Laboratories that are not Laboratories

I must get a dozen questions a year about what NFPA 45 Fire Protection for Laboratories covers. In section 1.1.3 NFPA 45 notes that it does not cover the following:

(1)* Laboratories for which the following conditions apply:

(a) Laboratory units that contain less than or equal to 4 L (1 gal) of flammable or combustible liquid

(b) Laboratory units that contain less than 2.2 standard m3 (75 scf) of flammable gas, not including piped-in low-pressure utility gas installed in accordance with NFPA 54

(2)* Pilot plants

(3) Laboratories that handle only chemicals with a hazard rating of 0 or 1 for all of the following: health, flammability, and instability, as defined by NFPA 704

(4) Laboratories that are primarily manufacturing plants

(5) Incidental testing facilities

(6) Physical, electronic, instrument, laser, or similar laboratories that use chemicals only for incidental purposes, such as cleaning

(7)* Hazards associated with radioactive materials, as covered by NFPA 801

(8) Laboratories that work only with explosive material, as covered by NFPA 495

(9)* A laboratory work area containing an explosion hazard great enough to cause property damage outside that laboratory work area or injury outside that laboratory work area requiring medical treatment beyond first aid

Let’s look at these one at a time.

Point (1) Is easy to understand. If the laboratory has essentially de minimis quantities of flammable or combustible liquids then following all the requirements of NFPA 45 may not be necessary for safe operations. (After all most of us have more than these amounts in our homes which are not sprinkler protected not ventilated to at least 4 ACH!) This is similar to the requirements of Point (3) where it notes that NFPA 45 does not cover laboratories that handle only innocuous chemicals with a hazard rating of 0 or 1. Again, in this case, all the provisions of NFPA 45 may not be necessarily appropriate. You may, and probably should, consider what NFPA 45 requires when designing these laboratories but all its provisions may be somewhat overkill for these low hazard operations. Having said that, however, I usually find that many of NFPA 45’s provisions are easily met without any additional expense so reviewing them carefully is warranted.

Point (2)?says that NFPA 45, which covers laboratories which are facilities (i.e., rooms or areas), does not cover pilot plants, which are process equipment within a facility. (See What is a Good Definition of a Pilot Plant?, https://www.dhirubhai.net/pulse/what-good-definition-pilot-plant-richard-palluzi ?and What is a Pilot Plant, https://www.dhirubhai.net/pulse/what-pilot-plant-richard-palluzi/?for a discussion of what constitutes a pilot plant.) You can, and should, apply NFPA 45 to the laboratory area (the room) but it cannot be applied to the design of the equipment, i.e., the pilot plant. The presence of a pilot plant is, however, ?likely to require additional mitigation measures. It may increase the area electrical classification due to the larger volume of flammable and combustible liquids and the higher pressures and temperatures in the pilot plant. ?It may require additional exits if the pilot plant creates obstacles to easy egress in an emergency. It may require additional fire protection due to the larger flammable and combustible liquid inventory. (See Can I Put a Pilot Plant in a Laboratory?, https://www.dhirubhai.net/pulse/can-i-put-pilot-plant-laboratory-richard-palluzi/, and Can you apply NFPA-45 to a Pilot Plant?, https://www.dhirubhai.net/pulse/can-you-apply-nfpa-45-pilot-plant-richard-palluzi/ for more background on this point.)

Point (4) is another problem area. Many manufacturing operations from scale up laboratories, to kilo laboratories, to true manufacturing facilities require or utilize a laboratory environment for some or all their operations. They require hoods, benches, exhaust ventilation, and all the other things one sees in a standard laboratory. Their manufacturing equipment may fit in a standard hood (so it is hard to tell it is not a research laboratory by just looking), fit inside a larger or custom hood, or be in a specially designed ventilated or total enclosure or glove box. Again, in this case,?you can, and should, apply NFPA 45 to the laboratory area (the room) but the manufacturing operation itself is likely to require additional mitigation measures to ensure its safe operation and the safety of the area due to the additional hazards it introduces. This is likely to include ?provisions from the International Fire Code or NFPA 30 The Flammable and Combustible liquids code due to the larger volumes of hazardous materials. It may require a higher area electrical classification due to the larger volumes, higher pressures, or routine operations. So NFPA 45 may no longer be adequate as a stand alone safety measure.

Point (5) tries to differentiate research and manufacturing laboratories from “laboratories” that are just cubicles or small rooms with some test equipment in a plant. Usually they are small, often air conditioned spaces with a few instruments used to perform frequent and routine QA/QC measures. The presence of a single hood (to allow cleaning containers and equipment) and/or a GC or tensile tester requires fewer provisions as the risks are much less. As these laboratories get larger, as more equipment is involved, as tests become more varied and extensive, and as quantities of hazardous materials become larger than following NFPA 45 becomes more necessary. The intent of (5) was to allow these cubbyholes and small area with minimal test equipment and operations to consider less stringent requirements. Should NFPA 45’s requirements be considered? Absolutely, but all of them may not always all be appropriate. You might think that these would be excluded under points (1) and/or (3) but, in fact, these areas may use more than these quantities.

Point (6) ?is intended to similarly point out that laboratories whose function does not involve chemicals and so handle little hazardous materials may not require the full scope of NFPA 45.?Just the presence of a small amount of flammable and combustible liquids above the 4 L threshold may still not be enough to require all NFPA 45’s requirements, particularly if theses materials are only used in an ancillary role such as cleaning. Again NFPA 45’s requirements?should be considered but all of them may not always all be appropriate. Larger volumes of hazardous materials, more extensive ancillary operations, more equipment and operations that use these materials would be a strong reason for complete compliance.

Points (7), (8) and (9) are somewhat the converse of Points (5) and (6). In this case the intent is to make sure that the owner understands that NFPA 45 alone is not sufficient to address the hazards associated with these potentially more hazardous operations. In the case of radioactive or explosive materials, additional safeguards will be necessary. In these cases, particularly with larger volumes or more extreme potential hazards, the facilities may look less and less like a typical laboratory. Glove boxes and specialty hoods may be required for radioactive materials. Barricades and blast cells may be necessary for explosion hazards. Some- or even – all the area may look like a standard laboratory but it will always need some additional mitigative measures. NFPA 45 does a good job of addressing these additional measures in section 1.1.1.2 where it states:

In such cases where a laboratory work area contains an explosion hazard, NFPA 45, supplemented by appropriate shielding, handling, and similar protective measures, does apply.

?NFPA 45 provides the basic framework upon which other codes and safeguards build to create a safe working environment. Is it always easy to identify what areas NFPA 45 covers? No. Is it easy to identify what other mitigative measures might be required or which provisions of NFPA 45 may be over kill? No. That is what you may need the assistance of a qualified person to address these issues.?NFPA 45 is always a prudent starting point but not an absolute in every case.

For more information on the design of laboratories you may want to consider the University of Wisconsin course, Successful Laboratory Design: Grassroots, Renovations and Relocations to be given virtually on Sept 21-23, 2021. For more information go to https://interpro.wisc.edu/courses/successful-laboratory-design-grass-roots-renovations-and-relocations/ .