FM Global DS 8-22: Baled Storage (Fiber, Waste Paper, Plastics)

Short Answer

The current title of FM DS 8-22 is Baled Storage, and it covers baled storage of waste paper, natural or synthetic fibers and plastics. The logic of the data sheet fits in one sentence: because a bale fire advances by burrowing into the pile, sprinklers alone do not extinguish it, so pile size, height and separation distance are the main tools of protection.

Identity of the Data Sheet: DS 8-7 Now Lives Here

The copy used here is dated April 2026 and has 8 pages (cover, PDF p.1). Under Section 1.2 the document has been completely revised, with three significant changes (PDF p.2):

• The title changed from Storage of Baled Waste Paper to Baled Storage.
• The guidance of DS 8-7 Baled Fiber Storage was incorporated into this data sheet and DS 8-7 became obsolete.
• The protection guidance was updated and automatic monitor extinguishing systems were added as a primary protection option.

Specifications that reference DS 8-7 should therefore be updated. For the overall framework see the site's warehouse fire protection guide.

Why the Hazard Is Different

Section 1.1 describes the particular hazard of baled storage (PDF p.2): because bales are densely compressed, ventilation is limited and moisture and heat are trapped. High moisture content in waste paper or fiber bales can lead to spontaneous ignition through bacterial growth and the heat the bacteria generate. Lithium-ion batteries in or near bales, sparks from metal banding and hot work are also ignition sources.

The same section describes how the fire behaves: bale fires tend to smoulder and burrow; sprinklers generally do not extinguish these deep-seated fires, and the pile has to be broken apart while hose streams are applied.

The general approach to lithium-ion batteries is covered in the DS 7-112 article; DS 8-22 Section 2.6.3 requires incoming material to be verified free of ignition sources such as lithium-ion batteries by IR scanning, metal detection or an equivalent method (PDF p.6).

Outdoors: Three Protection Routes

Section 2.4.1.1.1 defines three protection methods for outdoor baled storage (PDF p.3): an automatic monitor extinguishing system, barriers with manual response, or separation distance with manual response.

Limits that apply regardless of method:

What changes with the chosen method:

The separation distances in Table 2.4.1.4.1 are (PDF p.4): 30 ft (9.1 m) for a 5 ft (1.5 m) pile; 35 ft (10.7 m) for 10 ft (3.0 m); 40 ft (12.2 m) for 15 ft (4.6 m); 45 ft (13.7 m) for 20 ft (6.1 m).

Barriers must be of noncombustible material with at least a 2-hour rating; the data sheet notes that a typical cement or cinder block wall will meet this rating (Section 2.4.1.3.2, PDF p.3). A measure such as wire mesh over piles of paper commodities is also required to keep embers from igniting neighbouring piles (Section 2.4.1.3.4, PDF p.4). Section 2.2.6 refers to DS 1-20 to protect buildings and conveyors from a yard fire (PDF p.2); the logic of exterior exposure is covered in the neighbouring building exposure article.

Indoors: Sprinklers or Automatic Monitors

Section 2.4.2.1.1 recognises two indoor protection methods: an automatic sprinkler system or an automatic monitor extinguishing system (PDF p.4).

Indoor arrangement limits: pile area not more than 1,600 ft2 (150 m2), pile height not more than 20 ft (6.1 m), and 8 ft (2.4 m) aisles between piles and other combustibles (Sections 2.4.2.1.2-2.4.2.1.4, PDF p.4). In addition, Section 2.2.4 requires a cutoff of at least 1-hour rating between indoor baled storage and other operations, and Section 2.3.2 requires at least 2 ft (0.6 m) between the storage and walls, barriers, structural steel, columns and sprinkler risers (PDF p.2-3).

On the commodity side, two thresholds decide (PDF p.4):

• Baled storage with 30% or more plastics by weight is treated as solid-piled uncartoned unexpanded plastic (UUP) and protected per DS 8-9; DS 3-26 can be applied where the incidental storage criteria are met (Section 2.4.2.1.7).
• Incidental storage of baled paper is protected as a Class 3 commodity per DS 3-26 Fire Protection for Nonstorage Occupancies (Section 2.4.2.1.6). That data sheet is covered in the DS 3-26 article.

For rack storage, baled paper products are protected as a Class 3 commodity, or as cartoned unexpanded plastic (CUP) if stored on non-FM Approved plastic pallets (Section 2.4.2.1.8, PDF p.4). For the definitions of the commodity classes see the DS 8-1 commodity classification article.

Indoor Sprinkler Design

Section 2.4.2.2 sets the sprinkler side (PDF p.5): FM Approved storage sprinklers installed per DS 2-0; a wet-pipe system unless the protected area is unheated and the temperature can fall below 40°F (4°C); standard-response pendent or upright sprinklers; a minimum of K11.2 (K160) sprinklers.

Table 2.4.2.2.5 gives the design demands for waste paper and fiber bales with less than 30% plastics by weight (PDF p.5):

A 1,000 gpm (3,790 L/min) hose allowance is added to this design, and the water supply must be able to meet the design flow plus hose allowance for 2 hours (Sections 2.4.2.2.5-2.4.2.2.6, PDF p.5).

Why 2 Hours and Why Manual Response

Section 3.3 states the reason for the water supply duration plainly (PDF p.6): large-scale tests showed that fire spreads by burrowing into the pile, so sprinkler protection alone cannot achieve final extinguishment. Indoors in particular, the role of the sprinklers is to suppress the flames and protect the building so that the fire crew can break the pile apart. The first two hours are critical for gaining control, after which water use usually drops; because bale fires can last for days, a 2-hour supply is considered reasonable for site operations to start and for additional planned supplies to be brought in.

Section 3.1.1 gives a detail that affects handling: bales absorb water when exposed to it and can expand up to 1.5 times in area; this added weight must be accounted for both when moving wet bales and in rack design (PDF p.6).

For this reason Section 2.5 requires a pre-incident and emergency response plan per DS 10-1; the plan includes access routes, manual protection methods, the water supply for long-duration fires, the method of moving damaged bales, a designated area off site where bales will be taken, and the final extinguishment plan (PDF p.5).

Loss History

Section 3.5 notes that an FM review of the last 10 years found 28 fire losses involving baled storage. According to Table 3.5, 61% of the losses occurred outdoors but accounted for only 24% of the total dollar value; indoor losses were 39% by number but produced 76% of the value (PDF p.6-7).

The example incidents in the data sheet make the table concrete (Section 3.5.1, PDF p.7):

• In an indoor waste paper bale fire, self-heating ignited a bale and the flames ignited paper dust accumulations at ceiling level. Removing the burning bales from the building took 42 hours, and a total of 67 sprinklers operated.
• In yard storage, pile height and area limits had been exceeded and aisles filled; with no detection on the yard, the alarm came from local authorities, and the fire consumed all of roughly 10,000 tons of baled cardboard.
• At a waste paper yard protected by automatic monitors, a fire was detected and suppressed quickly, and a second monitor extinguished a second fire that started from embers.

Field Note

When this data sheet is taken to site, the hardest part is not protection but arrangement discipline. The aisles of Table 2.4.1.4.1 and the 10,800 ft2 (1,000 m2) pile limit are the first things sacrificed at the peak of the season; the second example incident in the data sheet describes exactly that (PDF p.7).

The second point is that final extinguishment is a planning job. Section 2.5.1.2 requires a documented procedure for moving bales during a fire, and Section 2.5.1 requires the off-site area where bales will be taken to be designated in advance (PDF p.5). The swelling information in Section 3.1.1 is also part of that plan: a wet bale may not be movable with the same forklift as a dry one.

Checklist

• DS 8-7 references in the specification updated; baled fiber is now within DS 8-22 (Section 1.2)
• Plastics content of the bales by weight determined; if the 30% threshold is exceeded, protection built on DS 8-9
• Outdoors, pile area kept within 10,800 ft2 (1,000 m2) and height within 20 ft (6.1 m)
• A 30 ft (9.1 m) main aisle left on at least one side of each pile; aisles not closed with storage
• Yard hydrants placed at not more than 300 ft (91 m) spacing; FM Approved IR or video detection provided outdoors
• Separation, barriers and water allowance taken correctly for the chosen outdoor method
• Indoors, pile area of 1,600 ft2 (150 m2), 8 ft (2.4 m) aisles and a 1-hour cutoff provided
• Sprinkler design taken from Table 2.4.2.2.5, with a 1,000 gpm (3,790 L/min) hose allowance and 2-hour duration added
• Incoming material screened for lithium-ion batteries and other ignition sources
• Pre-incident plan, off-site bale relocation area and final extinguishment method put in writing

Frequently Asked Questions

Which materials does DS 8-22 now cover?

Under Section 1.0 it covers indoor and outdoor baled storage of waste paper, natural or synthetic fibers and plastics. In the April 2026 revision the title changed from Storage of Baled Waste Paper to Baled Storage, and DS 8-7 Baled Fiber Storage was incorporated into this data sheet and made obsolete.

How far are bale pile size and height limited?

Outdoors, a pile is limited to 10,800 ft2 (1,000 m2) in area and 20 ft (6.1 m) in height, with a main aisle of at least 30 ft (9.1 m) on at least one side of each pile. Indoors, a pile is limited to 1,600 ft2 (150 m2), again to a height of 20 ft (6.1 m), with 8 ft (2.4 m) aisles kept between piles and other combustibles.

Why is the water supply duration 2 hours for baled storage?

According to Section 3.3, fire burrows into the bale pile, so sprinklers alone cannot achieve final extinguishment. The first two hours are critical for gaining control, after which water use usually drops. Because bale fires can last for days, a 2-hour supply is considered reasonable for site operations to start and for the additional supplies in the emergency plan to be brought in.

How does the plastics content of bales change the protection?

Under Section 2.4.2.1.7, baled storage containing 30% or more plastics by weight is treated as solid-piled uncartoned unexpanded plastic (UUP) and protected per DS 8-9; DS 3-26 can be applied where the incidental storage criteria are met. The sprinkler designs in Table 2.4.2.2.5 are for waste paper and fiber bales with less than 30% plastics.

References

1. FM Property Loss Prevention Data Sheet 8-22, Baled Storage, April 2026. Sections used: 1.0-1.2 (PDF p.2), 2.2-2.3 (p.2-3), 2.4.1.1-2.4.1.3 (p.3-4), Table 2.4.1.4.1 and 2.4.2.1 (p.4), 2.4.2.2 and Table 2.4.2.2.5 (p.5), 2.5 (p.5), 2.6 (p.6), 3.1-3.5 (p.6), Table 3.5 and 3.5.1 (p.7), Appendix A (p.7), Appendix B (p.8).
2. FM Global, Property Loss Prevention Data Sheets: https://www.fmglobal.com/research-and-resources/fm-global-data-sheets
3. selvi.org, FM Global DS 8-1: Commodity Classification
4. selvi.org, FM Global DS 3-26: Water Demand for Nonstorage Occupancies
5. selvi.org, Warehouse Fire Protection Guide

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