Please help me understand hazardous classifications for oil-based paint

[PatrickGSR94]

We have a client with a pavement paint striping business, that moved into about half of a ~6.000 SF building several months ago. The city is now looking for some sort of letter or code analysis regarding the building and the amounts and types of paint this business is storing in the building.

As far as I know the building is unsprinkled. The owner sent me MSDS documents and quantities of the types of paint they used, the largest of which is about 450 gallons of oil-based acrylic pavement marking paint.

The MSDS's say the paint is a Flammable Liquid - Category 2. Building and Fire Codes in the hazardous material MAQ tables only list classes IA, IB and IC for flammable liquids, then for combustible liquids it has class II, IIIA and IIIB. I've seen some tables that say a Class 2 liquid per OSHA could be either Class II or IIIA in the NFPA, depending on the liquid's flash point. But the only thing I can find in the MSDS regarding flash point is this: "Closed cup: -17°C (1.4°F) [Pensky-Martens Closed Cup]". Soooo.... the flash point is below freezing????

None of this makes any sense. If the paint is Class II then they have too much of it even with fire-rated storage cabinets. If it's Class IIIA then they should be able to store 450 gallons in cabinets since the 330 gallons allowed can be doubled with proper storage cabinets. But all of that hinges on the material's flash point, which according to the data sheet is less than 73°F which should make it a Class IA, the MOST hazardous of flammable liquids???

 

[RLGA]

Look at IFC Appendix E. This appendix provides the criteria for Class IA, IB, and IC. The two characteristics to consider are flash point and boiling point temperatures.

• Class IA:
  • Flash Point: < 73 deg. F.
  • Boiling Point: ≤ 100 deg. F.
• Class IB:
  • Flash Point: < 73 deg. F.
  • Boiling Point: ≥ 100 deg. F
• Class IC:
  • Flash Point: ≥ 73 deg. F.
  • Boiling Point: < 100 deg. F.

I do not know what your client's SDS shows for the two characteristics mentioned above, but I looked at one manufacturer's SDS for their oil-based acrylic traffic marking paint and it has the following:

• Flash Point: 150.8 deg. F.
• Boiling Point: 147.2 deg. F.

Based on the criteria, the paint is not a Class IA, IB, or IC flammable liquid. Thus, the quantities are not limited per IFC Table 5003.1.1(1) or IBC Table 307.1(1).

 

[PatrickGSR94]

So the paint in question is Sherwin-Williams Setfast solventborne traffic paint, which apparently does indeed have a flash point of -3°F. Doesn't that technically make it a Class IA flammable liquid? 60 gallons max storage in approved cabinets, if the building is not sprinkled, right?

 

[PatrickGSR94]

Product page: https://www.sherwin-williams.com/ho...st-solventborne-acrylic-traffic-marking-paint

 

[RLGA]

The SDS for the product you posted has a flash point of -2.2 deg. F. In other words, as soon as they open a container, the volatile substances will immediately begin to evaporate creating a potentially explosive environment. The boiling point is 131 deg. F. This means at that temperature, the liquid will begin its transition to a gas, making the material again potentially explosive.

That would make it a Class IB flammable liquid. Your client would be limited to 120 gallons in the building without any modifications. If they sprinklered the building throughout, they can increase that to 240 gallons. If they also store the paint in approved cabinets, they can have up to 480 gallons. If they do not sprinkle the building but store the paint in approve cabinets, then the quantity would be limited to 240 gallons.

The other options your client has are:

1. Classify the storage occupancy as Group H-2 and comply with the requirements for that occupancy group.
2. Create three other control areas per Section 414.2. You are allowed four control areas on a first story. The building itself is considered one control area and they would need to create three separate rooms with 1-hour fire barriers. Then divide the paint quantity equally among each control area (i.e., 112-113 gallons per area).
3. Create one other control area and store the paint in approved cabinets. That provides two control areas with an acceptable quantity of 240 gallons stored in each.

That addresses the quantity issue. However, there are other things that must be considered, such as ventilation (414.3) and explosion control (414.5.1). The latter would only apply if the paint is used or dispensed in the area--if they are stored in containers and remain in those containers until use at a project site, then explosion control is not required.

 

[PatrickGSR94]

The SDS for the product you posted has a flash point of -2.2 deg. F. In other words, as soon as they open a container, the volatile substances will immediately begin to evaporate creating a potentially explosive environment. The boiling point is 131 deg. F. This means at that temperature, the liquid will begin its transition to a gas, making the material again potentially explosive.

That would make it a Class IB flammable liquid. Your client would be limited to 120 gallons in the building without any modifications. If they sprinklered the building throughout, they can increase that to 240 gallons. If they also store the paint in approved cabinets, they can have up to 480 gallons. If they do not sprinkle the building but store the paint in approve cabinets, then the quantity would be limited to 240 gallons.

The other options your client has are:

1. Classify the storage occupancy as Group H-2 and comply with the requirements for that occupancy group.
2. Create three other control areas per Section 414.2. You are allowed four control areas on a first story. The building itself is considered one control area and they would need to create three separate rooms with 1-hour fire barriers. Then divide the paint quantity equally among each control area (i.e., 112-113 gallons per area).
3. Create one other control area and store the paint in approved cabinets. That provides two control areas with an acceptable quantity of 240 gallons stored in each.

That addresses the quantity issue. However, there are other things that must be considered, such as ventilation (414.3) and explosion control (414.5.1). The latter would only apply if the paint is used or dispensed in the area--if they are stored in containers and remain in those containers until use at a project site, then explosion control is not required.

Thanks for the detailed explanation. That's a big help. Since this is a tenant in a larger building, I doubt there will be any sprinklers added.

 

[RLGA]

Thanks for the detailed explanation. That's a big help. Since this is a tenant in a larger building, I doubt there will be any sprinklers added.

Probably not. One other option I did not mention is the storage of the paint in an exterior storage area--removing it completely (or partially) from the interior of the building. There are other requirements for exterior storage (besides having the space to do it and security) that must be considered, but they are usually less restrictive that the requirements for interior storage.