Adding a tasting area to a craft brewery is a popular way to create an additional revenue stream and expose a new group of customers to your product, however, it can present challenges when it comes to planning the space and getting approval from your local building department.
The building code classifies different spaces according to their use, or occupancy, such as residential, office, assembly, industrial and retail. Each occupancy typically has unique fire and life safety requirements associated with it. There are also requirements related to how occupancies can be combined within a building. For example, certain occupancies are not even permitted to be located in the same building.
Under the building code, breweries are typically considered industrial occupancies, while tasting areas are typically considered assembly occupancies (i.e. like bar or a restaurant). The code requires a fire separation between the two if they are each considered a major occupancy.
A major occupancy is defined as “the principal occupancy for which a building or part of a building is used or intended to be used, and is deemed to include the subsidiary occupancies that are an integral part of the principal occupancy.”
A fire separation is a barrier that is designed to resist the spread of fire and smoke from one space to another. Creating one between a brewery and a tasting area can present some challenges.
It necessitates constructing a wall that extends from the floor all the way up to either the slab or roof above, which can be expensive. The wall would mean that all your beautiful brewing equipment would no longer be visible from within the tasting area, which arguably takes away from the experience for patrons and could make both spaces feel cramped. Windows in the wall could help make the spaces feel less cramped and allow patrons to see the brewery, but any window in a fire separation requires a fire-protection rating. This means it either needs to be wired glass in a steel frame, provided with a fire shutter, or it needs to be sprinkler-protected. Wired glass windows are not especially aesthetically appealing, fire shutters are costly, and sprinkler protection can be expensive or difficult to install, especially in a building that is not already provided with sprinklers.
Similar to windows, any door in a fire separation is also required to be fire-rated, which adds to the cost and can make the two spaces feel disconnected. Fire-rated doors are typically constructed of steel, with very small windows if any, and provided with steel frames. Rated doors are required to be provided with self-closing hardware and are generally required to be kept closed at all times unless they are provided with specialized hold-open hardware connected to the building’s fire alarm system.
Like the windows and doors, openings in the fire separation for things like plumbing or HVAC would also need to be protected. Openings for services like pipes would need to be provided with firestopping, which is a product/system that is specially designed to maintain the integrity of the fire separation. Openings for ductwork would need to be protected with combination fire/smoke dampers, which are also designed to maintain the integrity of the fire separation.
Finally, subdividing your space with a fire separation could introduce some operational challenges. The floor area on the tasting area side of your operation is space that could be used for storage, moving equipment or receiving deliveries when the tasting area is not open. With a fire separation dividing the two spaces, moving large equipment or product between the two spaces would be difficult unless the wall is provided with a rolling door, which again, would need to be fire-rated.
With some foresight and planning regarding the operation and design of the tasting area, the building code can be applied in a way that may not require a fire separation between the brewery and tasting area.
In some cases, the tasting area can be considered a retail occupancy rather than an assembly occupancy. The code does not require a fire separation between medium- or low-hazard industrial major occupancies, such as breweries, and retail major occupancies. This is a relatively straightforward way to apply the building code but it does limit the maximum number of occupants, or occupant load, and therefore also limits the revenue that can be generated from the tasting area.
Another option is to examine whether or not the tasting area can be considered subsidiary to the industrial major occupancy. Subsidiary occupancies are generally not required to be fire separated from the major occupancy they serve. The main advantage of this approach is that it can allow for more occupants than the retail approach discussed above.
“Subsidiary occupancy” is not defined in the building code, which leaves it open to interpretation and means you need to make a strong case as to why the tasting area should be considered subsidiary to the brewing operations. This generally involves evaluating the scale of both the brewing operation and tasting area based on floor area and occupant load, reviewing how the two spaces will operate in terms of business hours and control, demonstrating that the two spaces are co-dependent, and evaluating how access is or isn’t provided between the two spaces.
Some building departments will be receptive to this approach and approve it after receiving a letter or report explaining how the Building Code is being applied to the project. Other building departments may require an Alternative Solution to be submitted. An Alternative Solution is a formal process where you need to demonstrate to the building department’s satisfaction that your design achieves a level of performance that is equivalent to what is intended by the requirements contained in the building code. Alternative Solutions are submitted with the building permit application and typically include a report prepared by an engineer that describes the design in terms of fire and life safety, and explains how the required level of performance is achieved. Sometimes building departments require the design to include mitigating measures in order to accept the Alternative Solution. Examples of mitigating measures include additional exit/egress doors, shorter travel distances to exits, and limiting occupant loads to a particular number.
However you approach it, there are cost-effective ways to add a tasting area to your brewery while providing the level of safety intended by the building code, but without compromising on the experience for your patrons or practicality for your operations.
