Reconcile NFPA 30 MAQ vs. NFPA 13 Protection?

12/18/2024

How do you reconcile NFPA 30, 2021 Edition, Chapter 9 General Storage Requirements which reference NFPA 13, 2019 Edition, and vice versa?

NFPA 30 Section 9.6.1 says that the MAQ is doubled when the building is sprinklered per NFPA 13.

NFPA 13 has the Extra Hazard Group 2 occupancy, which covers "substantial amounts of combustible or flammable liquids." The word substantial obviously makes it an engineering judgment for when EH2 should be applied.

Hypothetical example: An existing warehouse is sprinklered per NFPA 13 to protect rack storage of Class I-IV commodities and cartoned group A plastics. The owner wants to store a Class III-B liquid in the existing warehouse on the storage racks. They would store more than the baseline MAQ but less than double the MAQ they get for having an NFPA 13 system.

In my opinion, this storage arrangement would be out of the scope of NFPA 13, so the double MAQ for sprinklering per NFPA 13 would not apply. I'd require a protection scheme from Chapter 16 of NFPA 30.

Do you disagree?

What if they only wanted to store under the baseline MAQ amount? Would you require a protection scheme from Chapter 16 of NFPA 30?

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7 Comments

Glenn Berger

12/18/2024 08:13:37 am

I would de-conflict the standards in the following manner: (without validating the storage arrangement, etc.)

Design Criteria iaw NFPA 30
Installation, Testing, etc iaw NFPA 13

12/18/2024 08:24:19 am

I believe NPFA 30 allows for increases to the MAQ for a sprinklered building because of the additional protection provided with a sprinklered building versus non-sprinklered building.

The standard mentions NFPA 13 to probably avoid any conflicts with someone trying to apply a less lenient standard in order to gain an increase to the MAQ. The hazmat chapters in the IBC/IFC also require NFPA 13 in order to allow for increases to the MAQ.

For your example, I'd defer to the fire protection design schemes in NFPA 30 instead of 13 if your project meets those requirements. If not, then I recommend consulting with a fire protection engineer if the storage arrangement is outside the scope of NFPA 13 and 30.

Matt Hamilton

12/18/2024 08:30:37 am

NFPA 13 Chapter 26 (2019) or Chapter 27 (2022) Special Occupancy Requirements references back to NFPA 30 for the protection criteria of flammable and combustible liquids, so it circles you back to there. So, yes I would agree with you that you should reference NFPA 30 to come up with the correct design criteria.

Jesse

12/18/2024 11:40:53 am

I would select the design criteria and protection scheme from 30. 13 is more than just a means to find design criteria as it covers installation and aceptance. So 13 will come into play in the execution of the system designed to 30

Todd E Wyatt

12/18/2024 11:54:24 am

The referenced standards (e.g. NFPA 13 & NFPA 30) prescribe HOW an automatic sprinkler system (ASPS) is to be designed, installed, inspected, and maintained whereas the adopted (scoping) Code (e.g. IBC-2024 and IFC-2024) prescribe WHERE an ASPS is to be installed based on the building’s Occupancy Classification (OC) and other specialized requirements per Chapter 9 Fire Protection and Life Safety Systems, 903.2 Where Required.

I recommend you start in IBC-2024 Chapter 3 to determine if the Hazardous Materials (HM) exceed the Maximum Allowable Quantities (MAQ) requiring these storage areas to be classified as a Group H Hazardous OC versus Group S Storage. If the MAQs permit this space to be classified as Group S Storage, refer to Section 413 for compliance of the “rack storage.” IBC-2024 413.1 then references to the International Fire Code (IFC-2024).

“Rack storage” is referenced in IFC-2024 in 3208, 5104.4.3, and 5704.3.3.6. See REFERENCES below. Focus on Section 3208 Rack Storage & Section 3206 General Fire Protection and Life Safety Features.

Todd Wyatt

12/20/2024 10:35:19 am

REFERENCES
IBC-2024
Chapter 3 Occupancy Classification and Use
Section 307 High-Hazard Group H
[F] 307.1 High-Hazard Group H
[F] TABLE 307.1(1) MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A PHYSICAL HAZARD
[F] TABLE 307.1(2) MAXIMUM ALLOWABLE QUANTITY PER CONTROL AREA OF HAZARDOUS MATERIALS POSING A HEALTH HAZARD
[F] 307.2 Hazardous Materials
Hazardous materials in any quantity shall conform to the requirements of this code, including Section 414 , and the International Fire Code.
311.1 Storage Group S
311.1.2 Combustible Storage
High-piled stock or RACK STORAGE, or attic, under-floor and concealed spaces used for storage of combustible materials, shall be in accordance with Section 413.

Chapter 4 Special Detailed Requirements Based on Occupancy and Use
Section 413 Combustible Storage
413.1 General
High-piled stock or RACK STORAGE in any occupancy group shall comply with the International Fire Code.

Chapter 9 Fire Protection and Life Safety Systems
Section 903 Automatic Sprinkler Systems
[F] 903.1 General
[F] 903.1.1 Alternative Protection
[F] 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.

IFC-2024
Chapter 32 High-Piled Combustible Storage
Section 3208 Rack Storage
3208.1 General
Rack storage shall be in accordance with Section 3206 and this section. Bin boxes exceeding 5 feet (1524 mm) in any dimension shall be regulated as rack storage.
3208.1.1 Storage Racks
3208.2 Fire Protection
3208.2.2 Racks With Solid Shelving
3208.2.2.1 Fire Protection
3208.3 Flue Spaces
TABLE 3208.3 REQUIRED FLUE SPACES FOR RACK STORAGE
3208.3.1 Flue Space Protection
3208.4 Column Protection
3208.5 Extra-High-Rack Storage Systems
3208.5.1 Fire Protection

Section 3206 General Fire Protection and Life Safety Features
3206.1 General
3206.2 Type of Protection
TABLE 3206.2 GENERAL FIRE PROTECTION AND LIFE SAFETY REQUIREMENTS
3206.2.1 Extent of Protection
3206.3 High-Piled Storage Areas
3206.3.1 Size of High-Piled Storage Area
3206.3.2 Multiple High-Piled Storage Areas
3206.3.2.1 Multiple Class High-Piled Storage Areas
3206.4 Automatic Sprinklers
AUTOMATIC SPRINKLER SYSTEMS shall be provided in accordance with Sections 3207, 3208 and 3209.
3206.4.1 Pallets
3206.4.1.1 Plastic Pallets
3206.5 Fire Detection
3206.6 Building Access
3206.7 Fire Department Access Doors
3206.7.1 Exterior Walls Without Fire Department Access Doors
3206.7.2 Where Located
3206.7.3 Access to Doors
3206.7.4 Marking on Fire Department Access Doors
3206.7.5 Number of Doors Required
3206.7.6 Door Size and Type
3206.7.7 Locking Devices
3206.7.8 Key Box
3206.8 Smoke and Heat Removal
3206.9 Fire Department Hose Connections
3206.10 Aisles
3206.10.1 Width
3206.10.1.1 SPRINKLERED BUILDINGS
Aisles in SPRINKLERED BUILDINGS shall be not less than 44 inches (1118 mm) wide. Aisles shall be not less than 96 inches (2438 mm) wide in high-piled storage areas exceeding 2,500 square feet (232 m2) in area, that are open to the public and designated to contain high-hazard commodities.
Aisles shall be not less than 96 inches (2438 mm) wide in areas open to the public where mechanical stocking methods are used.
Exceptions:
1. Aisles in high-piled storage areas exceeding 2,500 square feet (232 m2) in area, that are open to the public and designated to contain high-hazard commodities, and that are protected by an automatic sprinkler system designed for multiple-row racks of high-hazard commodities, shall be not less than 44 inches (1118 mm) wide.
2. Aisles that are in high-piled storage areas exceeding 2,500 square feet (232 m2) in area, not open to the public and protected by an automatic sprinkler system designed for multiple-row racks, shall be not less than 24 inches (610 mm) wide.
3206.10.1.2 Nonsprinklered Buildings
3206.10.2 Clear Height
3206.10.3 Dead-End Aisles
3206.11 Portable Fire Extinguishers

Jose Figueroa

12/21/2024 01:59:56 pm

I would like to share an insightful analysis from an NFPA expert regarding the reconciliation of various standards.

Neither NFPA 30 or NFPA 13 stands alone without precedence from another building and life safety code such as the IFC, NFPA 1, Fire Code and/or NFPA 101, Life Safety Code. NFPA 30 or NFPA 13 relate to how the installation is done while the building safety code dictates where the protection is.

I will be referencing the 2024 NFPA 101 (LSC) as it is the most comprehensive code for life safety in existing buildings.

The existing building is primarily a storage occupancy which refers to Chapter 42 and the related fundamental chapters referenced by that chapter.

The hazard categories for storage facilities contained in NFPA 13 are established for the design of automatic sprinkler systems.

An AHJ must review and approve the designer's designation of hazard categories.

LSC: "42.3.2 Protection from Hazards. Where hazardous materials are stored, used, or handled, the provisions of 8.7.3.1 shall apply."

LSC:"8.7.3.1 Where required by the provisions of Chapters 11 through 43, occupancies with storage, use, and handling of hazardous materials shall comply with the following codes unless otherwise modified by other provisions of this Code: NFPA 30, NFPA 54, NFPA 55, NFPA 58, NFPA 400, and NFPA 495."

Chapter 60 of NFPA 1, Fire Code, establishes MAQs which can take precedence over NFPA 30.

The specified MAQs are not absolute maximums.

They represent the maximum quantity of a material permitted in a single control area without requiring additional protection features.

Where the MAQ is exceeded in a control area, additional protection requirements are specified by NFPA 1.

Very complex relationship between the parent codes and the subordinate standards/codes.

Reconcile NFPA 30 MAQ vs. NFPA 13 Protection?

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