Hazardous Locker on Building or Separate?

3/2/2022

I wanted to pose the question on hazardous material storage lockers. We wish to protect the locker in accordance with Chapter 14 of NFPA 30 and have rated it for 4-hours to eliminate the need for fire separation distance to the immediately-adjacent main building as allowed.

The locker will not be structurally attached and will only have flashing connecting the two to keep out the elements, garbage, and animals. The locker will only have people in as necessary to get the liquids out.

The main building has a door on the "exterior wall" that opens and "reveals" the 3-hour rated hazardous material locker door, which you have to open to get inside the locker.

NFPA 30 2015 handbook Section 14.4.3 denotes that lockers over 1500 sqft should be protected permanent building such as attached buildings or warehouses. Our locker is under the 1500 sqft requirements so therefore I would say we are not a building but a "locker".

Therefore, the exterior wall openings allowances of IBC (2015) Table 705.8 would be to the lot line (over 10ft) and not the locker itself (0ft), allowing our client to access the locker from the inside of the main building and not having to go outside to access it from the exterior.

I was wondering if anyone has had a similar experience or if we should just call it part of the main building and protect it as such and lose the allowances of Chapter 14.

Thanks in advance!

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4 Comments

Jesse

3/2/2022 08:10:31 am

This really is a question for the AHJ as they will have overall say in the matter.

I've seen this arrangement many times, and my 2 cents is to protect the "room" using the appropriate protection scheme in NFPA 30. I had one event where there was dispensing in the "locker" or "room" and inadequate bonding and grounding. There was a fire originating in the room and extended into the main building because the door wasn't self-closing.

See what the AHJ wants.

Alex

3/2/2022 08:52:36 am

HI,

When I was going through your question, I was taking down notes of code sections and definitions. Typically, I would remove the notes and simply answer the question asked. Today, I wanted to leave my notes here since we don’t see a lot of NFPA 30 on this forum and many could learn something new from your question and others replying today.

Disclaimer: I haven’t worked with storage lockers. The notes below are simply from my research conducted this morning. I don’t believe they will help you much but may help others learn as they read through this post unfamiliar with NFPA 30.

NFPA 30 (2015) 3.3.25 states that a hazardous material storage locker is a “movable prefabricated structure, manufactured primarily at a site other than the final location of the structure and transported completely assembled or in a ready-to-assemble package…”

In addition to the definition above, to use NFPA 30 (2015) Chapter 14 (Hazardous Material Storage Lockers), you are required to be under 1,500 SQ.FT. like mentioned.

From Table 14.5.2 notes, with a fire resistance rating not less than 4 hours, distance requirements can be waived. This distance requirement is to any structure and lot lines.

IBC (2015) 706.8 states that any openings within a fire wall shall be protected in accordance with Section 716.5. 716.5 discusses the fire rating of your door contingent on the exterior wall.

I don’t believe there would be any issue if the locker is not permanently attached to the locker. If you’re looking to protect against rain/snow, a wide overhang could do the trick. I would ensure that both doors (building and locker) have automatic closers on them. Ensure that the building door is not a required means of egress. If it is, ensure that the path of egress outside of the building is not compromised.

Thanks,
Alex

Todd Wyatt

3/2/2022 11:59:02 am

Be careful using the term "Fire Wall" as this has specific prescriptive requirements per 2021 IBC Section 706 Fire Walls (see https://codes.iccsafe.org/content/IBC2021P1/chapter-7-fire-and-smoke-protection-features#IBC2021P1_Ch07_Sec706).

Per this application, we're determining the fire-resistive rating (FRR) requirements for "Exterior Walls", see Section 705 Exterior Walls (https://codes.iccsafe.org/content/IBC2021P1/chapter-7-fire-and-smoke-protection-features#IBC2021P1_Ch07_Sec705) as based on the Fire Separation Distance. The minimum required FRR protection for associated openings (e.g doors & windows) is identified in Section 716 Opening Protectives.

Eric D.

3/2/2022 09:04:15 am

Well, the first issue is separation. Remember, the Code defines Fire Separation Distance as the distance measured from the face of a building to the closest interior lot line, centerline of a street or public way, or the distance to an imaginary line between two buildings on the same lot - this last section is critical in this example)? Is the building far enough away from the main structure or are openings and walls protected from each other in accordance with the adopted codes (which I believe you said was not the case between the building and the locker)? If the separation is not there - boom, it is now part of the main building and needs to be protected as such. If fire separation is provided (via walls, glazing, opening protection, etc), then you can consider the "locker" as a separate building and may be able to get an AHJ to see it that way and not have protection.

Talk with your local building and fire officials to get their intrepretation on the codes and what they are going to want to see as far as code compliance.

Hazardous Locker on Building or Separate?

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