There is a misconception that the National Fire Code of Canada applies only to industrial facilities handling bulk volumes of liquids such as refineries or manufacturing facilities. Or perhaps to specialized laboratories with highly flammable or hazardous activities. While those facilities are absolutely regulated under Part 4 of the Fire Code; other less obvious liquids and uses are also regulated.

This includes: the paint thinner used in an art class, the preservatives used in medical facilities, and used motor oils stored in a repair garage. 

I can not count the times that I’ve had someone say something along the lines of – “You must be joking – I need to do WHAT because I have this little bottle of ethanol in this room? You know I have WAY more dangerous stuff in my garage at home, right?”. This response usually follows a brief discussion of the application of Part 4 to a new design project or following a site inspection of an existing building or operation and topics around requirements for ventilation, fire separations, spill control, and ignition source control.

This type of response usually stems from one or two common misconceptions:

1. Small volumes of flammable or combustible liquids are not regulated under the Fire Code, and/or
2. Small volumes of flammable or combustible liquids do not pose a fire hazard.

I’m going to debunk these misconceptions and point the reader to the list of storage activities that ARE exempt from Section 4.2. of the National Fire Code for container storage and handling.

I’m also going to debunk my debunking, for those willing to join this journey.

I would also like to note that there are things that you may undertake in your own home (or garage), that might not be regulated to the same degree that the exact same activity may be regulated when conducted in a working environment that is subject to health and safety regulations. This post is not about those cases.

2015 National Fire Code of Canada – Sentence 4.2.1.1.(2)

Sentence 4.2.1.1.(2) of the National Fire Code states that Section 4.2., “Container Storage and Handling”, does NOT apply to the following (focusing on small container exemptions):

a) bulk plants covered in Section 4.7., refineries covered in Section 4.9. and 

distilleries covered in Section 4.10., 

b) liquids in the fuel tank of motors or engines, 

c) distilled beverage alcohol in closed containers when stored in conformance with 

Part 3, 

d) food and pharmaceutical products when in closed containers having a capacity of 

not more than 5 L, or 

e) products containing not more than 50% by volume of water-miscible flammable 

liquids or combustible liquids with the remainder of the solution being non-flammable, when in closed containers having a capacity of not more than 5 L. 

Just those five exemptions – that’s it.

The above list excludes the large industrial spaces that are otherwise regulated under specific Sections of the Fire Code, and excludes liquids in fuel tanks of vehicles. However, the final three exemptions are quite specific and do not cover many common liquids or applications.

Breaking it down – considering clause (c) – (e) above, we can note that many common consumer goods may be exempt which are typically prepackaged containers not more than 5 L in capacity and which are alcoholic based beverage products (beer, wine, spirits with ethanol), foods or pharmaceuticals (rubbing alcohol used in your home, some hand sanitizing solutions), or are diluted to not more than half of a flammable liquid in water (diluted liquids such as ethanol that are not used for human consumption).

The list above does not exempt most pure, or highly concentrated, flammable or combustible liquids in small containers.

The above debunks myth #1 – small volumes of pure or highly concentrated flammable or combustible liquids ARE regulated under the Fire Code (or to be more specific, they are not exempt). For example, a literal application of Part 4 would regulate 1 mL of acetone, ethanol, methanol, isopropanol, or many other common solvents or liquids.

Tipping Point – How much liquid is too much?

When we consider myth #2 – that small containers do not pose a hazard; the answer is – it depends.

Small volumes of pure solvents may not pose a significant fire or explosion risk – but in certain circumstances those liquids could significantly increase the overall risk of fire associated with an activity. If you don’t believe a risk is present in having 1 mL, what about 1 L, or what about 10 L? How confident are you? A 1 L container of acetone in a large warehouse of consumer commodities will not likely have an impact on the overall fire risk for the warehouse – but that same 1 L container in a small workshop with poor ventilation and a number of potential ignition sources would represent a very different risk profile. 

Expanding on the statement above, a literal application of Part 4 would regulate 1 mL of acetone – but how?

Perhaps a flammable liquid storage cabinet is an easy solution from a storage standpoint.

Perhaps the liquid could be replaced with a non-flammable alternative?

There are numerous solutions and it’s not necessarily a significant burden from a design standpoint. Regardless of the solution selected, the liquid is required to be addressed under Part 4.  

Lesson of the day – do not dismiss small containers of flammable or combustible liquids without digging deeper. A helpful tool in evaluating the application of Part 4 is Sentence 4.2.1.1.(2) of the National Fire Code, regarding storage or handling applications.