Fire and Building Codes and Storage of Baled Cotton

Cotton fibers were considered combustible fibers and listed in a Hazardous Material Classification in the fire and building code standards for the two national fire and building code organizations in the U.S. -- International Code Council (ICC) and National Fire Protection Association (NFPA) after they were revised in 2000. This placed unnecessary requirements on Baled Cotton Warehouses for both new construction and occupancy permits for existing buildings. In 2004-05 based on the extensive research conducted by and for the cotton industry (Wakelyn and Hughs, 2002,  “Evaluation of the Flammability of Cotton Bales”, Fire and Materials 26, 183-189), meaningful changes in the 2006 NFPA Code Revisions and 2006 ICC Code Revisions have been accomplished (both published in Fall 2005 and effective 1/1/06). The same course was followed in 2005 for NFPA 13 (Standard for the Installation of Sprinkler Systems). 

Amendments to International Code Council (ICC Home Page] 

Internal Fire Code (IFC) [amendments accepted 2005 for 2006 code]

International Building Code (IBC) [amendments accepted 2005 for 2006 code]

The amended ICC code (IFC and IBC) contains the similar new language and storage requirements for densely-packed baled cotton [cotton made into banded bale with a packing density of at least 22 lbs/ft³ (225 kg/m³); complies with ISO 8115] as the amended NFPA 1, 101, and 5000.

• Defines densely-packed cotton bales in Section 2902(IBC) [F] 307.2.
• Section 201 (IBC [F] 307.5) General Definitions High-hazard Group H-3 excludes densely-packed cotton as a combustible fiber and
• Revises Table 1804.2 (IBC [F] Table 415.9.2.1.1) Quantity Limits for Hazardous Materials in a Single Fabrication Area in Group H-5 to exclude densely-packed baled cotton.

Seed cotton is listed as an agricultural product [Section 2903.4] and defined [Section 2903.1] as a “Perishable raw agricultural commodity … which requires ginning to become a commercial product” in the IFC. Ginning is an agricultural process operated by agricultural workers (according to the comment support language used to justify the listing in Section 2903.4 Agricultural Products). So it follows that ginning facilities are agricultural buildings, covered by fire and building code requirements for agricultural buildings not general industrial rules.

Amendments to National Fire Protection Association (NFPA) 

NFPA 1 Uniform Fire Code (UFC) [amendments accepted 2005 for 2006 code]

NFPA 5000 Building Code [amendments accepted 2005 for 2006 code]

NFPA 101 Life Safety Code [amendments accepted 2005 for 2006 code]

NFPA 230 Standard for the Fire Protection of Storage [withdrawn]

NFPA 13 Standard for the Installation of Sprinklers Systems [amendments accepted in principle]

The amended NFPA 1, 101, and 5000 contains the similar new language and storage requirements for densely-packed baled cotton [cotton made into banded bale with a packing density of at least 22 lbs/ft³ (225 kg/m³); complies with ISO 8115] as the ICC code (IFC and IBC).

• A new definition for "densely-packed baled cotton" [cotton made into banded bales with a packing density of at least 22 lbs/ft³ (225 kg/m³)] is included in the NFPA codes ( NFPA 1, 101, and 5000);
• NFPA 230 is withdrawn and Annex D of 230  (storage of baled cotton) becomes Annex L (Protection of Baled Cotton History of Guidelines) of NFPA 1 (Annex L is final; see the document that was approved);
• Chapter 62 of NFPA 1 (on combustible fibers) becomes Chapter 45 of NFPA 1, which puts it outside the jurisdiction of the section on hazardous materials;
• Chapter 60 of NFPA 1 (hazardous materials) has no requirements for “densely-packed baled cotton";
• Chapter 34 of NFPA 1 (on general storage moved from NFPA 230) has no requirements for baled cotton storage.
• NFPA 13 is being revised to follow Annex L. (accepted in principle in 2005)

What this means

This means that in IFC, IBC, and NFPA regulations densely-packed baled cotton is not a combustible fiber or a hazardous material and the non-mandatory guidance for storage of baled cotton (formally Annex D of NFPA 230) is now in Annex L of NFPA 1. Annex L is a similar to Annex D but a revised/updated version of the former Annex D of NFPA 230.

In the IFC seed cotton is as an agricultural product, ginning is an agricultural process, and so it follows that ginning facilities are agricultural buildings.

These amendments should result in lower insurance costs for cotton bale storage and bring reason to fire and building code requirements for storage of baled cotton [reduce costs of new warehouses by 40% and allow existing warehouses to expand or have other warehouses re-designated for cotton storage without increased requirements]. NCC, NCGA, and gin associations will make insurance companies aware of these changes and work to have insurance rates reflect it and be available to help in states that have not updated their codes to 2006.

Table 1. Cotton Producing States and the Codes Presently in Force

Looking for additional information? Check out ICC – International Code Adoptions  for information concerning codes that may apply in your area.