Applying building code to outdoor space 1

[TheBorg123]

We have a manufacturing facility, and we do painting in an open air area. We have never had an issue over the previous 40 years during fire inspections. We even had OSHA and the DNR come through in the past and the VOC's we release are within the allowable amount.

Recently, a new deputy fire marshall came through and said we have 30 days to erect a spray painting enclosure. We believe he's applying building codes to an area that doesn't fall under the scope of building codes, since it's completely outdoors. Additionally, we're painting steel (non-combustible).

If the deputy fire marshall is correct, then how do water towers get painted without a paint booth?

Is there any information to help me fight this?

 

[cdafd]

1. when you say open area, do you mean completely open?? no side walls, no canopy?

2. Do you know which fire code and edition the city has adopted???

3. Which state is this in?

 

[UFT12]

Just because an outdoor facility is outside doesn't mean it does not impose a hazard. One major factor is the distance to other structures. See the building code of your area if it addresses this case.

In addition, could it be that the spray application due to proximity with anything passing by could create a health hazard as well?

 

[TheBorg123]

cdafd, see below:

1. when you say open area, do you mean completely open?? no side walls, no canopy? That is correct, it is completely open. No walls or canopy.

2. Do you know which fire code and edition the city has adopted??? I believe it's the 2018 North Carolina State Building Code, which is based on the 2015 International Fire Code.

3. Which state is this in? North Carolina

 

[cdafd]

A booth is not needed, to spray outside. in my opinion,,,With that said, in my state you run into the State environmental regs, which basically does not allow open air spraying, forcing you into a booth.

Most of IFC applies to a building.... It does regulate outside of buildings also,but I would say if spraying outside in the open,,,, NO

Unless the city or state has laws that say otherwise.

101.2 Scope

This code establishes regulations affecting or relating to structures, processes, premises and safeguards regarding all of the following:

The hazard of fire and explosion arising from the storage, handling or use of structures, materials or devices.
Conditions hazardous to life, property or public welfare in the occupancy of structures or premises.
Fire hazards in the structure or on the premises from occupancy or operation.
Matters related to the construction, extension, repair, alteration or removal of fire suppression or alarm systems.
Conditions affecting the safety of fire fighters and emergency responders during emergency operations.






2404.2 Location of Spray-Finishing Operations

Spray-finishing operations conducted in buildings used for Group A, E, I or R occupancies shall be located in a spray room protected with an approved automatic sprinkler system installed in accordance with Section 903.3.1.1 and separated vertically and horizontally from other areas in accordance with the International Building Code. In other occupancies, spray-finishing operations shall be conducted in a spray room, spray booth or spraying space approved for such use.

Exceptions:

Automobile undercoating spray operations and spray-on automotive lining operations conducted in areas with approved natural or mechanical ventilation shall be exempt from the provisions of Section 2404 when approved and where utilizing Class IIIA or IIIB combustible liquids.
In buildings other than Group A, E, I or R occupancies, approved limited spraying space in accordance with Section 2404.9.
Resin application areas used for manufacturing of reinforced plastics complying with Section 2409 shall not be required to be located in a spray room, spray booth or spraying space.




may not have this::


SPRAYING SPACE. An area in which dangerous quantities of flammable vapors or combustible residues, dusts or deposits are present due to the operation of spraying processes. The fire code official is authorized to define the limits of the spraying space in any specific case.



FLAMMABLE VAPOR AREA. An area in which the concentration of flammable constituents (vapor, gas, fume, mist or dust) in air exceeds 25 percent of their lower flammable limit (LFL) because of the flammable finish processes operation. It shall include:

The interior of spray booths.
The interior of ducts exhausting from spraying processes.
Any area in the direct path of spray or any area containing dangerous quantities of air-suspended powder, combustible residue, dust, deposits, vapor or mists as a result of spraying operations.
The area in the vicinity of dip tanks, drain boards or associated drying, conveying or other equipment during operation or shutdown periods.

The fire code official is authorized to determine the extent of the flammable vapor area, taking into consideration the material characteristics of the flammable materials, the degree of sustained ventilation and the nature of the operations.





Also check all your spraying liquids, to make sure you are actually spraying something flammable::


FLAMMABLE FINISHES. Coatings to articles or materials in which the material being applied is a flammable liquid, combustible liquid, combustible powder, fiberglass resin or flammable or combustible gel coating.

check the defintions for flammable and combustible::

https://up.codes/viewer/north_carolina/ifc-2015/chapter/2/definitions#flammable_liquid

Good luck, if all fails hire a Fire Protection Engineer, that has delt with haz materials, to assess and advise you,, Money spent may save you alot!!!

https://up.codes/viewer/north_carolina/ifc-2015/chapter/2/definitions#flammable_liquid

 

[FacEngrPE]

In Virginia. I remember when shipbuilding painting was untented, periodically when the wind blew in the correct direction we would get damage claims from over-spray spotting cars and houses.
The reason all of our outside blasting and painting is under tents now comes from environmental air regulations. You should review your facilities air permits, and verify they are written correctly for the painting operation.

 

[chicopee]

Ask the Fire Marshall which code he is applying. What is the concern of the Fire Marshall about you outdoor facility unless he has some reasons to believe that you are violating the clean air act with overspray particulates and solvents released into the atmosphere.