How to Address Control Areas in Old Buildings?

1/27/2025

We are a large metropolitan area with multiple universities that have been operating for decades with high levels of hazardous materials. They want to have separated control areas, but their building construction does not meet current requirements.

On one side we can only enforce the code that these were built to, which was BOCA or even no building code at the time, but on the other hand, there is a reason why control areas came about in the first place.

As they cannot easily upgrade the structure to meet 2-hr requirements, I am planning on just using equivalent level of safety through sprinkler protection and other factors, but was wondering if anyone had experience doing enforcement like this?

Is NFPA 45 enforceable here?

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8 Comments

Glenn Berger

1/27/2025 08:08:31 am

We cannot tell you about the applicability of NFPA 45 in your jurisdiction.

My approach is to bring the facility into compliance as best as possible and educate users on why change is required. I would try to relocate and reduce the quantity of hazardous materials to the least amount possible.

Brett

1/27/2025 08:15:44 am

Regardless of whether NFPA 45 is adopted, it won't be applicable because NFPA 45 says that flammable or hazardous chemicals are outside its scope.

Todd link

1/27/2025 09:42:58 am

Brett, Not sure where you see the broad scope exclusion for flammable liquids and hazardous materials. NFPA 45 does genereally apply to these hazard categories. It does exclude chemical with a health, flammable or instability hazard rating of 0 and 1 which are the lowest hazard materials in those categories. It also excludes very small quantities, less than 1 gal of flammable/combustible liquid and less than 75 scf of flammable gas in a lab unit. There are ither specific exclusions as well. But to broadly say that it would not be applicable is not correct. That being said, NFPA 45 is not referenced by the I-Codes and would not be enforceable except where specifically adopted by the jurisdiction. In some states I have worked, the State Fire Marshal adopts NFPA Codes/Standards parallel to any I-Codes that are adopted by the city, county, state.... I agree with Glenn and NFPA 45 would serve as a good tool to bring these labs into come level of compliance. I am somewhat surprised that the university does not have some type of lab safety, fire safety champion to manage and advocate for concerns such as this.

Todd E Wyatt

1/27/2025 09:31:56 am

Review the CONTROL AREA requirements per the scoping Codes (e.g. IBC-2021 & IFC-2021).

IBC-2021
414.2 Control Areas
Control areas shall comply with Sections 414.2.1 through 414.2.5 and the International Fire Code.

IFC-2021
Chapter 50 Hazardous Materials - General Provisions

Referenced standards (e.g. NFPA 45) are only applicable per Section 102.4.

102.4 Referenced Codes and Standards
The codes and standards referenced in this code shall be considered to be part of the requirements of this code to the prescribed extent of each such reference and as further regulated in Sections 102.4.1 and 102.4.2.
102.4.1 Conflicts
Where conflicts occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.
102.4.2 Provisions in Referenced Codes and Standards
Where the extent of the reference to a referenced code or standard includes subject matter that is within the scope of this code or the International Codes specified in Section 101.4, the provisions of this code or the International Codes specified in Section 101.4, as applicable, shall take precedence over the provisions in the referenced code or standard.

Todd E Wyatt

1/27/2025 09:36:32 am

Since this is an existing building, review the International Existing Building Code (IEBC) Chapter 13 Performance Compliance Methods :

Chapter 13 allows for existing buildings to be evaluated so as to show that alterations, while not meeting new construction requirements, will improve the current existing situation. Provisions are based on a numerical scoring system involving 19 various safety parameters and the degree of code compliance for each issue.

The AHJ may permit "using equivalent level of safety through sprinkler protection and other factors" to meet this intent.

Todd E Wyatt

1/27/2025 12:20:57 pm

NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals, a referenced standard, is referenced per the following scoping Codes (e.g. IBC-2021 & IFC-2021) :

IBC-2021
Chapter 4 Special Detailed Requirements Based on Occupancy and Use
Section 428 Higher Education Laboratories
428.3 Laboratory Suite Construction
428.3 Laboratory Suite Construction
Where laboratory suites are provided, they shall be constructed in accordance with this section and Chapter 38 of the International Fire Code. The number of laboratory suites and percentage of maximum allowable quantities of hazardous materials in laboratory suites shall be in accordance with Table 428.3.
428.3.7 Ventilation
Ventilation shall be in accordance with Chapter 7 of NFPA 45, and the International Mechanical Code.

IFC-2021
Chapter 38 Higher Education Laboratories
Section 3803 General Safety Provisions

3803.1 Scope
Laboratories and laboratory suites applying the requirements of this chapter shall be in accordance with the general safety provisions in Sections 3803.1.1 through 3803.2.2.
3803.1.5 Time-Sensitive Materials
Containers of materials that have the potential to become hazardous during prolonged storage shall be dated when first opened, and shall be managed in accordance with NFPA 45, Section 8.3.4.4.1.
Section 3804 Laboratory Suite Construction

3804.1 General
Where laboratory suites are provided, they shall be constructed in accordance with this chapter and Section 428 of the International Building Code.
3804.1.1 Laboratory Suites
The number of laboratory suites and percentage of maximum allowable quantities of hazardous materials in laboratory suites shall be in accordance with Table 3804.1.1.
3804.1.1.7 Ventilation
Ventilation shall be in accordance with the International Mechanical Code and Chapter 7 of NFPA 45.

3805.2 Nonsprinklered Laboratories
3805.2.1 Restricted Materials Storage
Additional quantity increases shall be prohibited, and such materials shall be stored in accordance with all of the following:
1. Containers shall be completely sealed and stored in accordance with the manufacturers' recommendations.
2. Storage shall be within approved hazardous material storage cabinets in accordance with Section 5003.8.7, or shall be located in an inert atmosphere glove box in accordance with NFPA 45, Section 7.11.
3805.2.2 Restricted Materials Use
Additional quantity increases shall be prohibited, and such materials shall be stored in accordance with all of the following:
1. Use shall be within an approved chemical fume hood listed in accordance with UL 1805, or in an inert atmosphere glove box in accordance with NFPA 45, Section 7.11, or other approved equipment designed for the specific hazard of the material.

Other than the scope of these (1) + (4) references, NFPA 45 is not an “adopted standard” unless another AHJ (e.g. Fire Marshal) has adopted this as a referenced standard.

RayJ link

1/27/2025 09:35:54 am

Ask the AHJ, the local Fire Department and their insurance company. All of them are going to be involved in case of a fire.

Jack G

1/27/2025 11:04:46 am

Hard to answer without knowing specifics of the hazardous material.
Big area? small Area? Entire warehouse ?
Is it possible to draft stop the hazardous materials area? Or small enough for water curtains?
Polar solvent? Arfff- fff- afff- hydro carbon foams ?
Could you use automatic water cannons ( monitor nozzles ) to apply direct water- or a blanket of foam?
I’d follow the IBC and consult the owners insurance company and the code official for that municipality. It sounds like the contractor should not be making that decision.

How to Address Control Areas in Old Buildings?

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