The storage of wooden and plastic pallets has been a recognized hazard for many for years, but not everyone recognizes the hazard or respects what a pile of pallets can do when they catch on fire. Those that have seen a pallet fire know first hand how quickly things can get out of hand; this is primarily due to their means of construction which allows for great air flow during the fire. The 2018 IFC calls out this storage with several new requirements:
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Combustible pallets are added to the list of stored combustible materials which require a permit.
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Requirements are added to the code for height limitation and separation to buildings and property lines for the outdoor storage of idle pallets constructed of wood or plastic. There are also new pallet storage limitations at pallet recycling and manufacturing facilities.
And these requirements apply to just idle storage of both new and used pallets and both inside and outside. Where we see a lot of serious process hazards is when these piles of new/used pallets find their way next to process vessels, under pipe racks, and next to combustible dust collectors. When these poor inventory management practices are allowed, they can have devastating impacts on our process(s).
Early in my career, I saw first hand what a pile of used wooden pallets could do to an atmospheric storage tank of Toluene. And to add to the misery, the fire was started by contractors doing Hotwork. And sadly an HW permit had NOT been issued as the work was technically “outside” and it was being done “outside of the process battery limits” thus a permit was not required. So we had a contractor doing Type 1 Hotwork (e.g., torch, grinding) right next to a 20′ tall pile of wooden pallets. The results were $300,000 in property damages, and EPA citation for foaming our local creek, and a loss of production for three days (had to be in the millions of lost revenue). As you can imagine, my outlook on HW Permitting was forever changed, as well as my sensitivity to “pallet management” practices.
The 2018 IFC addresses pallet storage in a number of areas:
315.7 Outdoor pallet storage. Pallets stored outdoors shall comply with Sections 315.7 through 315.7.7. Pallets stored within a building shall be protected in accordance with Chapter 32.
315.7.1 Storage beneath overhead projections from buildings. Where buildings are equipped throughout with an automatic sprinkler system, the outdoor storage of pallets under eaves, canopies or other projections or overhangs are prohibited except where automatic sprinklers are installed under such eaves, canopies or other projections or overhangs.
315.7.2 Distance to lot line. Pallet storage shall not be located within 10 feet (3048 mm) of a lot line.
315.7.3 Storage height. Pallet storage shall not exceed 20 feet (6096 mm) in height.
315.7.4 Pallet pile stability and size. Pallet stacks shall be arranged to form stable piles. Individual pallet piles shall cover an area not greater than 400 square feet (37 m2).
315.7.5 Pallet types. Pallets shall be all wood, with slatted or solid top or bottom, with metal fasteners, or shall be plastic or composite pallets, listed and labeled in accordance with UL 2335 or FM 4996. Plastic pallets shall be both solid and gridded deck, independent of the pallet manufacturing process, type of resin used in fabrication or geometry of the pallet.
315.7.6 Pile separation distances. In addition to the other requirements of this section, pallet stacks and piles shall be separated in accordance with Sections 315.7.6.1 and 315.7.6.2.
315.7.6.1 Building separation. Pallet stacks and piles shall be separated from buildings in accordance with Table 315.7.6(1) for wood pallets and Table 315.7.6(2) for plastic pallets.
315.7.6.2 Separation from other pallets and on-site storage. Pallets shall be separated from other pallet piles and other storage in accordance with Table 315.7.6(3) for wood pallets and Table 315.7.6(4) for plastic pallets.
315.7.7 Prohibited locations. Pallets shall not be stored underneath high-voltage transmission lines, elevated roadways or elevated railways.
