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If the street,
sidewalk, or the sewer is NOT to be used for hazardous materials spill
containment, how then is it permissible to incorporate areas typically
used as a means of egress in a building as part of the hazardous material
primary spill containment area? Is it reasonable or prudent for any
Emergency Response/Management Plan to allow direct channeling of hazardous
materials into the aisles and other areas where emergency first responders
can be expected to be during an incident? In fire fighting situations
where a routine tactic is to crawl on the floor, wouldn’t it be prudent to
ensure spill containment is NOT part of the areas where persons may find
themselves during normal and emergency operations?
Using egress
aisles as part of lead-acid battery spill management systems is now a
reality with more presently being planned for and installed. Morning Star
has learned there are facilities in at least one major industry that are
incorporating Uniform Fire Code™ (UFC) Article 64 as an alternate method
to Article 80 for lead-acid batteries by defining the entire room,
including the aisles, as the containment area. Morning Star believes there
is no reasonable and prudent Emergency Response/Management Plan that could
utilize an arrangement where an extremely hazardous substance, sulfuric
acid, is permitted in areas where the emergency first responders may be
standing or crawling.
While UFC
Article 64 does require "… a liquid-tight 4-inch (101.6 mm) spill-control
barrier which extends at least 1 inch (25.4 mm) beyond the battery rack in
all directions," we understand the intent of the 1 inch extension was for
the dripping acid to fall within the containment base. We further
understand UFC Article 64 is intended to be in harmony with other parts of
code. This harmony includes UFC Section 1203 which states "Means of egress
shall not be obstructed in any manner and shall remain free of any
material or matter where its presence would obstruct or render the means
of egress hazardous."
In our opinion,
incorporating full or partial room spill containment for lead-acid battery
systems is unacceptable and is not to code. We recommend all installations
incorporating this sort of containment be corrected and that no additional
similar installations be permitted. |
