Significant 2021 Code Changes Affecting Distilleries

The 2021 and newer editions of the IBC (International Building Code) involved major changes affecting the design of distilleries. Jurisdictions adopt different editions at varying times. Many jurisdictions are still utilizing 2018 and earlier codes, but in the coming years, most jurisdictions will begin to adopt 2021 and newer editions. Check with your location jurisdiction on their current and upcoming adoptions.

IBC 307.1.1 lists uses that shall not be classified as Group H.  The 2021 IBC adds exception #18 which states “distilling or brewing of beverages conforming to the requirements of the IFC”. In essence, this states that a distillery, even if it exceeds the MAQ’s, is no longer an H-3 occupancy, rather an F-1 occupancy.

But, the IFC (international fire code) contradicts the IBC distillery H-3 exception- 2021 IFC T.5003.1.1 requires facilities that store or process 1B and 1C Flammable Liquids, in excess of their MAQs, to be classified as H-2 or H-3 occupancy. 

So, what do we do with this contradiction?

 Each jurisdiction must interpret which of these two contradictory code requirements should govern. The options we have are summarized as below:

Option 1

If a jurisdiction elects to follow the requirement in the MAQ table in the IFC, exception #18 to IBC 307.1.1 will not apply and the code change will have no effect on this distillery design.

Option 2

If the jurisdiction elects to enforce exception #18 by voiding the IFC T.5003.1.1 requirement that 1B and 1C flammable liquids in excess of the MAQs must be an H-2 or H-3 occupancy, but the remainder of the IFC requirements are enforced, the following chart describes the net effect of this application of the two contradictory codes on key H-3 code requirements.

H-3 Occupancy Requirement2018 IBC/IFC2021 IBC/IFC2021 IFC chapter 40 Barrels
25% perimeter on exterior wallIBC 415.6no requirementnot required
SprinklersIBC 415.4IBC 903.2.4.2required
Spill ControlIBC 414.5.3IFC 5004.2.1required
Secondary ContainmentIBC 414.5.3IFC 5004.2.2required, no specific volume
Explosion ControlIBC 414.5.1IFC 5004.6, 911.1not required, exempt from 50&57
1CFM/SF VentilationIBC 414.3IFC 5004.3.1required or maintain < 25% of LFL
Emergency AlarmsIBC 415.5IFC 5004.9not required, exempt from 50&57
Occupancy SeparationIBC 508.3.3 ex.1no requirementnot required

Regardless of the option selected by the AHJ, the new IFC chapter 40 adds the requirement for spill control and secondary containment where barrels are stored, but does not quantify that requirement.

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