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Achieving Hazardous Materials Compliance in University Laboratories

Universities are constantly evolving and growing. One area that is currently realizing rapid change and growth is university research laboratories. These lab spaces are often planned and constructed for a specific professor or even for a specific research project. Growth and change of lab spaces is so rapid that labs are being introduced into all types of building environments. Labs may be part of an existing building that was not originally designed for laboratory use, be repurposed from a previous lab, or be part of a new state of the art laboratory building. One item that can easily be overlooked in the planning, design, construction and repurposing of lab space is the potential impact of the hazardous materials, used in the labs, to the safety of the building’s occupants and emergency responders. Applicable building and fire codes set acceptable limits for the maximum allowable quantity (MAQ) of hazardous materials in typical buildings through a concept known as control areas. The content of this blog is based upon the 2009 Edition of the International Building Code (IBC), which is currently the model code for numerous states.

Control Area Basics

One method of addressing the use of hazardous materials within a building is to classify the occupancy as a Group H occupancy. Group H occupancies have relatively high limits on the amount of hazardous materials. However, Group H occupancies lower flexibility of use due to limitations on other occupancies within the building and strict limits on maximum height and area. In many situations, use of control areas is an attractive solution compared to classifying a space as a Group H occupancy. Control Areas are defined by the IBC as:

“Spaces within a building where quantities of hazardous materials not exceeding the maximum allowable quantity per control area are stored, dispensed, used or handled” (IBC 2009, §307.2).

The control area concept gives the building user more flexibility by allowing the building to be separated into two or more control areas and then imposing limits on hazardous materials in each individual space. When this method is used, more flexibility is provided because the building is separated into multiple compartments that are bounded by fire barriers (rated walls) and horizontal assemblies (rated floors).

Impact of Floor Levels Above Finished Grade on a Control Area Compliance Strategy

One of the most important considerations when developing a control area strategy is to account for the effects of storage, use, or handling of hazardous materials on floors other than floor level located at grade. This issue is often overlooked in the early phases of projects and can lead to construction delays, costly change orders, and space that does not meet the future needs of an Owner. There are more restrictions on storage, use, and handling of hazardous materials on floors other than the first floor above grade plane due to the associated emergency response challenges. The following parameters vary based upon floor level in relation to grade plane:

  1. Number of allowable control areas on each floor.

  2. Required fire resistance to separate control areas.

  3. Limits on allowable quantities of hazardous materials in each control area.

The effects on MAQ can be drastic. For instance, the first floor is allowed eighty (80) times more hazardous material than the tenth floor above grade plane. The figure below shows a graphical representation of how the location above grade affects MAQ.

Other Considerations that Affect MAQ per Control Area

There are some ways to increase the MAQ in a given control area. One of the most commonly exercised MAQ increases is a 100% increase in MAQ allowed for most hazardous materials when the building is fully sprinklered. It is important to note that the entire building must be fully sprinklered per NFPA 13, not just the control area in which the increase is sought. Another potential allowable 100% increase in MAQ for specific hazardous materials can be realized by storing the hazardous materials in approved storage cabinets, day boxes, gas cabinets, exhausted enclosures, or listed safety cans. These increases can be applied cumulatively resulting in up to four (4) times the MAW amount listed in the IBC. This increase can be critical to provide the owner flexibility, particularly in labs at higher elevations. Each hazardous material arrangement is different and it is important that a full hazard analysis be performed against all applicable codes and standards.

Challenges and Recommendations for Continued Compliance

One challenge owners face is ensuring long-term compliance with the control area strategy at the time of construction. Often, the compliance strategy is not clearly documented or communicated to the Owner by the design team. Buildings containing labs frequently undergo changes of use and a documented control area strategy is often not available. In cases of changing the use of existing labs, or adding labs to an existing building, the current control area strategy should be carefully reviewed by the owner, architect, and code consultant. If a documented control area strategy is not available, a study should be performed to document the current use of hazardous materials to ensure that the use of the space at the completion of the project will be in accordance with applicable codes and standards. The results of this study should be turned over to the owner to facilitate future compliance. The following recommendations will help to ensure future compliance for storage of hazardous materials:

  1. Perform and document a full hazard analysis against all applicable codes and standards.

  2. Ensure future lab uses for the building are provided for during design of the control area strategy. Based on need for future flexibility, control area boundaries can be strategically located. Adding control area boundaries after initial construction often proves excessively costly.

  3. Clearly indicate control area boundaries on life safety plans. Control area boundaries should be clearly identified on construction documents to assist the owner in maintaining compliance. It is also recommended that wherever egress / life safety plans are posted in the building that these plans also identify control area boundaries.

  4. Communicate the limits on MAQ in each control area as well as how control areas are laid out in writing to the Owner. After initial control area concept is set up during design, building ownership needs to be informed on what requirements it is responsible for complying with at the end of a project. A clearly documented control area strategy should be turned over to the Owner at project completion.

  5. Establish a continued compliance program. This program should include inspections by appropriate staff at regular intervals to ensure continued compliance.

Soon-to-be-Released Guidance on University Labs

University labs can pose a challenge to achieving and maintaining compliance with applicable codes and standards due to the constantly changing nature and use of some labs. Fortunately, the 2018 International Building Code provides university laboratories relief from the strict control area limits by utilizing a laboratory suites concept. Laboratory suites are required to be separated from non-laboratory areas of the building and the code gives additional freedom with regard to both the number of laboratory suites on a given level above grade and the MAQ in each laboratory suite. While this code has not yet been adopted by any of the New England states, a fire protection engineer can use this concept as a basis for an equivalency, if approved by the authority having jurisdiction.