Paint Shop Planning—From Floor Plan to First Spray

Article 03 of 28

Meet the Authority Having Jurisdiction Early

The worst time to discover a code requirement is after the equipment has been installed.

Paint shops involve flammable and combustible materials, mechanical ventilation, electrical equipment, fuel-fired systems, structural penetrations, fire protection, worker exposure, and environmental emissions. Those responsibilities may involve several different authorities.

The people responsible for interpreting and enforcing the applicable requirements are commonly described as the Authorities Having Jurisdiction, or AHJs.

What Is an Authority Having Jurisdiction?

An Authority Having Jurisdiction is an organization, office, or individual responsible for enforcing a code, approving equipment, accepting an installation, or determining whether a facility satisfies an applicable requirement.

There may not be one single AHJ for the entire paint-shop project. Different officials may have authority over different portions of the work.

Why Requirements Differ From One Location to Another

A booth that was accepted in one city is not automatically approved in another. Requirements can vary because jurisdictions may adopt different editions of the building, fire, electrical, and mechanical codes. They may also adopt local amendments.

The project may be affected by:

• The state, county, and municipality where the facility is located
• The adopted editions of applicable codes
• Local amendments and administrative rules
• The building’s construction and occupancy
• The coatings, solvents, and cleaning materials used
• The quantity of flammable or combustible material stored
• The type of spray application and curing process
• The size and location of the spray area
• The presence of existing sprinklers or fire-protection systems
• The available electrical, gas, and ventilation systems
• Environmental emissions and production volume

This is why statements such as “We installed the same booth at another location” do not settle the question.

NFPA Standards and the NEC Are Not Automatically the Local Law

NFPA standards and the National Electrical Code provide widely recognized requirements and technical guidance. However, the enforceable requirements for a specific project depend on what has been adopted by the applicable jurisdiction and how those requirements apply to the proposed installation.

A project team should not assume that the newest published edition, the edition used by the equipment manufacturer, and the edition adopted locally are automatically the same.

At the beginning of the project, ask:

• Which edition of the building code is adopted?
• Which edition of the fire code is adopted?
• Which edition of the National Electrical Code is adopted?
• Which mechanical and fuel-gas codes apply?
• Are there state or local amendments?
• Does the jurisdiction reference NFPA 33 or other NFPA standards?
• Are stamped engineering drawings required?
• Are listed or approved equipment assemblies required?

The answers should be documented and provided to the project’s qualified design professionals.

Contact the AHJs Before Final Equipment Selection

Many owners wait until they have selected a booth before contacting the authorities. That reverses the proper order.

The proposed equipment may affect:

• The required building location and clearances
• Fire-rated walls and separation
• Exhaust-stack location and height
• Distance from property lines, openings, and air intakes
• Electrical area classification
• Fire-suppression design
• Available gas and electrical service
• Air-permit calculations
• Roof and structural modifications
• Required exits and access routes

If the authority requires a change that affects the equipment configuration, it is better to discover that before the purchase order is released.

Prepare for the First AHJ Meeting

An early meeting is more productive when the project team brings useful information. Do not arrive with nothing more than a booth photograph and a question about whether it is acceptable.

Questions to Ask the AHJs

The first meeting should identify the approval path—not attempt to obtain final approval for a project that has not yet been designed.

1. Which departments must review this project?
2. Which code editions and local amendments apply?
3. What permits, notifications, or applications are required?
4. Are sealed architectural or engineering drawings required?
5. What information must be shown on the plans?
6. Is a hazardous-location classification drawing required?
7. What equipment listings or certifications are expected?
8. Must the fire-suppression system be reviewed separately?
9. Are air permits or emissions calculations required?
10. Are there requirements for exhaust discharge location?
11. Which inspections will be required during construction?
12. What work must remain visible until inspected?
13. What testing and documentation will be required before startup?
14. Who has final authority to approve operation?

Document the Answers

Verbal conversations are useful, but important decisions should be confirmed in writing. Record:

• The meeting date and location
• Names and titles of participants
• Code editions and requirements discussed
• Documents requested by the authority
• Open questions and responsible parties
• Required permits and submission dates
• Inspection and testing expectations
• Any interpretations specific to the project

Distribute the meeting notes to the project team. Ask participants to identify any misunderstanding while the discussion is still fresh.

Approval Is a Process, Not a Single Signature

A paint-shop project may require several approval stages:

Do Not Confuse a Permit With Complete Project Acceptance

A permit authorizes specified work to proceed under defined conditions. It does not necessarily mean every project requirement has been satisfied.

For example:

• A building permit may not satisfy environmental permitting.
• An electrical inspection may not approve the fire-suppression system.
• Fire-department approval may not verify production performance.
• Code approval may not satisfy the insurance carrier.
• Final inspection may not confirm the owner’s quality or capacity requirements.

The project owner must track every required approval and every contractual acceptance condition.

Common AHJ Planning Mistakes

• Assuming the equipment supplier is obtaining every permit
• Ordering equipment before confirming local requirements
• Using drawings prepared for a different building or jurisdiction
• Failing to identify the adopted code editions
• Calling the fire marshal only after installation
• Beginning work before permit issuance
• Covering wiring, piping, or structural work before inspection
• Changing the equipment layout without revising approved plans
• Assuming used equipment will be accepted because it operated elsewhere
• Failing to coordinate building, fire, electrical, mechanical, and environmental reviews
• Scheduling production before final inspections and approvals

The Bottom Line

The AHJ should not be treated as the person who arrives at the end of the project to admire the new equipment and sign a form.

The applicable authorities are part of project constraints from the beginning. Their requirements can affect the building, equipment, utilities, fire protection, electrical design, environmental approval, construction schedule, and total cost.

Meet them early. Bring useful information. Ask specific questions. Document the answers. Then give those answers to the professionals responsible for designing and building the project.

A ten-minute question before equipment is ordered can prevent a ten-thousand-dollar answer after it arrives.