Why Fire Codes & The Philosophy of Managing Hazardous Materials Jay Swardenski, Fremont Fire Department Varun Gopalakrishna, Kinestral Technologies, Inc. SESHA Northern California Mini-Conference 2015
Why Fire Codes & The Philosophy of Managing …seshaonline.org/meetings/miniNorCal2015presentations/Why...Why Fire Codes & The Philosophy of Managing Hazardous Materials Jay Swardenski,
Why Fire Codes & The Philosophy of Managing Hazardous Materials Jay Swardenski, Fremont Fire DepartmentVarun Gopalakrishna, Kinestral Technologies, Inc.
SESHA Northern California Mini-Conference 2015
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As a bit of background, Lynn Kilpatrick called and asked if I would be willing and available to participate in a SESHA mini-conference, had not heard of SESHA for a while, but of course said yes. Then I received my topic & read it a couple times… Why part is pretty easy: save lives, conserve property and protect the environment Philosophy, really, me?… so I emailed Aaron and asked what he really had in mind He replied: “Just some history of the fire codes, considerations that go into their development, and how their set up or organized.” And so Varun and I came up with this piece. As some of you may know, the “fire” codes did not start out as such (next slide)
Early Organizations
1835 Factory Mutual (FM)
1866 National Bureau of Fire Underwriters (NBFU)
1890 Factory Insurance Association (FIA)
1896 National Fire Protection Association (NFPA)
1903 Underwriters Laboratories (UL)
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Their origin can actually be traced back to the mid-late 1800 ‘s as an initial effort by Insurance companies to prevent losses not only from fires, but also the materials, processes, and wastes from an industrializing nation. AS SLIDE SHOWS: FM; intended to insure factories considered “good risk” NBFU: formed to control insurance costs by pushing “prevention”, led to development of first national building code (1905) and national electrical code (1897) FIA: formed to compete w/FM and wrote insurance only on sprinklered risks NFPA: formed by yet another a group of insurance organizations concerned w/ the reliability of automatic sprinklers due to a lack of standardization. Technical committees and consensus adoption programs followed.
A long long time ago…
The underwriters had it figured out back in the 1930s
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These Underwriters were on to something, especially if you review some of the post-incident reports of the day: A few examples, highlight some of the key factors. 1) Excessive storage (15-tons) in one location, mixed storage, w/ flammables (ethyl alcohol and acetone) 2) ARTICLE CONCLUDES: Lack of laws or ordinances dealing with this material, permitted in such a location, building not suited to the occupancy (aka: use), practically all good safety practices were violated… any of this sound familiar?? (i.e. plan check, inspection, incident follow-up) Side note: Pyroxylin incidents from early 1900’s still reflected in todays CFC Chapter 65 (pyroxylin plastics) Or take article 2 findings: UL listed tanks, supports for piping that won’t burn, shut-off valves close to the tanks, check valves, diking (secondary containment), fire protection suitable to the hazard Common themes, focused on the hazards and engineering options of the time. Fast forward 50 years.
“Fire” Code meets Hazardous Materials
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NOW USING- Last “fire code”; Obviously, I sat this a little tongue in cheek, because we are still trying to prevent fires and other incidents, get people out of buildings, Chapters 9-10 apply to 100% of facilities, but illustrates the point that roughly 60% of the chapters are specific to hazardous materials classifications and processes. 1982 UFC Article 80, addressed Hazardous Materials, ALL 6 pages of it! (excepting FL, LPG) Mid-80’s incidents; 1982-87-Fairchild UST 1984- Union Carbide’s Bhopal incident 1985 UFC Article 51, Semiconductor Fabrication facilities Using Hazardous Production Materials (HPMs) was adopted and the recent evolution/trend started Particularly in this area, 3 year cycles were not enough where (next slide)
In our own backyard…
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We have this new industry emerging, with new materials being used, new types of equipment and new hazards emerging TGO entered in 1986-87 time frame and we have Semiconductor Industry Association (SIA) forming as well along side SSA ( later became SESHA).
In our own backyard…the TGO
Expanded and refined definition of gases
Included containment standards (cabinets) and 21 specific installation requirements
Exterior Storage or Use
Inside Storage or Use
Monitoring and “discharge treatment”
On-site Transportation
Toxic Gas Management Plan HMBP
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TGO is a good example of local issues and local controls What did TGO do? Created 5 levels of toxicity, 21 “general” provisions to deal w/ these newer threats Many of the 21 have made their way into the CFC
The Industry Mix in Silicon Valley
U.S. Bureau of Labor Statistics, September 08, 2009: High-tech employment in Silicon Valley
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And if we look at the industry mix, & the increases in manufacturing activities, the data continue to support the logical progression of the code toward incrementally increased emphasis on hazardous materials management. (e.g. variety of manufacturing environments, more research, pharmaceuticals, aerospace) Now energy production, energy storage, vehicle production (popular endeavor these days) & other categories of advanced manufacturing Before we jump into how today’s codes are structured and organized to prevent or manage an incident, let’s step back and review fire development and fire department basics
Fundamentals of Fire
Fire Tetrahedron
Combustible and flammable fuels five categories:–Class A fires – are fires
involving organic solids like paper, wood, etc.
–Class B fires – are fires involving flammable liquids
–Class C fires – are fires involving electrical equip
–Class D fires – are fires involving metals
–Class K fires – are fires involving cooking oils.
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About as basic as it gets, the fire tetrahedron, fuel, O2, heat/ignition source. Review classification of fires and more specifically extinguishers. �Emphasize that when preventative measures fail and you decide to act: Extinguishers are often our 1st opportunity to mitigate an incident. Often under rated, out of service, or not the right size or class for the space or activity. e.g.: Video of fire in Fremont that started out as a metals fire (class D): C&H machining- supplier to some of folks in room
Machine Shop Fire Video
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Origin; at down draft grinding/polishing table accumulated some aluminum shavings beneath it. Cause: accidental, maintenance worker came in needed his hoe sharpened, used the table, steel blade threw sparks onto the pile beneath, two extinguishers would not suppress incipient fire… they were the wrong type! 2-3 similar incidents in recent years. How did the fire get so big, so fast? Fire grows exponentially and doubles in size every minute it has enough fuel, oxygen and heat to sustain itself.
Only takes a few seconds…Fire Spread and Build-up Timeline
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As video demonstrates and this slide illustrates… With this in mind, in Fremont, our published response “goal” is to confine a fire to the room/contents of origin & start mitigation (water & ventilation) BEFORE flashover occurs (auto-ignition temps reached) Anyone that’s ever called 911 knows, it can seem like an eternity for help to arrive, so… (next slide)
Where is the cavalry?Response timeline
Fire Department response is time-centric–Arrival of 1st Engine: 6 minutes 40 seconds
–Arrival of 1st Alarm Assignment: 11 minutes 20 seconds–Effect Level A entry: within 60 minutes
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From our Standard of Cover, shoot for meeting them 90% of the time Sprinklers absolutely push these time lines out, as do many of the control features contained in our fire and building codes. Fremont relies heavily on good access and built-in fire protection systems. For hazmat releases: 60 minutes: this highlights WHY we build in control and mitigation features at the tool, process and facility levels
Learn CPR, How to use AEDs
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Slide is a little out of place, I’ll admit, but for many departments, 60-70% of our calls are medical, so while we are talking about response times, I would be remiss if I did not highlight the importance of another fairly straight forward initial response option Learn CPR and how to use an AED… Remember arrival time is around 6:40 seconds, therefore starting CPR or AED use in first couple minutes nearly doubles one’s chance of survival. That’s it for my public service announcement, thanks.
Who comes first?
Community and PersonnelRespondersEnvironment
Facility
• Asset protection needs to be “designed in” to the facility.
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Now that you know our response times and goals are, the next question that often follows is WHAT are the priorities once we receive a call or arrive on scene. Review slide How do we “design-in” asset protection?
Philosophy and Approach
How do buildings, people and fire interact?
The Code intends to foster/ support a “systems approach”:–Separate occupancies (uses)–Compartmentalize (or segregate) hazards–Employ early detection and warning systems–Build in Inherent safety mechanisms that limit releases
size (containment, RFOs, excess flow, emergency stops)–Include abatement systems as a last opportunity to
preclude community or environmental impacts
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Fire & building codes have 2 underlying macro approaches to their development (from CBC, CFC commentary) 1) Example: Heart of chapters 9&10: time and time again, “people being the wild card” Iroquois Theater, Beverly Hills Supper Club, more recently Station Nightclub. From a fire perspective: watch Station Fire video on you tube and read the post incident reviews to understand how quickly our interactions with a building and fire situation can turn tragic… 2) From a HM perspective, we take a more systematic approach: manage the materials themselves, manage the impact, manage the exposures Which at the facility level looks like = Separate occupancies (uses) Compartmentalize (or segregate) hazards Build in safety mechanisms that limit releases size (containment, RFOs, excess flow, emergency stops) Employ early detection and warning systems or include abatement systems as a last opportunity to preclude community & environmental impacts of an HM release (excursion lately) Both approaches have to balance technical, legal, economic, social and political interests that underlie code development process
Compartmentalization
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So what does this look like in practice: Includes: containment and separation of incompatible materials/hazard classes Compartmentaliztion at workstation, cabinet, room, or building
Early detection and abatement
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Gas detection Liquid leak detection POU abatement Facility or general exhaust scrubbers Includes: process specific controls & VENTILATION! Can’t overstate the role ventilation has in preventing dangerous conditions from developing. Probably should have had its own slide, but I think there will be more on ventilation in later presentations… When our preventive efforts fall short, (next slide)
Automatic Response and Suppression Systems
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We rely on “built in response and mitigation)
Community ProtectionZoning and Land Use
Fremont as a case study
General Plan policies and response goals (SOC)
Area specific reviews (e.g. Downtown, Warm Springs Area Plans)
Existing Entitlements for the “land”
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Also take this same systematic approach on a community scale create boundaries and limiting spread (managing materials, impacts and exposures) We do this as a City by adopting and implementing…. GP, Specific Plans, etc. If you are a facility looking to locate in Fremont, we review your HMIS to see if you qualify for a more thorough review through the dreaded “USE” permit process to secure an entitlement
Community ProtectionZoning
Hazardous Materials–The intent of FMC Sec. 18.190.220 “High intensity
hazardous materials users” is to encourage high intensity hazardous materials users to locate in the General Industrial and Restricted Industrial Zoning
Zoning Districts- IL, IR, GI mainly
Facility type and size, ranges 1 to 10, storage or use
Chemical types- group A, B, or C
On to Building and Fire reviews (CFC)
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Fremont specific process description…
Structure of the Code Today
Scope and administration (Chapters 1-2)
General Safety Provisions (Chapters 3-4)
Building and Equipment Design Features (Chapters 5-11)
Special Occupancies and Operations (Chapters 20-36)
Hazardous Materials (Chapters 50-67)
Referenced Standards (Chapter 80)
Appendices and Index
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Finally arrive at what the structure of today’s code looks like. Quick overview of how the CFC is set up; Chap 1: includes basic authority, permitted activities, inspection responsibilities and appeal mechanisms. Chap 2: Definitions Chap 3: General Requirements (vs. specific chapters) 4) Emergency Planning and Preparedness 5) Fire Service Features (roads, hydrants, command centers, radio comm) 6) Building Services (e-power systems, electrical basics, elevators, kitchens) 9 and 10) Fire Suppression, Alarm and Egress provisions (can become quite complex) 20-80) Specific Activities, Industries or Materials (fair number of reserved chapters?)
Chapter Structure and Organization
Scope & Definitions
General Requirements
Specific Activities or Materials
Use and Storage Hazardous Materials
Detection and Mitigation Strategies
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Within the chapters themselves, there is additional structure and organization. Make sure to read scope!! Does it apply, is it a general or specific section, chapter?) Definitions applicable to chapter Prescriptive design requirements, materials of construction, safety features, detection and mitigation measures specific to the industry or material Does it refer you to another “standard”? (CGA -G13-2006, NFPA) If so (next slide)
Some of the more common references… As prescriptive as the codes may seem to be, they can’t address or fit every situation. Built in Flexibility
Built-In Flexibility
Modifications based on “practical difficulties” (CBC 104.10, CFC 104.8)
Alternate materials, design and methods of construction and equipment (CBC 104.11, CFC 104.9)
Performance Based Designs (CFC 5001.3.3)
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Practical difficulties, (e.g size of tool in solar manufacturing environment) AMMR Performance based-designs, not often used up-front for facility siting, R&D environment (e.g LED mft., new process, performed a haz-op and developed a mini-RMP)
How does the code evolve?
We have incidents!
We see issues and innovations during site visits –new applications, cutting edge technology
Partnerships with industry
Risk Managers and Insurers share loss prevention data
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MANY sections can be traced back to major icidents or large losses of life. Chapters 9&10 Smaller incidents or issues Less frequently through Inspection programs Partnerships amongst industry, fire depts, insurance (FM), interests (code development)
Is the code still relevant?Recent Incidents
Texas fertilizer plant–15 people killed: including 11 firefighters–No sprinklers etc.–No fire code!
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Contemporary (2013) incident findings: excessive storage, mixed use area (nursing home, apts. Hospital, school), basic safety procedures ignored, no recent agency inspections…
Is the code still relevant?Recent Incidents
Barton Solvents–Ethyl Acetate filling Static spark–No fire wall/ fire doors–No sprinkler in packaging area–Fire essentially destroyed the building
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Fire Separation and Suppression The packaging area was adjoined to the flammable storage warehouse. A wall separating the two areas was not fire-rated, and large non-fire-rated doors between the warehouse and packaging area were kept open and were not equipped with self-closing mechanisms. The CSB believes that this lack of effective separation aided the fire to spread rapidly into the warehouse area. The warehouse had an automatic sprinkler system, which did not extend into the packaging area where flammable liquids were routinely stored. Barton’s property insurance company had recently recommended that Barton install an automatic fire suppression system in the packaging area. The fire started in the packaging area and quickly spread to the warehouse. The warehouse sprinkler system activated after the fire had gained momentum in the packaging area, but was incapable of extinguishing the blaze. If a fire suppression system had been installed in the packaging area and that area had been separated from the warehouse by fire-rated walls and doors, this fire likely would have been extinguished or contained before engulfing the entire warehouse. (2008 incident) both sound similar to 1933, so I would answer yes and emphasize that facility managers, engineers, designers, inspectors, and everyone else in this arena, stay vigilant, don’t’ take anything for granted, stay safe.
Additional Reading and Resources
U.S. Chemical Safety Board: http://www.csb.gov/
National Fire Protection Association: http://www.nfpa.org/
FM Global: https://www.fmglobal.com/
UL: http://ul.com/
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A few extra resources if you are interested in reviewing either these incidents or other information further. Thanks!
