Change of Occupancy

A member asked, “There has been a change of occupancy in a manufacturing facility’s loading dock. It is no longer being used as a loading dock, but instead is being used for storage of combustible liquids like acetone and oil. The standard calls for a green tag, but that doesn’t seem quite right to me.”

After reviewing NFPA 25 and Florida “recommendations”, this is not a deficiency and is not a tag. The requirement found in NFPA 25 in regards to change of occupancy is found in chapter 4 which is the “Owner’s” chapter. The tagging requirements clearly start in Chapter 5. So to answer this member I would say that a green tag is in order regardless of what has happened on the loading dock…. HOWEVER, I would highly recommend that the contract indicates through an “Observation” that it appears that there has been a change and an evaluation may be needed. See the annex explanation.

We encourage our members to call the director for code and especially FL specific questions, even if it is just to confirm their interpretation of the code. In this instance, the member was correct. With Florida’s new Green, Yellow and Red tag system, one can’t be too careful. Additionally, one can look into the 2500 informal interpretations archived on our national website,; or submit questions to AFSA’s “Engineer of the Day” for an informal interpretation.