Fire Safety Analysis FAQs
(Prepared 8/04)
Q1: Why do I need to do a fire safety analysis (FSA) for my existing plant?
A: The 2001 edition of NFPA 58, the LP-GAS Code, was changed to require a written
FSA for facilities with more than 4000 gallons water capacity (wc) of aggregate storage.
The FSA is required within three years of adoption of that edition of the Code by the
Authority Having Jurisdiction (AHJ).
Q2: What is the purpose of a FSA?
A: The purpose of the FSA is to provide local emergency response agencies with
information on the various safety features built into a propane installation that are used to
control the product and the operations that may take place at the facility. Also, the FSA
evaluates the hazard to the neighborhood surrounding the facility and the capabilities of
local emergency response agencies.
Q3: How do I determine whether a facility or installation requires a Fire Safety
Analysis?
A: A facility must have a written FSA prepared if it has storage containers that are
greater than 4,000 gallons water capacity; or, if the aggregate amount of storage
containers at the facility exceeds 4,000 gallons water capacity and those containers are
either connected to one another through a manifolded filling or service connection.
Q4: Who in my organization can perform the FSA?
A: There are no special credentials required to fill out the FSA forms. However, the
person doing so should be familiar with operations taking place at the facility and the
product control hardware and how it functions.
Q5: What if no one in my organization can perform the FSA?
A: In addition to providing direction for company employees performing FSAs, the
manual can also be used by a consultant, professional engineer or anyone else a company
wishes to designate to prepare this document.
Q6: What elements must be included in the analysis?
A: The manual has been developed to correspond to the general requirements of
Paragraph A.3.10.2.2 of NFPA 58 (product control measures, local conditions of hazard
within the container site, exposure to/from other properties, population density and
congestion, probable effectiveness of plant fire brigades or local fire departments,
consideration for adequate application of water for effective control of leakage, fire or
other exposures, and (if necessary) a designated time period for review with local
emergency response agencies).
All of the information contained in the FSA forms must be reviewed and filled out if it is
applicable to the facility. Additional information (drawings or details on the operation of
equipment) can be submitted at the discretion of the submitter or if required by the
authority having jurisdiction (AHJ).
Q7: Are there installations that are not covered by the FSA manual?
A: The manual does not address the following:
1. Marine terminals, refrigerated LP-gas storage and the transportation of LP-gas
either by rail tank cars or by cargo tank trucks.
2. Storage of LP-gas in salt domes and caverns.
3. Installations of ASME LP-gas containers on roofs of buildings. This type of
installation is excluded from the scope of this manual (even though a FSA is
required for such operations according to section 3.10.2.2 of the 2001 edition
of the Code) primarily because of the rarity of such installations in the United
States.
4. Cylinder filling operations at a dispensing facility, unless the storage threshold
for LP-gas has been exceeded, requiring an FSA to be prepared.
5. The use of facility employees performing as a “fire brigade.”
Q8: How do I present the analysis to the AHJ?
A: The owner or representative of the facility can schedule an appointment with the local
emergency response agency or AHJ and present the FSA at that time. Be familiar with
the elements of the FSA and be prepared to answer any questions that may arise.
Q9: My facility was built long before the town expanded to our property boundaries.
What do I need to consider in this situation as I prepare a FSA?
A: Existing facilities are required by the 2001 edition of NFPA 58 to have a written fire
safety analysis performed within 3 years of the effective date of the Code. The FSA
manual and forms allow and encourage users to perform the analysis using the edition of
the Code that was in use at the time the facility was constructed. (The FSA Manual
automatically takes this into account by indicating when certain product control
equipment became required by the Code.) This fact should be emphasized to the AHJ
and it must be made clear that by performing the FSA, a facility owner is not required to
“update” the facility by installing new equipment, except in the rare cases where
retrofitting of equipment was required.
Q10: What assurance do I have that the AHJ will accept the results of this FSA
document? Can the AHJ require a professional engineer to perform the analysis?
A: Although the AHJ is not required to accept the results of the FSA, the goal of
developing this tool was to provide a credible document to fire and code officials.
Hence, NFPA played a prominent role in its development; in addition, the effort was
enhanced by the participation of fire protection engineers currently serving on the
Technical Committee on Liquefied Petroleum Gases. Should any question arise as to the
credibility of the FSA, both NPGA and NFPA are available to clarify the development
and rationale of the manual.
Q11: Does submitting a fire safety analysis mean that a sprinkler or other type of water
protection will have to be added to an existing facility?
A: The FSA does not require additional equipment or systems to be added to existing
facilities. Rather, the FSA reflects NFPA 58 in that the first consideration shall be an
evaluation of total product control system, including emergency shutoff and internal
valves equipped for remote closure and automatic shutoff using thermal (fire) actuation
pull-away protection. Although fire suppression is an optional means of protection, the
most effective means is to prevent the uncontrolled release of fuel, and the requirements
in NFPA 58 for product control equipment and employee training effectively accomplish
this goal.
Q12: What are my options if the AHJ will not accept a proposed installation without
water protection for the facility?
A: The background and training of some AHJs will make applying water or other
suppression agents a priority to a propane facility. As the facility operator, you should be
knowledgeable on the important aspects of product control and training, as reflected in
the requirements of NFPA 58. Make an effort to contact the AHJ and utilize the
information in the FSA manual to educate the AHJ on the overall importance of product
control and the realistic product release scenarios that are portrayed in the manual.
Contact NPGA if additional assistance is needed.
Q13: How do changes in the new (2004) edition of NFPA 58 affect the FSA requirements?
A: The procedure is referred to as an “Incident Prevention Review” in the new edition of
NFPA 58; the essential elements of the process, however, have not changed. The code
also does not require an incident prevention review where a written fire safety analysis
exists.
