Fire Code Commission Decision Summary

DECISION NO.97A001-119
DATE:June 5, 1997

SUBJECT MATTER

An Inspection Order was served on the operator of an outdoor wood pallet storage yard. The Order prescribed height and area limits on the storage of the wood pallets located in the yard. The operator filed an appeal for a Review by the Fire Marshal. The Review modified the original Order and addressed the following:

maximum height and area of storage piles,
clearances around piles to other piles, buildings and property lines,
access routes and water supplies for fire fighting,
control of ignition sources,
fire safety planning,
yard security,
staff training,
control of combustible waste and vegetation, and
monthly fire safety inspections.

This modified Order resulting from the Review by the Fire Marshal was the basis for the appeal to the Fire Safety Commission.

GENERAL DESCRIPTION OF PREMISES

The property is a wood pallet repair and resale operation with an outdoor pallet storage yard. The property is 50 m wide by 86.1 m deep.

There is a one-storey building on the property, with an area of 1550 m² and of non-combustible construction. The building is used to repair and rebuild the wood pallets. The building contains office space separated from the pallet repair and storage area by a full height drywall partition. There are portable extinguishers located throughout the building.

The remainder of property is used as an outdoor storage space for refurbished pallets. The pallets are stored at the rear of the building across the entire width of the property. Pallets are also stored along the west side of the building and storage arrangement varies from time to time as stock is continually being shipped out and replenished each day.

There is a building located 7 m from the property line on the east side of the site and another building located 15 m from the property line on the west side of the site. To the north of the property, buildings are located 18 m from the property line. The areas located between the property line and the neighboring buildings are used for vehicle parking.

There is a fire hydrant located near the entrance roadway to the property. There is no fire safety plan for the property. “No smoking” signs are posted on the main entrance gate, along the east property fencing, on the propane storage cage and inside the building. Each fork lift truck operating on the property is equipped with a 1A:5BC rated portable extinguisher.

APPELLANT'S POSITION

The appellant stated that if the clearances specified in the modified Order are followed, no storage would be possible and the company would be forced out of business.

The Tribunal also heard from a member of the Wood Pallet Association who testified for the appellant. He indicated that he is familiar with the pallet industry, and while there have been a couple of fires in pallet plants, he does not believe that pallets are easy to ignite since there is no ignition source present. He also stated that there has been no fire at the subject premises. In his opinion, there is no reason why the pallets should not be stored right up to the building or the property line.

RESPONDENT'S POSITION

The respondent from the fire department stated that the fire hazard did not greatly affect life safety, as there are typically no people in the yard.

The District Deputy Fire Marshal testified that the hazard extends not only to the property but also to occupants, since there are workers at the plant as well as responding fire crews in the event of a fire.

COMMISSION RULING

The Commission upheld the original Order and incorporated the following modifications:

Individual wood pallet storage areas shall be limited to 1,000 m² in area with a maximum storage height of 6 m.
The outdoor wood pallet storage area shall be surrounded by a solid barrier made up of non-combustible shipping containers stacked two high. A clearance of at least 5 m shall be maintained between the outdoor wood pallet storage area and the rear of the building. A site plan showing the location of pallet storage and the shipping container barrier shall be submitted to the fire department. The height, structural resistance to collapse, as well as the permanent anchoring of the containers must be considered by the fire department.

The access opening through the surrounding containers into the storage area shall be located such as a collapse of the pile would not spread into the building through building openings.
An automatic deluge sprinkler system designed to meet NFPA 13 shall be installed along the entire north wall of the building. Three (3) copies of the drawings and hydraulic calculations shall be submitted for review and acceptance by the fire department.
The work in items #1, #2 and #3 shall be completed and the sprinkler installation operational by January 30, 1998.

REASONS

The Tribunal agreed that the storage of empty wood pallets is a serious fire hazard that, if not properly protected, would endanger life and property.

The Tribunal also finds that the method used by the Fire Marshal, their research and use of other codes that specifically address the question of pallet storage (such as National Fire Code, National Fire Protection Association and UK Fire Protection Association) to assess the hazard and arrive at a solution, is in line with the intent of the Fire Code. The latter, while silent on the pallet storage, does address stickered lumber, which the Tribunal agreed, to be similar to pallets in fire conditions.

The Tribunal does not agree that the pallets are not easy to ignite and that they can be stored right to the building limits. Therefore, safe clearances between the pallet storage and the building (or other storage) must be provided, unless proper compensatory protection is provided.