Micro-distilleries are a rapidly emerging industry that is creating a lot of concern among fire safety officials due to the unique fire risks they bring to the communities in which they are located. The potential causes of fire and explosion at a micro-distillery are no different than those associated with a large distillery. However, unlike large distilleries, which are typically located in rural areas, micro-distilleries pose additional safety risks due to their proximity to populated areas and other structures nearby. In addition to the fire hazards you would expect in any distillery operation, micro-distilleries in more populated areas pose additional risks including:
- Damage to neighboring buildings
- Injury to people walking, working, or driving near the distillery
- Injury to larger numbers of people within the distillery who are taking tours, visiting tasting rooms, and shopping in on-premises stores.
Given these risks and the fact that many micro-distilleries are opening up in buildings not originally designed to address them, we’re taking a deeper dive into the sprinkler requirements for micro-distilleries. This is because, in addition to good safety practices, sprinklers are the first line of defense against a fire spreading through your distillery, potentially destroying your business or worse – causing injury or fatalities.
How Do You Know if Sprinklers are Required?
One of the most common questions we get from micro-distilleries is where in their facility they need to install sprinklers and what types of systems they need. The craft distilling industry has grown so quickly in recent years that it has outpaced the ability of regulations to keep up. This does not mean that there are no applicable regulations. It just means there are few codes that specifically address the risks posed by micro-distilleries. In the absence of clear regulations pertaining to micro-distilleries, most jurisdictions will rely in large part on Chapter 9 of the International Building Code (IBC) to determine whether automatic sprinklers are required.
Occupancy and commodity classifications provide the basis for regulatory decisions regarding sprinkler requirements and design. Micro-distilleries are often more complex because they typically involve multiple occupancies – distillery operations combined with tasting rooms, on-premises stores, etc. These activities may require different types of sprinkler systems to ensure you have the right kind of protection for all areas of your operation.
The IBC criteria for the requirement of sprinkler systems in different areas of a micro-distillery operation are shown in Table 1. Here is a summary of how they might relate to the different business activities common to many micro-distilleries today:
Tasting Rooms and Distillery Tours – While the IBC classifies these activities as two different occupancies, the National Fire Protection Association (NFPA) 101 Life Safety Code classifies them as one. Under the IBC, a tasting room would require a sprinkler system if the space will hold 100 or more people. Any area along a distillery tour would require sprinklers if the tour includes 300 or more people at one time. In contrast, The Life Safety Code classifies both of these activities as an Assembly, which would require a sprinkler system if either your tasting room and tour involves more than 50 people. This difference illustrates why it is important to determine what codes your state and local fire regulations are based on.
On-Premises Store – One of the key requirements determining whether this space requires a sprinkler system is how large it is. While the term “micro-distillery” suggests a very small operation, this is not always the case. Micro-distilleries are defined not based on their physical size but rather based on their annual production volume and the different types of business activities they engage in. If your operation includes a store in an area bigger than 12,000 square feet, it will require a sprinkler system.
Business Office – Under the IBC, sprinklers are required whenever the floor areas exceed the permitted allowable areas for a non-sprinklered building based on the occupancy classification and the type of construction. Based on the areas provided in the table below and given the likely small size of your office area relative to the rest of your operations, sprinkler system protection would probably not be required for this area alone. However, by virtue of being part of a multiple occupancy, it would probably have to be included in any system installed to protect your operations.
Distillery Operation – As a whole, your distillery operation will likely be considered a High Hazard Industrial Occupancy, which is defined as the use of a building or space within a building for industrial operations that include the use of high hazard materials, processes, or contents. Given this, your entire distillery area must be fully covered by automatic sprinklers.
Storage Areas – In addition to the requirements in the IBC, the regulations contained in Chapter 16 of the NFPA 30 Flammable and Combustible Liquids Code will almost certainly apply to any distillery, particularly in storage areas because this is where the greatest risk of fire and explosion resides.
Table 1: IBC requirements for sprinkler systems based on IBC occupancy codes for common micro-distillery operations.
| Common Business Activities for Micro-distilleries | IBC Occupancy Group | IBC Requirements |
|
Tasting room |
A-2 (applies to a space within the building in which people gather for food and/or drink consumption) |
An automatic sprinkler system shall be provided for all fire areas containing Group A-2 occupancies where one of the following conditions exists:
|
|
Distillery tours |
A-3 (assembly for recreation or amusement and other assembly uses not otherwise classified) |
An automatic sprinkler system shall be provided for all fire areas containing Group A-3 occupancies where one of the following conditions exists:
|
|
On-premises store |
M (use of a building or space within the building for the display and sale of merchandise) |
An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy where one of the following conditions exists:
|
|
Business office |
B (use of a building or space within the building for office transactions, including storage of records and accounts) |
An automatic sprinkler system shall be provided throughout buildings containing a Group B occupancy where one of the following conditions exists:
|
|
Distillery operations |
F-1 Moderate Hazard Industrial or H-3 Hazardous Industrial (use of a building or space within a building for industrial operations that include high hazard materials, processes, or contents are conducted; applicable occupancy depends on the total quantity of spirits contained in the facility) |
IBC 903.2.4: An automatic sprinkler system shall be provided throughout all buildings containing a Group F-1 occupancy where one of the following conditions exists:
IBC 903.2.5: Automatic sprinkler systems shall be provided in high-hazard occupancies. |
|
Storage of distilled spirits |
S-1 Moderate Hazard Storage (use of a building or space within a building for storage that is classified as a hazardous occupancy and does not include S-2 low-hazard, non-combustible materials) |
IBC 903.2.9: An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists:
|
Types of Sprinklers Required
Unfortunately, it isn’t possible to provide a simple summary of the requirements regarding the specific types of sprinklers required in micro-distilleries because each operation is unique in terms of its location, building characteristics, and the types of business activities it engages in. Also, depending on what codes your state and local regulations are based on, requirements might differ from location to location.
If you are planning to locate your distillery in an existing building, you should conduct a thorough analysis that considers all the factors that could impact fire safety, including:
- How old is the building and how is it constructed?
- Are there sprinklers already installed in one/more areas and if so, what type are they? When was the last time they were tested?
- Will your distillery operation be more hazardous than the prior use it is replacing?
- Will any part of your operation require a change in occupancy classification?
These questions are important because if your building is divided into different fire areas with the barriers necessary to prevent a fire from spreading from one area to the next (e.g. firewalls), you may be able to install different systems tailored to the fire risk in each.
Most often, the requirements regarding the types of sprinklers needed will be based on the NFPA 101 Life Safety Code. Generally, these can be either wet or dry sprinkler systems, but wet systems are preferred[1] . Requirements for their installation will in most cases be based on NFPA 13 Standard for the Installation of Sprinkler Systems.
While the regulatory landscape with regard to fire safety requirements specific to micro-distilleries remains unclear, there are three important steps you can take now to ensure your distillery is well poised to be in compliance when new codes that may be developed for this burgeoning industry:
- Analyze your risks – Understand what type(s) of fire safety systems you have in the building where you are considering or already operating your distillery.
- Consult your local authority having jurisdiction (AJH) to see if there are any specific requirements locally and what requirements you will need to meet.
- Consult with a professional to ensure that any existing fire safety systems you have in place are in compliance with current codes and fully functional.
Count on Koorsen for Expert Navigation
Whether you are considering opening a new micro-distillery or are already in operation, Koorsen has experts ready to help you navigate the complex maze of regulations – including the gray areas – to understand which ones apply to your unique operation. We can help you ensure your micro-distillery will not only be in compliance with all applicable fire codes but will provide the fire protection you need to keep your employees and customers safe. Contact Koorsen today to learn more.
