With the increasing popularity of ready-to-drink (RTD) beverages, many breweries are looking to expand their lineup beyond beer. The production of RTD beverages involve ingredients that have a higher alcohol content than beer. Due to their high alcohol content, many of the ingredients used in RTD production are flammable and therefore pose fire and explosion risks that brewers may not be familiar with. Managing these risks in conjunction with local building codes and fire codes can prove challenging for smaller operations, as the codes tend to be written with large industrial operations in mind, not a local brewery. It’s important to manage these risks for a number of reasons: to keep employees and customers safe, to protect your operation from downtime associated with an accident or noncompliance, to satisfy your insurer, and to get acceptance from your local building and fire departments for any renovations associated with the expansion into RTDs.
Here’s a little background on why many RTD ingredients pose additional fire and explosion risks. Aqueous solutions (i.e. a solution involving water) of alcohol are generally considered not to be flammable or combustible when the concentration of alcohol is at or below 20% alcohol by volume (ABV). Studies have shown that as the concentration of a solution of alcohol is reduced below 20% ABV, the fire point and flash point of the liquid increase rapidly. The fire point is the temperature at which a liquid will produce sufficient vapour to sustain a flame. The flash point is the temperature at which a liquid will produce sufficient vapour to produce a momentary flash when exposed to an ignition source. From a safety perspective, a higher flash point and higher fire point are desirable as less (or no) flammable vapours will be available to sustain a fire or cause an explosion. This 20% ABV cutoff is recognized in codes throughout Canada. Exceeding this cutoff in a production facility can have significant implications in terms of the design of your facility. While beer is typically well below this threshold, many of the ingredients used in the product of RTD beverages are not. For instance, one common ingredient in RTD production is grain neutral spirits (GNS). Grain neutral spirits are often shipped in alcohol concentrations up to 95% ABV, making them highly flammable.
The two main risks associated with these ingredients are fire and explosion. Fire is self-explanatory, explosion may not be. Flammable liquids produce flammable vapours as they evaporate. If these flammable vapours are not managed correctly, they can accumulate within a facility or vessel. At that point, ignition from any number of sources can cause an explosion. The fire and explosion risks associated with RTD production need to managed in a way that is suited to the scale of the facility’s operations and the actual operating procedures.
Adherence to local building codes and fire codes will help manage these risks, however, the resulting design of your facility may not be feasible or operationally practical. These codes tend to be written with large-scale industrial facilities in mind, not your local brewery. For example, the Ontario Fire Code (OFC) states that any facility producing, concentrating or otherwise processing alcoholic beverages more than 20% ABV is considered a distillery and is therefore considered a high-hazard industrial occupancy, regardless of the quantity of liquid. High-hazard industrial occupancies are prohibited by the Ontario Building Code (OBC) from being located in the same building as assembly occupancies. This means that an RTD production facility would not be permitted to be located in any building containing a tasting room or a restaurant, regardless of the size of either occupancy, the production scale, and whether or not the two are fire-separated. High-hazard industrial occupancies require more egress doorways than other occupancies and are required to have much shorter travel distances to exits. These are difficult to incorporate into the design of a building, especially in an existing building.
Fire codes also have many requirements that are particular to the storage, handling, and use of flammable liquids. The requirements include things like explosion-proof electrical equipment, explosion venting and damage-limiting construction, mechanical ventilation for flammable vapours, spill control and drainage, limits on the location and quantity of storage, the list goes on. Many of these can be difficult to retrofit in an existing building and are costly in any type of building.
In applying these requirements and managing the fire and explosion risks of RTD production, it’s important to look for opportunities to tailor the design to the actual scale and operations of your facility. This can help reduce installation, operating, and maintenance costs for equipment that doesn’t significantly contribute to the safety of your building. For example, the OFC requires mechanical ventilation for rooms where flammable liquids are dispensed. In a combination brewery/RTD production facility with an open floor area, this means the ventilation system would have to be provided throughout the floor area. If your RTD production area is only located in the corner of your brewery, it may not make sense to provide such a large ventilation system. It may be possible to show through engineering analysis that providing a local ventilation system only where the mixing of flammable liquids is actually taking place accomplishes the same goal. Another thing to consider is whether or not the distillery and high-hazard industrial classifications in the fire code are actually appropriate for your operations. Perhaps your RTD operation will only involve small quantities of alcohol. In that case, analysis of the combustible contents of your facility and the risks of your operations may show that a medium- or low-hazard industrial classification is more appropriate, thus avoiding some of the more onerous building and fire code requirements.
It’s best to start considering fire and explosion risk mitigation at the earliest stages of the design process, when you have the most flexibility in the design. There are often simple solutions to reduce the number of changes required to your building. As an example, if you’re considering adding RTD production to your brewery, it may be possible to store the high-proof alcohol outdoors and dilute it to less than 20% ABV before it enters your building. This would reduce the fire and explosion risks by not allowing flammable liquids to enter the building. It would also limit the extent to which high-hazard industrial occupancy requirements and many of the fire code requirements mentioned above would be applicable to your building. Of course, there will still be risks associated with the outdoor storage that need to be managed, but most requirements for the inside of your facility, such as mechanical ventilation and explosion venting, can often be eliminated.
Don’t let all of the building code and fire code requirements scare you away from expanding and diversifying into RTD production but don’t underestimate the risks posed by introducing flammable liquids to your facility. There are practical and cost-effective solutions to mitigate the fire and explosion hazards posed by RTD ingredients, and to comply with the requirements of building and fire codes. Some forethought and some help from experts will save you a lot of trouble down the road.
