The National Building and Fire Codes regulate hazardous industrial processes to maintain an acceptable level of risk within the built environment, while permitting some flexibility regarding the means through which the level of safety is achieved. Currently, some distillers desire to incorporate tasting rooms or restaurants in their facilities. Alternatively, some distillers are seeking to operate as a suite in multi-tenant buildings that include a variety of adjacent major occupancies. The National Building Code (NBC) Sentence 3.1.3.2.(1) prohibits a high-hazard industrial occupanffggdgdcy (Group F, Division 1) within a building containing assembly, institutional, or residential major occupancies (i.e. Groups A, B, or C, respectively). As distilling operations are prescriptively classified as a Group F, Division 1 occupancy regardless of size, this prohibition can preclude the aforementioned business plan of small distillers.
A distillery contains a process plant where distilled beverage alcohols are produced, concentrated or otherwise processed, and includes facilities where the concentrated products may be blended, mixed, stored or packaged. Distilled beverage alcohols contain more than 20% alcohol by volume. National Fire Code Sentence 4.10.2.1(1) specifies that buildings, or parts of buildings, where alcohol is distilled, processed, or stored in bulk are to be classified as high-hazard industrial occupancies. In certain cases, this classification poses no commercial challenges to achieve prescriptive compliance. In other cases, the condition of an existing building or a proposed design needs substantial analysis or modification, in order to be compliant.
Canada’s model Building and Fire Codes permit Alternative Solutions to be prepared for, and accepted by, the pertinent Authorities Having Jurisdiction. An Alternative Solution proposed by a design team must outline the aspects of the design which do not comply prescriptively with the Code, and then demonstrate that the proposed alternative provides a level of safety that is, at minimum, required by the prescriptive options. This performance-based methodology allows more flexibility to teams seeking different, unique, or complex designs, but is not always a straightforward process to contemplate from a fire safety standpoint.
Distilleries and specifically, smaller, craft-style distilleries seeking to incorporate food and beverage (assembly occupancy) areas within their proposed design, face a conundrum: can a sufficiently small and sufficiently safe distillery meet the acceptable level of risk required by the Code? Judging the level of performance required would have to balance the prescribed occupancy classification, the limits of NBC Sentence 3.1.3.2.(1) which states, “No major occupancy of Group F, Division 1 shall be contained within a building with any occupancy classified as Group A, B or C.” (emphasis added) against the logical notion that a certain size of distillation process and a certain quantity of alcohol would not present a greater hazard than other, permitted occupancies.
A frequently proposed Alternative Solution approach establishes that when sufficiently small quantities of ethanol are processed or stored, they create a comparable fire load to other combustibles commonly found in medium or low-hazard industrial occupancies. This analysis typically concludes that the limited quantity of ethanol does not warrant the prohibition of mixed building occupancies.
This analysis recognizes that fuel loading plays a large role in the anticipated fire dynamics of a compartment fire. This analysis is useful and serves to benchmark the proposed use of the craft distillery with other, more commonplace occupancies such as warehouses or factories. This rationale can make sense in some instances, such as remote floor areas separated from the hazards, but rarely accounts for the potential of an explosion. Calculation of average fuel load density throughout a floor area also under-represents peak fuel concentrations surrounding process equipment and storage areas. Alternative Solutions which focus only upon average fuel load assessments may under-predict hazards like vapour cloud explosions or liquid pool fires, which can create greater hazards to occupants and property.
The NBC Intent Statements behind the prohibited occupancy combination indicate that groups of people who may be unfamiliar with a site should not be exposed to undue risk of explosions or rapidly growing fires. Occupants socializing in tasting rooms and restaurants may require more time to evacuate than workers in a sparsely populated and familiar distillery space. The Code necessarily tolerates some level of risk associated with a building where a rapidly developing fire or explosion may occur, and where occupants are present. An Alternative Solution should demonstrate that building occupants who are not intimate with the distilling process are reasonably protected with hazard-appropriate building design features and fire or explosion risk mitigation features, to facilitate emergency egress.
High-quality Alternative Solutions seek to establish the level of acceptable risk within the Codes, define the level of risk presented by a distillery, guide the relevant aspects of the process towards more inherent safety, and develop fire and life safety features which meet that threshold. This serves to provide protection to all building occupants, while not resulting in undue burdens on activities, thereby, effectively achieving compliance with the intent of the Codes.
