AIRCRAFT HANGAR FIRE PROTECTION GUIDANCE
FOAM CODE COMPLIANCE
Publication of National Fire Protection Association (NFPA) 409, Standard on Aircraft Hangars,
2022 edition, has created confusion on foam fire suppression system requirements. The flow chart
(below) provides guidance on various options to achieve code compliance relative to fire suppression
systems based on the International Building Code® (IBC), 2021 edition; International Fire Code®
(IFC), 2021 edition; and NFPA 409, 2016 edition. NFPA 409, 2022 edition will not be referenced
by the IBC or IFC until the 2024 edition.
This document is intended to provide general understanding of hangar foam suppression system
requirements, options and alternates. It is highly recommended that the services of a licensed
and experienced design professional be be utilized for the design and permitting process to achieve
best success for the project.
Determine applicable International NFPA 409,
STEP 1 codes and standards,
adopted editions, and
Building Code,
International
Standard on
Aircraft Hangars
local amendments. Fire Code
STEP 2 GROUP I DOOR HEIGHT: 28 feet or higher OR
HANGAR BAY: over 40,000 sf
FOAM: Typically required. Go to Step 4.
Determine Hangar
Group Type GROUP II DOOR HEIGHT: 28 feet or less AND
Per NFPA 409 and HANGAR BAY: typically 12,000–40,000 sf
IBC Table 412.3.6. FOAM: May not be required. Go to Step 3.
GROUP III DOOR HEIGHT: 28 feet or less AND
HANGAR BAY: typically less than 12,000 sf,
may be up to 30,000 sf (see note)
FOAM: May not be required. Go to Step 3.
Note: Hangar construction type and fire rating may allow
hangar bay area increases (IBC Table 412.3.6)
National Air Transportation Association
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AIRCRAFT HANGAR FIRE PROTECTION GUIDANCE
STEP 3 YES
STOP. Foam fire suppression not required.
(IBC Section 412.3.6 “Exception”).
Fire sprinklers may still be required due to building
If a Group II hangar
area. Verify with local code requirements.
and IBC is applicable:
Is this an FBO with separate
repair facilities on site and NO Continue to Step 4.
used for storage of transient
aircraft?
STEP 4
Determine if foam is required
by hangar group and operations.
GROUP I GROUP II GROUP III
>28 FT. DOOR HEIGHT >28 FT. DOOR HEIGHT OR <28 FT. DOOR HEIGHT OR <12,000 SF,
OR >40,000 SF >12,000 SF OR < 40,000 SF may be up to 30,000 SF
(see note in Step 2)
Foam Required Foam Required Any Hazardous Operations?
Hazardous operations are
Foam fire suppression system required. See next page for potential defined as fuel transfer, welding,
alternatives to the foam requirement. torch cutting, torch soldering,
doping or spray painting.
YES
Foam Required
NO
No Foam Required
(IBC 412.3.1 and
NFPA 409 8.8.1.2)
Note: NFPA 409’s use of “hazardous
operations” in a Group III hangar is
NOT the same as “hazardous operations”
in a Group II hangar.
National Air Transportation Association
818 Connecticut Avenue, NW • Suite 900 • Washington, DC 20006
(202) 774-1535 • (800) 808-6282 • Email:
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AIRCRAFT HANGAR FIRE PROTECTION GUIDANCE
If foam is still required, consider the following:
n Utilize the services of a licensed and experienced n Use the Alternative Means and Methods Request
design professional (Fire Protection Engineer and/or (AMMR) process permitted by the IBC/IFC and the
Architect) to develop an alternative design approach local AHJ.
in lieu of foam. Both the IBC/IFC and NFPA provide
These alternative approaches typically require the
for alternative approaches if the prescriptive
integration of a Fire Protection Engineer and/or
requirements of the code cannot be achieved.
Architect to assist in evaluation, assembly of the
n Discuss the use of NFPA 409, 2022 edition with the reports and coordination with the AHJ.
Authority Having Jurisdiction (AHJ). If acceptable:
n Evaluate if the fire rating of the hangar can be increased.
Group I or II Hangar: Utilize the Fire Risk Assessment
For example, a 20,000 square foot Group II hangar
(Chapter 4) or the Performance-Based Design
(typically required to have foam) can be downgraded
(Chapter 5) approach to eliminate foam.
to a Group III hangar (without foam) by increasing
Group II Hangar: Foam may be eliminated if none the fire rating of the structure. (IBC Table 412.3.6)
of the following hazardous operations are performed
within the hangar: fuel transfer, welding, torch n Decrease the fire area of a single hangar by creating
cutting, torch soldering, doping, hot work, spray multiple hangars separated by 2-hour fire walls,
painting, oxygen service, composite repairs, fuel thus limiting the hangar to Group II or Group III.
system or fuel tank maintenance, aircraft cabling, (IBC 412.3.6.2)
wiring changes or initial electrical system testing. n Separate accessory spaces, such as offices and shops, by
a 1-hour fire barrier wall (gypsum board, concrete block
or concrete) to reduce the hangar fire area. Accessory
spaces can then be excluded from the hangar area used
to determine the hangar “group.” (IBC 412.3.6.2)
n Use high-expansion foam (no PFAS) with foam
generators at the ceiling or synthetic fluorine free foam
(no PFAS) with monitors (canons) along the perimeter.
In a Group II or Group III hangar, consider a closed-
head sprinkler system using synthetic fluorine free foam.
n Most importantly, engage the services of a qualified
Fire Protection Engineer and/or Architect to start
discussions with the AHJ. The design professional
must have experience with aircraft hangars, current
protection methods and applicable codes/standards.
National Air Transportation Association
818 Connecticut Avenue, NW • Suite 900 • Washington, DC 20006
(202) 774-1535 • (800) 808-6282 • Email:
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AIRCRAFT HANGAR FIRE PROTECTION GUIDANCE
Recommendations to Reduce Inadvertent (Accidental) Discharge
Keep in mind that inadvertent (accidental) foam system discharges have occurred due to inappropriate activation
of the foam releasing system (the electronic components). NFPA 409 only requires the foam system to discharge
upon activation of the ceiling sprinkler system waterflow switch or a manual release station. These are the minimum
requirements; however, additional features can be added to increase the robustness and reliability of the foam
releasing system. Consider the following:
Use optical flame detection in lieu of the fire Use weatherproof/weather resistant manual
sprinkler waterflow switch with AHJ approval. release stations mounted in weather resistant
covers.
n Less prone to inadvertent activation
n Provide gasketing around the cover to reduce
n More robust device
water entry
n Can be sequenced to require activation of two
n Install with conduit entering from the bottom of the
flame detectors before releasing foam
manual release station to reduce water/condensation
n Use multi-spectrum infrared flame detectors entry into the device
with no UV component
Use a foam releasing control unit (panel)
n Some landing lights utilize a light within the separate from the building fire alarm system.
UV spectrum that could cause an inadvertent
n Reduces potential for discharge when testing the
activation
fire alarm system
Use two methods of activation to eliminate n Isolates all foam initiating features in one separate
a single point of failure with AHJ approval. location
Methods include:
Discuss the use of abort/stop stations with
n Two optical detectors
the AHJ.
n One optical detector and a sprinkler waterflow
n Abort stations can hold discharge when first
switch
activation signal occurs
n One optical detector and a ceiling heat detector
n Stop stations (combined with special valves) located
n One ceiling heat detector and a sprinkler water- adjacent to manual release stations can stop the
flow switch flow of foam once started
Most importantly, engage the services of a qualified design professional (Fire Protection Engineer
or Architect), experienced in aircraft hangars and current fire protection methods.
RESOURCES | LINKS Click on report names below to view online.
• NATA Fire Marshal Toolkit >
• Review of Foam Fire Suppression System Discharges in Aircraft Hangars, November 2019 >
• Review of Foam Fire Suppression System Discharges in Aircraft Hangars, February 2021 >
• Performance Criteria for Aircraft Hangar Fire Protection Systems, January 2022 >
• NFPA 409, Standard on Aircraft Hangars, 2022 edition >
• US Air Force Foam Sundown Policy, November 2021 >
National Air Transportation Association
818 Connecticut Avenue, NW • Suite 900 • Washington, DC 20006
(202) 774-1535 • (800) 808-6282 • Email:
[email protected] 4
AIRCRAFT HANGAR FIRE PROTECTION GUIDANCE
Top 10 Most
Frequently Asked
Questions about
Foam Requirements
Q: Are Fire Marshals required to
use the 2022 edition of NFPA
409? A: Each local authority adopts
new versions of NFPA standards at
different cycles. Since NFPA 409 is
typically adopted by reference in the
IBC/IFC, these codes still reference the
2016 NFPA 409. The 2022 edition may
not be adopted until the 2024 IBC/IFC
are adopted.
Q: Why are Fire Marshals still
enforcing the 2016 edition of Q: What are my options for new Q: When should I use the AMMR
NFPA 409? A: NFPA 409 is typically construction if my Fire Marshal is process? A: An AMMR should be
adopted through reference with the not willing to follow the 2022 used if a prescriptive approach to code
IBC/IFC and these codes will not adopt edition of NFPA 409? A: If the code compliance, or “by the book,” cannot be
the 2022 edition until the 2024 edition is does not allow for removal of the foam used to eliminate foam.
released. system for new construction, the IBC/ Q: When should I consider using
Q: How often does the NFPA IFC allow for the use of an Alternate a high-expansion foam system?
409 standard get updated? Means and Methods Request (AMMR) A: Whenever foam is required.
A: Every five years. approach. Many AHJs have a standard High-expansion (hi-ex) foam does not
format to use for this approach. contain PFAS and typically requires less
Q: How often does the IBC/IFC
get updated? A: Every three years. foam concentrate than other foam
systems. In addition, high-expansion
Q: Does the IBC/IFC take prece- foam systems use generators that mount
dence over NFPA 409? A: Yes, the up in the ceiling area so they do not
IBC/IFC reference NFPA 409 for fire take up floor area in the hangar.
suppression requirements. Where
NFPA 409 provides non-suppression Q: Do high-expansion foam
design requirements in conflict with systems use AFFF? A: No. AFFF
the IBC/IFC, the IBC/IFC shall govern (aqueous film forming foam) contains
unless the entirety of NFPA 409 has been PFAS, which has become an environ-
adopted by the local AHJ. It is advised to mental hazard, and makes very small
consult the local AHJ if a conflict occurs. bubbles that float on the hangar floor.
Hi-ex does not contain PFAS, discharges
Q: What is the relationship through a generator at the ceiling level,
between the IBC/IFC and NFPA and drops bubbles down to the hangar
409? A: The IBC/IFC provide reference floor. Hi-ex systems are designed to fill
to NFPA 409 for fire suppression the hangar to at least 1 meter of foam
requirements. bubbles.
National Air Transportation Association
818 Connecticut Avenue, NW • Suite 900 • Washington, DC 20006
(202) 774-1535 • (800) 808-6282 • Email:
[email protected] 5
