The 2021 edition of the IBC (International Building Code) Introduced some major changes regarding distillery occupancy.
2021 IBC 307.1.1 #18 and #19 states that distilleries and storage of distilled spirits in casks shall not be an H (high hazard occupancy) and shall rather be the occupancy that is most nearly resembles.
It is important to note that these uses shall “still be in compliance with the fire code”
Per the 2021 IBC, a distillery of any size would be an F-1 (medium hazard factory), as 306.2 lists manufacture over beverages over 16% ABV under this occupancy.
For barrels, under 311.2, S-1, (medium hazard storage), we see this includes storage of beverages over 16% ABV.
This is a big shift from 2018 and earlier editions of the IBC, which, if the MAQ was exceeded, would require an H-3 (High hazard occupancy) for distilleries and barrel storage.
In summary, the following occupancies apply under 2021 IBC, regardless of quantities:
A major implication of this occupancy designation, as opposed to previous editions of the IBC, is that a distillery, and barrel storage, of F-1 and S-1 would not necessarily need a fire separation from other occupancies when utilizing the non-separated mixed use provisions of the code.
A major conflict exists, due to the fact that the IBC says these uses shall still be in compliance with the IFC (fire code).
When we go to the fire code, Table 5003.1.1(1) tells use that when we exceed the MAQ of 240 gallons of class IB and IC flammable liquid (ABV >16% ), in a sprinklered building, then the occupancy shall be H-3. So, this clearly conflicts with the building code, and requires an interprettation from the local building and fire departments to see which rule shall govern.
Basically, if you have a distillery under 2021 IBC, over the MAQs, you need to have the local authorities make a determination as to if the IBC or IFC rules, making a distillery F-1, or H-3, respectively.
The barrel storage is less ambigous, as it is except from chapter 50 in the IFC that requires distilleries to be H-3. Also, a new chapter 40, and its commentary in the fire code explictitly calls out that barrel storage shall be S-1, so it is solidified in both IBC and IFC that barrel storage shall certainly be F-1.
The 2024 editions of the IBC and IFC have newer language, eliminating MAQs for distilleries and barrel storage, and therefore eliminating the IFC Table 5003.1.1(1) conflict. Under the 2024 IBC and IFC, all distilleries and barrel storage, regardless of size are plainly F-1 and S-1 occupancies. respectively.
