For several editions, the IFC has incorporated a “Performance-Based Design Alternative” to comply with the requirements of Part V—Hazardous Materials (Chapters 50-67). This was initially added so that facilities already doing PSM/RMP could show compliance with the state fire code without any additional work. In the 2021 edition of the IFC, this alternative has been expanded to include some new management system elements that, in my professional opinion, puts this SMS over and above PSM/RMP. If only OSHA or EPA would recognize this alternative SMS. Here are the elements and their requirements (FREE ACCESS):
5001.3 Performance-based design alternative
Where approved by the fire code official, buildings and facilities where hazardous materials are stored, used or handled shall be permitted to comply with this section as an alternative to compliance with the other requirements set forth in this chapter and Chapters 51 through 67.
5001.3.1 Objective
The objective of Section 5001.3 is to protect people and property from the consequences of unauthorized discharge, fires or explosions involving hazardous materials.
5001.3.2 Functional statements
Performance-based design alternatives are based on the following functional statements:
1. Provide safeguards to minimize the risk of unwanted releases, fires or explosions involving hazardous materials.
2. Provide safeguards to minimize the consequences of an unsafe condition involving hazardous materials during normal operations and in the event of an abnormal condition.
5001.3.3 Performance requirements
Where safeguards, systems, documentation, written plans or procedures, audits, process hazards analysis, mitigation measures, engineering controls or construction features are required by Sections 5001.3.3.1 through 5001.3.3.18, the details of the design alternative shall be subject to approval by the fire code official. The details of actions granting the use of the design alternatives shall be recorded and entered in the files of the jurisdiction.
5001.3.3.1 Properties of hazardous materials
The physical- and health-hazard properties of hazardous materials on-site shall be known and shall be made readily available to employees, neighbors, and the fire
code official.
5001.3.3.2 Reliability of equipment and operations
Equipment and operations involving hazardous materials shall be designed, installed and maintained to ensure that they reliably operate as intended.
5001.3.3.3 Prevention of unintentional reaction or release
Safeguards shall be provided to minimize the risk of an unintentional reaction or release that could endanger people or property.
5001.3.3.4 Spill mitigation
Spill containment systems or means to render a spill harmless to people or property shall be provided where a spill is determined to be a plausible event and where such an event would endanger people or property.
5001.3.3.5 Ignition hazards
Safeguards shall be provided to minimize the risk of exposing combustible hazardous materials to unintended sources of ignition.
5001.3.3.6 Protection of hazardous materials
Safeguards shall be provided to minimize the risk of exposing hazardous materials to a fire or physical damage whereby such exposure could endanger or lead to the endangerment of people or property.
5001.3.3.7 Exposure hazards
Safeguards shall be provided to minimize the risk of and limit damage from a fire or explosion involving explosive hazardous materials whereby such fire or explosion could endanger or lead to the endangerment of people or property.
5001.3.3.8 Detection of gas or vapor release
Where a release of hazardous materials, gas, or vapor, would cause immediate harm to persons or property, means of mitigating the dangerous effects of a release shall be provided.
5001.3.3.9 Reliable power source
Where a power supply is relied on to prevent or control an emergency condition that could endanger people or property, the power supply shall be from a reliable source.
5001.3.3.10 Ventilation
Where ventilation is necessary to limit the risk of creating an emergency condition resulting from normal or abnormal operations, means of ventilation shall be provided.
5001.3.3.11 Process hazard analyses
Process hazard analyses shall be conducted to ensure reasonably the protection of people and property from dangerous conditions involving hazardous materials.
5001.3.3.12 Prestartup safety review
Written documentation of prestartup safety review procedures shall be developed and enforced to ensure that operations are initiated in a safe manner. The process of developing and updating such procedures shall involve the participation of affected employees.
5001.3.3.13 Operating and emergency procedures
Written documentation of operating procedures and procedures for emergency shutdown shall be developed and enforced to ensure that operations are
conducted in a safe manner. The process of developing and updating such procedures shall involve the participation of affected employees.
5001.3.3.14 Management of change
A written plan for management of change shall be developed and enforced. The process of developing and updating the plan shall involve the participation of affected
employees.
5001.3.3.15 Emergency plan
A written emergency plan shall be developed to ensure that proper actions are taken in the event of an emergency, and the plan shall be followed if an emergency condition occurs. The process of developing and updating the plan shall involve the participation of affected employees.
5001.3.3.16 Accident procedures
Written procedures for investigation and documentation of accidents shall be developed, and accidents shall be investigated and documented in accordance with these procedures.
5001.3.3.17 Consequence analysis
Where an accidental release of hazardous materials could endanger people or property, either on- or off-site, an analysis of the expected consequences of a plausible release shall be performed and utilized in the analysis and selection of active and passive hazard mitigation controls.
5001.3.3.18 Safety audits
Safety audits shall be conducted on a periodic basis to verify compliance with the requirements of this section.