Fire Code use-closed, use-open and MAQ questions

[Minnesota Paul]

Sorry if I'm revisiting a topic, I'm new to this site and was unsuccessful in my topic search. My fault not the site.

The Maximum Allowable Quantity(MAQ) per control area tables in the fire code, were still using the 2006 version until March or April, uses the terminology use-open and use-closed. The code definitions for both are relatively straight forward, however depending on how the reader interprets both the table and the footnotes, the results can be drastically different. I'll will point out an example from Table 2703.1.1(1) from the 2006 FC version, and while other versions have changed the location of the table they read nearly the same.

Without using the allowable increases in the footnotes;

Class IA flammable Liquid. Allows 30 gallons in storage, 30 gallons in use-closed, and 10 gallons in use-open. Footnote "b" states the aggregate quantity - storage, use-closed, and use-open, cannot exceed the quantity listed for storage. In other words all together you are allowed 30 gallons.

Example:

Scenario #1. The container in storage is 30 gallons. I transfer 10 gallons into an open container and put the original 30 gallon container back in storage. The simple math tells me that I have 20 gallons in storage and and 10 gallons in use-open which would comply with footnote "b". However, most fire code officials will tell you that a 30 gallon container is always a 30 gallon container regardless of the remaining quantity, therefore there is 30 gallons in storage and 10 gallons in use-open - a violation of footnote "b".

Scenario #2. The same condition as above. I attended two separate seminars on this next subject and received two separate answers to my question as follows; is the 30 gallon container now considered use-closed or use-open? The first seminar answer was the 30 gallon container is now use-closed because the cap has been put back on. The second seminar answer was the 30 gallon container is now use-open because the original sealed cap has been removed.

I would like some input from this group on both scenarios because these greatly affect the MAQ's for buildings other than H occupancies.

 

[cda]

Are you getting terminology mixed up?

The difference between a closed system and an open system is whether the hazardous material involved in the process is exposed to the atmosphere. While not specific in the definition, certain gases are also allowed in closed systems, as indicated in Tables 307.7(1) and 307.7(2). Materials in closed or open systems are assumed to be "in use" as opposed to "in storage." Gases are always assumed to be in closed systems, since they would be immediately dispersed in an open system if exposed to the atmosphere without some means of containment (see the definition of "Open system").

Book is talking about a system, plus the fire code covers a wide variety of use, storage and handling of combustible and flammable liquids.

Without a specific set of circumstances, I would say it is hard to give a general statement about storage, use and handling.

 

[cda]

OPEN SYSTEM. The use of a solid or liquid hazardous material involving a vessel or system that is continuously open to the atmosphere during normal operations and where vapors are liberated, or the product is exposed to the atmosphere during normal operations. Examples of open systems for solids and liquids include dispensing from or into open beakers or containers, dip tank and plating tank operations.

CLOSED SYSTEM. The use of a solid or liquid hazardous material involving a closed vessel or system that remains closed during normal operations where vapors emitted by the product are not liberated outside of the vessel or system and the product is not exposed to the atmosphere during normal operations; and all uses of compressed gases. Examples of closed systems for solids and liquids include product conveyed through a piping system into a closed vessel, system or piece of equipment.

 

[JBI]

The short (snarky) answer would be to buy 3 10 gallon containers.

Personally I think using the container size as opposed to the actual quantity is a stretch, but I'm not a hazmat guy.

Once the cap is back on and the less than full container is back in the STORAGE room/cabinet, it is in storage not use.

Does that about cover it?

BTW, we do have some hazmat folks here, so maybe one of them can provide additional guidance.

 

[cda]

any other takers!!!

Or OP any follow up questions during the debate?

 

[Builder Bob]

The container that is dispensing the fuel is a use-open condition. The fact hat a seal remains or doesn't remain does not change the process and the potential for issues. If three containers are in there, there is the potential for have three containers in a use open condition which would place this area in violation of the code. The best answer is to have a separate storage area for materials to be staged in a processing area........thus the process of using the product doesn't have as much potential to cause a bigger problem when things go wrong.

In response to putting the lid back on and changing the status.....not acceptable due to vapors being able to escape if an employee is lazy and doesn't tighten the lid, or cross threads it, or just doesn't put it back on.

The condition of the product can be verified easily by a fire inspector - if the seal is open from the original shipper, it is in use.......if the seal is intact, it is in storage.

However, the maximum quantity of a product in a given area (control area) is based upon the most restrictive requirements of the code. Therefore, if you have one building without any fire separations, the entire building is considered to be one control area. thus the quantities would be limited to 1 - 10 gallon container in this example if the seal has been removed.

 

[cda]

The container that is dispensing the fuel is a use-open condition. The fact hat a seal remains or doesn't remain does not change the process and the potential for issues. If three containers are in there, there is the potential for have three containers in a use open condition which would place this area in violation of the code. The best answer is to have a separate storage area for materials to be staged in a processing area........thus the process of using the product doesn't have as much potential to cause a bigger problem when things go wrong.In response to putting the lid back on and changing the status.....not acceptable due to vapors being able to escape if an employee is lazy and doesn't tighten the lid, or cross threads it, or just doesn't put it back on.

The condition of the product can be verified easily by a fire inspector - if the seal is open from the original shipper, it is in use.......if the seal is intact, it is in storage.

However, the maximum quantity of a product in a given area (control area) is based upon the most restrictive requirements of the code. Therefore, if you have one building without any fire separations, the entire building is considered to be one control area. thus the quantities would be limited to 1 - 10 gallon container in this example if the seal has been removed.

Would say depends on a lot of conditions

And a general answer can not be given that applies always