Is a Brewery used for a "similar purpose" as a kitchen?

[ChrisEllis]

I just had a building plan disapproved because a means of egress passes by the brewing area of a brewpub. This is the reason given:

The brewery area as proposed : shows it will have cooking like a kitchen, it has a cooler like a refrigerator in a kitchen, a storage area for food products like a pantry in a kitchen, dish cleanup area like in a kitchen and also a mechanical room that you have to pass by to egress.

While I am a bit confused because there is no "dish cleanup area" in the designated brewing space, the statement uses Chapter 10, Section 1014.2 of the IBC as it's reasoning:

Egress shall not pass through kitchens, storage rooms, closets or spaces used for similar purposes.

Is it reasonable for them to say that a brewery is used for a "similar purpose" as a kitchen?

This is my opinion to the contrary:

The 2012 International Building Code offers two classifications for a Commercial kitchen:

303.3 Assembly Group A-2. Assembly uses intended for food and/or drink consumption including, but not limited to:

• Restaurants, cafeterias, and similar dining facilities (including associated commercial kitchens)

306.2 Moderate-hazard Factory Industrial, Group F-1. Factory industrial uses which are not classified as Factory Industrial F-2 Low Hazard shall be classified as F-1 Moderate Hazard and shall include, but not be limited to, the following:

• Food processing and commercial kitchens not associated with restaurants, cafeterias, and similar dining facilities.

However, a brewery falls very explicitly under the category of F-2:

306.3 Low-hazard factory industrial, Group F-2. Factory industrial uses that involve the fabrication or manufacturing of noncombustible materials which during finishing, packing or processing do not involve a significant fire hazard shall be classified as F-2 occupancies and shall include, but not be limited to, the following:

• Beverages: up to and including 16-percent alcohol content

This brewery is not used for similar purposes as a moderate-hazard food processing factory, as we see per 306.3 that it is low hazard by definition.

1. A brewery achieves a lower hazard rating because the brewing environment lacks the combustible grease vapors and residues of a commercial kitchen.
   
2. The brewing process also avoids the open flames, intense radiant heat, or otherwise focused heat of gas and electrical kitchen appliances because an insulated steam jacketed kettle is used to heat the materials, while the steam boiler itself is relegated to a fire-rated mechanical room.
   
3. Materials are a water/grain slurry or sugar solution heated to between 145°F and 215°F, which is the boiling point of strong wort (sugar solution). Combustion is clearly not a likelihood.
   
4. A brewery uses stationary vessels for production, and then transfers fluids through a closed circuit of hoses. This is unlike a commercial kitchen which uses movable vessels and dangerous utensils such as sharp knives.
   
5. Finally, but perhaps most obviously, a kitchen prepares "food." Food is a different category as "beverage," thus the need for the clarifying phrase “food and beverage.”
   

I value any input that members more experienced with the nuance of this code may be able to share.

Thanks

 

[cda]

Welcome....

Which state are you in?? Sometimes helps when answering a question.

 

[cda]

Thought you had a separation question.

Are they requiring separation between the brewing and other occupancy??

I think I would agree to the point of exiting through a more hazardous area. No matter what you call the occupancy

 

[ChrisEllis]

Welcome....

Thanks for the welcome! This site looks to be an incredible resource. I hope I don't send too many people's eyes rolling with the slew of new-to-the-biz questions that I have.

-Chris

 

[cda]

"""""The concern in Item 4 is that kitchens, storage rooms and similar spaces may be subject to locking or blockage of the exit access path. This is not a general provision for all Group S occupancies; therefore, it is not the intent of this provision to address the situation of egress for offices through an associated warehouse space. Item 4, Exception 1, does not apply this same prohibition to areas within dwelling or sleeping units. However, for other spaces, for example, a means of egress should not be through the working portions of a commercial kitchen behind a restaurant or the stock storage area of a storage room behind a mercantile occupancy.""""

http://publicecodes.cyberregs.com/icod/ibc/2009f2cc/icod_ibc_2009f2cc_10_sec014.htm?bu2=undefined

 

[cda]

Thanks for the welcome! This site looks to be an incredible resource. I hope I don't send too many people's eyes rolling with the slew of new-to-the-biz questions that I have.-Chris

Us old code people get lost in the black and white.

Monday should bring more replies.

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Cheap consultation fee!!!

 

[ChrisEllis]

Which state are you in?? Sometimes helps when answering a question.

I'm in Cedar Rapids, IA. The applicable codes used locally are IBC ad IFC.

Are they requiring separation between the brewing and other occupancy??

I am separating the assembly area A-2 from the brewing F-2 for safety, though there is no separation required in a sprinkled building.

I think I would agree to the point of exiting through a more hazardous area. No matter what you call the occupancy

Fair enough. However Chapter 10, TABLE 1012.4 of the International Existing Building Codes defines F-2 as the lowest hazard area.

My question to you would be, why is it more hazardous? Nothing involved in the brewing process will impede the path of egress. And from a fire safety standpoint, I have non-combustible liquids in stainless steel tanks. What is the fire hazard?

 

[cda]

I am not saying there is a fire hazard and there does not have to be a fire hazard.

Even exiting through a Subway sandwich shop prep area is a hazard.

Are you able to post a floor plan???

 

[ChrisEllis]

I have attached the full plan, plus a break out with the actual brewery layout overlay.My ultimate goal is, of course, a safe and compliant environment. However, a walled in corridor through the middle of the back room makes things more difficult and the work more dangerous for the people that will actually be spending time in the brewing area.Complicating everything is the fact that this building has a preliminary determination to be a contributing building within a potential historic district. I'm trying to please the State Historic Preservation Board as well as the building services group. And as a century old auto garage, SHPO would like to see the back as open as I can get it. A walled corridor would be ugly and obtrusive and may affect the historic tax credits I am eligible for.I know there is some leniency for historic buildings, but I haven't gotten deep enough into the code to parse all that out yet. That was going to be one of my next questions: "Is a preliminary determination of a contributing building within a potential historic district enough?"Thanks!(and cheap consultation indeed! I plan to contribute)

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[cda]

That one is a little hard to accept.

The other thing to me is the cased openings people exiting my wonder through

I take it there are buildings connected on each side?

 

[ICE]

Brent makes the claim that beer is food. That would mean that a brewing area is a beer kitchen. The reality is that one wall would separate the "kitchen" from a corridor. 10 to 12 feet of wall shouldn't be that big of a deal to the SHPO. Put a bunch of glass in the wall.

 

[Francis Vineyard]

ChrisEllis do they view the vats as cooking appliances?

If so I don't see how without a fuel.

And does your locality or state require permits and food processing facilities be reviewed by the health dept.?

If not then that may change their minds.

Hope this helps.

ps and welcome to the forum

 

[MASSDRIVER]

My ultimate goal is, of course, a safe and compliant environment.

Here we go again with remedial education;

The ultimate goal is to get the effing beer brewed so we can drink it.

Actually the Ultimate goal is to get wasted and tell lies about how good we are, but i'll give a little and say it is to brew beer. I don't give a single shlt if you can do it safe, just get it done.

RELAX ICE, I'm not inferring they HAVE to brew it unsafely...if they can get it done, and not waste a bunch of time, and do it safely, then yay for them. Otherwise, whatev.

And beer IS food, unlike wine which something women drink to get get drunk but still maintain a "standard".

Brent.

 

[cda]

Brent makes the claim that beer is food. That would mean that a brewing area is a beer kitchen. The reality is that one wall would separate the "kitchen" from a corridor. 10 to 12 feet of wall shouldn't be that big of a deal to the SHPO. Put a bunch of glass in the wall.

I think the ahj is looking at the complete path from the front to the back exit door. And does not like it. Me either passing through to many areas

 

[north star]

= [ : ] : [ : ] =



ChrisEllis,

Welcome to The Building Codes Forum !

In looking at your floor plan, ...I too would be leaning towards

identifying your "proposed" Exit Path through a Kitchen type

similar area also.

REASONS: (1) there is a Pizza Oven towards the front area,

(2) there is an area that will be used for washing dishes, (3)

there are cased openings that "could" cause occupants to

wander in to during an emergency, (4) as is common in most

food \ beverage \ alcohol serving establishments, ...things

DO get piled up in the wrong areas, ...stock \ kitchen

equipment \ furnishings DO end up not being where they

should be, ...(5) what if there is sewer line stoppage and a

plumber is using that rear entrance to enter & exit with

their equipment, and on and on and on.

IMO, ...too much potential for a blockage in the current

floor plan Exit path............And Lord help you all if someone

like Brent gets all liquored up and goes stumbling thru the

back area trying to find the P__ss-a-torium.........Yep, it's

gunna be ugly !

Re-design & re-submit.

= [ : ] : [ : ] =

 

[ICE]

I don't see too many areas... It's a short trip to the corridor right past the pizza oven....wait a minute there's a pizza oven....that's not in a kitchen? With a grease hood?

 

[JBI]

A quick Bing search for 'brewery fires and explosions' led to well over 24 million hits.

A others have pointed out the bigger concern is that the exit would likely get blocked by stuff.

While a pizza oven doesn't necessarily need a Type I hood (no appreciable grease laden vapor), they are nonetheless 'cooking' equipment.

 

[cda]

And the vessels are defiantly cooking the good stuff.

 

[Frank]

To the other side is a storage room

THat said Virginia has an amendment to allow one exit through these areas

 

[cda]

To the other side is a storage roomTHat said Virginia has an amendment to allow one exit through these areas

In any occupancy ??

Or just M?

 

[ChrisEllis]

Thanks, everybody, for your perspective. It's definitely helping me see this as a more comprehensive issue than I had thought.To some of the points raised about the actual kitchen area that is reflected, this drawing does not show the present kitchen configuration. The present kitchen has a deck pizza oven (rather than the wood fire) and a range... and, yes, a Type 1 hood. I am not sure why this was not updated for the drawings that were submitted.I had not been looking at the kitchen and the brewing area as the same space. As you can see from the brewery overly, there is not direct access to the brewery area from the kitchen's dishwashing area because the brewing equipment blocks that opening. And, in fact, I was going to use that gap to put an icemaker and dough mixer. Would a wall (or half wall so that a historic beam will remain visible) separating those areas mitigate any issues? See the updated brewery overlay attached.The primary workflow hurdle that I am trying to overcome is easy access back and forth between the brewery side and the overhead door side. A big cart full of spent grain after a brew (~600 lbs) will be difficult to move through multiple doors to get to the overhead door. My favorite option is to just flip the brewery over to the other side of the back area. Then it can all be walled in without the workflow impediments. Unfortunately, it is also going to be the most expensive option, as the floor has already be cut for sanitary plumbing for the original layout. And mechanical and electrical plans have already been drawn. There'd be a bit of starting at square one.One thing that I have found very odd so far in this process is how many people that have reviewed my plan have told me, "Well, since this isn't a sprinkled building, blah blah blah" without actually telling me that I need to sprinkle the building. This is odd for two reasons. First, while there may be some gray area open for judgement calls elsewhere in the Code, it seems pretty darned black and white to me that sprinkling is necessary for my use and occupancy load. Second, I am sprinkling the building. The Building Plan Review on the first page states this clearly and presents a number of determination based on the fact that it will be sprinkled. I don't know how this keeps getting overlooked. Oi.

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[ChrisEllis]

To the other side is a storage roomTHat said Virginia has an amendment to allow one exit through these areas

While the rear portion was labeled "storage," for practical purposes it is just a receiving area from the overhead alley access door. There may be a pallet or two waiting to get unloaded at any given time, but it will not be a stockroom or storage room in any real sense. Would simply re-labeling that space mitigate any of the present issues?

 

[Francis Vineyard]

In any occupancy ??Or just M?

This exception was in the BOCA; Virgnia kept it when the I-codes where adoted.

1014.2 Egress through intervening spaces.

Egress through intervening spaces shall comply with this section.

1. Egress from a room or space shall not pass through adjoining or intervening rooms or areas, except where such adjoining rooms or areas and the area served are accessory to one or the other, are not a Group H occupancy and provide a discernible path of egress travel to an exit.

Exception: Means of egress are not prohibited through adjoining or intervening rooms or spaces in a Group H, S or F occupancy when the adjoining or intervening rooms or spaces are the same or a lesser hazard occupancy group.

2. An exit access shall not pass through a room that can be locked to prevent egress.

3. Means of egress from dwelling units or sleeping areas shall not lead through other sleeping areas, toilet rooms or bathrooms.

4. Egress shall not pass through kitchens, storage rooms, closets or spaces used for similar purposes.

Exceptions:

1. Means of egress are not prohibited through a kitchen area serving adjoining rooms constituting part of the same dwelling unit or sleeping unit.

2. Means of egress are not prohibited through stockrooms in Group M occupancies when all of the following are met:

2.1. The stock is of the same hazard classification as that found in the main retail area;

2.2. Not more than 50 percent of the exit access is through the stockroom;

2.3. The stockroom is not subject to locking from the egress side; and

2.4. There is a demarcated, minimum 44-inch-wide (1118 mm) aisle defined by full- or partial-height fixed walls or similar construction that will maintain the required width and lead directly from the retail area to the exit without obstructions.

3. A maximum of one exit access is permitted to pass through kitchens, store rooms, closets or spaces used for similar purposes provided such a space is not the only means of exit access.

 

[cda]

Thanks, everybody, for your perspective. It's definitely helping me see this as a more comprehensive issue than I had thought.To some of the points raised about the actual kitchen area that is reflected, this drawing does not show the present kitchen configuration. The present kitchen has a deck pizza oven (rather than the wood fire) and a range... and, yes, a Type 1 hood. I am not sure why this was not updated for the drawings that were submitted.

I had not been looking at the kitchen and the brewing area as the same space. As you can see from the brewery overly, there is not direct access to the brewery area from the kitchen's dishwashing area because the brewing equipment blocks that opening. And, in fact, I was going to use that gap to put an icemaker and dough mixer. Would a wall (or half wall so that a historic beam will remain visible) separating those areas mitigate any issues? See the updated brewery overlay attached.

The primary workflow hurdle that I am trying to overcome is easy access back and forth between the brewery side and the overhead door side. A big cart full of spent grain after a brew (~600 lbs) will be difficult to move through multiple doors to get to the overhead door. My favorite option is to just flip the brewery over to the other side of the back area. Then it can all be walled in without the workflow impediments. Unfortunately, it is also going to be the most expensive option, as the floor has already be cut for sanitary plumbing for the original layout. And mechanical and electrical plans have already been drawn. There'd be a bit of starting at square one.

One thing that I have found very odd so far in this process is how many people that have reviewed my plan have told me, "Well, since this isn't a sprinkled building, blah blah blah" without actually telling me that I need to sprinkle the building. This is odd for two reasons. First, while there may be some gray area open for judgement calls elsewhere in the Code, it seems pretty darned black and white to me that sprinkling is necessary for my use and occupancy load. Second, I am sprinkling the building. The Building Plan Review on the first page states this clearly and presents a number of determination based on the fact that it will be sprinkled. I don't know how this keeps getting overlooked. Oi.

I saw I the op that the space would have sprinkler protection, that in away is a non issue.

I am not to worried about placement of the pizza oven. I go to three places the wood fired pizza oven is part of the dining area.

Just the totality of the exit path, I have a problem with.