EPA’s RMP Emergency Drills vs. International Fire Code Drill Requirements

The EPA’s revisions of its Risk Management Plan requirements regarding emergency drills have gotten much attention.  However, they were always a bit behind when it comes to the International Fire Code.  And need I remind those of you reading this that many states have adopted the IFC in some form.

A Group H occupancy is defined as:

Group H, High-hazard. High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials that constitute a physical or health hazard in quantities in excess of those allowed in control areas complying with Section 5003.8.3, based on the maximum allowable quantity limits for control areas set forth in Tables 5003.1.1(1) and 5003.1.1(2). Hazardous occupancies are classified in Groups H-1, H-2, H-3, H-4 and H-5 and shall be in accordance with this code and the requirements of Section 415 of the International Building Code. Hazardous materials stored or used on top of roofs or canopies shall be classified as outdoor storage or use and shall comply with this code.

Here is what a facility that has Group H occupancies has to meet:

403.6 Group H occupancies

An approved fire safety and evacuation plan in accordance with Section 404 shall be prepared and maintained for Group H occupancies.

403.6.1 Group H-5 occupancies.

403.6.1.1 Plans and diagrams.

In addition to the requirements of Section 404 and Section 407.6,

1) plans and diagrams shall be maintained in approved locations indicating the approximate plan for each area;

2) the amount and type of HPM stored, handled and used;

3) locations of shutoff valves for HPM supply piping;

4) emergency telephone locations and locations of exits.

403.6.1.2 Plan updating.

The plans and diagrams required by Sections 404, 403.6.1.1, and 407.6 shall be maintained up-to-date and the fire code official and fire department shall be informed of major changes.

403.6.1.3 Emergency response team.

Responsible persons shall be designated as an on-site emergency response team and trained to be liaison personnel for the fire department. These persons shall aid the fire department in

1) preplanning emergency responses,

2) identifying locations where HPM is stored, handled and used, and

3) be familiar with the chemical nature of such material. An adequate number of personnel for each work shift shall be designated.

403.6.1.4 Emergency drills.

Emergency drills of the on-site emergency response team shall be conducted on a regular basis but NOT LESS THAN once every three months.

Records of drills conducted shall be maintained.

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