The 1997 Uniform Fire Code™ has
added Article 64 - Stationary Lead-acid Battery Systems to its code. This code is adopted
as law in about half of the United States. BOCA Code in the Northeast section of the
United States has similar requirements. Since battery systems are classified as
constituting a distinct hazard to life or property, there is no "grandfathering"
or exempting this requirement.
Before addressing the Uniform Fire
Code ™ (UFC) Article 64, it should be noted that even in the 1980’s, UFC Article
80 required spill management of battery systems totaling 17 gallons or more. Article 80
specifically requires a liquid-tight recessed or raised sill of a minimum height of 4
inches when the toxic aggregate quantity exceeded approximately 17 gallons of battery
electrolyte.
Sulfuric acid battery electrolyte is
classified as both a physical and health hazard. Specific classifications include:
Oxidizer - Class 1
- Water
Reactive - Class 1
- Carcinogen
- Corrosive
- Toxic
- Other
Health Hazards
Since it is estimated there are well
over 100,000,000 gallons of sulfuric battery acid already within "business"
classified buildings, the probability times seriousness of exposure to occupants and
emergency responders dictates risk minimization actions such as the implementation of UFC
Article 64. Provisions of UFC Article 80, and now UFC Article 64, is not only justified,
it is the law.
Permits (’97 UFC Section 105)
"… constitutes permission to maintain, store, use or handle materials, or to
conduct processes which produce conditions hazardous to life or property, or to install
equipment used in connection with such activities." Lead-acid batteries fall under
the permitting process by way of two specific categories, Hazardous Materials (’97
Section 105.8.h.1) and Battery System (’97 Section 105.8.b.1). Since permitted
functions are by definition hazardous to life or property, battery systems, by definition,
constitute a distinct hazard to life and property.
Referring to ’97 UFC Section 102
entitled "Retroactive Application to Existing Conditions," we see there are
three criteria that address retroactive application. They are:
- Conditions
arising after the adoption of the requirement of spill management
- Conditions
not legally in existence at the adoption of this code
- Conditions
that constitute a distinct hazard to life or property.
Conditions arising after the adoption
of the requirement are well understood by the industry. Usually the building permitting
process will surface the need of conformance to code.
Conditions not legally in existence at
the adoption of specific code addressing spill management means to the author that even if
the existing installations do not have spill management systems in place, if the
conditions arose in the 80’s of latter, they are not legal installations without UFC
Article 80 spill management provisions.
Conditions that constitute a distinct
hazard to life or property are by definition battery systems and, therefore, require
retroactive application to existing conditions.
The above requirements are for
building and fire code. Additional similar requirements found under the Occupational
Safety and Health Act and other environmental acts are applicable. If there is no spill
management provisions in place for battery system, there is low probability that a
reasonable and prudent emergency management plan is in place. If there is no emergency
management plan in place, there is lower probability that the battery hazardous materials
have been reported under provisions of the Emergency Planning and Community Right-To-Know
Act (EPCRA). If proper reporting has not been done under the provisions of EPCRA, then the
State Emergency Response Commission, Local Emergency Planning Committee, and the local
fire department having jurisdiction have not been formerly alerted to the safety, health,
and environmental issues and, therefore, have been denied the opportunity to plan for
emergency situations that may arise from the presence of these reportable lead-acid
battery systems.
In summary, implement UFC Article 64
in all applicable battery systems. The downside risk in terms of employee, emergency
responder, and community safety and health and the potential effects on the environment
far exceeds the relative minimal cost of implementation. |
