Hazardous Materials and the Applicability of NFPA 400
As I discussed in a previous blog, organizations, and even different documents produced by the same organization, define hazardous material differently. NFPA 400, Hazardous Materials Code, defines hazardous material as:
A chemical or substance that is classified as a physical hazard material or a health hazard material, whether the chemical or substance is in usable or waste condition.
One quality that makes a chemical or substance a physical hazard material is if it is flammable. If that material is a liquid, how would you know if NFPA 400, NFPA 30, Flammable and Combustible Liquids Code, or both apply?
The answer to this question and many like it can often be found in Chapter 1 of most NFPA documents. Chapter 1 is typically the administration chapter. I believe it is often overlooked but contains some extremely important information regarding the scope and application of a particular document. Let’s focus on the scope and applicability of NFPA 400.
There are two different components that must be considered when determining if NFPA 400 is applicable to a particular situation: 1) what is the material; and 2) what is being done with that material. NFPA 400 covers the use, storage, and handling (including on-site transportation) of certain hazardous materials. Any other use, such as off-site transportation, of these materials would be outside the scope.
NFPA 400 covers the following materials:
- Ammonium nitrate solids and liquids
- Corrosive solids and liquids
- Flammable solids
- Organic peroxide formulations
- Oxidizer—solids and liquids
- Pyrophoric solids and liquids
- Toxic and highly toxic solids and liquids
- Unstable (reactive) solids and liquids
- Water-reactive solids and liquids
- Compressed gases and cryogenic fluids as included within the context of NFPA 55
There are chemicals or substances that meet the hazardous materials definition in NFPA 400 that fall outside the scope of the document. One example is a flammable or combustible liquid. Ignitibility is one characteristic that results in a liquid being considered a physical hazard material; however, you will not see ignitible liquid (or flammable or combustible liquid) in the above list. This is because a flammable or combustible liquid, which has no other physical or health hazard properties covered by NFPA 400, is outside the scope of NFPA 400. Instead, NFPA 30 would provide the requirements. If, however, the flammable or combustible liquid has an additional health or physical hazard property covered by NFPA 400, then both NFPA 30 and NFPA 400 would be applicable.
It is important to remember that multiple codes and standards may apply. So, when designing or determining how much of a material can be stored or used it is imperative that all relevant documents be consulted. For example, if quantities of hazardous materials exceed certain thresholds set by Occupational Safety and Health Administration (OSHA) or Environmental Protection Agency (EPA) then federal requirements under the Process Safety Management and Risk Management Program may apply in addition to NFPA 400.
Chapter 1 of NFPA 400 not only identifies what is covered, it also includes a list of items that are not covered. Many of the situations that NFPA 400 does not apply to, are covered by other codes and standards, like the ignitible liquid example above.
The complete list of what NFPA 400 does not apply to is:
- Storage or use of hazardous materials for individual use on the premises of one- and two-family dwellings
- Explosives or blasting agents, which are regulated by NFPA 495, and fireworks
- Refrigerants and refrigerant oil contained within closed-cycle refrigeration systems complying with the fire code and the mechanical code adopted by the jurisdiction
- High-hazard contents stored or used in farm building or similar occupancies and in remote locations for on-premises agricultural use
- Corrosive materials in stationary batteries utilized for facility emergency power or uninterrupted power supply, or similar purposes, in accordance with NFPA 1
- Aerosols complying with NFPA 30B
- Corrosive materials displayed in original packaging in mercantile occupancies and intended for personal or household use or as building materials
- Ignitible (flammable or combustible) liquids having no other physical or health hazard properties covered by NFPA 400
- Organic peroxide formulations that are capable of detonation as manufactured or when unpackaged or in authorized shipping containers under conditions of fire exposure, when stored, manufactured, or used in accordance with NFPA 495
- Combustible metals, as defined in NFPA 484
- LP-Gas complying with NFPA 58 or NFPA 59
- Where approved, materials that have been satisfactorily demonstrated not to present a potential danger to public health, safety, or welfare based upon the quantity or condition of storage
- The off-site transportation of hazardous materials when in accordance with Department of Transportation (DOT) regulations
- Cellulose nitrate film complying with NFPA 40.
As you can see, there are a number of documents that regulate hazardous materials. Therefore, before even digging into the actual requirements you need to: 1) make sure you are defining a hazardous material correctly; 2) confirm that the material you have, in the specific situation you have, is covered by that particular document. Remember, Chapter 1 of NFPA documents will help you through this process.
Be on the lookout for my future blogs which will take a deeper dive into NFPA 400, covering topics like, maximum allowable quantities (MAQs), control areas, and more. If you missed the first blog in the series on how to define hazardous materials, you can find it here.