Chemical Compliance Options for Multi-Tenant Lab and Manufacturing Buildings

The Boston Herald ran an article over the weekend announcing plans for a new 355,000 square foot multi-tenant research, design, and manufacturing facility in the Seaport. While this is certainly exciting news for the expanding “Innovation District”, I couldn’t help but think of the design challenges this type of project presents to the design team and building owner. The hazardous chemicals that are inherent in any pharmaceutical & manufacturing operation bring with them additional regulations beyond that experienced by most commercial buildings from the Massachusetts State Building Code (780 CMR), Massachusetts Fire Prevention Regulations (527 CMR), and referenced NFPA Codes & Standards. As one might imagine, the code prescribed protection features, and associated cost of construction, vary significantly based on the corresponding fire hazard presented by the combination of the physical properties and quantity of the chemicals in use or storage.

The key in delivering a successful project in this type of facility is identifying the owner’s and/or developer’s objectives for the project early on. A client who wants to own and operate this type of facility for a long time will likely desire a shell and core design that can accommodate a wide array of users, including those with significant chemical quantities and hazard types. Alternatively, a client whose objective is to sell the property in the near term may be looking for a building that can accommodate their present tenant’s needs and nothing more.

There are numerous chemical compliance options available in 780 CMR for designers to implement on this type of building to fit the client’s objectives. At one end of the spectrum, there are control areas. Control areas are essentially fire-resistance rated compartments that are permitted to have a certain quantity of chemicals within each. 780 CMR permits a certain number of control areas and a certain quantity of chemicals per floor depending on the ease of fire department access. One benefit of control areas is that they do not change the Use Group classification of the building and when compared with other protection approaches require less specialized protection features. The drawback of control areas is the chemical limits imposed on users. This is especially true in multi-tenant buildings, where separate tenants may be forced to share a control area, creating the operational issue of tracking chemical quantities between neighbors to stay under a single limit.

At the other end of the spectrum are Use Group H, High Hazard Occupancies. While these types of occupancies have much more liberal quantity restrictions when compared with control areas, it comes at a cost. The construction type required to have sizeable H occupancies or H occupancies located above grade is greater than that compared with other occupancies. The hazards presented by chemicals in use or storage will also require specialized protection features such as dedicated mechanical exhaust, classified electrical equipment, explosion control or prevention systems, and spill control and secondary containment systems to just name a few.

The decision to utilize control areas vs. Use Group H occupancies, or a combination thereof, should be evaluated on a case-by-case basis depending on the owner’s and tenant’s needs. For the design community, it’s certainly worth noting that 780 CMR has a requirement in Section 414.1.3 for a report to be issued with the Construction Documents outlining the proposed hazardous material protection approach on the project. Given the code complexities that go along with hazardous materials, this report is often a useful tool to help Building and Fire Officials in their review of the building and also in the operation of the facility post occupancy.