2025 Fire Code and Hazardous Material Reporting

Posted: June 25th, 2025

Authors: Elijah W.

As industrial and commercial facilities continue to handle a wide range of hazardous materials, understanding and complying with fire code requirements is more critical than ever. This article highlights key takeaways from a recent presentation — featuring ALL4 consultants Eli Waddell and Meredith Pedraza — on fire code standards, permitting obligations, and hazardous material reporting.

International Fire Code (IFC) and Local Application

The International Fire Code (IFC) sets minimum safety standards for fire prevention, protection, life safety, and the handling of hazardous materials. Developed by the International Code Council (ICC), the IFC is updated every three years and is supported by related I-Codes including building, mechanical, plumbing, and electrical. Unlike the National Fire Protection Association (NFPA), which provide several standards that are focused on specific operations, hazards, or fire protection methods and equipment, the IFC provides broader regulations pertaining to a building’s construction and occupancy, especially concerning hazardous material storage and use.

The IFC has been adopted by 41 states and many municipalities, often with localized modifications. However, jurisdictions may claim adoption of the IFC without having effective permitting systems in place, making local enforcement and compliance complex. California, for example, has adopted its own code nearly identical to the IFC.

Understanding Group H Occupancies and Thresholds

Facilities must track the types and quantities of their hazardous materials to ensure they stay below the limit for each hazard category, known as a Maximum Allowable Quantities (MAQs). If MAQs are exceeded within a given control area, the area may be reclassified as a Group H Occupancy (H-1 through H-5), each with increasing hazard levels and corresponding code requirements, such as:

Mechanical ventilation
Spill control and secondary containment
Automatic fire suppression systems
Standby power
Fire rated walls and separations

Depending on the type of operation, there may be additional requirements that apply and the change in occupancy could have additional impacts on the buildings design and allowable area. Even outdoor areas and low-quantity storage must comply with specific guidelines if thresholds are approached.

Permitting Requirements

The IFC relies on local adoption and enforcement through two main types of permits:

Construction Permits: Needed for installing or modifying fire systems or specific types of equipment, or for processes and areas where hazardous materials exceed permitting thresholds.
Operational Permits: Required for ongoing activities involving hazardous materials or other regulated operations (totaling 57 distinct types under the IFC).

Permit applications often require submission of a Hazardous Materials Inventory Statement (HMIS) and, in some cases, a Hazardous Materials Management Plan (HMMP). Where quantities of hazardous materials exceed a corresponding MAQ, it is common for the City or Authority Having Jurisdiction (AHJ) to request a more detailed application, often including a Fire Code Technical Report, or even complete a conditional use permit application as part of the preliminary process.

HMIS and HMMP: Key Reporting Tools

The HMIS provides critical information for first responders and authorities by documenting:

Product names and chemical composition
Hazard classifications and storage/use quantities
Locations and control area details

The HMMP, where required, includes business details, facility layouts, storage maps, and emergency contact information. Requirements vary by jurisdiction—some cities like Phoenix, AZ request HMMPs only upon inspection, while others like Scottsdale, AZ provide standardized forms.

California’s HMBP: A State-Specific Mandate

In California, facilities handling significant quantities of hazardous materials (equal to or greater than 55 gallons of liquids, 500 pounds of solids, or 200 cubic feet of gases) must submit a Hazardous Material Business Plan (HMBP) through the California Environmental Reporting System (CERS). The HMBP includes business info, hazardous inventory, emergency response plans, and site maps, and must be updated within 30 days of any significant operational change.

Final Thoughts and Compliance Tips

Accurate reporting is essential. Over-reporting may lead to unnecessary expenses and misclassification, while under-reporting can result in non-compliance, unsafe conditions, and legal liabilities. Understanding your local code, identifying applicable permit types, and accurately classifying materials are vital for operational safety and regulatory compliance.