Since 2003, the International Fire Code has offered an “alternative” to complying with all the special hazard chapters of the “code”; it’s called the Performance-Based Design Alternative (PBDA). This alternative was intended to provide some relief to facilities that are already doing PSM/RMP style activities for their hazardous material(s) and to provide an IMPROVED alternative to following the prescriptive design requirements found in the Code chapters.
2012 Chapter 50, Hazardous Materials-General Provisions states…
5001.3 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 section as an alternative to compliance with the other requirements set forth in this chapter and Chapters 51 through 67.
(Please note Chapters 51 – 67 are the chemical specific hazards such as Aerosols, Combustible Fibers, Compressed Gases, Corrosive Materials, Cryogenic Fluids, – Explosives and Fireworks, Flammable and Combustible Liquids, Flammable Gases and Flammable Cryogenic Fluids, Flammable Solids, Highly Toxic and Toxic Materials, Liquefied Petroleum Gases, Organic Peroxides, Oxidizers‚ Oxidizing Gases and Oxidizing Cryogenic Fluids, Pyrophoric Materials, Pyroxylin (Cellulose Nitrate) Plastics, Unstable (Reactive) Materials, Water-Reactive Solids and Liquids)
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.
When 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.
The eighteen (18) sections closely mirror those in OSHA’s PSM and EPA’s RMP:
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 upon 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 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 the participation of affected employees.
5001.3.3.13 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 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.
However, PLEASE do not think that following this code in any way meets our obligations under PSM and RMP. The alternative is intended to be an ALTERNATIVE to complying with all the HAZMAT codes if you do the PBDA for your hazardous materials. So basically the IFC is telling us that if our HAZMATs are being managed per PSM/RMP type programs then we do NOT have to comply with all the specifics in the IFC.
With all that said, I personally feel the IFC, IMC, and IBC are GREAT BASELINE CODES from which we build our PSM/RMP programs upon. I suggest we view the IFC and the State Codes as our first building block to managing ALL of our hazardous materials and when we have quantities on site that exceed the PSM/RMP thresholds we ADD ANOTHER LAYER by complying with PSM/RMP. But for those HAZMATs that are NOT PSM/RMP listed chemicals, this PBDA is a GREAT way to take manging our HAZMATs to the next level.