Last September, a draft code application bulletin, called CAB for short, was developed by the Washington-based National Association of State Fire Marshals (NASFM), an association of senior fire officials from states across the U.S.
Titled “Pallet Fire Loading Impact on Sprinkler Design,” the CAB sparked a blazing debate that has intensified over the last seven months.
Jim Narva, chief project manager at NASFM, says the purpose of the CAB is to “provide accurate technical guidance to code officials in jurisdictions that have adopted a model fire code and are verifying that the installed automatic fire sprinkler system has been maintained as originally installed per NFPA 13.” The National Fire Protection Association (NFPA) standard outlines the minimum requirements for the installation of automatic sprinkler systems.
“All the draft CAB is intended to do is remind fire code officials to verify that the automatic sprinkler system has been designed and installed to protect the hazard that currently exists in the area protected,” says Narva. “NASFM is not a code enforcement agency. The draft CAB is not a law or an enforceable code. Rather, it is a guidance document and educational tool for use by code officials.”
But that’s not how some pallet manufacturers and associations see it. Several have banded together to dispute that seemingly innocuous goal.
A Serious Threat? The controversy arises from language in the CAB indicating pallets with composite wood blocks require the same sprinkler protection as their all-plastic counterparts.
According to the draft CAB, solid-oak, stringer-type pallets were used years ago to develop pallet classification and protection requirements. “These pallets are hardly used today because of their cost and weight,” the document states. Instead, many wood pallets use composite blocks made from wood chips and sawdust bound together with plastic resin. This, according to the CAB, means those wood pallets, under NFPA 13, are considered reinforced plastic pallets, requiring a UL 2335 listing, a two-commodity class sprinkler protection upgrade or large 16.8 k-factor sprinkler protection.
Citing section 184.108.40.206 of the 2007 edition of NFPA, the CAB states, “‘a pallet having any portion of its construction consisting of a plastic material’ is considered a plastic pallet. Some plastic
components are obvious to spot, while others may not be. Since composite wood is made by binding together wood particles with adhesive resins, which are made into pallet components, such as top boards, sideboards, blocks and the like, these pallets are considered plastic.”
NASFM concludes that inspectors enforcing a model fire code should note any changes to occupancy or activities that would negatively impact operation of the automatic fire sprinkler system. “A change in pallet type would be an example of a potential violation,” the document states. The CAB then provides a list of pallet types subject to sprinkler upgrades and idle storage protection penalties (See chart on pg. 28.). All UL 2335-listed pallets, regardless of construction, would not require upgrades or penalties. Also exempt are UL 2335-listed plastic pallets, 100% wood pallets with metal fasteners and 100% steel/ aluminum pallets.
Opponents of the CAB say it is inappropriate for NASFM to issue the guidance to code enforcement officials before requesting formal interpretation from the NFPA 13 committee or a technical change to the NFPA 13 standard.
In February, the National Wooden Pallet and Container Association (NWPCA) released an industry alert to members stating the “state fire marshals’ proposal is devastating to our industry, end users and retailers.” Calling the CAB a “serious industry threat,” the alert stated, “the traditional benchmark wood pallet, around which warehouse sprinkler systems were designed and installed, is being challenged—despite the fact that there is no body of evidence to suggest any need whatsoever for such changes.”
The alert went on to describe the “threat” in detail: “NASFM is proposing a two-grade increase for the fire ratings on block pallets and reexamining ratings for stringer pallets…Wood pallet companies who make, repair or store wood block pallets would have to upgrade sprinkler systems as would all warehouse industries.”
The notice referenced an unnamed safety engineer who said “the change would cost an estimated $2 billion to change the sprinklers throughout his company’s warehouse and distribution system to accommodate the new fire ratings.”
The other problem with the CAB, according to NWPCA, is that “NASFM has given plastic pallets containing the fire retardant deca-bromine a fire grade equal to the current oak stringer pallet benchmark.” This action, along with the upgrade on wood block pallets, would lead end users to switch to plastic pallets without a scientific reason to do so, the association said.
Furthermore, the NASFM “has ignored the fact that five states have banned use of bromine in furniture and other wood products because of health concerns. It further has failed to consider those wood products use a few grams of this chemical, while the average plastic pallet contains three to four pounds of the potentially harmful substance.”
Finally, the NWPCA says the CAB proposes new certification requirements that are unnecessary and even harmful. “Of the 1.2 billion pallets in circulation in the U.S., 93% are wood; less than 1% are certified,” said Bruce Scholnick, president and CEO of the NWPCA, in a prepared statement. “This requirement would obviously provide a lucrative new revenue source to a certification entity,” he continued. “But it would be at the expense of businesses trying to stay afloat in a troubled economy.”
The controversy reached a fever pitch in early March, when NASFM hosted a meeting at the headquarters of Underwriters Laboratories in Northbrook, Ill. The goal of the meeting was to gather comments and ultimately finalize the CAB.
But that didn’t happen. “Several attendees of the March 12 meeting expressed concern that the draft CAB was being perceived in the field as a final document and being viewed as an enforceable law or a code enforcement directive,” says NASFM’s Narva. “This misunderstanding persists today, though the document is clearly marked ‘Discussion Draft—Subject to Revision.’ To alleviate this, NASFM has removed the draft CAB from the NASFM Web site pending further review and revision.”
Narva was quick to point out that “the draft CAB is not a proposal. NASFM is not proposing to change any language in NFPA 13,” he explains. “NASFM is not proposing any new certification requirements. Further, NASFM is not suggesting any reinterpretation of existing model codes and standards.”
But companies that include wood pallets in their overall product offering disagree. Desmond Hadden, account manager for Ongweoweh Corp., recently wrote customers to alert them to “sweeping changes being proposed by NASFM that will have a disastrous effect on the pallet industry and inflict a massive increase in supply chain costs.” The impact on users of pallets, Hadden wrote, “is twofold: more expensive pallets combined with the burden of costly facilities upgrades.”
Kevin Shuba, group president of CHEP Americas, wrote in comments to NASFM that the NFPA created a new definition of a plastic pallet in the 2007 version of NFPA 13. A plastic pallet was described as “a pallet having any portion of its construction consisting of a plastic material,” Shuba stated. CHEP, a pallet and container pooling company, supplies and manages both wood and plastic pallets for end users.
That definition created an unnecessary code enforcement challenge, according to comments submitted jointly by NWPCA’s Scholnick; CHEP’s Shuba; David S. Russell, president of IFCO Systems; and David Lee, CEO of PECO Pallet Inc. The authors make note of the NFPA 13-2007 retroactivity clause, which states, “a requirement for a sprinkler upgrade based solely on the plastic pallet definition change would be unnecessary in any facility or structure in which the sprinkler system has been appropriately designed to manage pallet fire loading in accord with previous editions of NFPA 13.”
“A typical wooden pallet with composite wood blocks is roughly 95% wood and 5% urea formaldehyde [considered a type of plastic by NFPA] by weight,” added Shuba in a separate letter to NASFM. “It is largely indistinguishable from a nine-block, all-wood pallet. The use of urea formaldehyde in this application is an adhesive and does not have the burning properties commonly associated with other plastics.”
Scholnick of the NWCPA backs up Shuba’s comments in his own letter to NASFM. “The blocks themselves are primarily wood chips bound by an adhesive that does not contain chemical components similar to those of plastic,” he writes. “Furthermore, that material does not make a wood pallet a plastic pallet any more than the nails used to hold the boards together make it a metal pallet.” Scholnick concludes: “The fact that minute particles are being added to wood does not change those properties to a degree that would warrant a dramatic alteration to existing warehouse infrastructure.”
According to Shuba, the draft NASFM bulletin contains language stating that nine-block, all-wood pallets represent a “severe hazard,” requiring significant upgrades in sprinkler protection. However, says CHEP’s president, “there are no product standards or listings that are required for allwood pallets—this is because the fuel load and performance characteristics associated with all-wood materials are well established. Indeed, decades of experience have shown that current sprinkler protections in manufacturing and shipping facilities for wood pallets provide adequate control.”
Shuba closes his letter to NASFM by reiterating that CHEP is “aware of no new developments in the use, construction or performance of allwood, nine-block pallets or wooden pallets containing composite wood blocks that would constitute a rationale for an urgent new enforcement regimen.”
The Grocery Manufacturers Association wrote to NASFM in support of NWCPA and CHEP.
The Other Side
Not every pallet company believes the CAB is a threat. In fact, some welcome it. In written comments to NASFM, Rex Lowe, president of iGPS Co., a supplier and pooler of plastic pallets, urged the association to issue and implement the draft in its current form without delay.
“Any further delay in the implementation of the NASFM draft continues to unnecessarily place the safety of lives and property at risk, as evidenced by recent warehouse fires fueled in part by stored wooden and composite pallets at the Imperial Sugar warehouse in Georgia and the Knight Transportation warehouses in Phoenix, among others,” Lowe wrote.
Steve Letnich, vice president of sales and marketing at Worthington Steelpac, a provider of steel pallets, says: “If the recommendations become the standards, then the steel pallet industry could benefit because our product is non-combustible.” He explains that the current standard is based on a traditional wood stringer pallet with metal fasteners and says that Worthington Steelpac’s products, because they are non-flammable, are assumed to exceed the requirements of the current standard. For that reason, “the steel pallet industry needs to push the certification organizations to create a separate standard for the use of steel versus wood or plastic,” he continues. “Currently, we are grouped in with the wood stringer pallet in terms of the standard for sprinkler coverage in buildings, and the benefits of steel are not being considered within the standard,” Letnich says.
He adds, however, that if the NASFM CAB is implemented as written, most facilities would not have the proper sprinkler systems in place. “They will need to upgrade their sprinkler systems to remain compliant,” he says.
Brent Theiling, general manager of LM Containers, a supplier of aluminum pallets and containers, also feels something is missing from the CAB. Other non-flammable options, such as aluminum pallets, are not being explored or publicized, he says.
In formal comments to NASFM, Theiling references the CAB summary chart outlining pallet types subject to upgrades or penalties. “There are several pallet types that have no associated penalties,” he writes. “With the use of these pallets, business owners have options other than upgrading their sprinkler systems or being subjected to a two-commodity class change…I would recommend that NASFM incorporate technical information about aluminum pallets into the upcoming training.”
Theiling adds: “Aluminum pallets are durable, last many years and can be recycled. It takes a great deal of heat to melt aluminum, but even if an aluminum pallet melts, there is still residual value because it can be put back in service or recycled. The first thing people think about is converting to plastic pallets. But they might consider other options.”
NASFM is planning to roll out its education program, or report on its progress, at its annual conference June 19-21 in Redmond, Wash. If finalized, the program will be used as guidance for code enforcement personnel to determine the adequacy of fire protection of pallets.
Updates will be posted at NASFM’s Web site.