NFPA 30 (2021)

PRACTICAL VIEWPOINTS TO ENSURE

CODE COMPLIANCE

Mike Snyder, PE, CSP, CFPS and Sarah Eck, PE, CCPSC

Since 1913, NFPA 30, Flammable and Combustible Liquids Code, has served as the leading information
source for safe handling and storage of “flammable and combustible liquids.” It is a widely used
Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) in the field of Flammable and
Combustible Liquid Risk Management.

Introduction Establishing a Basis of Safety for Liquid

Use and Storage
Since 1913, NFPA 30, Flammable and Combustible Liquids Code,
has served as the leading information source for safe handling and The main purpose of NFPA 30 is to provide information that serves
storage of flammable and combustible liquids. It is a widely used as fundamental safeguards for storage, handling, and use of liquids.
Recognized and Generally Accepted Good Engineering Practice This is accomplished by, initially, requiring and recommending
(RAGAGEP) in the field of Flammable & Combustible Liquid Risk measures that focus on preventing the ignition of fire. The fire
Management, and is applied by government authorities, emergency prevention strategy relies on the reliable application of controls to
responders and end-users to ensure safe storage and handling of break one or more than one of the legs of the Fire Triangle
liquids. Many state and regionally adopted Flammable and (Figure 1 on page 2).
Combustible Liquid Codes are based on recent editions of NFPA 30.
US-OSHA enforces 29 CFR 1910.106, Flammable Liquids, which is NFPA 30 is structured to recognize that reducing fire risk from
based on the NFPA 30 (1969), and include a series of interpretive prevention, alone, is typically not adequate to address all aspects of
letters and agency directives. the liquid risk. The standard provides additional requirements for
the use of fire and explosion safeguards or control systems to
This paper will overview the principles required to establish a basis provide life and structural safety in the event ignition occurs. The
of safety for proper handling and storage of liquids. Six significant extent of these protective systems is typically based on both the
changes proposed for the 2021 edition of NFPA 30 will be highlighted flammability characteristics of the liquids being stored, handled, or
and their implications to flammable and combustible liquid safety used and the quantity of material involved.
practices reviewed. Practical tips for the Process Safety Professional
to efficiently navigate older versions of NFPA 30 that are adopted
into present regulatory requirements.

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Figure 1: The Fire Triangle

FUEL The fire and explosion safeguards typically utilized in NFPA 30 include:

> Proper design of containers, piping, and tanks to reduce leakage > Drainage & containment
and to provide containment of liquid in early stages of > Facility design, including use of fire walls, fire resistive
fire exposure construction, and separation distances
> Use of low level and local exhaust ventilation to prevent > Fixed fire protection systems
accumulation of flammable vapors > Emergency Plans
> Operational procedures to control emissions from Class I > Explosion protection (containment, relief venting, explosion
liquids in containers and tanks suppression)
> Housekeeping practice to control fuel sources that could
provide initial fire exposure to liquids in use and storage NOTE: Focus on this protection is needed when handling liquids
> Use of flash arrestor systems to limit exposure of flammable that are highly volatile (Class IA & IB) or are chemically unstable.
vapors within the headspace of tanks

Overview of NFPA 30
AIR/OXIDANT
NFPA 30, Flammable and Combustible Liquids Code, is a widely used
> In limited situations, container transfers and tank headspaces Recognized and Generally Accepted Good Engineering Practice
can have oxygen concentration lowered through the (RAGAGEP) in the field of Flammable & Combustible Liquid Risk
introduction of an inert gas. Management. It is applied by government authorities, emergency
> The basis of safety is to ensure that the oxygen concentration is responders and end-users to ensure safe storage and handling of liquids.
reliably held below the lower oxygen concentration limit
required for combustion. NFPA 30 has been developed and updated through NFPA’s standards
> Personnel safety must be carefully considered when using development process that is a full, open, consensus-based process.
this strategy to avoid worker exposure to asphyxiation risks. NFPA 30 is revised and updated approximately every three years.
The standard’s cycle takes approximately two years to complete.
Each revision cycle proceeds according to a published schedule,
IGNITION SOURCES which includes final dates for each stage in the standards development
process, and provides several opportunities for all members of the
> Section 6.5 of NFPA 30 provides an overview of fundamental public to provide input and commentary for changing, updating, and
strategies, focusing on 12 common sources of ignition in improving the standard. This information is tracked on the
liquid operations Document Info pages for each standard1.
> Key focus on adequate electrical (hazardous) area classification
(Chapter 7) The four fundamental steps in the NFPA standards development
> Controls for electrostatic risks, particularly when transferring and process are:
dispensing liquids
> Control of hot work operations > Public Input
> Public Comment
> NFPA Technical Meeting
> NFPA Standards Council Action (Appeals and Issuance of
Standard)

The Regulations Governing the Development of NFPA Standards

detail the procedures used during each step of the NFPA 30
Standards development process2.

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NFPA Technical Committees serve as the principal consensus bodies technical committees (Fundamentals, Operations, Storage & Warehousing,
responsible for developing and updating all NFPA codes and and Tank Storage & Piping Systems) are summarized in Table 1.
standards. Committee members appointed by the NFPA Standards
Council, representing a balance of interests. NFPA membership is not
required in order to participate on a NFPA Technical Committee. Common Methods for Safe Storage and
Appointment to a Technical Committee is based on such factors as Handling of Flammable Liquids
technical expertise, professional standing, commitment to public
safety, and the ability to bring to the table the point of view of a NFPA 30 is a widely used Recognized and Generally Accepted Good
category of interested people or groups. Engineering Practice (RAGAGEP) in the field of flammable and
combustible liquid risk management. It is routinely applied by
Due to the comprehensive nature of NFPA 30, there are four technical government authorities, emergency responders and end-users to
committees and one correlating committee that manage ensure safe storage and handling of liquids. Successful management of
the standard’s revision and update. The purpose of the correlating flammable liquid risks are most efficiently provided by understanding
committee is to manage and coordinate the activities of the four the structure of NFPA 30 and the source of its requirements and
technical committees involved with NFPA 30 and to ensure that the recommendations. This allows one to effectively use this information
document sections managed by each technical committee do not for the design and operation of liquids operations.
contain conflicts or inconsistencies. The responsibilities for the four

Table 1: Topical Coverage and Application of NFPA 30 Chapters

Chapter Application NFPA Technical

Committee

1-7 (5 is reserved) Requirements for all facilities where liquids are stored, handled, or used Fundamentals

8 Reserved

9 through 12 Storage of liquids in containers, portable tanks, and intermediate bulk

containers in the occupancies covered by each chapter’s scope

13 Storage of liquids in containers, portable tanks, and intermediate bulk

containers in detached unprotected buildings
Storage & Warehousing
14 Storage of liquids in containers, portable tanks, and intermediate bulk of Containers & Portable
containers in hazardous materials storage lockers Tanks (FLC-SWC)

15 Outdoor storage of liquids in containers, portable tanks, and

intermediate bulk containers

16 Fire protection design criteria used to protect storage of liquid in

containers, portable tanks, and intermediate bulk containers

17 Design and construction of facilities where liquids are processed or used

18 General requirements related to handling, dispensing, transfer, and

use of liquids Operations (FLC-OPS)

Specific equipment & operations that use liquids (recirculating heat

19 transfer systems, vapor recovery & processing systems, solvent distillation,
and cooking oil storage tanks in commercial kitchens)

20 Reserved

21 through 25 Bulk storage of liquids in tanks. Tank Storage & Piping

Systems (FLC-TAN)
27 Piping systems for transferring liquids

28 Loading and unloading systems associated with bulk storage of

liquids in tanks Operations (FLC-OPS)

29 Wharves associated with bulk handling of liquids

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NFPA 30 provides several options for facility and tank design for the When faced with a local adoption of NFPA 30, it is essential that you
storage, use, and handling of liquids. The options available are have access to both the edition of NFPA 30 that was adopted, as well
generally based on the hazards presented by the commodity (flash as a copy of any amendments made during the adoption process.
point & boiling point), construction of containers (or tanks) used, For example, the state of Michigan has adopted the 2012 edition of
and the configuration of storage or use. NFPA 30 and issued a series of amendments3 that both limit the
application of the standard to liquids with flash points below
As an example, Chapters 9 through 16 of NFPA 30 provide number of 200°F (93°C) and direct certain state activities for inspection and
options are available for storage of liquids in containers. Depending review to specific departments. For facilities subject to NFPA 30, this
on the risks involved and protection provided, the volume of storage information will be necessary to ensure that both current operations
is limited – which allows several design options based on operational and new projects are conducted in accordance with the specific
needs. The options available in storage situations include: state requirements.

> Storage configurations in detached, unprotected buildings Typically, when a jurisdiction has adopted an older version of NFPA 30
> Storage configurations in hazardous materials lockers and you desire to use features from newer editions, there are variance
> Outdoor storage configurations procedures that can be applied. Generally, the responsibility is placed
> Indoor protected storage (large quantities in specific on the variance requester to demonstrate that the proposed approach
configurations) provides equivalent safety to the original requirement. With adequate
> Indoor unprotected storage (limited quantities and justification, these requests are often approved. The key to success is
configurations) to engage the local fire code authority early in the process, to discuss
A commonly overlooked requirement from Chapter 17 is that processing the specific details of the request and align on the best way to accomplish
and handling of Class II and Class III liquids heated at or above their the desired objectives.
flash point shall follow the requirements for Class I liquids, unless an
engineering evaluation conducted in accordance with Chapter 6 OSHA 1910.106 (Flammable Liquid Standard) is based on the 1969
justifies following the requirements for some other (lower hazard) edition of NFPA 30. The OSHA standard has been given a limited
liquid class. update to incorporate Globally Harmonized System (GHS) terminology
(Categories) along with agency directives to address the introduction
of plastic containers that did not exist when the 1969 edition was
Navigating Code Requirements With published4.
Legacy Versions of NFPA 30
In 1995, OSHA produced a letter of interpretation that allowed
Generally, NFPA 30 is adopted as part of a local or state level facility owners to use a more current version of NFPA 30 in lieu of the
Flammable & Combustible Liquids Code through legislative action. older requirements in 1910.1065. OSHA states that they will accept
Often, the adopted version is from one or two code cycles earlier than later editions of consensus standards (such as NFPA 30) when those
the most current version, and local amendments may be made. later editions set forth requirements which are as protective as current
The most common amendment is to limit the coverage of the code requirements of the standard. In such situations, the employer has the
to liquids with flash points below 200F (93C). NFPA 30 Annex H burden of proof to demonstrate that the protective measures
provides guidance for adopting the standard in a local jurisdiction. implemented are in fact equivalently protective.

Table 2: OSHA Citations Against 1910.106 (2010 – 2019) – 71% of Citations Issued

OSHA Section Coverage Area Number of Citations

1910.106 (e)(6) Sources of ignition 1721

1910.106 (e)(2) Incidental storage or use of flammable liquids 1379

1910.106 (d)(2) Design, construction, and capacity of containers 1087

1910.106 (e)(9) Housekeeping 768

1910.106 (d)(4) Design and construction of inside storage rooms 634

1910.106 (g)(3) Service stations: Dispensing systems 507

1910.106 (d)(3) Design, construction, and capacity of storage cabinets 505

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OSHA’s Citation History Involving 1910.106 Key Changes Proposed for NFPA 30
(Flammable Liquids Standard) (2021 Edition)
As previously referenced, OSHA 1910.106 (Flammable Liquid The structure and chapter architecture of NFPA 30 (2021) will remain
Standard) is based on the 1969 edition of NFPA 30. The OSHA identical to that of NFPA 30 (2018). To address both continued
standard has been given a limited update to incorporate Globally challenges experienced in liquid risk management and to resolve
Harmonized System (GHS) terminology along with agency directives technical challenges presented by new containers and storage
to address the introduction of plastic containers that did not exist configurations, several specific technical changes were made, which
when the 1969 edition was published. The OSHA Standard applies to are summarized below. Two significant changes were proposed during
flammable liquids divided into four GHS categories. The standard the first draft of the document, and through the consensus process
scope covers liquids with flash points below 199.4°F (93°C) or any were reversed during the second draft processing. All proposed
liquid that is heat above or within 30°F (16.7°C) of its flash point. changes will be presented to the NFPA Standards Council for
adoption once any Notice of Intent to Make a Motion (NITMAM) are
In the period 2010 to 2019, Federal and State-based OSHA inspectors processed at the NFPA Annual meeting in June 2020. One NITMAM
issued over 9000 individual violations that referenced a specific was filed prior to the February 19, 2020 deadline; however, it is not
section of the OSHA 1910.106 standard6. A summary of the most focused on any of the technical changes reviewed here.
common violations is in Table 2 below.
Flammable & Combustible Liquid Nomenclature
The key observations from this analysis highlight the following
common risk factors in industry. Each of these areas is well covered Throughout NFPA 30 (2021), the term “ignitable (flammable or
by the modern editions of NFPA 30: combustible)” will be used to denote any liquid that has a flash point.
When referring to a specific type of ignitable liquid, NFPA 30 uses
> Improper ignition source management, including both electrical liquid class to denote boiling point and flash point ranges. Liquid
(hazardous) area classification and proper management of static classification is summarized in Table 3 below.
electricity hazards represent more than 10% of citations issued.
> Many industrial and manufacturing facilities where the use and This action begins the process of reducing the use of the terms
handling of flammable liquids is only incidental to the principal “flammable” or “combustible” to reduce confusion of terminology
business have weak practices related to the handling and storage arising from the definitions used by different agencies and the
of liquids. Impacted businesses include automobile assembly, Globally Harmonized System (GHS). For example, OSHA uses 140°F
construction of electronic equipment, and furniture (60°C) to delineate between flammable and combustible liquid classi-
manufacturing. fication, whereas NFPA uses 100°F (37.8°C). Longer term, use of
> Proper containers use and selection for the storage and handling liquid class provides more consistency in evaluating any liquid with a
of liquids remains a common problem area. flash point. In these cases, any liquid with a flash point can burn
> Housekeeping and control of materials that can become initial (that is, are ignitable liquids) given a sufficient ignition source.
sources of ignition remain a common threat in many industrial When ignited, these liquids generally produce high levels of heat
and manufacturing occupancies. output. The liquid classification (e.g. Class I, Class II, and Class III)
> The design and construction of small liquid storage rooms can provide more of a perspective on the relative ease of ignition.
(<500 ft2; 46.5 m2) frequently have problems with excessive
storage volumes, electrical wiring, and ventilation.
> Flammable liquid cabinet use, design, and loading of flammable
liquids remains a major identified non-compliance.

Table 3: Flash Points and Boiling Points of Liquid Classes used in NFPA 30 (Chapter 4)

Liquid Class Flash Point Boiling Point

IA Below 73°F (22.8°C) Less than 100°F (37.8°C)

IB Below 73°F (22.8°C) At or Above 100°F (37.8°C)

IC At or Above 73°F (22.8°C) but below 100°F (37.8°C) Any

II At or above 100°F (37.8°C) but below 140°F (60°C) Any

IIIA At or above 140°F (60°C) but below 200°F (93°C) Any

IIIB At or above 200°F (93°C), subject to having a Flash Point Any

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Treatment of Beverages, Medicines, and Other that previous editions of NFPA 30 had with other model Fire &
Consumer Products Containing Not More Than Safety Codes on this issue.
20% Water-Miscible Liquids
Anchoring of Tanks (Section 22.5.3)
In the 2018 edition of NFPA 30, beverages, medicines, foodstuffs,
cosmetics, and other consumer products are excluded from NFPA During the first revision, this new section was added to NFPA 30 to
coverage if they contained not more than 50 percent by volume of specify the conditions under which anchorage of tanks is required.
water-miscible flammable or combustible liquids, with the remainder The new section makes the consideration method for anchorage
of the product consisting of components that do not burn. This explicit and detailed.
exception in Section 9.1.4(4) applies to liquids in containers that do
not exceed 1.3 gallons (5 liters). Table 16.4.1(a) indicates that they Metallic/Nonmetallic Composite Piping (Section 27.4.7)
were to be stored and protected as either a Class I or Class II
commodity as described in NFPA 13, Standard for the Installation of A new subsection was added to cover metallic/nonmetallic composite
Sprinkler Systems (2019)7. piping. This listed piping material for flammable and combustible
liquids has been in use for 20 years with a variety of flammable liquids.
During the current revision cycle, additional fire testing data was The piping system contains an inner metallic liquid conducting tube
presented to support the reduction of this exclusion to not more than and an outer nonmetallic tube, which contains any leakage from the
20 percent by volume of water-miscible liquid. The 2021 edition of inner metallic tube. The space between the inner and outer tubes can
NFPA 30 will provide specific protection coverage in Tables 16.5.2.17 be monitored for pressure, to indicate leakage.
or 16.5.2.18, as applicable, or potentially treat the storage as unprotected.

Improvements to Application Flowcharts and New Significant Changes Considered But

Fire Protection Design Options in Chapter 16 Not Implemented
(Protected Storage)
Composite Intermediate Bulk Containers (Chapter 9)
Chapter 16 provides specifications for the design and configuration of
automatic fire protection systems for all inside storage of ignitable The fire risks presented by composite IBCs storing combustible
liquids in containers, intermediate bulk containers (IBCs), and liquids are well documented in the literature9. During the first
portable tanks that are being used in accordance with the container revision, additional restrictions on the use of composite IBCs were
requirements specified in Section 9.4. When liquids are protected in proposed that were subsequently removed and returned to language
accordance with the applicable requirements of this chapter, they are from the 2018 edition of NFPA 30. In summary, the requirements for
considered protected storage. Protected storage allows for virtually use and storage of composite IBCs include:
unlimited quantities of storage in the protected configuration.
> Composite IBCs are not authorized for the storage of Class I
Commercial use and development of liquids continues to drive the liquids, except in specific limited situations detailed in
need for new containers and configurations of storage, which require Section 9.1.4 of NFPA 30.
careful evaluation of what is required for effective fire protection > Composite IBCs containing a Class II or Class IIIA liquid must
design. The protection criteria modifications were validated by full be listed and labeled. Units not listed and labelled are prohibited.
scale fire testing described in reports reviewed by the FLC-SWC > Section 18.5.4.1, related to allowances for storage of liquids in
technical committee8. The testing information was produced in incidental-use applications, sets out requirements for conducting
alignment with the guidelines outlines in Annex D & Annex E of a hazard analysis and implementing a lower threshold for
NFPA 30, which focus on the development of fire protection system maximum allowable quantities that can be staged. It reduces the
design criteria used in Chapter 16. number of Composite IBCs that can be temporarily staged in an
operational area.
Significant additions to this Chapter include the following:
Local Exhaust Ventilation Credit Reductions
> Three new protection schemes are added in Section 16.5 for (Section 17.11)
small (<1 gallon; 3.7 liter) containers of alcohols and 50-50
alcohol-water mixtures During the first revision, the maximum credit available to be taken for
> New section 16.5.2.13 and 16.6.5 adding in-rack protection required ventilation available from local exhaust ventilation (LEV) was
criteria for Class II liquids in metal containers using K25.2 proposed for reduction from 75% to 50%, based on opinions expressed
extended coverage sprinklers about ventilation compromise that could exist by improper use of LEV
> New section 16.5.2.14 provides new fire protection criteria for equipment. This was reversed during the Technical Committee’s work
liquids with flash points less than 200°F (93°C) in cartoned, during second draft and restored to the maximum 75% credit.
two-ounce, plastic bottles
> New sections 16.5.2.15 and 16.6.4 provides new sprinkler protec-
tion criteria for liquids with flash points greater than or equal to Conclusion
450°F (232°C)
DEKRA has applied the principles within NFPA 30 for decades and
Flammable Liquid Cabinet Self Closing Doors recognizes them as a key part of an effective Loss Control Engineering
(Section 9.5.3) Program. We are committed to partnering with our clients to adapt to
the changes presented by the 2021 edition and to apply existing requi-
NFPA 30 has been updated to require that all new flammable liquid ements to address our Client‘s unique needs. Contact us to talk about
storage cabinets must have self-closing doors. This resolves conflicts how to manage these and other fire hazards!

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References
1 National Fire Protection Association, “NFPA 30: Flammable and Combustible Liquid Code”. 2018, http://www.nfpa.org/30

2 National Fire Protection Association, “Regulations Governing the Development of NFPA Standards”, Retrieved from: https://www.
nfpa.org/Codes-and-Standards/Standards-development-process/Regulations-and-policies, Accessed on February 19, 2020

3 State of Michigan Department of Licensing and Regulatory Affairs. (2014), “Flammable and Combustible Liquid Rules”. Retrieved
from https://www.michigan.gov/lara/0,4601,7-154-89334_42271_4115_4237-9432--,00.html. Accessed on February 19, 2020

4 United States Department of Labor. (1980), “Directive STD 01-05-014: U.S. Department of Transportation (DOT) Exemption Which
allows Shipments of Combustible and Flammable Liquids In Polyethylene”. Retrieved from
https://www.osha.gov/enforcement/directives/std-01-05-014. Accessed on February 19, 2020

5 United States Department of Labor. (1995), “Compliance with NFPA 30 Revisions in lieu of 1910.106”. Retrieved from https://www.
osha.gov/laws-regs/standardinterpretations/1995-07-18, Accessed on February 19, 2020

6 United States Department of Labor. (2019), “OSHA Enforcement Data”, Data Catalog. Retrieved from
https://enforcedata.dol.gov/views/data_summary.php, Accessed on February 17, 2020

7 National Fire Protection Association, “NFPA 13: Standard for the Installation of Sprinkler Systems”. 2019,
http://www.nfpa.org/13

8 FM Global (2018). Summary Report of Fire Testing Involving Ignitable Liquids – NFPA 30. Retrieved from
https://www.fmglobal.com/research-and-resources/standards-and-certification/code-support-reports. Accessed on
February 19, 2020

9 Snyder, M. D. (2019). Understand the Risks of Composite Intermediate Bulk Containers. Chemical Engineering Progress, 115(2),
39–43.

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