I am working with a client who is making every effort to comply with the Maximum Allowable Quantity (MAQ) limits for a flammable liquid process area. This process is a PSM-covered process, so I offered up how to work beyond the MAQ of 480 gallons1 for a fire control area. This compliance option 5001.3 was officially introduced in the 2015 edition of the IFC; however, a version of it first appeared in the IFC as Section 2701.3. This option is in NO WAY taking a shortcut to code compliance; it is simply a means for businesses to use OSHA’s PSM and EPA’s RMP management system and all the process RAGAGEPs in lieu of complying with Chapters 50-67.
Bottom Line… under the “Performance-based design alternative,” we should NOT have an MAQ. Let me explain.
Here is the “commentary” from the 2024 IFC regarding the “Performance-based design alternative,” explaining how PSM/RMP drove the creation of 5001.3 Performance-based design alternative.
The purpose of a performance-based design alternative is to promote innovative, flexible, and responsive solutions that optimize the expenditure and consumption of resources while preserving social and economic value. The model codes, including the International Codes® (I-Codes®), have traditionally incorporated alternative materials, designs and methods of
construction provisions, such as those found in Section 104.10. This section provides a framework and opportunity to use new materials, means, and methods where design equivalence to the prescriptive requirements of the code can be demonstrated to and approved by the fire code official.
For example, large chemical manufacturing and production facilities are typically required to comply with federal risk management plans (RMP) and process safety management (PSM) requirements, which, when properly implemented, can provide levels of safety greater than the prescriptive requirements in this code. This section is intended to be compatible
with federal RMP and PSM programs, so it would reduce the burden of having to comply with duplicative or conflicting local and federal regulations. However, in order to meet the requirements of this code, performance-based design alternatives must provide a level of safety equal to or greater than the prescriptive code requirements.
Because performance-based approaches are already in widespread use in order to comply with federal laws regulating chemical storage and handling facilities, this section provides a means to begin phasing performance-based design concepts into the code. While Section 5001.3 may appear to represent a huge loophole for the industry to avoid compliance with the code’s prescriptive requirements, this is not the case. The provisions within this section are duplicated from within Chapter 22 of the International Code Council Performance Code® for Buildings and Facilities (ICCPC®). The chapter was developed by trying to incorporate federal RMP and PSM regulations and then looking through the code’s prescriptive hazardous materials regulations to pick up topics that appeared to have been overlooked.
The text of this section was developed through a cooperative effort of fire officials and industry representatives in the IFC Performance Code Development Forum. Those who worked on the text believed that compliance with the proposed provisions would yield a facility that would be at least as safe, if not safer, than a facility constructed in accordance with the code’s prescriptive requirements.
It is true that the use of a performance-based design approach will likely require a tremendous amount of effort on the part of a permit applicant to demonstrate code compliance to local fire code officials. However, for those who might not use the performance-based design approach in its entirety, the performance objectives outlined herein greatly assist code users when seeking to apply alternative methods to unique facilities or operations by better defining the intent of the code.
See the ICCPC and its “User’s Guide” for a more comprehensive discussion of performance-based design concepts and philosophy.
- The baseline MAQ for a Flammable Liquid is 120 gallons, which we can DOUBLE that to 240 gallons if the building is sprinkled throughout, which we can DOUBLE this again to 480 gallons with the use of Flammable Storage Cabinets. ↩︎