Can I Put a Pilot Plant in a Laboratory?

 Published on September 14, 2019

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Richard Palluzi
Pilot Plant and Laboratory Engineering, Safety, and Design Consultant at Richard P Palluzi LLC
85 articles Following

The short answer is yes, of course you can locate a pilot plant in a laboratory. There are no codes
or regulations that prevent you from doing so as long as you meet all the other code
requirements. And those can be more difficult.

First you need to understand that the main code for laboratories, NFPA-45 Fire
Protection for Laboratories Using Chemicals does not cover pilot plants. It cannot
be applied to them regardless of what the organization wants to do. (See “Can you apply NFPA-
45 to a Pilot Plant?” at https://www.linkedin.com/pulse/can-you-apply-nfpa-45-
pilot-plant-richard-palluzi/ for more discussion on this point.) But NFPA 45 does not
prevent you from putting a pilot plant in a laboratory area. It will just require you to include the
pilot plant’s inventory of flammable chemicals in the laboratory’s total. Neither the International
Building Code (IBC) nor International Fire Code (IFC) prohibit you from putting a pilot plant in
a laboratory. Neither, in fact, ever mention a pilot plant. Again, they will require you to include
the pilot plant’s inventory of hazardous materials, a much broader list, in the laboratory’s total.
And, if this total exceeds what the IBC/IFC calls a maximum allowable quantity (MAQ) then
you will be forced to take expensive and difficult measures to upgrade the area. These include
more rigorous non combustible construction, shorter distances to exits, higher fire ratings, and
numerous other restrictions that can easily double the cost to construct the laboratory. (You may
want to consider the University of Wisconsin course Successful Laboratory Design:
Grass Roots, Renovations, and Relocations for more information on this area and
how to comply. For additional information see https://epd.wisc.edu/course/laboratory-
design/.)
What putting a pilot plant in a laboratory area will do is force you to evaluate several things:
1.      With the pilot plant’s inventory, will I need to raise my laboratory hazard classification to
comply with NFPA 45? Will I be able to comply even if I use the highest laboratory hazard
classification?

2.      With the pilot plant’s inventory, will I be able to stay below the IBC/IFC MAQ? If not, it is
usually almost always impossible to economically raise the laboratory to a H (High hazard)
classification once the area has been constructed.

3.      Will the amount of flammable materials in the laboratory due to the pilot plant and the
potential for leakage or release from the pilot plant require the area around the pilot plant,
perhaps even the entire laboratory to be electrically classified?

The last concern is often improperly evaluated leading to a very high potential for problems.
Section 5.5.5 of NFPA 45 states:

Laboratory work areas, laboratory units, and chemical fume hood interiors shall be considered as
unclassified electrically with respect to Article 500 of NFPA 70 unless operations are determined
to cause a hazardous atmosphere. (See 9.5.5 and 11.3.2.2.)

The annex provides more guidance on this subject:

A qualified design professional and owner safety officer should review the laboratory conditions
through a hazard analysis and/or risk assessment to determine if a hazardous (ignitable)
atmosphere could be developed within the laboratory work area, laboratory unit, and/or fume
hood. If a hazardous atmosphere could be developed, these areas should be electrically classified
per NFPA 70, Article 500.

In the author’s experience, rarely is a “qualified design professional” involved in this analysis.
Too often it is a researcher, an architect, or another engineer or scientist who, while very
knowledgeable and skilled in their field, is virtually clueless about the principles of electrically
classifying an area. Simple and incredibly inaccurate models are used to confirm their belief that
no fire or explosion hazard exists. Ventilation is assumed to be adequate with little or no realistic
analysis. (See “Ventilation Dilution: A Safe Way to Avoid A Fire or Explosion or a Placebo?”
at https://www.linkedin.com/pulse/ventilation-dilution-safe-way-avoid-fire-
explosion-placebo-palluzi/.)
 These and numerous other issues are never adequately addressed. And so often, significant
hazards go unrecognized. Consider the issues with the University of Hawaii explosion. (See
“Some Comments on the Accident Investigations Report to the University of Hawaii at Manoa
on the Hydrogen/Oxygen Explosion of March 16, 2016”
at https://www.linkedin.com/pulse/some-comments-accident-investigations-
report-hawaii-manoa-palluzi/ for further discussion.)
I am not suggesting that the mere presence of a pilot plant in a laboratory requires the area to be
electrically classified; I am suggesting that it needs to be looked at very carefully by someone
who understands the issues. And that is usually not going to be the researcher, the laboratory’s
architect, nor possibly even the facility’s fire official. (For more information on this subject, you
may want to consider the University of Wisconsin courses on Area Electrical
Classification and Hazardous Area
Wiring (see https://epd.wisc.edu/course/understanding-electrical-area-
classification-and-hazardous-area-wiring/ for more details) or Area Electrical
Classification for Pilot Plants and
Laboratories (see https://epd.wisc.edu/course/area-electrical-classification-
for-pilot-plants-and-laboratories/ for more details.)
For free standing pilot plants (i.e. those out on the laboratory floor versus inside a hood or
ventilated enclosure, putting them in a separate area adjacent to the laboratory but separated by a
fire wall may be a safer long term solution. For pilot plants installed in large custom ventilated
enclosures, careful attention needs to be paid to the ventilation design (See “Ventilated
Enclosures for Lowering Area Electrical Classification”
at https://www.linkedin.com/pulse/ventilated-enclosures-lowering-area-
electrical-richard-palluzi/ and “Ventilated Enclosures: Why Do They Often Fail to Work
Properly at https://www.linkedin.com/pulse/ventilated-enclosures-why-do-
often-fail-work-properly-richard-palluzi/).
These and similar subjects are addressed in more detail in the University of Wisconsin’s course
on Pilot Plant and Laboratory Safety 1: Basic Principles and Code Compliance. Further
information on this course can be found at https://epd.wisc.edu/course/pilot-plant-and-
laboratory-safety-1-basic-principles-and-code-compliance/.