Code Officials are fining companies that do not comply with High Piled Storage Regulations in cities across the United States. Officials in Houston, San Diego, Riverside, San Jose, Denver and Seattle seem to be leading the charge in citing violations for high piled combustible storage in warehouses that are not protected per the International Fire Code (IFC). Sure it is a revenue generator for these cities and as Fire Prevention Bureaus increase in staff across the USA, more cities will be following suit.
What is High-Piled Combustible Storage? According to Section 2302 of the IFC, it is defined as storage of combustible material in closely packed piles or combustible materials on pallets, in racks or on shelves where the top of storage is more than 12 ft. in height. Where required by the 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 ft. in height. A “high piled” storage building that is not properly designed and protected could have significant storage restrictions imposed.
An operational permit is required for any building or portion of a building that contains high piled combustible storage if the storage area exceeds 500 sq. ft. If the building is being constructed or renovated to accommodate high piled combustible storage, Code requires that plans be submitted to obtain a construction permit if automatic sprinklers, fire alarms and detection, fire pumps, private fire hydrants or a standpipe system are to be installed. The plans shall include the following:
- Floor plan of the building showing locations and dimensions of high-piled storage areas.
- Usable storage height for each storage area.
- Number of tiers within each rack, if applicable.
- Commodity clearance between top of storage and the sprinkler deflector for each storage arrangement.
- Aisle dimensions between each storage array.
- Maximum pile volume for each storage array.
- Location and classification of commodities in accordance with Section 2303 of the IFC
- Location of commodities which are banded or encapsulated.
- Location of required fire department access doors.
- Type of fire suppression and fire detection systems.
- Location of valves controlling the water supply of ceiling and in-rack sprinklers.
- Type, location and specifications of smoke removal and curtain board systems.
- Dimension and location of transverse and longitudinal flue spaces.
- 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, when required by the fire code official.
The stored commodities must be classified as part of Section 2303. This should include the height of storage and building height. Section 2303 divides the commodities into five different classes I, II, III, IV and High-hazard. Commodities are similar but not identical to the NFPA 13 classifications. Generally commodity classes are determined by heat of combustion using a one gram sample of a product burned in a calorimeter.
Approximate Heat Content of Commodities:
- Paper = 7,000 Btu/lb.
- Wood = 10,000 Btu/lb.
- Plastics = 15,000 to 22,000 Btu/lb.
- Gasoline = 22,000 Btu/lb.
Plastics are made from petroleum; hence, the similar heat of combustion to that of gasoline.
A review of Class III, IV and High-Hazard commodity classifications finds that these commodity classes include plastics, which are classified separately in the IFC and NFPA 13.
Group A (most challenging) plastics are classified as High-hazard. All the more common plastics such as polyethylene, polypropylene, polycarbonate, polystyrene, PVC, FRP, ABS and others are classified as Group A Plastics.
Group B plastics have a heat of combustion and burning rate higher than ordinary combustibles but less than Group A plastics. Examples include cellulosics, chloroprene, rubber, fluoroplastics, natural rubber, nylon, PVC < 15% and silicon rubber.
Class C (least challenging) plastics are classified as a Class III commodity.
Group A plastic pellets are classified as a Class IV commodity.
When classifying storage areas, a minimum 1 hour fire barrier/wall and 1 hour rated assembly opening areas (doors) needs to be provided. If no barrier is provided, the entire warehouse can be considered one fire area based on the highest commodity classification.
Table 2306.2, “General Fire protection and Life Safety Requirements” outlines eight topics and whether they are required or not for eight storage areas for Class I – IV commodity classes or six high hazard storage areas. The requirements are as follows:
- Automatic Fire Extinguishing System (All Storage Areas)
- Fire Detection System (All Storage Areas)
- Building Access (All Storage Areas)
- Smoke and Heat Removal (All Storage Areas)
- Draft Curtains (All Storage Areas)
- Maximum Pile Dimension (Solid Pile, Shelf and Palletized Storage)
- Maximum Storage Height (Solid Pile, Shelf and Palletized Storage)
- Maximum Pile Volume (Solid Pile, Shelf and Palletized Storage)
Size of storage areas range in categories from 0 to greater than 500,000 sq. ft.
Please see table below.
| COMMODITY CLASS | SIZE OF HIGH-PILED STORAGE AREAa (square feet) (see Sections 2306.2 and 2306.4) | ALL STORAGE AREAS (See Sections 2306, 2307 and 2308)b | SOLID-PILED STORAGE, SHELF STORAGE AND PALLETIZED STORAGE (see Section 2307.3) | ||||||
| Automatic fire- extinguishing system (see Section 2306.4) | Fire detection system (see Section 2306.5) | Building access (see Section 2306.6) | Smoke and heat removal (see Section 2306.7) | Draft curtains (see Section 2306.7) | Maximum pile dimensionc (feet) | Maximum permissible storage heightd (feet) | Maximum pile volume (cubic feet) | ||
| I-IV | 0-500 | Not Requireda | Not Required | Not Requirede | Not Required | Not Required | Not Required | Not Required | Not Required |
| 501-2,500 | Not Requireda | Yesi | Not Requirede | Not Required | Not Required | 100 | 40 | 100,000 | |
| 2,501-12,000 Public accessible | Yes | Not Required | Not Requirede | Not Required | Not Required | 100 | 40 | 400,000 | |
| 2,501-12,000 Nonpublic accessible (Option 1) | Yes | Not Required | Not Requirede | Not Required | Not Required | 100 | 40 | 400,000 | |
| 2,501-12,000 Nonpublic accessible (Option 2) | Not Requireda | Yes | Yes | Yesj | Yesj | 100 | 30f | 200,000 | |
| 12,001-20,000 | Yes | Not Required | Yes | Yesj | Not Required | 100 | 40 | 400,000 | |
| 20,001-500,000 | Yes | Not Required | Yes | Yesj | Not Required | 100 | 40 | 400,000 | |
| Greater than 500,000g | Yes | Not Required | Yes | Yesj | Not Required | 100 | 40 | 400,000 | |
| High hazard | 0-500 | Not Requireda | Not Required | Not Requirede | Not Required | Not Required | 50 | Not Required | Not Required |
| 501-2,500 Public accessible | Yes | Not Required | Not Requirede | Not Required | Not Required | 50 | 30 | 75,000 | |
| 501-2,500 Nonpublic accessible (Option 1) | Yes | Not Required | Not Requirede | Not Required | Not Required | 50 | 30 | 75,000 | |
| 501-2,500 Nonpublic accessible (Option 2) | Not Requireda | Yes | Yes | Yesj | Yesj | 50 | 20 | 50,000 | |
| 2,501-300,000 | Yes | Not Required | Yes | Yesj | Not Required | 50 | 30 | 75,000 | |
| 300,001- 500,000g, h | Yes | Not Required | Yes | Yesj | Not Required | 50 | 30 | 75,000 | |
Risk Logic is not a proponent of “Smoke and Heat Venting” in buildings protected with automatic sprinkler protection. If you require a variance we can provide a review letter on why heat and smoke venting should not be installed in a building protected by automatic sprinkler protection.
Chapter 4 of the High Piled Storage Application guide addresses the basic design criteria for automatic sprinkler systems used for the protection of high-piled combustible storage which is based on the requirements of NFPA 13, Standard for the Installation of Sprinkler Systems. NFPA 13 gets published every three years with the latest revision being 2016. The September 2015 Technical Article http://www.risklogic.com/articles/sep2015.html# highlights which year each state adopted NFPA 13. Some states such as Connecticut are far behind using the 2002 version of NFPA 13.
Each city can have a different High Piled Storage application. Ordinances can be added to the IFC for each cities application. An example of the Riverside, CA application is as follows:
http://www.riversideca.gov/fire/Pages/pdf/forms/High%20Piled%20Storage%20application.pdf
High Piled storage applications are becoming more and more prevalent throughout the United States. If you require an engineering consultant who is experienced in the High Piled Storage Permit process please contact Risk Logic. We have trained PE’s that have over 25 years of experience with deciphering NFPA as well as an excellent knowledge of the High Piled Storage Application process.