Need to Meet High Hazard During Construction?

3/8/2023

I am overseeing an NFPA 101, Chapter 43 reconstruction project in an existing storage occupancy that is changing to an industrial/high hazard occupancy.

I am trying to coordinate the means of egress during construction.

Other parts of the building are currently occupied and the new area is less than 50% of the building.

Section 43.7.2.3 requires that the area comply with the applicable new construction chapters of the occupancy. The hazard category per table 43.7.3 leads me to believe this would be a hazard category 1.

The question is: when is the construction area considered to be high hazard?

The contents of the hazardous occupancy will not be present through the entirety of the construction and will only be put in place after the space is ready to be occupied and compliant with all means of egress requirements. During construction, the "high hazard contents room" is just a small room with nothing located inside.

Even with no high hazard contents present until the space is ready to be occupied, does it need to meet the egress requirements of new industrial/high hazard or can it meet the egress requirements of existing for storage?

Thanks.

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3 Comments

chad

3/8/2023 07:34:43 am

1- do you have an NFPA 241 plan? Egress during construction should be covered by this. Also refer to 101:

4.6.10 Construction, Repair, and Improvement Operations.
4.6.10.1* Buildings, or portions of buildings, shall be permitted
to be occupied during construction, repair, alterations, or additions only where required means of egress and required
fire protection features are in place and continuously maintained
for the portion occupied or where alternative life safety
measures acceptable to the authority having jurisdiction are in
place.

4.6.10.2* In buildings under construction, adequate escape facilities shall be maintained at all times for the use of construction workers. Escape facilities shall consist of doors, walkways, stairs, ramps, fire escapes, ladders, or other approved means or devices arranged in accordance with the general principles of the Code insofar as they can reasonably be applied to buildings under construction

2- Until the construction is complete and accepted, its not a change of occupancy, as you do not have the new space approved for that use

Todd E Wyatt

3/8/2023 09:14:15 am

To piggyback on Chad’s correct response ...

“NFPA 241 Standard for Safeguarding Construction, Alteration, and Demolition Operations” provides prescriptive requirements for “Temporary Construction Barriers” (TCB) that “separate an occupied portion of the structure from a portion of the structure undergoing alteration, construction, or demolition operations when such operations have a higher level of hazard than the occupied portion of the building.” As Chad stated, the “construction portion” is not officially classified as an Occupancy (e.g. High-Hazard Industrial) until the AHJ has issued a Certificate of Occupancy.

Depending on IF the existing Storage building is protected with an automatic sprinkler system (ASPS), the fire-resistance rating (FRR) of the TCB can be reduced from 1-Hour FRR be 0-Hr IF the existing ASPS is modified (e.g. turn sprinklers up to the exposed roof to be compliant with NFPA 13) in the unoccupied, construction portion to remain operational (and compliant).

Per NFPA 101 Chapter 43, some Occupancy chapter (12-42) includes “##.7.9 Construction, Repair, and Improvement Operations” which reference 4.6.10 which reference NFPA 241.
Chapter 42 Storage Occupancies references “4.6.10.2” ... 42.1.1.4 Where construction, alteration, or demolition operations are conducted, the provisions of 4.6.10.2 shall apply ... which references NFPA 241.

Per NFPA 101 Chapter 43, the “Change of Occupancy” includes “Table 43.7.3 Hazard Categories and Classifications” which classifies “Industrial or storage occupancies with high hazard contents” as “Hazard Category 1 (highest)”, “General and special-purpose industrial, ordinary hazard storage” as “Hazard Category 3”, and “Industrial or storage occupancies with low hazard contents” as “4 (lowest hazard)”.

REFERENCES
2021 NFPA 101 Life Safety Code
4.6.10 Construction, Repair, and Improvement Operations.
4.6.10.1*
Buildings, or portions of buildings, shall be permitted to be occupied during construction, repair, alterations, or additions only where required means of egress and required fire protection features are in place and continuously maintained for the portion occupied or where alternative life safety measures acceptable to the authority having jurisdiction are in place.
A.4.6.10.1 Fatal fires have occurred when, for example, a required stair has been closed for repairs or removed for rebuilding, or when a required automatic sprinkler system has been shut off to change piping.
ENHANCED CONTENT
The provisions of 4.6.10.1 help to control a relatively common practice — the occupation of completed portions of a partially completed structure. The Code permits such occupation if certain conditions are met. For example, the Code requires that egress features for the portion occupied be complete and maintained to be usable. In many cases, the egress facilities, although completed, are not usable because they are blocked by stored building materials and equipment needed for the ongoing construction, or doors are locked to limit access to parts of the building still under construction. In such cases, occupancy is prohibited.
The Code also requires that fire protection features be in place and be continuously maintained. The incidence of fire is more frequent, and therefore more likely, during construction or rehabilitation. Extra caution and concern need to be exercised to ensure adequate egress capacity and arrangement during periods of construction in any occupied building.
Paragraph 4.6.10.1 recognizes that, in lieu of strict adherence to the egress and fire protection features, alternative life safety measures might make the building safe enough to be occupied. As usual, the authority having jurisdiction is charged with judging whether the alternative measures provide an acceptable remedy. Paragraph 4.6.10.1 is conceptually similar to 4.6.9.1.

4.6.10.2
Where required by Chapters 11 through 43, construction, alteration, and demolition operations shall comply with NFPA 241.
ENHANCED CONTENT
The provision of 4.6.10.2 first appeared in the 2018 edition of the Code. It permits the occupancy chapters to mandate compliance with NFPA 241, Standard for Safeguarding Construction, Alteration, and Demolition Operations, which relates directly to the goals and objectives of this Code, where such operations occur. Occupancy chapters mandating compliance with NFPA 241 via 4.6.10.2 include the following:
Chapters 12 and 13, New & Existing Assembly Occupancies
Chapters 14 and 15, New & Existing Educational Occupancies
Chapters 16 and 17, New & Existing Day-Care Occupancies
Chapters 22 and 23, New & Existing Detention and Correctional Occupancies
Chapters 28 and 29, New & Existing Hotels and Dormitories
Chapters 30 and 31, New & Existing Apartment Buildings
Chapters 36 and 37, New & Existing Me

3/8/2023 10:34:25 am

REFERENCES ... continued

4.6.10.3*
In buildings under construction, adequate escape facilities shall be maintained at all times for the use of construction workers. Escape facilities shall consist of doors, walkways, stairs, ramps, fire escapes, ladders, or other approved means or devices arranged in accordance with the general principles of the Code insofar as they can reasonably be applied to buildings under construction.
A.4.6.10.3 See also NFPA 241.
4.6.10.4
Flammable or explosive substances or equipment for repairs or alterations shall be permitted in a building while the building is occupied if the condition of use and safeguards provided do not create any additional danger or impediment to egress beyond the normally permissible conditions in the building.

Chapter 40 Industrial Occupancies
40.1 General Requirements.
40.1.1 Application.
40.1.1.6
Where construction, alteration, or demolition operations are conducted, the provisions of 4.6.10.2 shall apply.
40.1.2 Classification of Occupancy.
Classification of occupancy shall be in accordance with 6.1.12.
40.1.2.1 Subclassification of Occupancy.
Each industrial occupancy shall be subclassified according to its use as described in 40.1.2.1.1, 40.1.2.1.2, and 40.1.2.1.3.

40.1.2.1.1 General Industrial Occupancy.
General industrial occupancies shall include all of the following:
(1) Industrial occupancies that conduct ordinary- and low-hazard industrial operations in buildings of conventional design that are usable for various types of industrial processes
(2) Industrial occupancies that include multistory buildings where floors are occupied by different tenants, or buildings that are usable for such occupancy and, therefore, are subject to possible use for types of industrial processes with a high density of employee population

40.1.2.1.2 Special-Purpose Industrial Occupancy.
Special-purpose industrial occupancies shall include all of the following:
(1) Industrial occupancies that conduct ordinary- and low-hazard industrial operations in buildings designed for, and that are usable only for, particular types of operations
(2) Industrial occupancies that are characterized by a relatively low density of employee population, with much of the area occupied by machinery or equipment

40.1.2.1.3* High-Hazard Industrial Occupancy.
High-hazard industrial occupancies shall include all of the following:
(1) Existing industrial occupancies that conduct industrial operations that use, process, store, or handle high-hazard contents, as defined by 6.2.2.4
(2) New industrial occupancies that conduct industrial operations that use, process, store, or handle high-hazard contents, as defined by 6.2.2.4, in excess of the maximum allowable quantities (MAQ) as permitted by the fire code
(3) Industrial occupancies in which incidental high-hazard operations in low- or ordinary-hazard occupancies that are protected in accordance with Section 8.7 and 40.3.2 are not required to be the basis for overall occupancy classification

40.1.2.2 Change of Industrial Occupancy Subclassification.
A change from one subclassification of industrial occupancy to another shall comply with Chapter 43.

Chapter 42 Storage Occupancies
42.1 General Requirements.
42.1.1 Application.
42.1.1.1
The requirements of this chapter shall apply to both new and existing storage occupancies.
42.1.1.4
Where construction, alteration, or demolition operations are conducted, the provisions of 4.6.10.2 shall apply.

Chapter 43 Building Rehabilitation
43.1.2 Applicable Requirements.
43.1.2.2
Any building undergoing change of use or change of occupancy classification (see 43.2.2.1.5 and 43.2.2.1.6) shall comply with the requirements of Section 43.7.
43.2.2.1.6 Change of Occupancy Classification.
The change in the occupancy classification of a structure or portion of a structure.
43.2.2.1.7 Addition.
43.2.2.2* Equipment or Fixture.
43.2.2.3 Load-Bearing Element.
43.2.2.4 Rehabilitation Work Area.
43.2.2.5 Technically Infeasible.

43.7 Change of Use or Occupancy Classification.
43.7.1 Change of Use.
43.7.2 Change of Occupancy Classification.
43.7.2.3
Where a change of occupancy classification occurs to an occupancy classification of a higher hazard classification category (i.e., a lower hazard category number), as addressed by Table 43.7.3, the building shall comply with the requirements of the occupancy chapters applicable to new construction for the occupancy created by the change. (See Chapters 12, 14, 16, 18, 20, 22, 24, 26, 28, 30, 32, 36, 38, 40, and 42.)
43.7.3* Hazard Category Classifications.
The relative degree of hazard between different occupancy classifications shall be as set forth in the hazard category classifications of Table 43.7.3.
A.43.7.3
Table 43.7.3 groups all the residential occupancy classifications into the general category of residential. The category of residential includes one- and two-family dwellings, lodging or rooming houses, hotels and dormitories, and apartment buildings.

Need to Meet High Hazard During Construction?

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