Parts Inventory Room in Car Dealership - S-1 or S-2?

[PR22841MLF]

I've got a new automotive dealership to review and the applicant is wanting to apply the parts supply inventory as S-2 storage space to avoid sprinkling the building because the fire area exceeds the limits if it were deemed S-1. The adjacent repair garage area is separated by a Fire Wall and is appropriately classified as S-1.

What are some things I should consider or ask to ensure the parts room is indeed an S-2 classification versus S-1?

 

[Yankee Chronicler]

What will be stored in the parts room? If there will be motor oil, gear oil, and/or flammable solvents such as touch-up paint, brake cleaner, carburetor cleaner, or parts cleaning solvent I wouldn't agree to S-2.

Many many years ago at a code seminar somewhere, the instructor told us that S-2 is for storing iron ingots in steel pails filled with water. Anything else is S-1 unless it triggers H.

Here's the list of the types of things allowed in S-2. This is not exhaustive, but it illustrates the types of things appropriate for the S-2 classification (which is, after all, LOW hazard storage):

Asbestos
Beverages up to and including 16-percent alcohol
Cement in bags
Chalk and crayons
Dairy products in nonwaxed coated paper containers
Dry cell batteries
Electrical coils
Electrical motors
Empty cans
Food products
Foods in noncombustible containers
Fresh fruits and vegetables in nonplastic trays or containers
Frozen foods
Glass
Glass bottles, empty or filled with noncombustible liquids
Gypsum board
Inert pigments
Ivory
Meats
Metal cabinets
Metal desks with plastic tops and trim
Metal parts
Metals
Mirrors
Oil-filled and other types of distribution transformers
Public parking garages, open or enclosed
Porcelain and pottery
Stoves
Talc and soapstones
Washers and dryers

Then look at the (also not exhaustive) list of the types of things that should be classified as S-1:

Aerosol products, Levels 2 and 3
Aircraft hangar (storage and repair)
Bags: cloth, burlap and paper
Bamboos and rattan
Baskets
Belting: canvas and leather
Beverages over 16-percent alcohol content
Books and paper in rolls or packs
Boots and shoes
Buttons, including cloth covered, pearl or bone
Cardboard and cardboard boxes
Clothing, woolen wearing apparel
Cordage
Dry boat storage (indoor)
Furniture
Furs
Glues, mucilage, pastes and size
Grains
Horns and combs, other than celluloid
Leather
Linoleum
Lumber
Motor vehicle repair garages complying with the maximum
allowable quantities of hazardous materials specified
in Table 307.1(1) (see Section 406.8)
Photo engravings
Resilient flooring
Self-service storage facility (mini-storage)
Silks
Soaps
Sugar
Tires, bulk storage of
Tobacco, cigars, cigarettes and snuff
Upholstery and mattresses
Wax candles

In other words, stuff that burns and contributes so a significant fuel load is S-1. S-2 is for stuff that doesn't burn, which may be packaged in limited amounts of combustible packaging.

 

[PR22841MLF]

Thank you for your input. They have an oil storage room as part of their repair shop, so that wouldn't be included here. Most "Parts" in the space would be metal automotive parts for use in their shop, so combustibility isn't as much of a concern to me with those. You bring up a good point though, about solvents, cleaners, and other fluids that could contribute to flammability. I think I will include the Fire Marshal in the review. Should I ask for an anticipated inventory list for the spaces?

 

[RLGA]

Is the parts storage area on the other side of the fire wall from the repair garage area? If so, how does classifying the parts storage room a Group S-1 occupancy cause the fire area of the Group S-1 occupancy to exceed the threshold?

 

[RLGA]

If the building area with the parts storage room is greater than 12,000 sq. ft., why not just separate the parts storage with the required 3-hour fire barrier? It's not like a parts storage room needs to be wide open for all to see.

 

[PR22841MLF]

Is the parts storage area on the other side of the fire wall from the repair garage area? If so, how does classifying the parts storage room a Group S-1 occupancy cause the fire area of the Group S-1 occupancy to exceed the threshold?

Yes, the parts storage area is on the Office/Showroom side of the Fire Wall. Classifying it as S-1 non-separated from the B would govern the restrictions of IBC 903 requiring a sprinkler system because it exceeds the fire area limits. However, S-2 does not have those limits in this use.

 

[PR22841MLF]

If the building area with the parts storage room is greater than 12,000 sq. ft., why not just separate the parts storage with the required 3-hour fire barrier? It's not like a parts storage room needs to be wide open for all to see.

Ideally, that would make sense. But it's not laid out cleanly and part of it is on a second floor, which is why it needs to be non-separated mixed use.

 

[RLGA]

Ideally, that would make sense. But it's not laid out cleanly and part of it is on a second floor, which is why it needs to be non-separated mixed use.

Is it on a second story or a mezzanine? If the latter, there should be no issue (even though it must be included in the fire area square footage). If the former, are there other areas of the building also located on a second story? Posting a floor plan of the particular area (upper and lower floors) would help us understand the situation more clearly.

 

[PR22841MLF]

Is it on a second story or a mezzanine? If the latter, there should be no issue (even though it must be included in the fire area square footage). If the former, are there other areas of the building also located on a second story? Posting a floor plan of the particular area (upper and lower floors) would help us understand the situation more clearly.

By Code definition, it's on a second story and doesn't meet the criteria as a mezzanine. There are other Group B office spaces on the second floor. Like I said before, it's not set up to cleanly separate the uses. I was more concerned about how to treat the storage rooms unseparated knowing separation isn't feasible. I guess it really comes down to analyzing the inventory, I suppose.

 

[Yankee Chronicler]

Thank you for your input. They have an oil storage room as part of their repair shop, so that wouldn't be included here. Most "Parts" in the space would be metal automotive parts for use in their shop, so combustibility isn't as much of a concern to me with those. You bring up a good point though, about solvents, cleaners, and other fluids that could contribute to flammability. I think I will include the Fire Marshal in the review. Should I ask for an anticipated inventory list for the spaces?

I would certainly involve the fire marshal, and I absolutely would ask for an inventory.

In an former lifetime, I was active in auto racing and I hung out with employees and sons of car dealers. I've spent a LOT of time in dealerships, in both the shop areas and the parts rooms. I've never seen a parts room that didn't include lots of cans or carburetor cleaner, brake cleaner, and aerosol cans of touch-up paint.

Also, they usually have a stock of refrigerant (most recently 134A, but I think that is now being replaced) for servicing a/c systems. The refrigerant itself isn't flammable, but it is under high pressure and the containers can explode.

 

[steveray]

Use the stupid change to 311.1.1 and call it accessory….and then it is B…

 

[PR22841MLF]

The aggregate area of the storage spaces is more than 10 percent. Therefore, I have to look at this as mixed use and not accessory.

 

[Yankee Chronicler]

The aggregate area of the storage spaces is more than 10 percent. Therefore, I have to look at this as mixed use and not accessory.

IBC 311.1.1 doesn't limit the area of accessory uses to 10% -- which I think is why Steveray called it "stupid." But, stupid or not, it is what it is.

From the 2021 IBC Commentary to 311.1.1:

This provision allows accessory storage areas to be
classified in the same occupancy group as the primary
occupancy of a space. There are no limits on the size
of such spaces, nor how much of the floor area such
accessory storage can occupy. These storage spaces
could occur in any occupancy, such as a Group B
office building, a Group E classroom or a Group M
retail store. If the storage isn’t accessory to a primary
use, then the storage would be classified in one of the
Group S categories and Section 508 would be applicable
as a mixed occupancy. The Table 509.1 separation
requirement for incidental uses would apply to storage
rooms over 100 square feet (9.3 m2) in Group I-2 or
ambulatory care facilities.

 

[steveray]

IBC 311.1.1 doesn't limit the area of accessory uses to 10% -- which I think is why Steveray called it "stupid." But, stupid or not, it is what it is.

From the 2021 IBC Commentary to 311.1.1:

The committee thought it was redundant but approved it anyway and didn’t understand the confusion it would cause and whomever wrote the commentary just made it wirse…they Shirley did not intend it to wipe out storage uses in mixed buildings…