How to determine occupancy (F-1 or H-2) with Dust Hazard Analysis for permitting Woodworking Cabinet manufacture

[Marni]

I would appreciate any thoughts from folks who have dealt with smaller manufacturing projects. I am working to relocate a cabinet maker into a 25,000 s.f. area, which is also the control area, of an unlimited single-story, IIB facility, fully sprinklered, 2018 Codes. Tenant area on an exterior wall.
This owner believes the use should fall under F-1.
Question - How to determine (prove) the use is F-1 and dust does not exceed max allowable quantities in Building Code table 307.1(1) making the use an H-2 if the equipment is not up and running? We can't do a DHA-dust hazard analysis until it is in place and we can't get a permit until a use is identified.
To complicate matters, we were able to get a CO for some equipment, but are now looking at adding an exterior dust collection system and new equipment. I am not sure how to proceed. Permit as H-2, get into operation and then step it back to F-1 after a DHA? I know H-2 requires a 2-hour fire barrier, this is doable for this building, but what other ramifications are we looking at by going to H-2?
Again, I appreciate any thoughts or experience in this matter.

2018 Building Code – Dust collection in table 307.1(1) defines the maximum allowable quantity per control area. In this table, if the quantity is less than the max shown, then the use is not typically hazardous. This table for combustible dust refers to footnote q - q. Where manufactured, generated or used in such a manner that the concentration and conditions create a fire or explosion hazard based on information prepared in accordance with Section 414.1.3.
414.1.3 Information required - A report shall be submitted to the building official identifying the maximum expected quantities of hazardous materials to be stored, used in a closed system and used in an open system, and subdivided to separately address hazardous material classification categories based on Tables 307.1(1) and 307.1(2). The methods of protection from such hazards, including but not limited to control areas, fire protection systems and Group H occupancies shall be indicated in the report and on the construction documents. The opinion and report shall be prepared by a qualified person, firm or corporation approved by the building official and provided without charge to the enforcing agency.

 

[Joe.B]

I'm probably going to over-simplify this by a mile or so, but here's my take. You're designing something, so design it on paper as a F-1, with all the necessary equipment and procedures documented. Get the permit, build it, get the CO, then it's up to the owner/operator to be compliant.

 

[Yankee Chronicler]

Years ago the local high school in my town did a major alteration/renovation project. Part of it was an all-new, state-of-the-art woodworking shop. Lots of shiny new machines, fancy dust collection system, yada, yada.

One year later it blew up.

Question - How to determine (prove) the use is F-1 and dust does not exceed max allowable quantities in Building Code table 307.1(1) making the use an H-2 if the equipment is not up and running? We can't do a DHA-dust hazard analysis until it is in place and we can't get a permit until a use is identified.

Obviously, you can't "prove" anything until the facility is in operation.



The code requires a report, prepared by a qualified person, firm, or corporation. I don't know who is qualified to predict how much explosive sawdust a bandsaw or a planer is likely to produce. I'd start by asking the company(ies) that provide(s) the machines. The manufacturer(s) must have encountered this before.