Up to Code: Check Your Permits & Codes
Your grand opening won't be so grand if the space you've designed for your paint area doesn't comply with the necessary permit requirements and building codes.
By Tara Munro
1/1/1998
The grand opening of a new or remodeled shop
is one of the brightest moments for a collision repair business.
It's the result of a great deal of faith, thousands of dollars,
hours of labor and night after night of pacing the floor worrying
about the details.
But before the shop opens, an idea is born
in the mind of the shop owner - and that idea must be transferred
to paper. While not everyone has the luxury of building a brand
new shop tailored to their operational needs, those who do often
encounter difficulties in the permitting process and, subsequently,
generate additional costs with reverse engineering because permit
and code issues weren't factored in prior to breaking ground.
Blending a productive traffic flow with permit
requirements and building codes is the key to success. A multitude
of coding bodies and agencies in the United States, as well as
the American Disabilities Act, have an effect on the layout of
a shop - and these effects need to be anticipated in the design
phase. Just because you've met installation codes for that new
spraybooth doesn't mean your shop is "permitted" to
use it. The building that houses that spraybooth must also answer
to a specific code.
Until there's one code that applies nationwide,
it's impossible for this article to address every single issue
that can arise in the design, construction and operation of a
body shop. But by anticipating permit needs in the earliest stages
of the design phase, a shop owner has more control over his destiny
- and construction costs.
Zoning
Zoning will make or break a shop - certain
areas can be zoned for businesses but not for businesses with
spraybooths. For example, zoning can be appropriate for a painting
operation but not for the sale of used cars (an issue for auto
sales that operate or would like to operate a reconditioning facility).
Zoning hearings may be required.
Permit Terms
Parameters, as viewed by zoning and plans
review personnel, are defined by the nature of the permit request.
For instance, the words "install" vs. "replace"
(new or upgrade), "a change in use" (e.g. carpet store
to body shop), "transfer of ownership" and "use
groups" make all the difference in what's required to obtain
permits. It's immaterial as to whether the tenant owns or leases
the building. The language on the "Use and Occupancy"
permit determines what will actually take place in that building,
regardless of building ownership.
Code Authorities
Geography determines what layers of code must
be satisfied locally, as well as nationally.
- The Building Officials and Code Administration International,
Inc. (BOCA) and the National Fire Protection Association (NFPA)
are the ruling codes in the Midwest, Upper Midwest and Northeast.
- The Southern Building Code Congress International, Inc. (SBCCI)
governs the South as far west as Texas.
- The International Association of Plumbing and Mechanical Officials
(IAMPO) is recognized in 14 Western states, as well as in Maine
and Texas, as is the International Conference of Building Officials
(ICBO).
- The Uniform Fire Code (UFC) is recognized west of the Mississippi
River.
- The Occupation Safety and Health Administration (OSHA) relies
heavily upon the NFPA throughout most of the United States.
Various miscellaneous agencies, such as those appointed by the
cities of Chicago, Philadelphia, New York and the state of North
Carolina, are local code authorities that must be considered in
the process. One single entity, The National Electrical Code (NEC),
is recognized throughout the United States.
Currently, there's a concentrated movement to align all the various
codes and produce a single manual by the year 2000 that will be
recognized nationwide. While this will eliminate a great deal
of confusion, it will also produce opportunity for plans reviewers
and fire marshals to pay closer attention to a shop's design and
code compliance.
Building Requirements
- Height and width - This issue is especially critical for shops
installing oversized spraybooths for the painting of trucks, buses,
construction equipment, fire trucks, limousines, etc. The tail
wags the dog in that the building size and access door requirement
may increase the original square footage calculated to house the
operation.
- Paint storage and mixing rooms - The codes that cover the
mixing and storing of paints often confuse even the plan reviewers.
Regardless of geography, the three governing codes are OSHA, NFPA
and the appropriate building codes. Should a conflict in codes
arise, the most stringent of the three codes will prevail.
The standard for a paint-storage room is based on 150 gallons
of paint in storage. It's possible to store more but construction
standards will increase, as will fire suppression needs. NFPA
has a minimum one-hour burn rating for paint storage; BOCA requires
two hours. Also keep in mind that 18-gauge sheet metal is not
suitable for construction of paint-storage rooms. NFPA 30 (storage
and mixing of flammables) is used by OSHA for the criteria of
wall construction and ventilation of paint mixing and storage
rooms.
Most prefabricated mixing rooms will meet or exceed the minimum
criteria under NFPA 30, but they don't meet criteria for storage
under any codes, unless the walls are one-hour rated and carry
a UL rating for such. This is subject to local interpretation
of the applicable codes - what applies in Kansas may not work
in Boston. Also, if the booth is up and finished but the paint
storage problem hasn't been addressed, the permit will not be
finalized.
- Prep decks - As a distant cousin of the spraybooth,
prep decks are not generally described in code books and must
be modified to fall within known parameters, which is accomplished
by modifying a prep deck so it resembles and functions similar
to an open-face spraybooth. This allows local authorities to use
their existing code books to approve a prep deck, which can legally
host painting activity. Several manufacturers have already done
this.
Reversing the theory, however, isn't possible. Recycling prep
decks to be used as spraybooths, under OSHA guidelines (NFPA 33),
is neither permitted nor "permitable," since the curtains
on a prep deck are fire retardant but not fire rated.
- Access doors - For each personnel door in a spraybooth,
there must be two exits from the building in the immediate vicinity
of the spraybooth. These exits must be established specific distances
from the personnel doors of the spraybooth. Roll-up doors don't
satisfy this criteria.
- Aisles and access - Code requirements determine the
width (varies from 36 inches to 60 inches) of aisles or passageways
next to the booth that provide access to emergency exits. The
width of these passageways may be negotiable with local authorities
if there's consistently only one operator in the booth at any
given time. The UFC and NFPA are the prevailing authorities.
- Floor Pits (spraybooth and prep deck exhaust) - These
pits will cradle the duct work that supports the exhaust system
of the prep deck or spraybooth in particulate removal. Any concrete
pits may require a building inspector's approval.
- Exhaust Stacks - Ductwork supporting the exhaust stacks
must meet specific codes. The position and height of the stack
is controlled; the type of stack head required can be very specific;
and a spraybooth stack can't be piped in such a fashion that it
affects other air-exchange or climate-control technology used
by the shop. (One indicator of bad stack height and position is
a shop's office air conditioner smelling very much like the inside
of the shop's spraybooth.) The height of the exhaust stay may
also be determined by the local EPA office or health department.
- Air-makeup units - Special codes govern the use of
direct-fire air-makeup units inside a building, as well as the
use of an indirect-fire burner (air supply and vents). Code dictates
the area required around a panel box, the gas meter and ductwork.
- Electric and gas power supplies - These are determined
by shop size and equipment and need to be wired/piped accordingly.
Some jurisdictions may require such items as panel schedules and
gas/electric riser diagrams for a booth permit.
Booth Requirements
- Lighting - Many choices exist for spraybooth light
fixtures. Light fixtures must be faced with tempered or wire-reinforced
glass and be properly sealed. Lights used next to a door opening
must be Class I, Div. II vapor lights rated for that area. Surface-mounted
interior lights must be Class I, Div. I and explosion proof. Recessed-mounted
interior lights must be Class I, Div. II and are required to be
equipped with switches on the glass panels to control the spray
solenoid.
- Exits - Codes dictate that doors be available in a
high hazard area 75 feet in any direction from any point in the
spraybooth without common path of travel. The number of personnel
doors required in a spraybooth is determined by the length and
width of the booth itself. The distance between exits in a spraybooth
is a code issue (the minimum requirement for 200 square feet is
two doors), and the doors themselves should be 30 to 32 inches
wide. These are minimum requirements on such exits.
- Fire Ratings - Any wall construction in a booth must
meet or exceed the requirements of NFPA 33 (1995). Spraybooths
must be fabricated of 18-gauge sheet-metal steel and spray rooms
must be of one-hour rated firewall construction. The sheet metal
can have two walls (sandwiched) with a total metal thickness of
18 gauge (insulation between the walls doesn't count in this calculation).
The one exception to this rule is when the wall panel itself carries
a UL listing. An excellent example of this would be cooler rooms
annexed off the interior of a restaurant; walls of this nature
are required by code.
The Perks of Permits
Permits may seem like more of a hassle and a hindrance when you're
first trying to get your body shop up and running, but without
them, you may not be up and running for long. Getting all your
permits in order before you open your doors will ensure that you'll
be permitted to stay in business.
Writers Tara L. Munro, compliance administrator, and David
L. Hindman, president and technical consultant, are employed by
DLH Environmental, a company that provides permitting and testing
services to painting/coating professionals. To contact DLH, call
(888) 226-6040 or go to (www.dlhe.com).