In 2017, we issued a post discussing the adoption of NFPA 45, Standard on Fire Protection for Laboratories Using Chemicals, by the City of Boston. At the time, under the 2012 edition of the Massachusetts State Fire Code (527 CMR), the reference to NFPA 45 was deleted. However, the City of Boston still required compliance with NFPA 45 for laboratory projects through the City of Boston Fire Prevention Order 86-1.
Under the 2015 edition of 527 CMR, which went into effect on January 1, 2018, the reference to NFPA 45 is no longer deleted. The scoping language of 527 CMR states that all codes and standards referenced in 527 CMR are considered part of the Code, thus new laboratory projects throughout the state are required to comply with NFPA 45.
How does NFPA 45 work?
NFPA 45 covers the design and protection of laboratories using chemicals that present health and fire hazards. It utilizes the concept of Laboratory Units, which are similar in concept to control areas in that they are compartmentalized areas in which the allowable quantities of chemicals are limited. Laboratory Units are classified (A, B, C, or D) based on the amount of flammable and combustible liquids within the units. As quantities of flammable and combustible liquids increase, the requirements for protection become more stringent, including increased fire-resistance ratings, decreased allowable floor areas, more robust fire protection systems, and more restrictive means of egress requirements.
Doesn’t the Building Code Govern?
In general, 780 CMR will govern for any provisions relating to building construction, as stated in 527 CMR Section 1.1.2. However, where buildings contain flammable fluids or any substance having such properties that it may ignite or generate flammable vapors, 527 CMR Section 1.03 states that both 780 CMR and 527 CMR are applicable, and that the more restrictive requirements will govern.
What about Control Areas?
Because the Massachusetts State Building Code (780 CMR) requires the use of control areas where hazardous materials are present, these requirements must be applied in conjunction with the requirements of NFPA 45. If a conflict exists between the requirements of 780 CMR and NFPA 45, the most restrictive requirements should be applied.
If you have questions about applying these requirements to a laboratory, please feel free to contact us.