The Uniform Fire Code:

Realities and Options

In the United States there are three
major organizations producing model
fire codes. The International Fire Code
Institute (IFCI) headquartered in
Whittier, California published the
Uniform Fire Code (UFC). The Building
Officials and Code Administrators,
International or BOCA is headquartered
in country Club Hills, Illinois. The
Standard Fire Prevention Code (SFPC)
from Birmingham, Alabama is published
by the Southern Building Congress
International. An additional organization,
the Nation Fire Protection Association
(NFPA) in Quincy, Massachusetts, does
not produce a model code, but it does
develop and publish numerous
standards and technical documents.
NFPA materials cover a number of
subjects related to fire and building
code issues including hazardous
materials and emergency response.
NFPA standards are frequently
referenced as code documents by
governmental groups and the three
model codes.
The use of chlorine has been impacted
by fire and building codes. The
significant changes related to
hazardous materials have occurred
since 1988 when the UFC revised its
hazardous materials section, Article 80.
Article 80, in the 1985 UFC, covered
five and one half pages of the code
test. The next edition of the UFC,
issued in 1988, expanded Article 80 to
fifty one pages. Needless to say, this
has resulted in numerous new and
specific code requirements for handling
all hazardous materials including
chlorine. The other two major model
codes, BOCA and the Standard Code
followed the lead of the UFC and
greatly expanded their own hazardous
materials regulations.
When Article 80 was written, the
chemical industry was not adequately
involved in the fire code process. Many
items in the 1988 Uniform Fire Code
were written with apparently little
information and insufficient
consideration for their impact on both
industry and users of the materials. It
has proven much more difficult to
change existing code language than to
be part of the process from the
beginning. In contrast to the UFC, the
chemical industry, particularly the
chlorine, compressed gas and

swimming pool chemical industries

were more actively involved in the
initial writing of the BOCA Code
and SFPC Code hazardous
materials sections.

CAPITAL CONTROLS

Chlorine, Rural Water

Agencies and the UFC
The membership of the California Rural
Water Association is composed of
smaller utilities that tend to use chlorine
in 100 and 150 pound cylinders and ton
containers. Therefore, I will specifically
address the areas in Article 80 of the
UFC that are of a stronger interest to
this audience.
The Uniform Fire Code is the
predominant model fire code used in
California. The UFC classifies chlorine
as both a toxic gas and a corrosive gas
and the requirements for both
classifications must be met. However,
the code has a minimum quantity for
each hazard classification that must be
exceeded before the code applies. This
quantity is per control area, a term
that will be defined shortly. Any
hazardous material as defined by the
code used or stored indoors is
regulated if the quantity per control area
exceeds the exempt amounted listed in
tables 13A or 13B in Article 80 of the
UFC. For corrosive and toxic gases
(chlorine), this quantity is 810 cubic
feet which equates to exactly one 150
pound chlorine cylinder. This means
that if you have only one 150 pound
maximum cylinder chlorine per
control area you are not regulated
under the UFC. A control area is
defined in section 8001.8 of the 1994
UFC as a space bounded by not less
than one-hour fire resistant occupancy
separation within which the exempted
amounted of hazardous material may
be stored, dispensed, handled or used.
Except for retail stores, most buildings
can contain up to four control areas.
One way users of 100 and 150 pound
cylinders of chlorine can be exempted
from the code is to utilize this feature of
the code dealing with exempt quantities
per control area. The Uniform Building
code (UBC) gives specific details on
what constitutes a one-hour fire
resistant wall. Such walls can be
constructed of various substances and
do not require elaborate plans or
materials for construction. A water
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authority can install up to four control

areas per building including well head
structures. Thus, as many as four 150
pound cylinder per building are
exempt from the UFC. If the building
or control areas are sprinklered, you
can double these exempt amounts.
This means you can now have two
150 pound cylinders of chlorine per
control area or up to eight per building
and not be under the UFC
requirements.
The most troublesome requirement for
toxic and corrosive gases is the need
for a treatment system to mitigate a
release. Treatment systems are
required by the UFC if the amount of
chlorine exceeds the exempt amount
per control area. The code states that,
Treatment systems shall be capable of
diluting, adsorbing, absorbing,
containing, neutralizing, burning or
otherwise processing the entire
contents of the largest single tank or
cylinder of gas stored or used.
When total containment is utilized, the
system shall be designed to handle the
maximum anticipated pressure of
release to the system when it reaches
equilibrium.
For chlorine, this generally means a
scrubber, although some fire chiefs
have approved dilution systems. The
code requires that treatment systems
must be designed to discharge a gas at
a maximum concentration of one-half of
the IDLH level. The IDLH for chlorine is
currently 10 parts per million. It should
be noted that the SFPC, the BOCA
Code and NFPA Standard #55 all allow
the use of chlorine emergency kits or
cylinder containment vessels to serve
as substitutes for the treatment system
requirement.
If a facility must operate with quantities
above the exempt level of the UFC,
there is a second option. Section
103.1.2 of the UFC allows the chief to
approve alternate materials or methods
that comply with the intent of the
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code. If the chief is satisfied that the

community can be adequately
protected by alternative measure such
as trained responders using Chlorine
Emergency Kits, the requirement can
be waived. In some areas covered by
the UFC, local chiefs have stated that
they believe the treatment systems
are not the only answer and they
entertain this option. A case should be
made to the chief and the local
officials about specific situations. The
Chlorine Institute takes the position
that the use of trained responders
along with the appropriate chlorine
emergency kit can protect the
community. Each site should be
evaluated independently to determine if
additional measures like treatment
systems are needed.
There is one, important new item in the
UFC. The 1994 edition of the UFC has
less than one page, section 8001.4.3,
devoted to piping systems for all
hazardous materials. (The Chlorine
Institute alone has a fifty seven page
pamphlet on piping systems for dry
chlorine.) The 1994 code does not allow
the use of threaded or flanged piping
for toxic or highly toxic service unless an
exhausted enclosure around the gas
piping was provided. Through the
efforts of several industry groups and
the support of many UFC members, the
UFC now allows the use of threaded
piping up to 1.5 inches in diameter and
the use of flanged piping above 1/2
inch. These changes follow the basic
recommendations in Chlorine Institute
Pamphlet #6, PIPING SYSTEMS FOR
DRY CHLORINE. These changes

were approved at the August, 1995

Code Hearings in Las Vegas, and will
be published in the 1997 edition of the
UFC.
One additional, important step is to
determine which code and code year is
legally binding in your location(s). Each
facility should contact their local
governmental jurisdiction and
determine which fire and building
codes are in effect. The year of the
adopted code is also critical. Only
legally binding codes can be enforced
by the fire service or building officials.
The codes themselves are not legally
binding documents until an
appropriate governmental agency
votes to adopt them. The provisions of
more recent yearly editions may not
be enforceable.
What Steps Can Water Utilities
Take?
The UFC can effect every water
treatment facility using chemicals
regardless of size. There is a
disagreement between many in the
chemical and water treatment industries
over some of the specific requirements
in the UFC. The UFC is trying to protect
their communities in the best manner
possible based on the sources of
information available to them. Most
have limited knowledge about the
properties of the thousands of
chemicals they encounter as well as the
standard industrial practices for
managing these chemicals. As critical
first step, you should establish a dialog
with your local fire officials. Show them
how hazardous materials are handled,
your training and your emergency

response plans and invite them to

drills. Work with them, and express in
writing any code concerns you have
and the reasons behind your
concerns. The local government also
should be contacted since code
requirement can have a serious
economic impact on the community.
A second step, is to become active in
the UFC code process. These code
meetings occur twice each year at
various locations throughout the nation.
Also, most states have a state
association of fire chiefs that meets
within the state to discuss code
proposals. (California has two such
groups - northern and southern group.)
Although time consuming, it is the only
way to let the chiefs know about the
effects future changes will have on your
industry, before they become part of the
next UFC.
Have the trade associations that
represent you get involved at the two
annual UFC code hearings. They can
support or oppose pending code
changes, as well as, introduce code
change proposals for the industry. The
many members of the water and
wastewater industry must make a
united effort and become active in the
code processes. They must work with
both the code organizations and the
local and state governments adopting
the codes to make certain that code
requirements are justified and enhance
safety in a cost effective way.
From a paper by: Gary F. Trojak
Vice President of Packaging and
Technical Services, The Chlorine
Institute, to the California Rural Water
Association, Sacramento, CA, 1996.

Design improvements may be made without notice.

Represented by:

CAPITAL CONTROLS
Severn Trent Water Purification, Inc.
3000 Advance Lane Colmar, PA 18915
Tel: 215-997-4000 Fax: 215-997-4062
Web: www.severntrentservices.com
E-mail: marketing@severntrentservices.com
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