Higher Education Laboratories and the International Fire Code

The International Fire Code addresses hazardous materials using concepts such as maximum allowable quantities, control areas, and hazardous occupancies. Beginning with the maximum allowable quantity (MAQ), the Code establishes maximum quantities of various hazardous materials that are permitted within a building that is not considered a Group H occupancy (occupancies containing materials presenting a health hazard).

The quantity of materials identified in the MAQ table can be increased based upon whether the building is protected throughout with an automatic sprinkler system and whether the materials are in stored in hazardous material cabinets. For example, where the MAQ table permits up to 30 gallons of a Class IA flammable liquid within a control area, that quantity is increased to 60 gallons if the building is protected with an automatic sprinkler system or the liquids are stored in a flammable liquids cabinet. If the building is protected with an automatic sprinkler system and the liquids are stored in a flammable liquids cabinet, the MAQ is increased to 120 gallons.

The control area concept is a method by which one can prevent a building or area thereof from being considered a Group H occupancy. Recognizing that the story on which the hazardous materials are located is a risk factor, the Code reduces the number of control areas permitted per story, increases the fire resistance rating of the fire barriers that are used to define control areas, and limits the MAQ to a percentage of the value in the MAQ table. For example, the MAQ of 30 gallons per control area for a Class IA flammable liquid applies when the liquid is on the first story of the building.

There can be up to four control areas on the first story, each limited to 30 gallons, and the control areas need only be separated by fire barriers having a one-hour fire resistance rating. However, if the flammable liquids are located on the 7th story of the building, the MAQ is limited to 1.5 gallons. There can only be two control areas on the story, and the control areas need to be separated by fire barriers having a two-hour fire resistance rating. The intent of these provisions is to encourage facilities to locate the hazardous materials closer to the first story because manual fire suppression efforts would be less complicated.

Where the quantity of materials exceeds the MAQ in one or more controls areas, those portions of the building are classified as a Group H occupancy. When not a Group H occupancy, a laboratory in a campus building is likely to be considered a Group B or Group F occupancy, both of which have more relaxed height and area restrictions than a Group H occupancy. As such, the fire resistance rating of the building structural elements will be increased if the building is considered a Group H occupancy.

Laboratories in Higher Education Facilities

A group of university design and fire safety personnel formed a task group to develop a different set of requirements for laboratories in higher education facilities. The concern was that the MAQs were too limiting, especially in multi-story higher education facilities. Encouraging the laboratories to be closer to the first story was not consistent with the typical design practice in higher education buildings wherein the first story would typically be used for classrooms (Group A or Group B occupancies) and faculty offices (Group B occupancies). The task group felt that a number of factors should be considered for higher education facilities that, as a group, do not apply to the typical laboratory using hazardous materials. These factors include:

• Lower chemical density in individual laboratories: Many higher education facilities will have a number of smaller laboratories on each story that individually have a limited quantity of hazardous materials, but as a group, the quantities will exceed the traditional MAQ limits.
• Ongoing oversight by special experts: Laboratories in higher education facilities have capable professionals who provide fire and life safety expertise and oversight.
• Limited or directed funding streams: Many funding sources for university research only fund personnel and equipment, not upgrades to the building.
• Mixed-use occupancies: When classrooms and lecture halls are forced to the upper floors in buildings containing laboratories, those occupants would then need to egress past the areas where the hazardous materials are located.

Code Requirements for Higher Education Laboratories

The new requirements were first introduced as Chapter 38 of the 2018 edition of the International Fire Code (and Section 427 of the 2018 edition of the International Building Code) and include the following provisions:

• Increased general laboratory safety requirements: The new provisions require compliance with NFPA 45, which includes requirements for dating time sensitive materials, limits individual container sizes for certain materials, and establishes density limits for certain materials. The lower density limits mitigate the overall risk, a concept that is also recognized by the Code for semiconductor manufacturing facilities.
• Relaxed control area limitations: For example, in the previous example using Class IA flammable liquid, while the number of control areas on the seventh floor would still be limited to two, the MAQ for each control area (laboratory suite) would be 50% of the traditional MAQ. Therefore, in a building protected throughout with an automatic sprinkler system, the MAQ would be 30 gallons per control area, or 60 gallons if the liquids are in a flammable liquids cabinet.
• Special provisions for existing, non-sprinklered laboratories: Smaller quantities are permitted in existing buildings that are not protected with automatic sprinklers since there are many of such existing buildings on higher education campuses.

The concept of laboratory suites essentially replaces the control area concept but is used in a similar matter. The MAQ limits apply to the laboratory suite, and the number of suites per story of the building are limited. Laboratory suites are required to be separated from each other by fire barriers having a one-hour or two-hour fire resistance rating, depending on the story where the laboratory suites are located. In addition, laboratory suites are required to be separated from non-laboratory areas in the building. Laboratory suites may contain more than one laboratory space.

The Future

It should be noted that these provisions are an option to using the traditional control area concept and restrictions. Except for mostly editorial changes, the provisions have remained in the 2021 and 2024 editions of the International Fire Code and International Building Code. However, during those same two revision cycles the healthcare industry proposed to include medical laboratories in the types of laboratories that can use these provisions. Those proposed changes were not accepted but caused some to reconsider the unique provisions for laboratories in higher education facilities.

Based on discussions during the 2024 revision cycle, it is likely that proposals may be submitted to delete the higher education laboratory provisions and return to the traditional control area concept. To retain the provisions, it may be necessary to revisit the underlying assumptions as to what makes higher education laboratories unique and, for those that have utilized these provisions, to document that there has been no adverse fire experience associated with these new provisions.

APPA will be monitoring any proposed changes to the higher education laboratory provisions and will reach out to members for assistance and data as necessary.

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William Koffel is senior director of special projects at Koffel Associates in Columbia, MD. He can be reached at [email protected].