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Change of use/Occupancy - Printing/publishing to Wood Pallet Manufacturing?

Chapter 19 is not applicable.

1901.1 Scope.

The storage, manufacturing and processing of timber, lumber, plywood, veneers and byproducts shall be in accordance with this chapter.

This is a lumber yard under chapter 19

stock-photo--large-wheeled-front-end-log-loader-working-the-log-yard-at-a-lumber-processing-mill-that-134853446.jpg


This is a plywood plant

2472709957_24d5008d7d_o.jpg
 
Chapter 19 is not applicable.1901.1 Scope.

The storage, manufacturing and processing of timber, lumber, plywood, veneers and byproducts shall be in accordance with this chapter.
Chapter 23 is where this all started and what we've always used to address the citation. The building is a cobbled up mess of 56000 sq.ft. under roof. We asked them to develop a plan with a design professional to address the size of the fire areas and the cutting operation. They haven't done that either.

The chapter 19 reference seemed reasonable even though we never pursued it originally. We've got lumber stacked in excess of 12 feet high all around the building in every parking area and only a few feet from the building in many cases. I'm not trying to argue with you if you don't think it applies. I noticed all of the language on raw products , logs stump etc. and I wasn't sure but it seemed like the Scope language concerning the processing of lumber was reasonable. The place absolutely looks like a lumberyard from the outside with the amount of material stacked everywhere....not to mention the piles and stacks of new pallets and old ones waiting to be recycled.
 
Chapter 19 is not applicable.1901.1 Scope.

The storage, manufacturing and processing of timber, lumber, plywood, veneers and byproducts shall be in accordance with this chapter.

This is a lumber yard under chapter 19

stock-photo--large-wheeled-front-end-log-loader-working-the-log-yard-at-a-lumber-processing-mill-that-134853446.jpg


This is a plywood plant

2472709957_24d5008d7d_o.jpg
Sorry

Must have been thinking about

903.2.4.1 Woodworking operations. An automatic sprinkler system shall be provided throughout all Group F-1 occupancy fire areas that contain woodworking operations in excess of 2,500 square feet in area (232 m2) which generate finely divided combustible waste or which use
 
The cutting operation can be limited to less than a 2,500 sq ft fire area. The manufacturing area of the pallets is an F-1. The storage area for the pallets is an S-1. The building can be broken up with fire barriers if the operation will permit.

The high piled storage is a separate issue and would need to comply with Table 2306.2. Pallets fall under High Hazard Commodity and are very limited in size when no sprinklers are provide.

This is where you should find the charging language to require sprinklers, not in Chapter 9 IMHO if you are challenged in court or by the powers to be.

Section 102 is general in it tells the fire code may be applicable under certain conditions/situations. You have to find the specific code sections that apply to each condition or situation and apply it accordingly.

The IEBC is pretty specific when requiring a sprinkler system for a change of occupancy and "level of activity" is not included

912.2 Fire protection systems.

Fire protection systems shall be provided in accordance with Sections 912.2.1 and 912.2.2.

912.2.1 Fire sprinkler system.

Where a change in occupancy classification occurs that requires an automatic fire sprinkler system to be provided based on the new occupancy in accordance with Chapter 9 of the International Building Code, such system shall be provided throughout the area where the change of occupancy occurs.
Just trying to clarify ,,

So in th OP, would you require sprinklers, if they were doing high piled stock ??
 
Just trying to clarify ' date=',So in th OP, would you require sprinklers, if they were doing high piled stock ??[/quote']HIGH-PILED COMBUSTIBLE STORAGE. Storage of combustible materials in closely packed piles or combustible materials on pallets, in racks or on shelves where the top of storage is greater than 12 feet (3658 mm) in height. When required by the fire 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 feet (1829 mm) in height.Over 6 feet High Piled Storage Chapter 23 applies2306.1 General.Fire protection and life safety features for high-piled storage areas shall be in accordance with Sections 2306.2 through 2306.10.Table View attachment 2181

2306.2 501-2,500 sq ft nonpublic accessible (option 2) (whatever that is) Automatic fire extinquishing system not requiredThere is a provision to not require them for high piled high hazard commodity. I am playing devils advocate here. If it was in my jurisdiction I would probably be sending them off to a fire protection engineer for a review of the options available before I demand a sprinkle system with a fire pump and holding tanks since that seems to be the real issue. View attachment 2181
/monthly_2016_02/572953f50c41e_highpiled.JPG.fdbb60ed7c2011a69742a51b0b0d4718.JPG
 
The problem one will encounter with an occupancy of this type regardless of the chopping up approaches one may consider is the policing. A pallet manufacturer will stack pallets throughout 16-18' high since this is what will fit in a transport trailer. The operations is all about handling costs v. labor and the more they need to transfer and process the lower the profit margins they have. The access throughout the exteriors will always be blocked because the nature of their business is making and movement of product. Ours is 50K+ and designed at .60/2000 + 15 heads. They now call this control mode in the standard and based on my experience and understanding on fire behavior any design work is guess work since one can not model a fire within a occupancy like this, the variables are far to excessive versus the burning rate potential. You may want to show the responsible parties and administrative leaders some of the facility fire videos or articles out there to allow them to reconsider if they want to assume the liability to damages to exposure properties (if applicable).
 
The problem one will encounter with an occupancy of this type regardless of the chopping up approaches one may consider is the policing. A pallet manufacturer will stack pallets throughout 16-18' high since this is what will fit in a transport trailer. The operations is all about handling costs v. labor and the more they need to transfer and process the lower the profit margins they have. The access throughout the exteriors will always be blocked because the nature of their business is making and movement of product. Ours is 50K+ and designed at .60/2000 + 15 heads. They now call this control mode in the standard and based on my experience and understanding on fire behavior any design work is guess work since one can not model a fire within a occupancy like this' date=' the variables are far to excessive versus the burning rate potential. You may want to show the responsible parties and administrative leaders some of the facility fire videos or articles out there to allow them to reconsider if they want to assume the liability to damages to exposure properties (if applicable).[/quote']I mentioned the fact that we burned a smaller facility to the ground a few years ago. It was the middle of the day with an engine company setting a couple blocks away. The workers saw smoke coming from the break room that backed up to the storage area and called 911. 3 minutes later the first company reported heavy fire showing on three sides of the structure.
 
The following is from FM Data Sheet 8-24 regarding idle pallet storage, some interesting data on these types of fires.

3.1 Loss History

A review of FM Global losses involving the storage of idle pallets from 2002 to 2012 shows that:

91% of the losses involved idle wood pallet storage, with the remaining 9% involving plastic pallets. 65% of the losses occurred in storage located outside a building.

57% of the indoor fires reported indicated sprinkler protection was effective, with the remaining reported as ineffective in reducing the extent of the loss. The average monetary loss of fires involving adequately protected pallet storage was 12% of the fires where no or ineffective protection was provided.
 
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