Crossposted from: The Collaborative Biodiesel Tutorial
by Dave Andreas
Dave has over 15 years as a firefighter-paramedic, HazMat Specialist, and Fire Inspector.
This is his perspective on dealing with the local authorities.
Notes From the Firehouse
Fire departments are dynamic organizations that are currently under a barrage of competing tasks. Increasing emergency call volume, regulatory compliances, unfunded mandates from county, state and federal authorities coupled with budget cuts all result in limited time to handle inspections and more routine functions.
That said, most fire marshals are still acutely aware of the growing interest in progressive technologies and the effects on fire safety and protection. Believe me, no fire marshal wants to entertain a question from the mayor as to how it was allowed to have a 1000 gallon tank of (insert your favorite chemical here) in "plain view" of somebody's house. Worse is when an engine company responds to a fire in a garage that contains 1000 times the combustible load expected and people get killed or injured. The prevailing philosophy in those conditions would be to simply "forbid" the whole deal and make you prove otherwise in someone's appeals court. Yipes!
Most of the discussion to date, on the fire protection listservers discuss the following common denominators:
- Biodiesel has no tangible MSDS - there is the soy product MSDS that is talked about. Result - convince the fire marshal that your storage is "benign" However nobody really agrees on a standard MSDS.
- Biodiesel (B100) is considered a class IIIb combustible liquid -
That's good in that it reduces a large amount of regulatory requirements on the larger biodieselers and coops
- Methanol and/or Ethanol are considered more hazardous and like Terry correctly stated is limited (by many juristictions) to (2) 5 gallon containers similar to gasoline.
- NaOH and/or KOH are considered caustics and may be limited to "reasonable" quantities - again that word is definable by the AHJ (authority having jurisdiction - read fire marshal)
- Tallow/grease/wvo are all considered - well I'm not sure, each jurisdiction can probably define it as they like. Most likely determined by the county hazmat coordinator or waste manager.
- Building codes vary from location to location - You might see BOCA, ISO, UBC, UFC or "special other" used by the agency that serves your location. Don't expect that what one group is doing is ok in your area - using the excuse that "its done everywhere else" is guaranteed to get MY fire marshal cranky.
- There is never any excuse to cut corners, take short cuts or ignore good safety rules and common sense. I say this because it applies in ALL areas that I have been involved with - not just folks interested in biodiesel. You would truly be amazed by what some people or businesses do in the absence of fire safety concerns.
Some agencies love to inspect the %&^$ out of you and your process and other agencies don't even seem to care. This, I guess, relates a little bit to #6. You might be careful, though, evoking the name of another coop to your local FM to justify your actions, though. You can EXPECT your FM to contact the other jurisdiction for background info, problems, caveats, special considerations etc. that may unintentionally make the other coop life more difficult.
- Some agencies don't even WANT to know what you're doing. This is hard for me to believe but I have unofficially heard it from a couple of HM regulatorory people.
This pretty much sums up what I have heard in my limited arena. My list is not guaranteed to be absolute in all jurisdictions, nor is expected to be even complete.
Finally my recommendations on what to do BEFORE beginning discussions with the local fire department:
- Make a careful safety analysis
- Build/assemble each component to NEC or appropriate "universal" codes. (i.e. use explosion proof equipment wher indicated etc)
- Label all chemicals and identify MSDS in a professional manner. An emergency of any kind is not the time for an engine company or paramedic to determine what is going on in your operation.
- Keep a fire extinguisher handy - 2A10BC minimum, preferably a couple in opposite corners of your installation.
- Consider "secondary containment" for spills of WVO, BD and any other liquids. Personally, I LOVE epoxy paint for this application and recommend it to people in my district that store any quantity of diesel (no BD yet)
- Consider "overpack precautions" for dry chemicals. Yes, anybody from fire or hazmat will consider KOH and NaOH to be hazardous. The amount they will allow may be based upon your storage methods. I would probably like to see in a poly type drum approved for such storage.
- ALWAYS use eye and respiratory protection - make it painfully obvious in your installation where it is. Other safety equipment should be nearby also.
Limit access. Dogs/cats/birds/kids/burglars etc.
- Limit smoking/food consumption of any kind.
- Make a site map and laminate it for quick reference to emergency responders. I would love to see things like nearest fire hydrant, phone numbers for neighbors, emergency contacts etc on this.
- Keep other combustibles away from your installation. Dry grass, weeds, wood storage, diapers (biomass?) etc. should be kept to a minimum around the work area.
- I recommend a covered, non-attached (to your dwelling) outdoor, non-combustible (concrete/block wall etc) area for working. A working water spigot, and emergency phone would also be awesome.
- When dealing with a fire department it is always best to handle a problem or a question on the lowest possible level first. If you start getting the "white helmets" at an early stage, you may have your project cancelled before it gets started. But at the "engine company" level you build a rapport with the agency and more importantly recruit advocates to your cause. The advocates are those engine company captains that you have shown respect and interest in their safety expertise. They also get a very clear message that you are actually concerned with THEIR welfare by including them in safety preplanning efforts and reduction of hazards that they are paid to care about. With so many citizens either complaining or trying to "fly under the radar" a straightforward approach is almost always to be greeted favorably. If it is appropriate, those captains can "go to bat" for you and convince the "white helmets" that your project is legitimate, worthwhile, and not an unreasonable hazard to the community.
This is what I would do BEFORE I discussed these things with my fire department. I live in a different jurisdiction than I work, but still know all the players. In fact, this is what I plan to do on my own BD installation. I will probably even go a little farther in my recommendations because it would look bad for my community to see a great big fire happen at my house, with burning flammable liquids running into the creek leading to the church kiddies playground (ok - I'm a real pessimist). Of course, I'm supposed to know better Wink.
In closing, I would also contact my nearest fire station (not fire department). I would bring in my site map, msds and any articles relating to BD that I could. I'd make an appointment with the station captain and invite the crew over to inspect my installation. I'm not so sure that they would take that badly. They also have limited jurisdiction of what a private individual can and cannot do in their own home. Unless they see something that is flagrantly dangerous they will probably shrug their shoulders and thank you for the interest. Remember, they are the pros and might spot something that isn't safe that can be cleaned up or mitigated quickly. They also have the resources to help you research a safer way. You might even find a couple of friendly diesel enthusiasts right there!
I am a big proponent of personal privacy and rights. However, I am just as big a proponent of safety and responsibility to one's neighbors and environment. It also keeps you honest about what you are doing - if you don't want to show it to your fire department, then maybe you better think about why not.