Fire and Building Codes and Storage of Baled Cotton

Published: October 20, 2005
Updated: April 12, 2022

“Cotton fibers” were considered combustible fibers and listed in a Hazardous Material Classification in the fire and building code standards of the primary U.S. fire and building code organizations -- International Code Council (ICC) and National Fire Protection Association (NFPA) -- after both sets of codes were revised in 2000 (Wakelyn et al. 2004, 2005, and 2006). The amended codes placed unnecessary requirements on Baled Cotton Warehouses for both new construction and occupancy permits for existing buildings. In 2004-05 based on the extensive research conducted by and for the cotton industry (Wakelyn and Hughs, 2002, “Evaluation of the Flammability of Cotton Bales”, Fire and Materials 26, 183-189), meaningful changes in the 2006 NFPA Code Revisions and 2006 ICC Code Revisions have been accomplished (both published in Fall 2005 and effective 1/1/06). The same course was followed in 2005 for NFPA 13 (Standard for the Installation of Sprinkler Systems).

Amendments to International Code Council (ICC Home Page) 

Amendments adopted during the 2005 code revision cycle mean that the 2006 ICC International Fire Code (IFC), ICC International Building Code (IBC), and NFPA fire and building codes recognize that densely-packed baled cotton [cotton made into a banded bale with a packing density of at least 22 lbs/ft3 (352 kg/m3); complies with ISO 8115 (Part 3: Bales of Cotton – Packaging and labeling, ISO 8115-3:1995{E})] is not a combustible fiber or a hazardous material.

Amendments to International Code Council (ICC Home Page]

  • IBC [amendments accepted 2005 for 2006 code]
    • IBC: Section 2902 (IBC [F] 307.2) Defines densely-packed cotton bales.
    • IBC: Section 201 (IBC [F] 307.5) General Definitions High-hazard Group H-3 excludes densely-packed cotton as a combustible fiber and
    • IBC: Revises Table 1804.2 (IBC [F] Table 415. Quantity Limits for Hazardous Materials in a Single Fabrication Area in Group H-5 to exclude densely-packed baled cotton.


  • IFC [2018 code]
    • IFC: Seed cotton is listed as an agricultural product [Section 3703.4] and defined [Section 202] as a “Perishable raw agricultural commodity … which requires ginning to become a commercial product”. Ginning is an agricultural process operated by agricultural workers (according to the comment support language used to justify the listing in Section 3703.4 Agricultural Products). So it follows that ginning facilities are agricultural buildings, covered by fire and building code requirements for agricultural buildings not general industrial rules. Cotton warehouses must meet general industrial fire and building code requirements rules because baled cotton is considered a commercial product.


Amendments to National Fire Protection Association (NFPA) 

  • NOTE: Amendments to NFPA 1 Fire Code (UFC) and 101 Life Safety Code® are similar to new language and storage requirements for densely-packed baled cotton found in the amended ICC IFC and ICC IBC (see above).
  • NFPA 1 Uniform Fire Code (UFC)
  • A new definition for "densely-packed baled cotton" [cotton made into banded bales with a packing density of at least 22 lbs/ft3 (352 kg/m3)] is included in the NFPA codes (NFPA 1 and 101);
  • Chapter 62 of NFPA 1 (on combustible fibers) becomes Chapter 45 of NFPA 1. RESULT: puts densely-packed baled cotton outside the jurisdiction of the section on hazardous materials;
  • Chapter 60 of NFPA 1 (hazardous materials) has no requirements for “densely-packed baled cotton";
  • Chapter 34 of NFPA 1 (on general storage moved from NFPA 230) has no requirements for baled cotton storage.


  • NFPA 5000 Building Code [amendments accepted 2005 for 2006 code] While several amendments relating to densely-packed baled cotton were affirmed, the NFPA Report on Proposals contains the following comment concerning why a densely-packed baled cotton definition to the NFPA 5000 was rejected: “Densely-packed baled cotton clearly does not fit the definition of a flammable solid found in NFPA 5000. Therefore, the proposed changes are not necessary.” (p. 5000-54)


  • NFPA 230 Standard for the Fire Protection of Storage [withdrawn] and Annex D of 230 (storage of baled cotton) becomes Annex L (Protection of Baled Cotton History of Guidelines) of NFPA 1 (Annex L is final; see the document that was approved)
  • NFPA 13 is revised and follows Annex L.

What this means

This means that in IFC, IBC, and NFPA regulations densely-packed baled cotton is not a combustible fiber or a hazardous material and the non-mandatory guidance for storage of baled cotton (formally Annex D of NFPA 230) is now in Annex L of NFPA 1. Annex L is a similar to Annex D but a revised/updated version of the former Annex D of NFPA 230.

In the IFC seed cotton is as an agricultural product, ginning is an agricultural process, and so it follows that ginning facilities are agricultural buildings.

These amendments should result in lower insurance costs for cotton bale storage and bring reason to fire and building code requirements for storage of baled cotton [reduce costs of new warehouses by 40% and allow existing warehouses to expand or have other warehouses re-designated for cotton storage without increased requirements]. NCC, NCGA, and gin associations will make insurance companies aware of these changes and work to have insurance rates reflect it and be available to help in states that have not updated their codes to 2006.

Table 1. Cotton Producing States and the Codes Presently in Force


2015 IBC, 2015 IFC


Building Codes are established by the city jurisdictions in Arizona.
Contact the cities directly for their code information.


2012 IBC, 2012 IFC
Arkansas codes are mandatory statewide minimums (unless otherwise noted).
Local jurisdictions may amend the codes only to make them more stringent.


2015 IBC, 2015 IFC
California has adopted statewide, mandatory codes based on ICC's Uniform codes.
Local jurisdictions may only amend the California Building Code to make it more
stringent because of unique local climatic, geological or topographical conditions.
All local amendments must be filed with the California Building Standards Commission.


2006 NFPA 1 (a.k.a. Florida Fire Prevention Code,
2015 IBC (a.k.a. Florida Building Code)
Florida has a statewide building code; under certain strictly defined conditions,
local governments may amend requirements to be more stringent than the code.


2012 IBC, 2012 IFC
Georgia has fourteen "state minimum standard codes". Each of these separate codes
typically consist of a base code and a set of Georgia amendments to the base code.
Georgia law dictates that eight of these codes are "mandatory" (are applicable to all
construction whether or not they are locally enforced) and two are "permissive" (only
applicable if a local government chooses to adopt and enforce one or more of these


2006 IBC, Kansas Fire Prevention Code (IFC 2006, NFPA)
Only the Kansas Fire Prevention Code is mandatory statewide. Local jurisdictions may
amend the fire code to make it more stringent.


2015 IBC, NFPA 101 Life Safety Code – 2006
Louisiana's building codes are mandatory minimums for all buildings except one and two
family dwellings, unless otherwise indicated.


2015 IBC, 2015 IFC
The state of Mississippi does not have a statewide building code. Building code
adoption and enforcement is primarily the responsibility of local jurisdictions.


No State Mandated Building or Fire Code
Building codes in Missouri are adopted and enforced at the local level.

New Mexico

2015 IBC, 2015 IFC
New Mexico's building codes are mandatory minimum standards for all buildings.

North Carolina

2015 IBC, 2015 IFC
North Carolina statewide mandatory building codes apply to all buildings
except one and two family dwellings…;
...adopts the model code every three years;
...amendments are adopted every three years.


2015 IBC, 2015 IFC and NFPA 101
Oklahoma's codes (listed above) apply as a mandatory minimum to all buildings
except one and two family dwellings.

South Carolina

2015 IBC, 2015 IFC
South Carolina requires that every local jurisdiction adopt a code and mandates
which code the local government must adopt… Local jurisdictions may amend
codes to make them more stringent with the approval of the Building Codes Council.


2012 IBC, 2012 IFC
Tennessee's codes apply as a mandatory minimum to all buildings except one and
two family dwellings and licensed health-care facilities, except as otherwise indicated.


2003 IBC, No state mandated fire code;
in rural areas the default code is NFPA 101;
in all other areas the Texas Authorities Having Jurisdiction (AHJ) may choose fire code


Virginia USBC (2015 IBC), 2015 IFC (Virginia Statewide Fire Prevention Code)

Looking for additional information? Check out ICC – International Code Adoptions or Reed Construction Data  for information concerning codes that may apply in your area.


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