I am working on a code evaluation project and the client had a different interpretation (more strict) that I did so I reached out to the Ohio Fire Marshal to settle the discussion.  The question arose as to how much flammable solid(s) can one store without having to raise the occupancy classification to an "H".  TABLE 307.1, Maximum allowable quantity per control area of Hazardous materials posing a physical hazard allows for 125 pounds of flammable solid per control area; however, this comes with two (2) footnotes which allow more than 125 pounds under certain conditions and when BOTH conditions are met, even more can be stored...

Notes "d" and "e" state the following: (emphasis by me)

The state and federal political climate is just crazy these days!  We now have one of our original 13 colonies claiming they have a constitutional right to manage their state EPCRA program as they see fit and not how Federal EPA believes it should be managed and how their own 2015 Manual said it was to be managed.  The state of NJ, in some strange interpretation, have come to believe that the Emergency Planning and Community RIght-to-Know Act (EPCRA) does not require the state to release the chemical information to the "communities".  You just can not make this stuff up and good tax money is being wasted in courts to argue the "intent" of EPA's EPCRA rule.  In their lawsuit, the plaintiff's claim the State of NJ's  State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC) in Linden, NJ has failed to publicly disclose facility emergency response plans (ERPs) as required under EPCRA. The state has responded and argues that EPCRA only requires states to set up a system for industrial facilities to release information to LEPCs - but not for the state officials on a SERC to require the local planners to disclose the data to the public.  Now, remember, the name of this Act is the Emergency Planning and Community RIght-to-Know Act (EPCRA).  To show how this is just politics as usual here is the State of NJ's own EPCRA compliance manual - pay close attention to pages 8-11.  Here is the arguments put forth...

The 2017 Ohio Fire Code has been validated by JCARR and will become effective on Dec. 15.  The 2017 version of the Ohio Fire Code is essentially the International Code Council’s 2015 International Fire Code with the incorporation of certain relevant provisions of that code.  Education opportunities on the new code will be available in spring 2018.  Except as otherwise provided in paragraph (B)(1)(b) (102.1.2) of this rule, the construction and design provisions of this code shall apply to: (emphasis by me)

Those of you that follow me know my love for the International Fire Code and Mechanical Code, as well as how each state utilizes these codes.  I use these codes daily in my process safety and fire safety work as I truly believe they provide us an excellent baseline in our risk reduction efforts.  This year the state of OH has been working to revise it's state fire code to the newer IFC 2015.  This process has been very educating to me in a number of ways, but mostly from reading the comments/concerns brought forward by the commenters.  One such concern was one that I have been an unknowing party to for decades and one I am quite embarrassed to admit I never even considered.  Take a look at these pictures and tell me what you see:

gym1  Gym2

In the past several weeks I have received inquiries regarding NFPA 704, 4.2.3.2 so I figured I should put it in writing so that others can understand this single clause which apparently has become a “whipping boy” for a particular hazardous material. The quick answer is YES, but apparently, there is some confusion on why NFPA 704, 4.2.3.2 permits this. This is what it says:

4.2.3.2* It shall be anticipated that different physical forms of the material or conditions of storage and use could result in different ratings being assigned to the same material.

*Due to the large number of variables, the requirements and guidance presented in this standard are general in nature and are limited to the most important and common factors. For example, although ‰ash point is the primary criterion for assigning the ‰flammability rating, other criteria could be of equal importance. For example, autoignition temperature, ‰flammability limits, and susceptibility of a container to failure due to †fire exposure also should be considered. For instability, the emphasis is on the ease by which an energy releasing reaction is triggered. These factors should all be considered when calling on one's judgment during the assignment of ratings.

 

In reality, the same material may have different ratings based on where it is in the process. For example:

 
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