In Transit: CIBC guidelines and regulations that may apply
NFPA Journal®, January/February 2009
When CIBCs are in transit, U.S. Department of Transportation (DOT) and United Nations (UN) transportation regulations apply. Many users mistakenly assume that if a container is DOT- and UN-approved for transportation, it has been explicitly assessed for fire performance in a storage scenario. However, this is not the case. There is no fire test required for DOT-approved Packaging Group II or III CIBCs.
Once in a warehouse, state and local building and fire codes typically apply. In many jurisdictions, the requirements of NFPA 30, Flammable and Combustible Liquids Code, are adopted or referenced. OSHA enforces the 1969 edition of NFPA 30 as OSHA 1910.106. Insurers may also apply their own fire protection and storage criteria before they underwrite a particular hazard.
A thorough knowledge of flammable and combustible liquid definitions and classifications is required to understand storage and packaging limitations. One major difficulty in the current CIBC classification process is that many containers are approved for transporting Packaging Group II liquids, which include Class IB and IC flammable liquids, although most fire codes prohibit the storage of any flammable liquid in these containers.
NFPA 30 attempts to reduce fire hazards by setting requirements for the design and construction of containers, intermediate bulk containers, and portable tanks. Because Section 9.4 of the 2008 edition of NFPA 30 describes acceptable containers in which to store liquids, only certain types are allowed. While Section 9.4 specifies what might be considered “approved,” NFPA does not, in fact, approve individual designs or specifications. That is DOT’s responsibility. However, NFPA 30 does permit rigid CIBCs that meet DOT Title 49 CFR, Parts 100–199, or Part 6 of the UN publication Recommendations on the Transport of Dangerous Goods, for Classes 31H1, 31H2, and 31HZ1.
Since the mid-1990s, the NFPA 30 Technical Committee has evaluated fire test data and associated variables related to commodities, container types and sizes, storage arrangements, and automatic fire suppression design parameters to establish criteria for protecting stored liquids. Mandatory protection criteria were adopted and are continually updated based on new fire test data.
NFPA 30 now recognizes that only CIBCs listed and labeled in accordance with UL 2368 or an equivalent test procedure are considered protected storage in a warehouse where associated fire protection design criteria, found in Chapter 16, are followed. Otherwise, the storage of such containers is considered unprotected. In addition, these containers are acceptable only for the storage of Classes II, IIIA, and IIIB liquids. NFPA 30 prohibits the storage of Class I liquids in CIBCs.
NFPA 30 allows an unlimited quantity of liquid in a protected liquid warehouse, but quantities are restricted in unprotected storage. For example, NFPA 30 permits a maximum of 8,250 gallons (31,230 liters) of Class II liquids in CIBCs in an unprotected liquid warehouse. This restriction is eliminated for detached, unprotected buildings, subject to the AHJ’s approval.
The International Fire Code (IFC) used to conflict with NFPA 30 regarding storage of liquids in plastic containers, but it was recently modified to reference NFPA 30. CIBCs must now meet the requirements of both the IFC and NFPA 30 for container and portable tank design, construction, and capacity. This effectively limits CIBC storage to Classes II and III liquids.
OSHA uses the 1969 edition of NFPA 30, which does not address container storage to the degree that the current standard does. Several interpretive letters related to liquid storage in plastic containers suggest that OSHA recognizes the NFPA 30 language that only approved containers and portable tanks be used. This interpretation would limit CIBC storage to Classes II and III liquids.
Insurers may impose further limits on the indoor storage of liquids in CIBCs. For example, the guidelines published by Norwood, Massachusetts-based FM Global, found in its Property Loss Prevention Data Sheet 7-29 (“Flammable and Combustible Liquid Storage in Portable Containers,” September 2004) are more restrictive than those in NFPA 30, suggesting that additional research is needed to finalize a test for evaluating CIBC performance.