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Utilizing Shipping Containers for Storage to Maximize Warehouse Space
Is anyone insulating or firewalling 20 ft containers within a warehouse space (not fire rated) to create a storage facility for filled barrel storage or small still footprint? Is this an option rather than having to 2 hour firewall or 1 hour firewall with sprinklers? I’ve seen foam insulated 20 ft containers with venting used for Barrel storage outside, but was wondering if you could create a “fire-rated” space internally with the containers.
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24 Replies
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Is your goal to increase your MAQ beyond 240 gallons? If so, and if your fire marshal will allow you to declare a container to be a control area it might work. But, you have to figure out a way to sprinkle the container in order to have 240 gallons stored in it. This link has some links to data on how fire resistant a shipping container is that you might use as a starting point in discussions with your AHJ. https://discourse.sfpe.org.nz/t/steel-shipping-containers-inherent-fire-rating/181/5
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Are you looking to just store barrels in the container or bulk spirits as well?
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Possibly both.
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For Bulk spirits if you want to legally store more than 240 Gallons in your distillery you would need to have a talk with your local fire marshal to see if they would be willing to consider the container a “separate” designated space for storage if it is inside, outside you can store in properly locked, UL rated containers, with no issues.
Edited August 19, 2021 by Kindred SpiritsClarification
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I believe this statement to be incorrect. Please provide any documentation you have that will confirm what you have posted.
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2018 NC Fire Code
“5001.1 ScopePrevention, control and mitigation of dangerous conditions related to storage, dispensing, use and handling of hazardous materials shall be in accordance with this chapter.This chapter shall apply to all hazardous materials, including those materials regulated elsewhere in this code, except that where specific requirements are provided in other chapters, those specific requirements shall apply in accordance with the applicable chapter. Where a material has multiple hazards, all hazards shall be addressed.Exceptions:
In retail or wholesale sales occupancies, the quantities of medicines, foodstuff or consumer products and cosmetics containing not more than 50 percent by volume of water-miscible liquids and with the remainder of the solutions not being flammable shall not be limited, provided such materials are packaged in individual containers not exceeding 1.3 gallons (5 L).Quantities of alcoholic beverages in retail or wholesale sales occupancies shall not be limited providing the liquids are packaged in individual containers not exceeding 1.3 gallons (5 L).Application and release of pesticide and agricultural products and materials intended for use in weed abatement, erosion control, soil amendment or similar applications where applied in accordance with the manufacturers’ instructions and label directions.The off-site transportation of hazardous materials where in accordance with Department of Transportation (DOTn) regulations.Building materials not otherwise regulated by this code.Refrigeration systems (see Section 606).Stationary storage battery systems regulated by Section 608.The display, storage, sale or use of fireworks and explosives in accordance with Chapter 56.Corrosives utilized in personal and household products in the manufacturers’ original consumer packaging in Group M occupancies.The storage of distilled spirits and wines in wooden barrels and casks.The use of wall-mounted dispensers containing alcohol-based hand rubs classified as Class I or II liquids where in accordance with Section 5705.5.”
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You are making an error by not consulting the Building Codes as well. The NC building codes call out the MAQ, barrels count.
https://codes.iccsafe.org/content/NCBC2018/chapter-3-use-and-occupancy-classification#NCBC2018_
@DalkitaConstruction explains this well in one of their articles https://www.dalkita.com/maqs-maximum-allowable-quantities/
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NEW 2021 IBC clarifies that distilleries no longer will be classified as H-Spaces provided they conform to the 2021 IFC
Edited August 23, 2021 by Kindred SpiritsClarified due to new codes
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Four firewalled, sprinkled spaces.
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Looks like the 2021 IBC finally addressed the confusion with the storage of alcohol in a space.
Sections 307.1.1 Note 18 & 307.1.1 Note 19 No longer mandates that distilleries in compliance with the international fire code be relegated to a H designation, this is in regards to spirit production and storage in casks.
Thus 2021 IFC section 5701.2 Nonapplicability applies to spirits housed in casks.
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57 of the IFC does not apply but it appears that the new Chapter 40 does.
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What if you place the containers outside? Exterior walls don’t need burn ratings.
As well, theoretically, doesn’t the wall of the container already meet a burn rating standard? It’s all metal.
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I’m not sure what you’re saying. Do you believe that the MAQ has in someway change or the barrels are no longer to be considered part of the MAQ? Or, does this have no effect on MAQ and an occupancy of F-1?
There was never a mandate. There are many distilleries around the county that are F-1 occupancy. Maybe we’re talking about two different subjects. Most of the questions on this forum are about storing more hooch while remaining an F-1 occupancy. What is the subject you are addressing?
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The 2021 IBC 307.1.1 notes 18 &19 state that distilleries should follow the 2021 IFC regulations.
Chapter 40 of the 2021 IFC is a new chapter that was added. It clearly states the rules that distilleries should follow.
In this chapter it states, that the chapters 50 and 57 of the 2021 IFC do not apply to spirits stored in barrels.
Distilleries can house barrels, provided that they follow all of the rules laid out in the 2021 IFC and be considered a S-1 Space. They are no longer considered a H-Space if they exceed the MAQ, because they are exempt from the MAQ as laid out in Chapter 50.
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I’ll run this by some people and post their response. @InsuranceMan 2.0how about checking with your contacts.
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Slickfoss, you make a very good point. I would never have my ethanol storage tanks indoors because outdoors all I need is a UL 142 listed tank with TTB approved padlocks. It’s a huge savings compared to storing indoors. Some don’t have the appropriate outdoor space for outdoor ethanol storage tanks but many do and for those that do, outdoor storage is the way to go.
For barrels I would use a traditional rick house that is completely ventilated and on the side of a hill if possible. They can be built cheaply from rough, air dried, pallet grade, sawmill lumber and cants. Storing barrels inside a building with only a small amount of ventilation is a bad idea. Whiskey barrels should be exposed to all of the daily and seasonal changes in humidity, temperature, atmospheric pressures and wind. Everything except for the sun and rain.
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Have you had any response to this?
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If the question is whether of not an F-1 occupancy can exceed 240 gallons within one control area, the answer is no.
It’s a real stumper, a code review is being done by several entities and I don’t expect a final answer for a couple of weeks. And, it depends on what will be accepted by your AHJ.
We are F-1 occupancy, 240 gallon MAQ. It is possible for an AHJ to allow dual occupancies within the same structure. We are outfitted with sprinklers that would allow us to meet either F-1 or S-1. The question in our case is whether or not the AHJ will allow the dual occupancies. The other question is, what will that mean to our insurance company.
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According to the new code, an argument can be made to have a F-1 space that exceeds the MAQ of 240 Gallons.
307.1.1 States “An occupancy that stores, uses or handles hazardous materials as described in one or more of the following items shall not be classified as Group H, but shall be classified as the occupancy that it most nearly resembles”
This does not talk about trying to use dual occupancies. You are a F-1 space, but with the new wording of the code you could reason in the following manner to store a reasonable amount of barrels over your MAQ, especially since you are already sprinklered.
Since your distillery is already A F-1 space as long as you are in compliance with the 2021 IBC, which states to follow the 2021 IFC guidelines, you can handle a larger amount than designated by the MAQ, because the new 2021 IFC clearly states in its new chapter that barrels are exempt.
Following these guidelines as set out in the new codes, a distillery that has 5-10 barrels filled with spirits “most nearly resembles” an F-1 space a factory space with some storage, vs a S-1 storage area which could have hundreds of barrels according to the new regulations, but no production space.
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Thanks for your input. I just got an email from my AHJ. Unfortunately S-1 is a storage occupancy whereas a distillery is a manufacturing occupancy (F-1). This is why a dual occupancy would be required. But, if your AHJ will buy your argument, go for it. Mine will not. But, I can apply for dual occupancy. This will take a plan review by an architect who will decide if we meet all the requirements of S-1.
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Sorry you’re dealing with this shit, we have a great architect that has learned a lot with us through our growth. If you’re looking for someone let me know I can share contact info. I think they were down at ADI this year actually, Sketchworks out of Middleton WI
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Thanks @SlickFloss Actually we’re good. But, if I didn’t have to be concerned about an MAQ, it would be even better. I’m going through this fact finding for the other folks on this forum as well as myself. I have a wonderful building inspector and a great fire inspector, they want us to be here and are giving me every opportunity to investigate dual classification.
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Here’s the scoop from one AHJ. My guy invited me to explore dual classification with my architect. BUT, Ohio code is based on IBC 2017 or earlier since it was adopted in Ohio in 2017. (All states are different) SO, I shot him back a quick questions which was: “Since the Ohio Building code is based on IBC 2017 or early, I would not be able to take advantage of this new code since it is based on 2021 IBC. Am I correct?” His answer was that “My assumption made sense”
In my case, I will wait until Ohio adopts IBC 2021 and try again.
Cheers
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Sorry to hear that your AHJ isn’t open to accepting the newer code right away.
Hopefully they accept the new codes soon and you can make the changes you want.
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