# Flammable liquids in wholesale and retail sales and storage areas



## code2driver (Dec 8, 2010)

Code question: if IFC-2003, Section 3401.2 (exception 2) exempts wholesale and retail sales and storage areas from the requirements of Chapter 34, why does 3404.3.4.1 (paragraph 2) contain a maximum allowable quantity of flammable liquids in wholesale and retail sales uses?  The commentary does not address the discrepancy, but it does state that “to control the potential hazard, the quantities of flammable and combustible liquids are limited in the control area.”

Researching this because a vodka-blending business (40% ethanol) that will distribute the product (and therefore claim to be a wholesaler) is invoking Section 3401.2 (exception 2) to prove that storage quantities are unlimited, although the proposed plan indicates the storage area as an Group S-1 occupancy classification.

The owner of the business is one of these "moving target" sort of guys, with plans changing almost daily, so I would like to at least be solid on this part of the Code.


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## cda (Dec 8, 2010)

appears if they meet 3401.2 they do not fall under chapter 34

and if something is not exempted by 3401.2 and is in a M occupancy then they can use 3404.3.4.1

not sure if that answers your question

so are they trying to just get out of chapter 34 requirements or both chapter 34 and fire sprinklers???


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## Frank (Dec 8, 2010)

If blending is he bringing it in in bulk containers?

See note that limits container size to 1.3 gallons for this exception.


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## code2driver (Dec 8, 2010)

They do meet 3401.2(2) if they are a Group M wholesale or retail sales business.

I'm not sure if it does answer my question, which another way can be stated, are they limited to 1600 gal. since it's a non-sprinklered building.

Frank, the 100% ethanol is stored and filtered outside, then piped in and watered down to 40% (80 proof), then bottled.  He is under 120 gal. of 40% ethanol in the building until it gets bottled.


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## code2driver (Dec 8, 2010)

And they are trying like anything to get out of both Chapter 34 and NFPA 13 requirements.


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## cda (Dec 8, 2010)

If they meet the exception 2 if I remember right, then chapter 34 does not apply

No matter what occupancy they are!!

How about require a technical report for the entire building and operation

That might settle the issue, and you might get sprinklers out of the deal

Also is the mixing / dispensing all closed system??


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## code2driver (Dec 9, 2010)

IFC (2003) 3401.2(2) is a specific exception for wholesale and retail sales and storage areas.  They wanted to call their storage area a non-separated Group S-1 area, but am requiring them to call it M in order to use the exception.  Not that M is any different from S-1 in terms of the Building Code, but for future reference.

The system is closed up to the bottling machine, so we do have ventilation control at that point.

My BO is considering (and I am advocating for) requiring the technical report and special inspection for several aspects of the project, so we can still hope.


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## FyrBldgGuy (Dec 9, 2010)

Whether or not it is wholesale or retail the operation involves a open/closed system flammable liquid process.  See Table 2703.1.1(1) the process system exceeds the notation for 1.3 gallons for retail and wholesale exception.  It is the same for a distiller.


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## code2driver (Dec 9, 2010)

True.  BO is considering the bottling as accessory to the M occupancy, and is enforcing IFC Chapter 27 and 34 w/r/t flammable liquids in amounts that do not exceed the maximum allowable quantity per control area.


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## cda (Dec 9, 2010)

How is this place an M?????

309.1 Mercantile Group M. Mercantile Group M occupancy

includes, among others, buildings and structures or a portion

thereof, for the display and sale of merchandise, and involves

stocks of goods, wares or merchandise incidental to such purposes and accessible to the public. Mercantile occupancies

shall include, but not be limited to, the following:

maybe F/S and a few other things

yes the processing area needs to be looked at as far as quantities and process to see what is required


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## FyrBldgGuy (Dec 9, 2010)

A guy walks into a bar... The bar has an dispenser for liquor it is connected to a manifold.  Right there it becomes a open/closed system.  Bottles tend to be larger to reduce the time it takes to change out empties.  The 1.3 gallon exception goes away.


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## FM William Burns (Dec 9, 2010)

What does their Act 58 License say they are Wholesale or Retail Warehouse Distillery?


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## cda (Dec 9, 2010)

But is it open to the general public to go in and walk around???

If not do not see how it is a M???


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## TJacobs (Dec 12, 2010)

Sounds like an F & S, no M involved.


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## Architect1281 (Dec 12, 2010)

M use is Buying little boxes in bigger boxes - opening the big boxes and selling the little boxes

F is buying multiple components and making a new or different component  (blending) packaging and sending product out the door.

Not matter what you hear they are factory not mercantile.

a Bakery making pies from flower and fruit is Factory in the kitchen and the sales area is Mercantile- even if they run tours in the kitchen


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