F-2 Occupancy (2001 CBC)?

For years, we have been using the F-2 occupancy for Stone Fruit Packing Buildings or Orange Packing Buildings. Once in a while, a BO will refuse to accept it citing "food Processing" as an F-1. What do members here think?

The stone fruits (peaches, plums, nectarines) are non-combustible as they are mostly water. Same for Oranges.

They are not processed in any way. (No slicing, cooking etc.)

They are usually run through a washer waxer and maybe a hydrocooler. Many times water is used in handling the culls.

There is an amount of combustible packing materials in the building used in packing, but those same materials (boxes) are part of the contents in the S-2 cold storage associated with the packing building.

The facilites are usually next to or entwined with cold storage facilities, S-2.

What are the opinions of others?
Original Post
SUMMARY OPINION:
Certainly Group F1 Food processing is the catch all occupancy, but does not readily address containers or wrappings or packaging, and does not prohibit combustible packaging ... Principally, Group F2 is facilities producing noncombustible or non explosives materials however, peaches, plums, nectarines are produced on the tree and not created in the plant facilities ... Yet, both Group S2 and F2 are intended to be related to produced noncombustible materials or products and the processing and handling of fruit produce may somewhat be described ... Further, Group F1 in part describes uses not classified as Group F2, thus opportunity for review of actual operation per CBC 301 as well ... Considering Group S2 allows noncombustible materials and products on wood pallets, or in paper cartons, or in paper wrappings, then peaches, plums, nectarines in wood boxes may be reviewed and classified by Building Official per CBC 301, considering Group F2 potential fire and life hazard, upon review of owner or the owner representatives submitted operational statement and subsequent determination by local building official in cooperation with local fire department, who provides local fire protection services and fire code maintenance inspections.

CODE SECTIONS:
2001 CBC 301 states in part ... "Any occupancy about which there is any question shall be classified by the building official based on proposed fire and life hazard"
2001 CBC 311.1 Group S2 in part describes storage of noncombustible materials such as products on wood pallets, or in paper cartons, or in paper wrappings which includes
Item #12, Food in noncombustible containers,
Item #13, Fresh fruit in non-plastic trays or containers
Item #14, Frozen foods
2001 CBC 306.1 Group F2 in part describes facilities producing noncombustible or non explosives materials which during finishing packing or processing do not involve significant hazard
2001 CBC 306.1 Group F1 in part describes uses not classified as Group F2 which includes
Item #20, Food processing
The Building Official can certainly elect to classify this building as an "F-1" occupancy group and be justified as a "food processing" occupancy (Section 306.2 of the 2007 CBC).

Although the potential hazard and fire severity of the multiple uses in the Group F occupancy classification is quite varied, these uses share common elements. The occupants are adults who are awake and generally have enough familiarity with the premises to be able to exit the building with reasonable efficiency. Public occupancy is usually quite limited, and most occupants are aware of the potential hazards the use creates. Group F occupancies are generally regarded as factory and industrial uses. The degree of hazard between the uses is very broad, and therefore the occupancy is divided into two divisions.

Many of the Group F-1 uses contain some degree of hazardous material as a necessary part of the manufacturing process. However, where the amount of hazardous material does not exceed the maximum allowable quantities set forth in Table 307.7(1) or Table 307.7(2), the lower lassification of Group F is deserved. Because of the similarity between the names of the uses in Group F-1 occupancies and those in Group H occupancies, care must be exercised when determining the appropriate classification, and operators of Group F-1 uses should be apprised of the limitations on the quantities of hazardous materials that are allowed.

Some of the activities specifically listed as Group F occupancies also occur in a limited sense as accessory functions, and as such are not to be classified as Group F. For example, food processing is identified as a Group F-1 occupancy, but this is not to say that a kitchen serving a restaurant, school or worship building should be classified as such. Kitchens are typically considered to be classified as a portion of the major occupancy that they serve. The food processing operations designated as Group F-1 occupancies primarily include large factories that produce canned or packaged items in bulk.

The hazard from uses in Group F-2 occupancies is very low; in fact, the activities are deemed as among the lowest hazard groups in the code. It is assumed that the fabrication or manufacturing of noncombustible materials will pose little if any fire risk to the building or its occupants. Foundries would be considered Group F-2 occupancies, as would facilities used for steel fabrication or assembly. Manufacturing operations producing ceramic, glass or gypsum products are also included in this classification.

You can certainly present the Building Official with an argument towards classifying the building as an F-1 based on detailed activities, uses, processes, occupant load, etc. The Building Official must then compare with various occupancy classifications based on information provided and determine which closely resembles the actual use.

Most of the time, the applicant/designer elect to classify such buildings as F-2 so as not to provide a fire sprinkler system in the building and to enjoy the UNLIMITED floor area provided for nonsprinklered F-2 occupancies- Section 507.2 of the 2007 CBC.

F-2 occupancies would be exempted from sprinklers (unless a local ordinance exits). F-1 occupancies will have to be sprinklered once a threshold is triggered.

The 2007 CBC exempts F-2 occupancy from providing a sprinkler system, while an F-1 occupancy is required to be sprinklered once the fire area exceeds 12,000 sf. See Section 903.2.3.
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