There are some major changes found in the 2024 edition of the International Building Code (IBC) and International Fire Code (IFC) that affect distillery design. Jurisdictions around the country adopt these codes at their own pace, so check with your state or locality to see what edition of codes is adopted/planned to be adopted soon. Not too many locations are on the 2024 codes yet, but we can expect more to adopt them in the coming years ahead.

2021 Code Conflicts

The 2021 edition of the IBC also saw a major change- focused on distilleries not being H-3. 2021 IBC 307.1.1 #18 listed distilling of beverages complying with the Fire Code as a NOT an H-3 occupancy. The problem in the 2021 editions, though, was that the 2021 Fire Code (IFC) still had language/ requirements stating that a building/ space would be an H-3 occupancy if it exceeded the MAQs (Maximum Allowable Quantities). So, there was this conflict found in the 2021 edition of the codes that required AHJ interpretation.

But, under the 2024 IFC, there are now exceptions found in the IBC as well as the IFC clearly stating that distilleries shall not be classified as H-3.

2024 IBC 307.1.1 and Table 307.1- Occupancy Exemptions and Hazardous Materials Exceptions

The 2024 IBC reorganized this section a bit, now providing part of the Distillery H-3 exception with a table rather than a list. These sections explain that materials in this table shall not be classified as a group H occupancy, and that they shall not contribute to MAQs. References are shown below:

2024 IFC Occupancy Exemptions

203.6.1 of the 2024 IFC reflects 307.1.1 of the IBC. It refers back to the table in the IBC, explaining that distilleries shall never be an H-3, and the materials shall not count toward MAQs.

What does this all mean?

The 2024 code changes have cleared up inconsistencies found between the IBC and IFC in the 2021 editions.

Under the 2024 IBC/ IFC, the following apply to distilleries:

1. All Distilleries, regardless of size will not be classified as an H-3 occupancy. The main components will be classified as a F (Factory) or S (Storage) occupancy depending on the use of the space.
2. Distilleries can often have no fire separation separating them from adjacent occupancies. Other requirements may trigger a fire separation, but since distilleries are no longer H-3 occupancies, it opens up many opportunities to have a non-separated mixed use building with a distillery of any size.
3. Distilleries of any size must be sprinklered. Even teeny tiny distilleries must now be sprinklered under the 2024 codes, per IBC 903.2.4.2
4. Allowable Areas are much larger for distilleries. As an example, under 2018 codes, an H-3, 1 story, wood constructed distillery building would have a max area of 5,000 sf. That same distillery under 2024, as an F-1 occupancy would now be allowed to be up to 34,000 sf.
5. Egress requirements are less stringent for F-1 as compared to H-3 occupancies. You can have a further distance to an exit.

What about exhaust, classified electrical, etc?

Other requirements, such as classified electrical regulations, high rates of exhaust, hazmat signage etc may still apply, as they may be triggered by other requirements besides occupancy and MAQs. The alcohol is still considered a hazardous material that still has other requirements found in the codes.

More to come in future blog posts about these details!