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Fire codes for baled cotton amended

The U.S. cotton industry has obtained amendments to national fire and building codes that had classified densely packed baled cotton as a hazardous material.

In addition, after testimony from the National Cotton Council and others, cotton gins were exempted from general industry standards for fire codes. Fire marshals in some states considered seed cotton the same as loose fiber for fire and building codes and also considered cotton as a highly combustible material for storage.

If the codes and classification had not been amended, it would have increased insurance costs, paperwork and new gin and warehouse construction costs significantly, according to the NCC.

Final approval of the revisions is expected this fall.

This is the second time in 10 years that the industry has addressed perceptions of densely-packed cotton bales as hazardous materials, according to Phil Wakelyn, National Cotton Council senior scientist of environmental health and safety.

“The first time, in the mid-1990s, the cost of shipping cotton was rising due to higher insurance and additional paperwork,” he said. “The Department of Transportation and the International Maritime Organization considered cotton a 4.1 flammable solid. It had to have certain hazardous duty papers.”

The American Cotton Shippers Association asked the NCC to request changes to the Department of Transportation and the International Maritime Organization rules for vessel shipment of baled cotton.

Wakelyn and a team of researchers ran standard tests that the Department of Transportation uses as well as other flammability tests. “We couldn't demonstrate spontaneous combustion with science. It would have to reach 700 degrees to ignite.”

The team also conducted tests on fire-packed bales, to determine whether an internal smoldering fire would eventually break through a bale and spread to others.

Ed Hughs, agricultural engineer at the USDA Ginning Laboratory in Las Cruces, N.M., showed in laboratory studies that when fire was initiated inside densely-packed bales, they do not sustain combustion.

The study showed that internal fires can smolder and eventually break out in a bale that is compressed under 14 pounds per cubic foot. Fire will not break out if the bale compression is greater than 14 pounds per cubic foot. U.S. cotton bales are compressed to 22 pounds per cubic foot, “so we have over a 50 percent safety factor built in,” Wakelyn said.

Cotton bales also passed a very severe open flame test, as well as match and cigarette tests.

The research was put into a petition and presented to the Department of Transportation and the International Maritime Organization. In 1999, the International Maritime Organization removed cotton as a flammable hazard and no longer required special papers for shipping. The U.S. Department of Transportation followed suit.

That was not the end of the issue, however, noted Wakelyn.

In 2000, various fire and building codes were combined under the International Code Counsel. In addition, the National Fire Protection Association developed separate fire codes. The International Code Counsel and National Fire Protection Association are the two major fire and building code councils operating in the United States.

They classified cotton bales as hazardous material, again raising concern in the cotton industry that insurance rates would be hiked and paperwork would increase

In 2004, using the research they did for the International Maritime Organization and the Department of Transportation, an action team consisting of Wakelyn, consultant Marcelo Hirschler of GBH International, BarryNevius, Southeastern Cotton Ginners Association and Dale Thompson, NCC's manager of marketing and processing technology, appealed to the National Fire Protection Association and the International Code Counsel to change the codes to reflect that cotton in compressed bales is not a flammable hazardous material.

“We did a good job of answering all questions and had a good scientific basis,” Wakelyn said. “We had good results to back it up and had the research published in a peer review journal.

“This was very important to the National Fire Protection Association and International Code Counsel codes committee,” Wakelyn said. “The National Fire Protection Association and International Code Counsel agreed with the NCC's position and made the appropriate revisions to the proposed codes.” They are expected to be approved at the National Fire Protection Association's annual meeting in June and the International Code Counsel meeting in September.

Meanwhile, “in North Carolina, a ginner who had remodeled his gin and wanted to build a new structure to house it, was told by a local fire marshal that numerous safety measures would be required for construction, including the installation of a sprinkler system.

“The fire marshal was considering seed cotton the same as loose cotton, a combustible fiber, and wanted to consider a gin operation as a general industry,” Wakelyn explained.

This classification, if applied to other gins, “would have made it very difficult to obtain new construction permits and would have increased the cost of construction of new gins by 40 percent.”

Gins and gin manufacturers in North Carolina, South Carolina and south Texas asked the NCC to take the issue before the International Code Counsel, the umbrella organization for the International Building Code and the International Fire Code. Both these codes are presently in force in the Carolinas and Texas.

In 2004, the NCC presented its position to the International Code Counsel, recommending that cotton gins be exempted from the industrial classification. The paper, also presented at the 2005 Beltwide Cotton Conferences, said in part, “ginning is part of agriculture and seed cotton is a raw agricultural commodity and should be considered such, and the ginning operation is an extension of the harvest.”

“When you think about it, when you remove cotton from the field, it's seed cotton,” Wakelyn said. “It's a perishable, agricultural commodity which has no value until you separate the seed from the fiber. It's enclosed during the processing, so it makes no sense to put sprinklers on it.

“At the end of the operation, the seed is conveyed into trucks and once it's in a storage house, it comes under a different regulation. Baled cotton goes to a warehouse and it comes under the regulations you would want for a densely-packed bale of cotton.”

The International Code Counsel's Code Development Committee first denied the cotton industry's request, but an appeal was made to the assembly and the committee's action was overruled by its membership in cotton's favor, according to the NCC's Thompson. The revisions will have to be reviewed and approved by the full body of the International Code Counsel at its fall annual meeting.

“It's difficult to pinpoint the exact economic impact of the change in codes and the classification of ginning as agriculture,” Wakelyn said. “But with the cost of production and the short margins in our cotton industry segments, every little thing we do to help growers and ginners operate in an efficient manner is helpful to them.”

Wakelyn said some states are expected to be slow in adopting the new codes or in coming to terms with them. But the cotton industry has built a strong case and will work to get variances until the states have fully adopted the new code changes.

“Local fire marshals are likely to follow guidelines closely,” Thompson said. “But they've also got a degree of autonomy. They can either waive rules or make them more onerous if they choose to.”

Thompson stresses that the cotton industry is not out to skirt issues of fire protection and fire prevention in gins or cotton warehouses, it only wants to be fairly and properly regulated. “But agriculture is unique. Through our education programs such as gin schools and the efforts of our gin machinery manufacturers as well as gin and warehouse associations, we've self-policed ourselves. We know what's in our best interests.”

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