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Insights Category: Technical Information

Wherever chemicals are stored or used, flammable liquid storage cabinets are a familiar sight. Whether it is a laboratory, industrial factory or warehouse, construction site, or repair garage, you are bound to come across a few. Flammable liquid storage cabinets are a common sight in many locations including labs, warehouses, factories, construction sites, and garages. They are usually easy to find as they are typically covered in an enamel-finish yellow paint with big red letters reading “FLAMMABLE KEEP FIRE AWAY”.

Beyond convenience and familiarity, there are many code reasons why cabinets are used:

  1. Separation of incompatible materials
  2. Increases to control area maximum allowable quantities
  3. NFPA 45 laboratory storage requirements
  4. OSHA storage requirements

To be considered adequate by the building and fire codes, storage cabinets for flammable and combustible liquids are required to meet the provisions of NFPA 30, Flammable and Combustible Liquids Code, or the International Fire Code, depending on the locally adopted fire code. Both codes provide allowances for listed cabinets and unlisted manufactured steel or wooden cabinets.

The more commonly used steel cabinets are manufactured to the following parameters:

  1. No. 18 gauge double-walled steel with 1.5” airspace between walls.
  2. Riveted or welded tight-fitting joints.
  3. Well-fitted doors that are self-closing and latching, with 3-point latch.
  4. A 2” liquid-tight sump at the bottom for nominal spill control.

The following are frequently asked questions regarding flammable liquid storage cabinets:

  1. Are flammable liquid cabinets required to be ventilated? Not typically. Unless required by local jurisdictions, the base codes and standards do not require that cabinets be ventilated.
  2. Are cabinets required to be grounded? Although many manufacturers provide a grounding screw on their cabinets for convenience, they are not required to be grounded when used for closed storage.
  3. How much can be stored in a cabinet? Up to 120 gallons of flammable and combustible liquids are permitted to be stored within a flammable cabinet per NFPA and ICC codes.
  4. Is a cabinet sufficient to meet spill control requirements? Most cabinets only provide a 2” sump capacity which is not always sufficient for a spill of larger containers such as drums.

If you have questions about Flammable and Liquid Storage Cabinets or the requirements when dealing with flammable and combustible liquids, please feel free to contact us.

“When am I required to have my elevator serve as an accessible means of egress?”

A question frequently asked and for the purposes of this response, the assumption is that the project is located in Massachusetts and will be designed under 780 CMR, Massachusetts State Building Code (9th Edition), which is based on the 2015 International Building Code (IBC).780 CMR 1009.2.1 requires at least one accessible means of egress to be an elevator in buildings where a required accessible floor is four or more stories above or below a level of exit discharge. The code defines the level of exit discharge as the story at which an exit terminates and an exit discharge begins. On a flat site, a building that is “four stories above the level of exit discharge” would equate to a 5-story building. See the figure below for examples. Once this number of stories is reached, at least one elevator serving all floors in the building would be required to serve as an accessible means of egress. In order to be considered as an accessible means of egress, the elevator would be required to comply with the provisions of 780 CMR 1009.4, including being equipped with a standby power source. To meet the standby power requirement, it is our experience that this necessitates an emergency generator and not battery-backup to satisfy.

When discussing such buildings, another common question is, “Are there any options to avoid installing an emergency generator to serve as the standby power source when an elevator is required as an accessible means of egress?”

Foremost, if the building is classified as a high-rise, elevators are required to be equipped with a standby power source in accordance with 780 CMR 403.4.8.3, and the generator is not able to be avoided.

If the building is not a high-rise, there may be an option to avoid an emergency generator depending on the specific building design. If the building is a low-rise and is more than four stories above the level of exit discharge, an alternate option is to utilize horizontal exits. 780 CMR 1009.2.1, Exception 1 states that in buildings sprinklered in accordance with NFPA 13 or 13R, an elevator is not required to serve as an accessible means of egress on floors provided with a horizontal exit located at or above the levels of exit discharge. This effectively means the following:

  1. The building cannot have any accessible stories located below the level of exit discharge;
  2. Horizontal exits, complying with 780 CMR 1026, must be provided on all floors.

Horizontal exits have their own series of requirements that must be met. A few considerations before you get rid of the generator include, but are not limited to:

  1. In most occupancies, horizontal exits are not permitted to serve as more than one-half of the required number of exit or egress capacity (780 CMR 1026.1).
  2. The horizontal exit must be 2-hour rated with 90-minute opening protectives and be continuous from exterior wall to exterior wall. Any cross-corridor doors will likely need to be bi-directional assuming that they serve more than 49 occupants on either side (780 CMR 1026.3).
  3. The horizontal exit must extend vertically through all levels of the building. It does not necessarily need to align vertically, but where horizontal transitions occur between stories, the floor/ceiling assembly and all supporting construction must be 2-hour rated (780 CMR 1026.2).
  4. An adequate refuge area complying with 780 CMR 1026.4 must be provided on both sides of the horizontal exit (780 CMR 1026.4). The refuge area must be adequate to accommodate the original occupant load of the refuge area plus the occupant load anticipated from the adjoining compartment.
  5. Standpipe hose connections may be required adjacent to the horizontal exit in accordance with 780 CMR 905.4(2).
  6. Exit signage and manual pull stations are required for the horizontal exit doors serving as a means of egress.

To summarize, there may be an option to avoid installing an emergency generator when elevators are required to serve as an accessible means of egress. However, there are a number of factors that must be considered including whether the building is a high-rise and whether there are any accessible stories located below the level of exit discharge. Beyond this, horizontal exits come with their own slew of requirements which could have significant implications on the design and cost of your project. Contact us today to see how we can help make the best informed decision on your project.

 

In recent years, the inclusion of high-end amenities such as natural gas grills and fireplaces have helped apartment and condominium complexes attract a wide range of renters. These touches of domesticity are a welcome luxury to building occupants, however due to their inherent safety risks, specific safety functions are required when incorporating into a building’s design.

As adopted and amended by 248 CMR, NFPA 54, National Fuel and Gas Code, outlines specific requirements for natural gas appliances such as outdoor fireplaces and grills. One such requirement is the need for an accessible, approved manual shutoff valve approved by the AHJ prior to installation. The manual valve must be dedicated to a single appliance and be located within 6 feet of such appliance unless specific exceptions are met. At decorative fireplaces, this valve may be located within the unit if listed for such use. The details associated with the valve and fuel piping are subject to the provisions of NFPA 54 and 248 CMR, and should be incorporated as a part of the plumbing design.

When arranging shutoff devices, numerous factors must be considered. For example, the manufacturer’s installation instructions/data sheet will provide specific criteria as to the height, orientation, approximate location, and means of attachment for a specific device. Since these are the conditions by which the device has been tested and listed, they must be complied with.

Equally important to the manufacturer guidelines are the requirements of the Authority Having Jurisdiction (AHJ). The AHJ will outline their specific requirements for type, number, and location of shutoff devices. These requirements can vary from jurisdiction to jurisdiction, meaning that up-front coordination during the design phase of a project is paramount to minimize unforeseen issues during the building sign-off process. As an example, some AHJ’s may require an emergency shutoff button in addition to the manual shutoff valve previously discussed. Typically these would be located in the vicinity of the appliance and/or situated at the entrance to the space containing the appliance to allow for remote shutoff.

Figure 1: Example of Gas Shutoff Switch at an Egress Door

Ultimately, when installing a natural gas heating appliance, special care should be taken in determining the location of safety devices. While NFPA 54 will outline basic requirements, the manufacturer’s data sheet and the approval of the AHJ should be consulted to ensure the most optimal arrangement is chosen. Proactive coordination will ensure devices are located appropriately from the outset of the project, limiting rework and any changes to overall design.

If you have any questions about concealed space allowances or have any other concerns associated to this topic, please feel free to reach out to info@crcfire.com for additional information.

 

This blog is the third in a series on Evacuation Planning, specifically addressing Fire Drills.  For Part 1 of the series focused on Emergency Action Plans, please see here. Part 2 of the series focused on Required Egress Posting, can be found here.

Fire drills are required within many jurisdictions that adopt NFPA 1, Fire Prevention Code. They are required in education, healthcare, residential board and care, ambulatory health care, dormitory, hotel, mercantile, and business occupancies either entirely based on the occupancy classification, or in some cases, based on additional conditions such as total occupant load (NFPA 1 Section 10.5).

Where drilling is required, the following items must be taken into consideration:

  • Drills are required to be done in cooperation with the local Authority Having Jurisdiction (AHJ);
  • The frequency of the drills should be such that occupants are familiar with the procedure and can display appropriate drill procedure as routine;
  • All building occupants subject to the drill should participate and be provided suitable accommodation to participate;
  • The drills should be focused on educating occupants on the correct procedures, rather than evaluated based on the speed of the drill;
  • Drills should be conducted at both announced and unannounced times and under varying conditions to simulate the unpredictability of when a true incident may occur;
  • The area of relocation should be predetermined; and
  • A written log of each drill should be completed by the person conducting the drill and maintained in an appropriate manner.

In addition to the provisions within NFPA 1, the local AHJ may also have unique requirements.  In the case of Boston Fire Department, specific expectations are listed for essential personnel, exit drill organization, emergency systems, and emergency operation (via Department Guidelines for Evacuation Planning Fire Prevention Order 72).

There is no reason for your next fire drill to resemble a scene from The Office. If you need assistance in creating a procedure or would appreciate assistance in conducting the fire drills on your preferred schedule, our team is available for such services (info@crcfire.com).

 

 

This blog is the second in a series on Evacuation Planning, specifically addressing egress posting requirements.  For Part 1 of the series focused on Emergency Action Plans, please see here.

In the state of Massachusetts, evacuation maps are required to be provided as a condition of building occupancy.  They are required to be posted by the owner on all floors of every building, except High Hazard, Factory, Correctional Facilities (780 CMR Section 111.5.2). In addition to the minimum per floor requirement, all rooms used as a place of assembly or as an R-l (i.e., hotel) sleeping space must include evacuation maps. Said placards are required be securely fastened to the building or structure in a readily visible place, showing exiting paths per floor.

Specifics associated with the placement, number, and composition of such evacuation maps are ultimately subject to the approval of the local building official, but are minimally recommended to include the following:

  • Illustrate a primary and secondary egress route;
  • It is recommended to orient floor plan to match;
  • Provide a “You are Here” designation;
  • Mark available “Exits”;
  • Provide a key/legend.

 

Emergency Action Plans, also referred to as Emergency Management or Evacuation Plans, are required in many jurisdictions, including those such as Massachusetts that adopt NFPA 1, Fire Prevention Code.   Such a plan must be submitted to the authority having jurisdiction (AHJ) as a condition of occupancy, whether initial or longstanding.

Though considered best practice for any and all commercial properties, the Code only mandates the Emergency Action Plan if you are classified as one of the following building/occupancy types (NFPA 1, Section 10.2):

  • High-rise;
  • Healthcare or ambulatory healthcare;
  • Residential board and care
  • Hotels and dormitories;
  • Assembly;
  • Special amusement buildings;
  • Educational (i.e., K-12);
  • Bulk merchandising retail buildings;
  • Underground and windowless structures;
  • Facilities storing or handling hazardous materials as defined by NFPA 1, Chapter 60; or
  • Where required by the AHJ.

The Plan is required to be submitted to the AHJ and updated when requested.  The Plan should be unique to the specific building in question, with consideration given to its architectural configuration, occupancy program/arrangement, ability of staff on site to act swiftly in an emergency to assist in evacuation and features of fire protection.

Specifics associated with the length, arrangement, and content of the Plan is at the discretion of the AHJ, but is minimally required to include the following (NFPA 1, Section 10.8.2):

  • Procedures for reporting of emergencies;
  • Occupant and staff roles and responsibilities in different emergencies;
  • Evacuation, relocation and/or shelter-in-place procedures appropriate to the building, its occupancy, emergencies, and hazards (this is often supplemented with evacuation diagrams);
  • Accommodations to assist occupants/staff with disabilities;
  • Appropriateness of the use of elevators;
  • Design and conduct of fire drills; and
  • Description of all features of fire protection and life safety systems.

Be mindful of additional expectations of the AHJ, which may be memorialized in amendments to the Code or city ordinances.  Boston, for example, scales the expectation for a Plan to additional building types (Boston Fire Prevention Code (Section 72-1-02)).  Said buildings are as follows:

  • That house building occupants below grade of such total numbers that their movement under emergency evacuation in fire conditions;
  • Buildings that include significant amounts of combustibles that would make it difficult or impossible to evacuate the occupants in a fire condition;
  • Buildings where a particular configuration (height, length, width, depth, type of construction, or topography) would hinder effectiveness of fire department operations;
  • Buildings 70-feet in height; and
  • Apartment buildings and hotels.

If you would like additional information or would like assistance in preparing an Emergency Action Plan, please contact info@crcfire.com.

As micro units and efficiency dwelling units become more prominent in architectural design, specific code requirements related to room size and minimum dimensions have become increasingly important. In Massachusetts, a few of these requirements come from 780 CMR, Massachusetts State Building Code, and 105 CMR 410.00 State Sanitation Code, which are used to establish the minimum required habitable area for dwelling units.

When sizing individual dwelling units, the following key code requirements must be used together to ensure that all necessary provisions are met:

Massachusetts State Building Code

  • All habitable spaces, other than a kitchen, must not be less than 7 feet in any plan dimension, §1208.1.
  • Every dwelling unit must have at least one room that is at least 120 square feet in net floor area. Furthermore, other habitable rooms are required to be at least 70 square feet in net floor area, §1208.1.

State Sanitation Code

  • Every dwelling unit shall contain at least 150 square feet of floor area for its first occupant, and at least 100 square feet for each additional occupant, which is calculated on the basis of total habitable room area (note that this applies to total area of the dwelling unit);
  • In a dwelling unit, every room occupied for sleeping by one occupant shall contain at least 70 square feet of floor area, and every room occupied by more than one occupant shall contain at least 50 square feet of floor space for each occupant (i.e. 70 square feet total for one occupant, 100 square feet total for two occupants);
  • In a rooming unit (i.e. dormitory), every room occupied for sleeping by one occupant shall contain at least 80 square feet of floor area, and every room occupied by more than one occupant shall contain at least 60 square feet of floor space for each occupant (i.e. 80 square feet total for one occupant, 120 square feet total for two occupants).

If you are considering a development that includes micro units or have any additional questions on this topic, send us an email at info@crcfire.com.

 

In accordance with the 9th edition of 780 CMR Massachusetts State Building Code, an interior exit stairway is defined as a means of egress component that “provides for a protected path of egress travel to the exit discharge or public way.” Where “land-locked” interior exit stairways do not have direct access to the building exterior, use of an exit passageway to connect the interior exit stairway to the building exterior is permitted by 780 CMR Chapter 10, and is a common approach to code-compliance. These exit passageways are designed to maintain the fire-resistance rating of the interior exit stairway(s) which they serve in accordance with the construction requirements of 780 CMR §1024.3.  In high-rise buildings, there is an added complication in that stairways are often pressurized as a means of satisfying the smokeproof enclosure requirements of 780 CMR §1023.11.  Where exit passageways are utilized to extend pressurized exit stairways, the exit passageway may require pressurization in the same fashion as the interior exit stairway, too, depending on its configuration.

Where interior exit stairways are pressurized, the termination of the pressurized exit stairways are subject to the requirements of 780 CMR §1023.11.1 ‘Termination and Extension.’  Exit passageways are specifically permitted to extend the smokeproof stair enclosure to the exit discharge, but are required to be “without openings” to adjacent building spaces.  In other words, the language of 780 CMR §1023.11.1 requires that exit passageways serving this function connect and communicate only with the interior exit stairway and the exterior of the building.  This configuration would not require the exit passageway to be pressurized; however, in practice it is often impractical or infeasible to avoid openings from adjacent building areas for egress purposes from those spaces.

In recognition of this practical challenge, Exception 1 to 780 CMR §1023.11.1 permits openings (from normally occupied spaces) into the exit passageway serving the smokeproof stair enclosure, when such openings are protected and the exit passageway is pressurized in the same manner as the smokeproof enclosure. The code requirement defining the performance criteria for stairway pressurization systems is 780 CMR §909.20.5, which requires 0.10 – 0.35 inches of water column be maintained throughout the interior exit stairway, relative to the building.  To qualify for Exception 1 to 780 CMR §1023.11.1, all doors communicating between the exit passageway and the adjacent building spaces would similarly need to meet the performance criteria of 780 CMR §909.20.5.

Pressurization of the exit passageway can be accomplished in a variety of ways such as the use of air transfer grille(s) in in the walls between the interior exit stairway and exit passageway, installation of ductwork connecting the two areas, or by installation of a separate fan for the exit passageway. In all cases, certain equipment and construction requirements will apply to ensure protection of the pressurization equipment and the integrity of the fire-resistance-rated enclosures are maintained.  Additionally, smoke detectors for the purposes of activating the pressurization systems are required outside of each exit passageway door in accordance with 780 CMR §909.20.6.

If you have any questions related to the requirements associated with pressurized exit passageways, please feel free to reach out to us and request additional information.

 

When designing a new, or even modifying an existing, fire alarm or fire protection system, it is important to be aware of the implications of all applicable codes and standards. Did you know that beyond the Massachusetts State Building Code, 780 CMR, and the Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00, there is a series of other requirements specific to fire prevention that could apply to your building? Of particular interest is Chapter 148, Fire Prevention, of the General Laws of Massachusetts (M.G.L.’s), which contains several such sections.

This blog is the third in a series on the requirements and caveats of the various subsections of M.G.L. Chapter 148 Section 26 which specifically address requirements for automatic sprinkler systems, fire warning and smoke detection systems, and carbon monoxide alarms in certain buildings. For Part 1 of the series focused on M.G.L Ch. 148 S. 26A and 26A½, please see here. Part 2 of the series focused on M.G.L Ch. 148 S. 26G, can be found here see here.

This third part of the series addresses M.G.L. Chapter 148 Section 26C.

M.G.L. Ch. 148 S. 26C: “Certain public accommodations; automatic smoke or heat detectors” reads as follows:

Apartment houses containing six or more dwelling units, hotels, boarding or lodging houses, or family hotels which are not regulated by section twenty-six A or twenty-six B shall be equipped with automatic smoke or heat detectors as provided by the rules and regulations of the board of fire prevention regulations.

The head of the fire department as defined in section one shall enforce the provisions of this section.

It is important to note that this section applies to rentable units of long-term housing when 6 or more are grouped within one building or to transient (short-term) housing buildings, where the building in either case is not considered to be a high-rise. When a building falls into one of these two categories, it is required to be provided with smoke and/or heat alarms/detectors as described within 527 CMR 1.00, Massachusetts Comprehensive Fire Safety Code, which is an amended version of NFPA 1.

This law does not apply to new buildings as new construction must comply with the requirements of the current editions of 780 CMR, Massachusetts Building Code, and 527 CMR 1.00. Instead, this law is meant to apply to existing, noncompliant, residential buildings that have been built prior to January 1, 1975 (and not altered since), that otherwise do not comply with the codes applicable today. In this instance, noncompliant buildings are those that are not currently provided with smoke and/or heat alarms/detectors in areas of the building that would otherwise require them.

In April of 2018, the State Fire Marshal released an advisory on the application of M.G.L. Ch. 148 S. 26C, which can be viewed here, where these buildings are required to provide a minimum level of safety. This level of minimum protection was detailed within the superseded version of 527 CMR 1.00 Section 13.7.4.5, which was based on the 2012 Edition of NFPA 1. The provisions included the following items to be installed in accordance with NFPA 72:

  • Single- and multi-station interconnected smoke alarms within each dwelling unit
  • Manual pull stations
  • Hard wired and interconnected smoke detectors in the common areas and hallways
  • A fire alarm system which is monitored
  • Notification throughout the building

The advisory document also outlined how the original M.G.L. was approved November 17, 1989 and provided compliance deadlines for various community population thresholds, all of which have passed as of November 17, 1994.

The current publication of 527 CMR 1.00 is based on the 2015 Edition of NFPA 1 which no longer prescribes the minimum level of protection discussed above since it was believed by the BFPR committee to be unnecessary as the compliance deadlines had long expired (over 25 years ago). If the language has been removed from 527 CMR 1.00, why should all of this matter to you?

The State Fire Marshal’s advisory document was published to bridge the gap between M.G.L. Chapter 148 Section 26C and the currently adopted 527 CMR 1.00, which no longer specifically addresses this topic, as many residential buildings have been found to remain noncompliant with this M.G.L. Therefore, if it is discovered that any pre-January 1, 1975 residential building fall under the purview of M.G.L. Ch. 148 S. 26C, the Head of the Fire Department still maintains with authority to mandate retroactive compliance with this Law even if no other alterations or renovations occurring in the building.

It is important to note that other codes may come into play when considering the necessary fire alarm upgrades outlined in M.G.L. Ch. 148 S. 26C, such as 780 CMR. An example includes existing, Use Group R-2, residential buildings that contain more than 3 dwelling units and are not currently provided throughout with automatic sprinkler systems. These specific buildings are also required to be provided with system-type heat detectors within 6 feet of each dwelling unit entry doorway, per the Massachusetts Existing Building Code, 780 CMR Chapter 34, Section 302.10.

For any proposed work regulated by 780 CMR 34.00, the building owner is required to have the existing building to be investigated and evaluated in accordance with 780 CMR 34.00 (780 CMR 34, Section 104.2.2.1) and accurately ascertain the effects of the work on the structural, means of egress, fire protection, energy conservation, lighting, hazardous materials, accessibility, and ventilation for the space under construction. The results of said investigation and evaluated are required to be presented to the building official in written report form.

Sequencing Inspection Requests: Shaft Wall Penetrations

Over the years as we continue to perform third party fire stop and fire-resistant joint inspections, a common sequencing question that continues to be asked is when does the inspector need to be called for the first wave of inspections as interior building construction commences. One of the driving factors for this sequencing is typically related to when shaft wall construction commences by the drywall sub-contractor.

As referenced in our Firestopping Special Inspections: More Than Just a Spot Check Blog Post, Section 10.8 of both ASTM 2174 and ASTM 2393 requires that “The inspector shall verify and document that the firestop systems required in the inspection documents have been installed.” The implication of this requirement when it comes to scheduling inspections is that shaft wall penetrations will require two rounds of visual and destructive inspections with the first prior to drywall installation such that the shaft layer portion of the firestopping assembly may be inspected and the second after drywall installation such that the drywall portion of the firestopping assembly may be inspected. Note that this is specific to where the submitted firestopping assembly from the manufacturer specifies firestopping at both the shaft wall and drywall layer (see examples below where firestopping application is required at both layers).

Have any other questions related to Firestopping Special Inspections or need Firestopping Special Inspection performed on your project? Feel free to reach out to info@crcfire.com for additional information and see the following link for more information about required frequently asked questions (Firestopping Frequently Asked Questions)