# IFC 2006 - 903.2.3.1 Woodworking operations



## Truck3capt (Aug 13, 2016)

We finally got into the pallet company that I mentioned some time  ago in another thread.  The long and short of it is that the owner has moved the entire pallet repair and recycling operation off-site to a location outside of our jurisdiction.   With that said, he's still building new pallets at this location. His assembly area is directly adjacent to his loading dock area.  The new pallets are completed and loaded into  the trucks and hauled off-site or shipped out the same day.   It appears he's addressed the high-piled combustible storage problem from previous inspections.  The handful of pallets that are not shipped out daily are stacked in piles under 6 feet following the NFPA guidelines for separation etc. 

Our problem is the area he cuts new lumber into the appropriate pieces for pallet construction.  The area is about 10,000 SF and has 6 or seven pcs. of equipment that cut or shape lumber.  The dust removal system needs work  and will be another issue, but one that the owner is working on.  The question we have after looking at the IFC commentary is how to calculate and confirm that the cutting operation is 2500 sq feet or less?  It doesn't appear that the operation has to be separated with fire barriers within the fire area.  The operation just has to be under 2500 SF to forego the requirement for sprinklering. 

Are we looking at this correctly? If so how do we calculate the area of the operation if the equipment is scattered all over the fire area and there does not appear to be any requirement to separate the "operation" with fire barriers?  We were headed down the road to requiring sprinklers in this area, but after looking at the commentary and reading this again I'm not sure it's required as long as the "operation" is under 2500 Sf.


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## cda (Aug 13, 2016)

I would say if the total
Of all areas of woodworking ,,, not just sawing is over 2500.  Sprinkle it


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## Truck3capt (Aug 13, 2016)

cda said:


> I would say if the total
> Of all areas of woodworking ,,, not just sawing is over 2500.  Sprinkle it



Does air nailing generate finely divided combustible waste?  I'm not trying to be a smart alec but when we went this last time there were more lawyers than inspectors. They were already looking at this section and questioning us about it before we even arrived on site.. 

"fire areas that contain woodworking
operations in excess of 2,500 square feet in area )
_which generate finely divided combustible waste_ or
which use finely divided combustible materials."

If for sake of argument the pallet nailing/assembly area doesn't generate _finely divided combustible waste_ can we look at just the area where the sawing and shaping is taking place?  I don't have the commentary with me here at home, but from what I remember it seemed to indicate that the woodworking areas (that produce finely divided combustible materials ) need not be separated in any way from the rest of the fire area.  The area they occupy just needs to be under 2500 sq ft to forego sprinklers. I'm not trying to let him off the hook on sprinklers but I have to make sure this one is right given the outside pressure we're getting on it. I asked ICC for an interpretation also, but I wanted to see what the members here thought about it.


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## cda (Aug 14, 2016)

Would start with F occupancy


To me woodworking falls under F-1 and is somewhat defined 

So I would say it is not just the sawing

Factory Industrial Group F: uses intended for assembling, disassembling, fabricating, finishing, manufacturing, packaging, repair or processing operations that are not classified Group H hazardous or Group S storage. Group is divided into two sub groups, F-1 Moderate Hazard and F-2 Low Hazard 


*ION 306 FACTORY GROUP F *

*306.1 Factory Industrial Group F. *
Factory Industrial Group F occupancy includes, among others, the use of a building or structure, or a portion thereof, for assembling, disassembling, fabricating, finishing, manufacturing, packaging, repair or processing operations that are not classified as a Group H hazardous or Group S storage occupancy. 

*306.2 Moderate-hazard factory industrial, Group F-1. *
Factory industrial uses that 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: 

Aircraft (manufacturing, not to include repair) Appliances 

Athletic equipment 

Automobiles and other motor vehicles 

Bakeries 

Beverages: over 16-percent alcohol content 

Bicycles 

Boats 

Brooms or brushes 

Business machines 

Cameras and photo equipment 

Canvas or similar fabric 

Carpets and rugs (includes cleaning) Clothing 

Construction and agricultural machinery 

Disinfectants 

Dry cleaning and dyeing 

Electric generation plants 

Electronics 

Engines (including rebuilding) 

Food processing establishments and commercial kitchens not associated with restaurants, cafeterias and similar dining facilities more than 2,500 square feet (232 m2) in area. 

Furniture 

Hemp products 

Jute products 

Laundries 

Leather products 

Machinery 

Metals 

Millwork (sash and door) 

Motion pictures and television filming (without spectators) 

Musical instruments 

Optical goods 

Paper mills or products 

Photographic film 

Plastic products 

Printing or publishing 

Recreational vehicles 

Refuse incineration 

Shoes 

Soaps and detergents 

Textiles 

Tobacco 

Trailers 

Upholstering 

Wood; distillation 

Woodworking (cabinet)


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## cda (Aug 14, 2016)

Not near the commentary till Wednesday so I am no help there 


Plus commentary is not code


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## cda (Aug 14, 2016)

One states thoughts 


http://www.oregon.gov/bcd/codes-stand/Documents/interp-08-04-autosprinklerwoodworkingops.pdf


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## Truck3capt (Aug 14, 2016)

cda said:


> Not near the commentary till Wednesday so I am no help there
> 
> 
> Plus commentary is not code


Thanks and I agree but I'm going to have this picked apart by my city legal department and the owners' legal counsel.  Their argument:  The occupancy classification never changed as the building was originally built as a commercial printing and  publishing company.  It was in operation for 30 plus years before the current owner bought the building.  Our building department wasn't interested in getting involved then because in their opinion the F-1 classification had not changed.  Our department (prevention) got involved based on the high-piled storage, idle pallets and change of use within the classification. Unfortunately not until after the city zoning department approved a use variance without ever consulting our department.

The argument I've been getting is that the Occupancy Classification has not changed so  I can't use the current F-1 classification requirements for the current fire code because the building was built under an earlier code and the occupancy hasn't changed. I've argued that the operations in the F-1 occupancy have changed allowing me to cite the adopted Fire Code currently enforced based on the operations that are specifically addressed in the fire code for existing and new buildings, like high piled combustible storage.

It's a mess.  I'm just trying to dot all of the i's and t's before I hand it all over to the fire marshal, politicians and city legal to decide how much responsibility they want to assume.  I'm a fire inspector with 2 1/2 years in the division splitting my time with fire investigations and now plan reviews due to the departure of our deputy fire marshal.  I'd love to drop it on the fire marshal's desk and say here you go, but that's not realistic.  I'm curious to see if what I get from the ICC is helpful.


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## cda (Aug 14, 2016)

Sounds good

Yes the woodworking changes things and has to meet present IFC

Page 616


http://www.cityoflongbeachms.com/NE...C Code And Commentary Volume I Compressed.pdf


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## cda (Aug 14, 2016)

Good Luck sometimes you just have to question it enough times and document your efforts in case something does happen


You cannot win all the battles


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## mtlogcabin (Aug 15, 2016)

Truck3capt said:


> The occupancy classification never changed as the building was originally built as a commercial printing and publishing company. It was in operation for 30 plus years before the current owner bought the building. Our building department wasn't interested in getting involved then because in their opinion the F-1 classification had not changed



It may not have been a change of occupancy group (still an F-1) however it is a change of occupancy by definition in the 2012 fire code 

2012 IFC
[EB] CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building *that involves a change in application of the requirements of this code.*


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## JBI (Aug 15, 2016)

IF the actual area where the dust is produced were properly separated into another 'fire area' THEN the sprinklers could be avoided. 
IF the entire fire area in which the dust is produced is in excess of 2,500 s.f. THEN sprinklers will be required.
Applicants choice. 
The dust will not limit itself to 2,500 s.f.. It will infiltrate the entire fire area in which it is created. That's why the square footage threshold is there.


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## cda (Aug 15, 2016)

Looks like 2015 IFC chapter 28 applies!!!




*SECTION 2801 GENERAL *

*2801.1 Scope.* 
The storage, manufacturing and processing of solid biomass feedstock, timber, lumber, plywood,      """"""nonmetallic pallets,""".    veneers and agro-industrial byproducts shall be in accordance with this chapter.


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## JBI (Aug 15, 2016)

From the 2015 Commentary -
General Comments
Woodworking, agro-industrial, solid biomass feedstock
and forest product processing facilities tend to be
located close to the source of the raw material, but facilities
manufacturing finished products for the building
trade industries may be found in or near most urban
areas. Any facility using mechanical methods to work
wood and solid biomass into a more finished form produces
dust or debris. The smaller the fuel package, the
more easily ignitable it will be. In fact, extremely fine
wood dust or wood flour may even produce deflagrations
(explosions) under the right conditions. Explosion
prevention practices must be implemented to minimize
the potential for such hazards. Accumulations of dust
must be prevented, controlled mechanically or removed
frequently. Automatic fire suppression systems are
required by Section 903.2.4.1. Deflagration venting (see
NFPA 69 and NFPA 495) is required where substantial
amounts of dust are usually present. Areas where dust
suspensions exist are considered Class II hazardous
locations by NFPA 70. Manual fire-fighting equipment
must be provided in the immediate vicinity of each
machine because dust cannot be completely eliminated
in any woodworking or wood-processing area.
Methods and procedures used to control hazards
associated with wood, agro-industrial, solid biomass
feedstock and forest product storage, sale and processing
must recognize not only the fuel properties but the
need to control and eliminate ignition sources, minimize
the effect of fires and explosions, and facilitate fire control
efforts by occupants at the incipient phase and fire
fighters at more advanced stages. Adherence to these
requirements will help secure these objectives.
Purpose
Most everyone is familiar with the hazards of wood as a
fuel; however, the scale of wood, agro-industrial, solid
biomass feedstock and forest product storage, manufacturing
and processing operations stretches the limitations
of their understanding. Wood has long been used
as a reference fuel for understanding fire, but the sheer
volume of materials present and the variety of fuel packages
represented in these occupancies make this a
hazard requiring special attention.
Sawdust, wood chips, shavings, bark mulch, shorts,
finished planks, sheets, posts, poles, timber and raw
logs represent a broad continuum of fuels. What they all
bear in common is the hazard they represent once
ignited; what is unique about each of these materials is
the ease or difficulty with which any single fuel package
may be ignited. The regulations recognize both of these
concerns.
Provisions of this chapter are intended to prevent
fires and explosions, facilitate fire control and reduce
exposures to and from facilities storing, selling or processing
wood and forest products.
This chapter requires active and passive fire protection
features to reduce on- and off-site exposures, limit
fire size and development, and facilitate fire fighting by
employees and the fire service. Design and maintenance
of these facilities must provide access to equipment
and exposures to facilitate fire control.


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## Truck3capt (Aug 15, 2016)

mtlogcabin said:


> It may not have been a change of occupancy group (still an F-1) however it is a change of occupancy by definition in the 2012 fire code
> 
> 2012 IFC
> [EB] CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building *that involves a change in application of the requirements of this code.*


I agree completely.  I've even shared that exact definition with those that will  make the final decision.


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## cda (Aug 15, 2016)

It is hard when you do not have support up the line to include city hall

Been there enough times


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