Hazardous Waste Treatment Storage and Disposal Facility Fire Code Gap Analysis

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Download the executive summary. (PDF, 19 KB)

Fire Protection Research Foundation report: "Hazardous Waste Treatment, Storage, and Disposal Facility Fire Code Gap Analysis" (PDF, 4 MB)
Author: Elizabeth C. Buc, PhD, PE, CFI, Fire and Materials Research Laboratory, LLC
Date of issue: June 2015


Following a series of TSDF losses, starting in 2005 at Environmental Quality (EQ) in Romulus, Michigan to a more recent fatality and serious burn injury at Heritage WTI in East Liverpool, Ohio in December 2011, the CSB has recommended the NFPA “develop a fire protection standard for TSDFs addressing fire prevention, detection, control, and suppression requirements.” The applicability of NFPA codes and standards to hazardous wastes and TSDFs was not clear. 

In 2013, the NFPA Hazardous Chemicals Technical Committee created a task group to further investigate the TSDF fire problem in the context of the NFPA 400 Hazardous Materials Code. The task group identified the need for additional research regarding TSDF incidents in the form of a gap analysis. This code fund project, through the Fire Protection Research Foundation  (FPRF), was created to gather information on TSDF losses including causes and contributing factors; to identify trends and challenges unique to TSDFs;  to review the fire codes in the context of TSDFs; to identify gaps, both real and perceived, by Chemical Safety Board (CSB) and others; and propose a strategy for implementing code language with the existing MAQ per control area approach to fundamental requirements, fire prevention and fire protection for TSDFs containing a cross section of hazardous materials.