or packaging (i.e. glass bottles to a plastic container) the commodity classification may change.

I would 100% hire a Licensed FPE / fire protection engineering firm to determine the commodity classifications and protection requirements for the spaces in the building. This is a perfect example of something that should be left to the professionals.

Hazard Classification for Whiskey Distillery?

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