1. Hand sanitizer storage
The unforeseen and dramatic increase in alcohol-based hand sanitizer production and shipment means there’s a corresponding increase in storage and warehousing of it out there – somewhere.
Manufacturers are still ramping up production in response to the extreme demand for alcohol-based hand sanitizer products generated by essential workers and those of us scooping it up, just about anywhere we can find it. And with the COVID-19 pandemic still surging, production is not likely to slow down soon.
2. Federal restrictions relaxed
The Federal Drug Administration (FDA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulate the production and transportation of alcohol-based hand sanitizers, respectively. And both have responded by developing temporary policies that relax restrictions and allow enforcement discretion while maintaining an appropriate safety level during this public health emergency.
3. Local fire and building code officials
Fire and building code officials are undoubtedly seeing the appearance and increase of this hazardous production process and corresponding bulk storage in their communities. So just how are they managing this new hazard?
The best way to address any hazard is to understand its risks and identify the controls needed to minimize them.
4. Are hand sanitizers a fire hazard?
Whether in a liquid or gel form, alcohol-based hand sanitizers generally contain greater than 60 percent ethanol or 70 percent isopropanol and have flash points around 65 degrees Fahrenheit making them Class I flammable liquids.
Like any other Class I flammable liquid, alcohol-based hand sanitizers present a significant fire hazard and can be easily ignited when exposed to air and an ignition source.
When stored in buildings, the risk they present is best managed by controlling quantities, storage arrangements, container types and capacities, and ignition sources. The fire hazard can be addressed by providing reliable fire detection and suppression systems.
5. Fire and building codes for hand sanitizer storage
The International Fire Code (IFC), published by the International Code Council (ICC), is currently used or adopted in 42 states and establishes quantity limits and restrictions, as well as building protection schemes for flammable liquids stored inside buildings.
Portions of NFPA 30, Flammable and Combustible Liquids Code, published by the National Fire Protection Association also typically apply in these jurisdictions. But, unlike federal regulations, these state and local requirements are not uniformly relaxed or relaxed at all for hand sanitizers.
So, what exactly are the quantity limits that apply to alcohol-based hand sanitizers, or any Class I flammable liquid, inside buildings? That all depends on where it is.
6. Storage (Group S) occupancy limits
Under the 2018 IFC, 120 gallons of Class I flammable liquids are allowed in each of four permitted control areas on the ground floor in unsprinklered buildings or warehouses designed and constructed to meet Group S, Storage occupancy requirements.
Two hundred forty gallons are allowed in each of the four control areas where sprinklers protect these buildings, or the liquids are confined to approved fire-resistant cabinets. Up that to 480 gallons if both sprinklers and cabinets are provided. Control areas are individual spaces separated by fire barrier walls having at least one-hour fire-resistive rated construction.
Under the best scenario, the maximum quantity of Class I flammable liquids allowed in a Group S occupancy is 1,920 gallons. That’s not much when you think of the scale of hand sanitizer sales and consumption these days.
7. Mercantile (Group M) occupancy limits
On the other hand, Group M, Mercantile occupancies, are buildings designed and constructed specifically to accommodate retail products.
The increased quantities allowed in these buildings is due to the safety considered inherent in consumer packaging and storage configuration restrictions. In Group M occupancies unprotected by an automatic sprinkler system, the IFC allows up to 1,600 gallons in each of the four permitted control areas on the ground floor.
In sprinklered Group M occupancies, anywhere from 7,500 to 15,000 gallons of Class I flammable liquids can be stored in each ground floor control area, depending on the sprinkler design and density. That’s a far cry from 1,920 gallons.
8. Business (Group B) occupancy limits
If storage quantities exceed those noted above, they must be in a liquid storage room or warehouse that also meets Group H, Hazardous occupancy requirements.
But what if the occupancy is not a Group S, M, or H occupancy? Instead, it’s a typical Group B, Business occupancy? Outside of areas used for drinking, dining, offices, or school within Group B occupancies, quantities outlined for Group S occupancies above are allowed to be stored in Group B occupancies.
9. Keeping communities safe
Knowing the building occupancy classification and the IFC storage configuration requirements are crucial in determining whether storage quantities exceed allowable quantities. So, while we all strive to stay safe from COVID-19 and keep hand sanitizer within an arm’s reach, local fire and building code officials are striving to keep an eye on how much is too much in storage.
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