What Is High Piled Combustible Storage

High piled combustible storage is determined by the storage commodity, storage height, and the storage area.  The commodities are divided into moderate hazard (Class I-IV) and high hazard (essentially Group A Plastics).  For moderate hazard commodities the height is limited to 12′ with a storage area of 2,500 square feet and high hazard commodities are limited to 6′ in height and 500 square feet.   When those limits are breached, then the International Fire Code (IFC) requires that plans be developed and submitted to show compliance with the requirements for high piled combustible storage. In addition to this building permit, the fire marshal of the municipality, which is considered the authority having jurisdiction (AHJ), may require a high piled combustible storage operational permit used to monitor and collect the fees for annual inspections for compliance. It is important to note the difference.

In its essence, a high piled storage permit is nothing more than a piece of paper, or more specifically the receipt for payment of the permit. What it is not, however, which is usually detailed in the “fine print,” is an approval for compliance of high piled storage because the permit was not accompanied by a plans review and final inspections to validate the permit.  This is often misleading to tenants because they obtain their occupancy certificate, then apply for and receive a high piled storage permit, only to be visited by a fire marshal and subsequently find out that it is invalid because plans were never submitted for for approval and inspections never called.

In its essence, a high piled storage permit is nothing more than a piece of paper, or more specifically the receipt for payment of the permit.

Every jurisdiction is different, and the above scenario is describing the City of Houston.  But Dallas, Fort Worth, San Antonio, Austin, and even other areas in Houston such as LaPorte, Missouri City, and Sugar Land have high piled storage requirements.  The reason for the confusion is that within the AHJ there are building departments and fire marshal’s offices, both of which have a stake in the high piled combustible storage process.  The degree to which they communicate and overlap resources will determine how confusing the process.

For any AHJ, plans must be submitted for any building permit involving a tenant move in, tenant addition, or tenant remodel, which are usually given in Chapter one of the building and fire codes. This includes the installation of racking as well as high piled combustible storage (even if only storing products on the floor), regardless if an operational permit is required. The correct process consists of properly filling out the occupancy permit application to include high piled combustible storage as part of the initial occupancy plans. Doing so ensures that the proper plans are reviewed for the occupancy permit corresponding to the actual use of the space.

These plans will include a fire code site plan, high piled storage code review pages, egress lighting pages, and structural rack pages (if racking will be used for storage). These documents are then submitted along with the supplied pages from the architect and other professional service providers, depending on the scope of tenant improvement work.

The actual high piled combustible storage permit is a fire marshal regulated operational permit, similar to sign, dumpster, liquid, propane, and other operational permits. This permit is often renewable per a certain time frame, such as annual or biannually, and helps the fire marshal keep track of the buildings with combustible storage to maintain an inspection schedule on these occupancies. Each tenant in each space of a building, whether a multi-tenant or entire building, is required to have a building permit for their certificate of occupancy. However, some AHJs do not have the operational permit requirements. This is where the confusion lies.

Therefore, the question of “Do I need a high piled storage permit?” is an incomplete question. For a building permit when getting your certificate of occupancy a building permit is always required for high piled storage. However, depending on the jurisdiction, an operational permit may not be required. The way to find this out is to call both the building department and the fire marshal’s office of the jurisdiction and ask both what they require for plans review and permitting.

Another option is to get assistance from a professional service provider such as Active Industrial Fire Protection.  Companies that have an expertise in the codes can help you  navigate the process to ensure a successful project.

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