Do you have an accurate, up-to-date inventory of the hazardous materials and chemicals within your organization? And are all of those materials properly classified? More specifically, are these materials classified for fire code?
Fire code classification long has been considered one of the more complex and confusing aspects of OSHA’s Hazard Communication Standard (HCS), which requires hazardous materials in the workplace to be labeled, ensuring that all hazards associated with the items are communicated to the employees. Each item in your inventory must be assigned a National Fire Protection Agency (NFPA) classification and a Hazardous Material Identification System (HMIS) rating.
NFPA offers a system for identifying the hazards of a chemical that was developed with the needs of fire protection agencies in mind. Your local fire department may require you to provide this information along with your chemical inventory. The HMIS rating was developed by the National Paint and Coatings Association to quickly help identify the hazards associated with a given material. There are other classification regulations that also may be needed when classifying hazardous materials, such as the International Fire Code (IFC), 29 CFR, etc.
Challenges in Fire Code Classification & Labeling
Fire code classification is unique in that there are many outside factors and agencies to consider when labeling chemicals and products. One of the challenges most often seen in fire code labeling assigns the correct classification, while taking into account the different definitions and related hazards of the independent agencies and labeling methods and how different they can be.
A great example of this is the classification of flammable solids. Flammable solids are defined by the 29 CFR as being a solid “other than a blasting agent or explosive as defined in 1910.109(a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard.” We then reference the definition per NFPA, which states: “Solid materials in a fibrous or shredded form that burn rapidly and create flash fire,” as well as: “Solids containing greater than 0.5 percent by weight of a flammable or combustible solvent are rated by the closed flash point of the solvent.”
As you can see, the descriptions vary between regulatory authorities. Where one instance may include items such as cotton balls and fibrous organic material, the others only may consider the material flammable if it meets specific criteria obtained through detailed individual tests, or if the material is soaked in solvents that are considered flammable or combustible in liquid form.
Another hurdle frequently faced by many companies today is the ability for each individual jurisdiction (state, county, city, etc.) to apply their own unique requirements on top of, or in place of, the federal OSHA standards. For example, you may have a county fire prevention department require that all reporting use the IFC, while a city fire department in another state requires that you classify the same product per the NFPA classifications.
A Complex Undertaking
While ensuring that the appropriate classifications are applied to the variety of hazardous products and materials certainly is a complex undertaking, there are a few things that you can do to simplify the process:
The first priority, especially if submitting a required report to a fire department or hazardous materials authority, would be to ensure that you are using the correct classification rules and standards (IFC, NFPA, HMIS, etc.), as well as the appropriate year of the required classification standard.
Another important step in providing accurate classification would be to ensure the item has been classified per the most recent information. Whether using transcribed information provided to you by the manufacturer, or conducting more specific and perhaps more accurate classification yourself, ensure that you are referencing the most current material safety data sheet (MSDS). Manufacturers update MSDSs continuously, and in doing so a lot of times the data provided for the product can change as well. This often will result in the need for more updated classification information.
As a classification specialist with 3E Co, Sean Nix ensures that customers’ products are properly classified to facilitate regulatory compliance. Nix has a BA in environmental studies and holds positions in 3E’s regulatory and classification departments.