Original Message:
Sent: 2/14/2023 3:24:00 PM
From: James Tien
Subject: RE: Ethanol Handling
Hello Dirk and all,<o:p></o:p>
Although I am not a qualified engineer or code expert, through my past researches and what I was told by three independent fire code consultants the ethanol handling falls under C1D2. As I mentioned in my earlier reply, consult to the local jurisdiction and qualified engineer/consultant will be the best path to be sure the project gets done right. <o:p></o:p>
For Dirk's concern regarding the classification, here is I quickly found online which is inline with my statement:<o:p></o:p>
<o:p> </o:p>
"CLASS I, DIVISION 2
Class I, Division 2 locations are those in which volatile flammable liquids or gases are handled, processed or used. Normally they will be confined within closed containers or in closed systems from which they can escape only in the case of rupture or deterioration of the containers or systems."<o:p></o:p>
<o:p> </o:p>
This website also explains other classes and divisions. https://www.ldpi-inc.com/resources/classification-codes/#:~:text=Class%20I%2C%20Division%202%20locations,of%20the%20containers%20or%20systems.<o:p></o:p>
<o:p>Cheers,</o:p>
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James Yii-Jen Tien
Whitby, ON
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Original Message:
Sent: 02-14-2023 11:33
From: Dirk Loeffler
Subject: Ethanol Handling
Dear James:
You are mentioning C1D2 requirements in your post for Ethanol handling in a brewery. This is a classification for Class 1 (Explosives) Division 2 (Hazmat division), which should not be applicable in a flammable liquid application, which is a Class 3 product. The flammable vapors produced by flammable liquids do not move the product into a different hazmat class or category. I frequently come across fire marshals who do not know the fire code and/or interpret it properly. Therefore, consulting with an experienced expert for these matters is extremely important and can make the difference between approval or denial as well as save you boatloads of money. We went through this with numerous bulk tank applications and often the city and the fire marshal interpreted the regulations incorrectly and we ended up with much less volume than we could have legally stored. The same applies for flammable liquids.
Find somebody locally (ideally, in same state if not possible) who can advise you on the requirements per your local fire code, which supersedes the national fire code and is often more stringent. Ask local businesses who handle hazardous materials similar to your who they worked with and what their experiences were.
Cheers,
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Dirk Loeffler
Loeffler Hygiene & Safety Solutions
(404) 229-7583
loeffler.dirk@loefflerhygiene.com
Original Message:
Sent: 02-13-2023 14:44
From: James Tien
Subject: Ethanol Handling
Hello Nate,
My past experience in a similar field was to retrofit our facility to a hazloc environment for using 95% ethanol in substance extraction. The extraction process includes flammable ethanol handling, storage, and spill control. Although this project was in Ontario, Canada, our consultant did review the NFPA, Canadian National Fire Code and Ontario Fire Code all together. You may want to check local jurisdictions for their guidelines.
- local fire marshal and building department usually can tell you from their prospointives. This may not work so well if you are in rural area. You can also talk to specialists such as Fire Code consultant and engineer as how I started on my project to obtain a feasibility study report.
- Code consultant will need to understand your process, location/space to run the process, where and how much ethanol will be used and stored, type of equipment required, etc. then a feasible study will provide what needs to be done to adapt the new process. The first important point is to limit flammable vapour and appearance outside the closed-loop process. In this report the area will be clearly defined as a C1D2 hazloc.
- Civil engineer and electrical engineer will evaluate the current building configuration and come up with a solution to meet the C1D2 hazloc. Basically, how to effectively avoid ethanol vapour accumulation and ignition by ventilation, grounding, fire separation, spill control, etc. Training, SOPs, posting requirements may also indicated in the feasibility study will be on your company to execute.
- Once the area is defined, and a retrofit design is made, it is time to submit for fire marshal and building department to review and apply for building permit to perform the retrofit construction if needed.
It will make things much easier if the process is in a separate building, or the ethanol gets diluted at the point entering the building so all the potential hazards can be limited. If I recall correctly, when it is below 21% is generally much safer to handle inside the building.
In addition, you may also want to let your insurance company know as this may impact on your current policy.
Hope this helps and happy to chat further if you like.
Cheers,
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James Tien
Whitby ON
Original Message:
Sent: 11-16-2022 12:11
From: Nate Prusak
Subject: Ethanol Handling
Hello everyone,
We are currently positioning to start getting into RTD's and hard teas are next up here. I was curious what challenges you all faced when it came to handling and manufacturing with 190 proof ethanol. We are currently looking into mixing tanks and hazmat storage for the ethanol drums. Also have been dabbling with the fire marshal and trying to be up to code with explosion proofing the equipment.
I appreciate the time to read this and welcome all feedback!
Cheers!
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Nate Prusak
Maintenance Technician
Great Lakes Brewing Co
Cleveland OH
(216) 771-4404
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