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Dust Hazard Analysis for Islamorada Brewery North
3200 St. Lucie Boulevard
Fort Pierce, FL 34946
Prepared For:
Mr. Tyrone Bradley, President, Co-Founder
Islamorada Beverages
82229 Overseas Highway
Islamorada, FL, 33036
5/14/2021
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Summary
This report will discuss and identify code and safety measures related to the potential hazard created by the presence of
dust at the Islamorada Brewery North located in Fort Pierce, Florida. This report along with the Dust Hazard Analysis
(DHA) is a requirement found in the Florida Building Code, Florida Fire Prevention Code, and pertinent referenced
documents including NFPA 652, Standard on the Fundamentals of Combustible Dusts, 2016 edition. It will identify and
evaluate the potential fire, flash fire, or explosion hazards associated with the presence of one or more combustible
particulate solids in the process and facility.
Overview
Islamorada Brewery North is occupying and operating a brewing and tasting company at Runway’s End Commerce
Center located in Fort Pierce, Florida. The authority(s) having jurisdiction is St. Lucie County Building Official and the St.
Lucie Fire and Control District Fire Marshal. The building construction type is Type II under the Florida Building Code
(FBC) and is fully protected with an automatic fire sprinkler system in accordance with NFPA 13. The occupancy
classification for the brewery section of the building is F-2 – Factory- Industrial per the FBC. The edition of the FBC and
Florida Fire Prevention Code (FFPC) utilized for permitting are both 5th editions. A silo was installed at the exterior of the
building storing grain used in the brewing process. Additional conversions consist of a closed conveying system
(intrinsically safe auger driven) to bring the grain from the silo to a hopper/mill and subsequently into the vats. On
average four times per day, fifteen (1500) pounds of grain is transported from the silo through the milling machine then
into the vats.
During the building permit process and plan review process, the building plans examiner raised a concern regarding the
presence of combustible dust. The grain is moved from the silo through enclosed conduit and dropped into a hopper
where the kernel is cracked in a milling machine. Rollers in the mill crack the grain kernels and then it is transported
through a wall in enclosed piping inside the brew house. This conveyance process is also done through an intrinsically
rated auger driven system. It is important to note that the grain is not ground into a combustible flour/powder.
However, the process does create a combustible dust. The plans examiner cited section 307.1 and 414.3 of the FBC.
Section 414.3 requires a dust hazard analysis to be submitted to the Building Official which identifies hazards created
and the methods of protecting such hazards. The client contacted Collins Fire Protection and Life Safety Solutions, LLC
(CollinsFLS) to provide the report. CollinsFLS provides life safety and fire protection consulting services and is registered
to conduct Professional Engineering services in the State of Florida.
Applicable Reference Statutes, Codes, and Standards enforced by St. Lucie County
Florida Statute 633, Fire Prevention and Control
Florida Fire Prevention Code – Seventh Edition
Florida Statute 553, Building Construction Standards
Florida Building Code, Seventh Edition
NFPA 61 – Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities, 2017
edition
NFPA 70 – National Electric Code, 2017 edition
NFPA 652 - Standard on Fundamentals of Combustible Dusts, 2016 edition
NFPA 654 – Standard for the Prevention of Fire and Dust Explosions from Manufacturing, Processing, and Handling of
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Combustible Particulate Solids, 2017 Edition
Permit History
A building permit was issued in 2016 to modify the building for the current tenant, Islamorada Brewing North.
A building permit was applied for in 2021 to add the grain silo on the north west corner of the building.
Code Analysis for Compliance
The current adopted edition of the FBC Table 307.1(1) q states that where combustible dust is manufactured, generated,
or used in such a manner that the concentration and conditions create a fire or explosion based on information
prepared in accordance with FBC 414.1.3, the area of the building shall be classified as an H-2 occupancy. Section
414.1.3 “Information Required” states that a report shall be submitted to the Building Official that identifies the
maximum expected quantities and the methods of protection.
The safe design of hazardous occupancies is material dependent and the material within this occupancy is dust only.
The Maximum Allowable Quantity (MAQ) for dust can be found in Section 307 of the FBC and more specifically in Table
307.1(1). For combustible dust an MAQ is not provided, however footnote “q” gives direction for determining the MAQ.
That note references 414.1.3 and codifies the requirement of the Dust Hazard Analysis be submitted to the Building
Official.
Specific Process for Brewing and the Potential Associated Dust Hazard
The process for brewing beer includes the use of grains for fermentation. The grain in and of itself is not considered a
hazardous material as defined in the FBC. Part of the brewing process in the milling or cracking of the shell of the whole
grain. A biproduct of the milling is combustible dust. When sufficient quantities of grain dust are present, ignition
sources occur, oxygen is present, and there is confinement, an explosion and/or fire may occur. To address the
potential hazard a site specific DHA in accordance with NFPA 652 is necessary to prevent this occurrence. For a dust
explosion to occur, the literature (SFPE Handbook, 5th edition) states the dust must form a cloud so dense that a 100
watt light bulb cannot be visible at a distance of ten (10’) feet. Another measure referenced in the literature is one’s
hand is not visible when fully extended in front of your face. For a flash fire potential to occur a quantity in the
approximate range of 1/32” dust layer covering at least five (5%) of the floor area must be present to create such an
event. The DHA (attached) demonstrates that these concentrations and quantities of dust are not present in the
building. The DHA also provides for methods of managing and preventing hazardous conditions. These include
controlling points of ignition and proper housekeeping to prevent dust build up.
Conclusion
The Dust Hazard Analysis report (attached) demonstrates that there is a minimal amount of combustible dust present
within the building as a result of conveying and milling of approximately 6000 pounds of grain through a closed system.
The amount witnessed does not reach the amounts found in the recognized literature and does not constitute a
hazardous occupancy. The conditions that are necessary for either a dust flash fire or dust explosion were not observed
during our site visit. Means and methods for the management of the presence of the combustible dust are included in
the DHA and shall be followed at all times. In my professional engineering opinion, and upon strict adherence to the
DHA, there is no hazard present that would classify the building as H-2.
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Respectfully Submitted,
Jeffrey P. Collins, MS, PE, CEO
Collins Fire Protection and Life Safety Solutions, LLC
361 Mulberry Grove Road
Royal Palm Beach, FL 33411