High-piled combustible storage is a process regulated by the Virginia Statewide Fire Prevention Code (i.e., Fire Prevention Code or SFPC). A building or structure containing high-piled combustible storage (i.e., combustible storage in access of 12 feet in height) requires additional consideration with respect to fire protection and life safety as compared to combustible storage arrangements maintained below 12 feet. Furthermore, when high-piled combustible storage is introduced into a building or structure (i.e., creation of an interior high-piled storage area), it not only increases the amount of materials that can burn (fuel), but can complicate the fire department effort to manually extinguish an unwanted fire because of increased storage heights of up to 40 feet and complex storage methods such as rack, pile, and shelf storage, all of which can significantly impact fire behavior inside the building or structure. Reducing potential fire risk is the focus of regulating this complex storage process.
Risk Reduction. The overall goal in the regulation of high-piled combustible storage is to prevent an unwanted fire from occurring through fire risk reduction; however, in the event a fire does occur in a building or structure containing high-piled combustible storage, code compliant storage arrangements and proper maintenance practices can help ensure all occupants, including employees, safely evacuate the building, which is the primary goal during any fire emergency. In addition, providing safe access for responding fire department personnel and limiting fire spread and would also be an important risk reduction objective focused at enhancing firefighter safety and limiting fire damage to the structure and its contents. Another element in risk reduction in buildings and structures containing high-piled combustible storage is the provision of adequate fire protection.
Fire Protection Requirements. Fire protection requirements for buildings or structures containing high-piled combustible storage is generally determined by the storage commodity type (i.e., combination of products, packing materials, and containers) as well as the height, quantity, and arrangement or method of commodity storage. A key concept in the protection of buildings and structures containing high-piled combustible storage is ensuring the level of fire protection provided is adequate for the commodity types and storage arrangements actually in place. This requirement is evaluated by the Fire Marshal's Office during the plan review of the high-piled storage plan and during periodic fire prevention inspections.
High-Piled Combustible Storage. High-piled combustible storage is the storage of combustible materials in closely packed piles or combustible materials on pallets, in racks, or on shelves where the top of the storage is greater than 12 feet in height. When required by the fire code official, high-piled combustible storage also includes certain high-hazard commodities, such as rubber tires, Group A plastics, flammable liquids, idle pallets and similar commodities and where the top of storage is greater than 6 feet in height. Commodities include the combination of products, packing materials, and containers.
High-Piled Storage Area. The Fire Prevention Code defines high-piled storage area as the area within a building which is designated, intended, proposed or actually used for high-piled combustible storage.
High-Piled Storage Plan. To avoid confusion with other construction documents associated with the building or structure, approved documentation for high-piled combustible storage is known as the high-piled storage plan. The contents of this plan typically include the high-piled combustible storage plan review application, required plan review documents, and completed evacuation plan for public accessible storage areas and large mercantile occupancies.
Questions related to the regulation of high-piled combustible storage in Fairfax County and the towns of Clifton, Herndon, and Vienna should be directed to the Fire Inspections Branch at 703-246-4849.
PLAN REVIEW REQUIRED
When Required. In accordance with sections 108.2 and 3201.2 of the Fire Prevention Code, a high-piled storage plan shall be submitted for any of the following circumstances or conditions:
- At the time of building permit application for new structures designed to accommodate high-piled combustible storage
- When requesting a change of occupancy/use or when increasing the storage hazard of an existing high-piled combustible storage arrangement
- At the time of application for an operational permit (i.e., Fire Prevention Code Permit) to maintain any high-piled combustible storage area
Required Documents. The high-piled storage plan shall be included in the plan submittal. This typically includes the high-piled combustible storage plan review application, required plan review documents, and completed evacuation plan for public accessible storage areas and large mercantile occupancies.
Floor Plan Specifications. Designers shall provide a scaled floor plan of the building showing locations and dimensions of all high-piled combustible storage areas and storage arrangements. Scaled drawings shall be: 1/8 inch = 1 foot. Dimensional drawings are not acceptable.
To assist in the preparation of a suitable floor plan for the high-piled storage plan submittal, designers are encouraged to consult the above diagram which is an example of a completed plan. A large, viewable image is available.
Evacuation Plans. In accordance with Section 3201.4 of the Fire Prevention Code, an evacuation plan for public accessible areas and a separate set of plans indicating location and width of aisles, location of exits, exit access doors, exit signs, height of storage, and locations of hazardous materials shall be submitted at the time of permit application for review and approval. Following approval of the plans, a copy of the approved plans shall be maintained on the premises in an approved location. Large mercantile occupancies shall comply with the Fire Safety & Evacuation Planning for Mercantile Occupancies.
Plan Review Application. An application for plan review shall be made via a Storage - High-Piled/Other record submission in PLUS.
Detailed code requirements related to high-piled combustible storage can be found in chapter 32 of the Fire Prevention Code.
Questions about the plan review process should be directed to the Engineering Plans Review Branch at 703-246-4806.
OPERATIONAL PERMIT REQUIRED
Permit Application. In accordance with Section 3201.2 of the Fire Prevention Code (as amended by Fairfax County), a Fire Prevention Code Permit (FPCP) is required to use a building or a portion thereof as a high-piled storage area exceeding 500 square feet. Furthermore, in accordance with Section 108.2, application for an FPCP shall be made to the fire official in such form and detail as prescribed by the fire official, and applications for permits shall be accompanied by such plans as prescribed by the fire official. Therefore, an FPCP application for high-piled combustible storage must be accompanied by an approved copy of the high-piled storage plan, which will be returned when the FPCP is issued at the time of the fire marshal site inspection.
Permit Notice. In accordance with Section 108.3.6 of the Fire Prevention Code, the issuance or granting of an operational permit shall not be construed to be a permit for, or an approval of, any violation of any of the provisions of this code or of any other ordinance of the jurisdiction. Permits presuming to give authority to violate or cancel the provisions of this code or other ordinances of the jurisdiction shall not be valid. The issuance of a permit based on other data shall not prevent the fire official from requiring the correction of errors in the provided documents and other data. Any addition to or alteration of approved documents shall be approved in advance by the fire official, as evidenced by the issuance of a new or amended permit.
Questions about the permit application process should be directed to the Revenue and Records Branch at 703-246-4803.
SITE INSPECTION REQUIRED
In accordance with Section 108.2.2 of the Fire Prevention Code, before a new operational permit (i.e., Fire Prevention Code Permit) is approved, the fire official is authorized to inspect the receptacles, vehicles, buildings, devices, premises, storage spaces, or areas to be used to determine compliance with this code or any operational constraints required.
Approved Plans. A copy of the approved High-Piled Storage Plan, which includes the completed plan review application, shall be maintained on the premises in an approved location, readily available for inspection by the Fire Marshal.
Site inspections may be scheduled by calling the Fire Inspections Branch at 703-246-4849.
Site Inspection Failure. The following are the leading causes for high-piled combustible storage site inspection failures:
- High-piled combustible storage arrangement(s) do not match approved high-piled storage plan
- Approved high-piled storage plan not available at inspection location (high-piled storage area)
- Minimum required aisle widths not properly maintained
- Required flue spaces not provided or maintained clear
- Maximum storage height limitation exceeded
- Storage of encapsulated commodities where not approved
Maintenance Requirements. Approved high-piled storage areas and storage arrangements shall be continuously maintained in accordance with the approved high-piled storage plan and the maintenance and housekeeping requirements of Chapter 32 of the Fire Prevention Code. In addition, buildings and structures approved for high-pile combustible storage shall be maintained in accordance with all applicable sections of the Fire Prevention Code.