Any project development clustered as a ‘high hazard’ requires special consideration and approval from respective authorities.
In Malaysia, the industrial practitioner is expected to be commonly exposed with such reports prepared by professional consultants, such as the Control of Industrial Major Accidents Hazard (CIMAH) report of the Department of Occupational Safety and Health (DOSH) and Environmental Impact Assessment (EIA) report by Department of Environment (DOE) for example, but...
Very rare we hear about the Fire Safety Design Philosophy (FSDP) report of BOMBA that has been widely practised since 2003 with the Performance Based Approach (PBA) for the non-compliance of the prescriptive code.
So, what is the FSDP all about?
In principle, FSDP is a technical assessment scrutinized by professionals to determine the potential fire hazard and risk, including possibilities of an explosion to have occurred (radius impact study) and dissemination of toxic release fume where all of these consequences are potential to cause fatalities, injuries of the workers and nearby people surrounding of the incident place including property damages.
Through the FSDP report, the competent building practitioner will determine the appropriate fire prevention system to be successfully designed, installed and tested with the clarified hazardous materials processing involved, bulk storage and production, a complex industrial chemicals and petrochemicals process and production, power plant facilities and others where the need for installation of these fire prevention systems is not clearly defined in prescriptive code (UBBL-by Law,1984-10th schedule) or (SBO-by Law,1994-Schedule J).
The assessment determines the appropriate fire prevention system for the fire hazard and risks inside the premises.
The need for FSDP preparation
In line with the allotment of Uniform Building By-law (1984), by-Law 236, where the Director General of FRDM could request any building owners to have a fixed installation system of unique fire detection and extinguishing systems if the said premises have a potential hazard and risk due to its ample storage, trend, occupancy or its size.
Moreover, referring to the 10th Schedule of UBBL-by Law or Schedule J of SBO by-Law also indicate that the purpose group for factory (VI), which runs the hazardous material processing and production or bulk storage, requires providing a fixed prevention and suppression system.
Unfortunately, both allotment (by-Law 236 & 10th schedule/ Schedule J) does not clearly define the types of firefighting and fire safety installation systems required.
Hence, the FSDP assessment is needed to overcome this matter. The purpose of FSDP is to determine the best appropriate firefighting and fire prevention system of the premises based on hazard and risk assessment conducted inside the premises considering various factors as explained in the above paragraph. It also serves as a guideline to FRDM personnel (Fire Safety officers) during plan processing and document verification for architectural and M&E plan approval.
Here are building categories that require for submitting the FSDP report which are; dangerous/high-risk buildings, dangerous/high-risk industrial buildings, industrial chemicals and petrochemical plants, power plant generating facilities, and any buildings not categorized in the purpose group of UBBL by Law/SBO by-Law and buildings with unique, complex and extraordinary design.
Processing plan involved with FSDP
The principal submitting person (PSP) or architect will inform the FRDM regarding the proposed development plan and would officially apply to meet for a technical discussion to determine the firefighting and fire prevention system proposed for the project development.
The PSP and the consultant or submitting person (SP) will present the technical presentation to FRDM regarding the proposed development plan. Typically, the content of the discussion in the earlier stage is merely focused on the proposed project development introduction, the design concept of the building, the exact location of the proposed site and the activity of the business, including fire prevention requirements.
From the above discussion, the appointed SP will prepare the FSDP accordingly and will present the outcome to FRDM again to finalize the proposed firefighting and fire prevention system of FSDP based on hazard and risk assessment.
One of the methods used by SP for the assessment is by using special design software to run a simulation, such as computational fluids dynamics (CFD). The compiled document (hard copy) will be submitted officially to FRDM if there is no amendment to be made after the presentation for written approval by FRDM.
Then, the architectural and M&E plan will be submitted according to the FSDP report for plan approval.
The content of the FSDP
The FSDP report is prepared only by Professional Fire Safety engineers, Mechanical engineers and Chemical engineers with a minimum of 5 years in the related field. The content of the FSDP, in general, is listed below:-
Introduction : (Briefly explained the company background, site location and proposed plant/premises)
List of Consultants : (Project Owner and Design, Architect, Civil & Structure Engineer, Mechanical Engineer and Fire Safety Consultant)
Finish Products and Raw Materials : (Including the byproduct if necessary, Material Safety Data Sheet (MSDS) to be attached)
Building and Structures : (Detail layout of buildings and structures to be attached such as dimension and usage)
Product Processes : (Briefly explain all the processes involved, excluding confidential business information)
Hazard and Risk Analysis
Fire Protection System including Fire Hydrant and Access Road
Water Supply Requirements for Fire Control and Extinguishment
Emergency Response Set-up
Maintenances of Fire Protection Systems
Fire Safety Training
Codes and Standards for System Design
As part of any design and development process, hazard and risk identification are required to determine the different levels of threats and fire risk areas. National Fire Protection Association 704 (NFPA 704) will be adopted as a tool for these purposes. The project components were categorized in four (4) risk rankings, namely High, Moderately High, Moderate and Low, based on the identified fire hazards, specifically:-
High: Areas where a catastrophic spontaneous fire is possible due to a large amount of combustible material and process-related ignition sources.
Moderately High: Areas where a spontaneous fire is possible due to the combustible material and process-related ignition sources.
Moderate: Areas where the spontaneous fire risk is low due to lack of either process-related ignition sources or combustible material; if flammable material is present, it is adequately protected by passive measures.
Low: Areas where a spontaneous fire is not possible under normal circumstances.
The worst-case fire scenario can be identified or estimated from the initial investigation of potential incidents at similar facilities worldwide. Potential events also can be described, together with possible consequences and safeguards employed to control incidents. The potential for such an incident can be effectively reduced by clearly understanding the FSDP for its hazard and applying adequate safety measures.
Fire protection requirements for the proposed development will be as 10th Schedule and Schedule J. The recommended fire protection systems shall be as to the level of hazard and risk involved for each building structure.
Buildings and structures that did not have a high fire risk and exposure hazards are clearly indicated in the 10th Schedule, and Schedule J follows the prescriptive requirements. Such an example of the building was Administration Buildings, Guard Houses, Canteen Buildings and Laboratory Buildings. The fire protection systems will be as to the 10th Schedule and Schedule J in areas involving hazardous processes.
Also, foot Note 2 of the Schedule as for any fire protection systems required by the FRDM. For Note 3, Fire Alarm System and Note 4, Emergency Lighting, the fire safety will follow the prescriptive requirements in the law for each building or structure. Under Extinguishing System, Note 2, of the 10th Schedule and Schedule J, areas involving hazardous processes were required to satisfy Section VI, Factory, and Item 5 Special Structures (b) Hazardous Processes. In this section, the extinguishing systems indicated were A, B, C and D only for UBBL, 1984 and A, B, C, D, E or F of SBO, 1994, which in Note 2 of the Schedule J, the letters mean as follows;
Note 2 of UBBL by-Law, 1984 (Amendment 2012). The letters in the second column of this Schedule refer to the types of fixed extinguishing systems, as follows:-
A-Hose Reel System
C-Gaseous Extinguishing System
D-Pressurized Fire Hydrant
While Note 2 of the SBO by-Law, 1994. The letters in the second column of this Schedule refer to the types of fixed extinguishing systems, as follows:-
A. = Automatic Sprinklers System
B. = Water Spray System
C. = High Expansion Foam System
D. = Carbon Dioxide System
E. = Approved Halogenated Extinguishing System
F. = Other Automatic Extinguishing System
G. = Hose Reel
H. = Hydrant System.
For the proposed development plan, the Fire Safety Concepts Tree of the National Fire Protection Association (NFPA) 550 will be the primary guide in identifying the fire extinguishing systems. The three primary fire safety objectives are life safety, property protection, operational continuity and environment safety.
The logic of the Fire Safety Concepts Tree is that fire safety objectives can be accomplished by preventing a fire from starting or by managing the impact of the fire. To determine the required firewater storage capacity, worst-case scenarios and fire occurrence areas need to be identified.
The proposed development will provide a dedicated fire water storage tank with a capacity of not less than the required minimum total fire water demand and is linked to a backup industrial water pit with a capacity of more than 50% of the minimum total fire water demand. Fire protection systems pumps will be located in a protected pump house at a safe distance. All fire pumps must
comply with FM/UL standards as stated in NFPA 20.
Besides the fire water demand, supplementary fire safety equipment shall also be provided, such as portable foam firefighting equipment according to foam AR-AFFF (Alcohol-Resistance Aqueous Film Forming Foam) concentrate calculation.
The following standards will also design an active fire protection system provided for this proposed development: -
Pressurize Hydrant System NFPA 24
Hydraulic Hose Reel System NFPA 14
Clean Agent Fire Extinguishing System NFPA 2001
Fire Alarm System NFPA 72
Water Spray System NFPA 15
Automatic Sprinkler System NFPA 13
Fire-Water Pump System NFPA 20