Minimum Requirements (from the System Supplier) for a Code Compliant Plan Review of Hazardous Material Area - Gas Detection & Emergency Alarm Systems!

2008-02-27T07:45:00.008-05:00

First off, thanks for clicking on the email link and visiting my new blog. As many of you know, I have a great respect for what all of you do for the community, and I can really appreciate the almost impossible challenges you face every day. I've learned so much in the last 25 years implementing Gas Detection and Emergency Alarm Systems for Hazardous Material Areas in automotive research, water and wastewater, general and heavy industry, educational, and health care organizations in the United States. I've never had a blog before, but feel compelled to start this one to reach out to the fire safety and inspection community, and share some of the things I see every day. I'd like to thank my staff for putting this together in a matter of days, and opening what could be a great, mutually beneficial communication channel.

Now that I've gotten the introduction out of the way, let me share with you my impetus for starting this blog. On an almost weekly basis for the last seven years I've faced the same question from property owners and customers, "why do we need to involve the fire inspector on this project?" Just today, I was at a major hospital in metro Detroit who asked for my help in rationalizing the many refrigerant monitoring systems in their facility. In the end we seemed to agree on what would be the best design, and I told the customer that ultimately, it would depend on the Fire Marshal's opinion on one particular issue we were wrestling with. And, as usual, one of the hospital employees in the meeting asked, "why does the Fire Marshal need to know anything about this project anyway?"

I proceeded to explain that in order to be code compliant there are clearly defined steps that must be followed to ensure a safe operating environment. This is usually when their eyes begin to glaze over as they contemplate their next objection. Further, I explained, if there is an accident and somebody is injured or killed, the plaintiffs lawyers will begin their investigation by examining the process used to construct the life safety system in question. This is usually where I start to get their attention. I go on to explain that if you utilize the best known processes and procedures in the design and implementation of your life safety, emergency alarm system, and follow all known applicable codes and standards, that you will help to minimize your personal and your company’s exposure from a system liability standpoint. At this point, most people can see the importance of installing a code compliant system. I'm extremely proud of the many systems my company has implemented from adhering to this philosophy.

So, many of you are probably wondering; "what's the big deal Jim, people seem to understand the importance of code compliance once you explain it to them?” This brings us to another situation I faced last week in the process of designing a flammable and toxic gas detection system for a new automotive research facility in metro Detroit. Just like the hospital employee that questioned the need for the Fire Inspector's involvement, the owners of this automotive research company were faced with cost overruns on their construction project and were not real interested in following the letter of the codes which would result in additional cost. Generally, I feel that I've let the customer down if I'm unable to convince them to design their system to be code compliant. Of course I'm disappointed that my company didn't win the bid because there was another company that was willing to short cut the process and not adhere to the codes. The successful bidder was a European company that has “never” provided an emergency alarm system to meet U.S. or Michigan codes and standards before. I was told that they didn’t feel that any codes were applicable and that no professional engineer from their firm will sign off on this system design. I said “WOW”! My only solace is that, I'm confident that the Fire Inspector will ultimately educate the owner on the importance of code compliance and that a suitable life safety system will be put in place! That is, if the Fire Inspector gets the real or “correct” application information and documentation from the owner to do his review.

This brings us to the reason I felt compelled to begin this dialogue. The Fire Marshal who is the AHJ for this automotive research prospect is fairly new; the owner understands this and has indicated that the Fire Marshal prefers to take a "hands off" approach to the hazardous area emergency alarm systems in his jurisdiction, and that he would rather rely on the judgment of the owners and engineers building the project. I have reviewed the engineers proposed plans on this project at least five (5) times in the last year. I had provided a list of errors to the project engineer, each of those five (5) times, that I had found in the drawings and specifications referencing explicit code compliance details missing in their life safety system design; but to no avail. The items I had listed added more money to the project. So now, despite my best efforts to educate the owner on their responsibilities to adhere to the codes, there is little I can do but to sit back and watch my prospect implement a life safety system that is substandard. Hopefully no one will ever be injured or killed as a result.

I see that the most critical part of the Plan Review process for the Fire Inspector, is insuring that you are getting complete and accurate information from the owner to do your Plan Review. Most of the owners that I deal with, who act like this one has; will simply avoid filing for installation permits and a Fire Marshal Plan Review of the Gas Detection and Hazardous Area Emergency Alarm System. If we convince them to do it, Ino-Tek will provide a Process Hazard Analysis in our design submittal package to the Fire Marshal; along with a code trail identifying all of the devices required in the system based on the quantity and types of hazardous materials being used, stored, dispensed, handled or generated.

This following may serve as a checklist to all who are interested!

A “complete” detailed, engineered system design submittal must be provided for a proper Fire Marshal (or Inspector) plan review that includes the following per the Michigan Building Code, International Fire Code and National Fire Protection Association:

A completed Process Hazard Analysis Report. This Process Hazard Analysis Report “must” include separate floor plans, for each zone, identifying the locations of anticipated contents and processes where Hazardous Materials are being used, stored, dispensed, handled or generated, and shall include the following detailed information indicated on the construction documents and within a separate three (3) ring binder in report format.

1. Identify all hazardous materials to be used, stored, dispensed, handled or generated.

2. Include the quantity of each hazardous material in each zone. Include the location of each and pertinent dynamic leak characteristics of each under operating and non-operating conditions. This will include information pertaining to the exposure limits, the vapor density, the operating pressure and temperatures, piping routes, locations of pressure reducing stations, valve stations, other pertinent equipment, etc. as required to provide a complete understanding of the processes involved.

3. Indicate locations of potential leak sources.

4. Indicate type of leak detection proposed and methods of protection being provided.

5. Provide an air movement analysis for each zone; including documentation showing airflow patterns under normal operating conditions and under alarm conditions. i.e. purge fan ventilation operation and standard temperature controlled ventilation conditions. This should be substantiated by smoke testing or other recognized standard for ventilation analysis.

6. Indicate proper location and quantity of sensors for each zone based on gases or hazards present, the dynamic leak characteristics of each hazard and ventilation analysis.

7. Indicate all applicable code and standard references for each device in the emergency alarm system required. References shall be quoted verbatim and documented within the report.

8. Describe the functionality of each device within the system and provide a complete sequence of operation referencing applicable codes and standards.

9. Indicate all applicable safety interlocks required with code and standard references.

10. This report is to be stamped by a state of Michigan, licensed, professional engineer certifying that all applicable codes and standards have been adhered to.

The package should also include:

Product Data
Electrical Schematic Ladder Wring Diagrams
Control Panel and Field Detail Wiring Diagrams
Monitoring System Hardware Details
Software Configuration
Emergency Power Load Calculations per NFPA / NEC
Bill of Materials
Plan Layout
Mechanical Piping Diagrams
Sequence of Operations
Electrical Riser Diagrams
Mechanical Installation Details
Tag and Sign Information
Remote Supervised Station Interlock / Details
Conduit and Cable Schedules

It's a lot of hard work going through this process, but at the end of the day, there really isn't any way to justify short-cuts. The codes are very clear and it is our fiduciary responsibility and obligation to follow them (even to the letter).

If the system is not something that the Fire Marshal (or Inspector) is not well versed in, and if he feels incapable of making a complete, thorough plan review, then he should submit this complete package to a plan review company that can help him out; for example: Fire Safety Consultants, TVA, ICC, even Ino-Tek. In our industry, it is understood, we, as the contractor, have to pay for that plan review. Don’t feel bad for charging us.

As always, I would appreciate your thoughts and comments.

Thank you,

Jim Parker

Attention Ladies and Gentlemen!

A call is out to any individuals that may be interested in starting an Automotive Research & Development (industry specific) support group in Southeastern Michigan to help their fellow inspectors and emergency responders understand the Hazardous Material Areas and Emergency Alarm / Gas Detection Systems required in this dynamic industry. There are many of you who have one (1) or two (2) Auto R&D facilities in your areas and have many questions, while others have four (4), five (5) and more similar facilities in their areas and probably know most of the answers. There is a great need for standardization among this industry and shared knowledge. If anyone is interested; please respond to this Blog and I will put you in touch with like minded individuals. If anyone would like to know more about the requirements for these areas; please respond to this Blog and I will also put you in touch with some of your local brothers that can help you.

We also offer training courses with approved CEU’s for this industry. Let me know if we can help!

Thanks Again - Jim

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Minimum Requirements (from the System Supplier) for a Code Compliant Plan Review of Hazardous Material Area - Gas Detection & Emergency Alarm Systems!