Chemicals can be intimidating – what hazards do they represent? How should I protect occupants from these hazards? How do I mitigate risks in a building used for chemical storage? As a Fire Code practitioner with a degree in Chemical Engineering – I find myself overwhelmed at times. However, I have learned a few helpful tools that I consider when applying the National Fire Code of Canada (NFC), specifically NFC Subsection 3.2.7., “Indoor Storage of Dangerous Goods”, that I will share in this post to help you to navigate a few of these concerns and to determine how many storage rooms you may require.

To be clear, I’m not going to outline how all chemicals are classified, or how to manage the risks associated with each classification of dangerous goods, or provide a detailed guide on the application of the NFC or related provincial Fire Codes to dangerous goods. This post is going to focus on what I consider to provide the roadmap to the overall regulation of dangerous goods storage activities in buildings: NFC Table 3.2.7.1., “Small Quantity Exemptions for Dangerous Goods”, and NFC Table 3.2.7.6., “Separation Chart for Storage of Dangerous Goods”.

The tables are included below – however, the notes associated with the tables are not included. Please always check the source material when applying the Codes.

I find myself referencing these two Tables, time and time again. In combination, the Tables function as fairly simple tools to assist a designer or authority in determining the following:

• Based on the amount of dangerous goods, or controlled substances, present in a facility, are special protection measures required under the NFC (Table 3.2.7.1.), and
• Can certain combinations of these dangerous goods, or controlled substances, be stored together (Table 3.2.7.6.)?

With this information – you can determine the number of storage rooms and fire compartments that are needed to house the storage of dangerous goods in a building, and the requirements of NFC Subsection 3.2.7. that apply to each room.

These tables are useful when I’m evaluating various projects including: laboratory spaces, chemical storage rooms, industrial manufacturing or processing facilities, and waste handling sites, for example. While any amount of a dangerous good will represent a certain level of risk, there are specific quantity thresholds outlined in the NFC to which prescriptive construction and operational requirements will apply.

I recommend that the following review sequence be applied to establish how many storage rooms or fire compartments will be required for a project that involves the storage of dangerous goods:

1. Classify all of the dangerous goods, or controlled substances, that need to be stored in the building or property [use the Safety Data Sheets (SDS) and reference the Transportation of Dangerous Goods Regulations (SOR/2001-286) – see Schedule 1 https://laws-lois.justice.gc.ca/eng/regulations/SOR-2001-286/page-46.html#h-1230877].
2. Compile an inventory of the total mass or volumes of each type of dangerous good, or controlled substance and separate each of the dangerous goods based on their Class and Division.
3. Using NFC Table 3.2.7.1., identify which, if any, of your dangerous goods exceed the “Maximum Exempt Amount of Stored Product” (Column C). For example, if you have less than 100 kg of Class 5, Division 2, Organic Peroxides (Class C, WHMIS), then the storage of those materials is NOT regulated under NFC Subsection 3.2.7. [check out NFC Sentence 3.2.7.1.(2)].
4. Once you’ve established if your storage activities are regulated, then use NFC Table 3.2.7.6. to determine if the chemicals are permitted to be stored in a common storage room, or if they are required to be segregated using horizontal distance separations or fire separations.
5. Once you have determined the number of storage rooms required, then the requirements of NFC Subsection 3.2.7. can be applied to each storage room or fire compartment, based on the chemicals permitted to be stored together.

Using these five steps, you’ve now determined how many storage rooms, if any, are required to be constructed for your project. With this information, the facility layout, operational requirements, and room construction may be established through the application of NFC Subsection 3.2.7. 

This isn’t the entire picture, but hopefully, with this guide you can navigate the application of NFC Subsection 3.2.7. with greater confidence and assess if a storage activity in a building is required to be located in a dedicated storage room and if specific combinations of chemicals are permitted. 

For the history lovers:

These two Tables were updated in the most recent revision to the NFC (2015 edition) to include references to categories and classifications of controlled products as described in WHMIS. However, the framework and principles presented in the Tables have remained fairly consistent since they were first introduced in the 1990 edition of the NFC. Prior to that, the requirements for dangerous goods were outlined in Part 5, but they were presented in traditional written statements based on the material classification – no tabular tool was provided.