THE SOLUTION - High-Piled Storage Permits
By now, if you have been following my blog, you know that I have worked in the storage field for years. I am an Alternate on the NFPA 13 Technical Committee and teach the three-day NFPA seminar. I regularly speak on items impacting the industry and have been blogging for several years on this web site. A long way to go in an attempt to prove my bona fides for identifying THE SOLUTION!
One thing that all of us in fire protection speak of and recognize as an industry wide problem (or opportunity) is that things change. It may be as simple as the plasticization of society— what was metal is now plastic— Tonka trucks, car bumpers, snow shovels, hose reels, the list goes on and on. Or it could be the introduction of a new unknown exposure in the warehouse (expanded exposed foam or lithium-ion batteries). Should a fire occur, the sprinkler system, which was designed for some other hazard, is now under-designed for the new hazard. As I travel throughout the country, I consistently hear the same story:
"Our department is understaffed due to cutbacks and I cannot do all of the inspections. We have just had 5 million square feet of warehouse open up in town so how can I ensure that the buildings are properly protected, when I can’t get out there?"
I named this blog THE SOLUTION so I better provide one. To the basic question “How can I ensure that the buildings in my jurisdictions are properly protected in an environment where I cannot do as many inspections as I previously did?” THE SOLUTION is a high-piled storage permit. Section 105.5.24 of the 2021 International Fire Code states
An operational permit is required to use a building or portion thereof with more than 500 square feet (46 m2), including aisles, of high-piled combustible storage.
High-piled combustible storage is defined in Chapter 2 as:
Storage of combustible materials in closely packed piles or combustible materials on pallets, in racks or on shelves where the top of storage is greater than 12 feet (3659 mm) in height. Where required by the fire code official, high-piled combustible storage also includes certain high-hazard commodities, such as rubber tires, Group A plastics, flammable liquids, idle pallets and similar commodities, where the top of storage is greater than 6 feet (1829 mm) in height.
Now let’s look at what is required by the International Fire Code in Chapter 32, High-Piled Combustible Storage. Specifically Section 3201.3 Construction Documents:
At the time of building permit application for new structures designed to accommodate high-piled storage or for requesting a change in occupancy/use, and at the time of application for a storage permit, plans and specifications shall be submitted for review and approval. In addition to the information required by the International Building Code, the storage permit submittal shall include the information specified in this section. The construction documents shall include all of the following:
1. Floor plan of the building showing locations and dimensions of high-piled storage areas.
2. Usable storage height for each storage area.
3. Number of tiers within each rack, if applicable.
4. Commodity clearance between top of storage and the sprinkler deflector for each storage arrangement.
5. Aisle dimensions between each storage array.
6. Maximum pile volume for each storage array.
7. Location and classification of commodities in accordance with Section 3203.
8. Location of commodities that are banded or encapsulated.
9. Location of required fire department access doors.
10. Type of fire protection systems.
11. Location of valves controlling the water supply of ceiling and in-rack sprinklers.
12. Type, location and specifications of smoke removal and curtain board systems.
13. Dimension and location of transverse and longitudinal flue spaces.
14. Additional information regarding required design features, commodities, storage arrangement and fire protection features within the high-piled storage area shall be provided at the time of permit, where required by the fire code official.
I think it is obvious that THE SOLUTION is geared to the authority having jurisdiction. As an AHJ, the requirements above provide you with the fundamental information you need to review and assess the sprinkler system adequacy. You are being given the storage arrangement, height, commodity and design criteria. What else would you need to determine if the sprinkler system can protect your hazard (I have assumed that the reviewer has the prerequisite knowledge). It should also be noted that Section 3201.3.2 requires that a legible drawing be provided, mounted and protected from damage be present at the facility. This drawing is required to have much of the information above available. No longer should your inspector walk into the building and have to determine if the protection is adequate. They can look at the drawing and see if what is shown is what is present.
Now, like all good consultants, let me provide the caveats. These are issues that strengthen THE SOLUTION and ensure that the information is adequate and especially correct.
The steps below show a process that should be followed for an occupancy permit. Drawings should not be collected and thrown in a drawer without someone looking at what is being provided.
At some point you still need to get into the building to make sure that the drawing accurately reflects what is present, however, your time spent on site is greatly reduced when verifying information versus collecting the data.
The information provided is only as good as the firm or individual that submits the information. I personally would like to see some rules spelled out surrounding the qualifications for who can do this work. A registered fire protection engineer would provide the knowledge and independence to complete this task.
In order to turn your annual warehouse inspections into quick 15-minute visits, you should implement a Storage permit process. The steps to be taken to accomplish this are:
1. Require an annual Occupancy Permit as outlined in the IFC, when buildings are used for the storage of High Piled Storage as defined by the Fire Code.
2. Provide a guide to owners/engineers for the development of High Piled Storage drawings. This will include qualifications required to complete the permit.
3. The drawings must be submitted for review for approval, and updated and resubmitted when the use, height, configuration, or commodities change.
4. The Approved High Piled Storage drawings shall be kept onsite for verification and use by inspectors. The inspector then only needs to verify that the building and storage are the same as what is on the approved High Piled Storage permit drawings and then they can move onto the next inspection.
The bottom line is that you have the authority in the code to require an operational permit. Uncle Ben told Peter Parker “With great power, comes great responsibility.” You have the power, now use it responsibly.
Next blog, I will talk about retroactivity which ties into this.
As always, I welcome your comments: firstname.lastname@example.org