The International Fire Code has another version of OSHA’s and EPA’s General Duty Clause. It is 5001.3 Performance-based design alternative. The code contains 18 elements that very closely mirror OSHA’s PSM and EPA’s RMP requirements, but the BIG DIFFERENCE is that the code makes no mention of quantities/thresholds!
The rule applies to all hazardous materials, including those materials regulated elsewhere in this code, except that when specific requirements, exceptions, or exemptions are provided in other rules, those specific requirements shall take precedence over the similar requirements of this rule. Where a material has multiple hazards, all hazards shall be addressed.
One interesting exemption from these requirements is “Refrigeration Systems”. Be sure to check your state Fire and HAZMAT codes to see if your state has these type of requirements, even though the quantities are not enough to trip PSM/RMP requirements. Here are the Ohio requirements:
1301:7-7-27 Hazardous materials-general provisions
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(3) 2701.3 Performance-based design alternative. When approved by the fire code official, buildings and facilities where hazardous materials are stored, used or handled shall be permitted to comply with this paragraph as an alternative to compliance with the other requirements set forth in this rule, and rules 1301:7-7-28 to 1301:7-7-44 of the Administrative Code.
(a) 2701.3.1 Objective. The objective of paragraph (A)(3)(2701.3) of this rule is to protect people and property from the consequences of unauthorized discharge, fires or explosions involving hazardous materials.
(b) 2701.3.2 Functional statements. Performance-based design alternatives are based on the following functional statements:
(i) Provide safeguards to minimize the risk of unwanted releases, fires or explosions involving hazardous materials.
(ii) Provide safeguards to minimize the consequences of an unsafe condition involving hazardous materials during normal operations and in the event of an abnormal condition.
(c) 2701.3.3 Performance requirements. When safeguards, systems, documentation, written plans or procedures, audits, process hazards analysis, mitigation measures, engineering controls or construction features are required by paragraphs (A)(3)(c)(i)(2701.3.3.1) to (A)(3)(c)(xviii)(2701.3.3.18) of this rule, 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.
2701.3.3.1 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.
2701.3.3.2 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.
2701.3.3.3 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.
2701.3.3.4 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.
2701.3.3.5 Ignition Hazards. Safeguards shall be provided to minimize the risk of exposing combustible hazardous materials to unintended sources of ignition.
2701.3.3.6 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.
2701.3.3.7 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.
2701.3.3.8 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.
2701.3.3.9 Reliable Power Source. Where a power supply is relied upon to prevent or control an emergency condition that could endanger people or property, the power supply shall be from a reliable source.
2701.3.3.10 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.
2701.3.3.11 Process Hazard Analyses. Process hazard analyses shall be conducted to ensure reasonably the protection of people and property from dangerous conditions involving hazardous materials.
2701.3.3.12 Pre-startup Safety Review. Written documentation of pre-startup 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 participation of affected employees.
2701.3.3.13 Operating and Emergency Procedures. Written documentation of operating procedures and procedures for emergency shut down 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 participation of affected employees.
2701.3.3.14 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.
2701.3.3.15 Emergency Response Plan. A written emergency response 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.
2701.3.3.16 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.
2701.3.3.17 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.
2701.3.3.18 Safety Audits. Safety audits shall be conducted on a periodic basis to verify compliance with the requirements of this paragraph.