BYKHY Annex 11 and Article 115: Liquid Quantity Limits

The Turkish Fire Protection Regulation (BYKHY) has two separate sets of numbers for liquid quantities, and they are often confused. Annex 11 says when a store must be notified and when a fire brigade permit is needed (Article 114). Article 115 gives the maximum quantities allowed outside a dedicated warehouse: in a storage room, a fire-resisting cabinet or a retail shop. This article puts both side by side with clause numbers.

Annex 11: notification and permit thresholds

Annex 11 is titled "Storage quantities by storage location" and gives litre ranges for two locations (consolidated text p. 70; Guide p. 263):

The table sets no limit by itself; Article 114(1) gives it meaning:

• Above the lower value of the range, the store must be notified under the relevant legislation.
• Above the upper value, or where the store is in a different location from the two listed, a fire brigade permit is also required.
• Classes IIIA and IIIB are outside this notification duty.

Example: 250 litres of Class II in a ground-floor store room exceeds the 100-litre lower value of the IB–II column, so it must be notified; it stays below the 300-litre upper value, so Article 114(1) does not add a permit. 80 litres of Class IA in the same room exceeds 60 litres and needs a permit.

Only two locations are defined. A room below ground falls outside both and counts as a "different location"; in any case Article 115(1) bans storage in basements and Article 118(1) does not allow a basement under a building that stores Class I.

Article 114: filling and equivalence

• 114(2): in an enclosed room where Class I and II liquids are filled, a fire brigade permit is needed if filling exceeds 200 litres per hour and more than 1000 litres of liquid are present. Both conditions must apply.
• 114(3): where Class II and IIIA are stored with Class I, 5 litres of Class II or IIIA count as 1 litre of Class I. Class IIIB is named in the opening words, but no ratio is given for it.

Annex 11 already groups IB, IC and II in one column, and the text does not explain how the equivalence rule interacts with those columns. For mixed stores, state your calculation and reading in the design report and have the fire brigade accept it.

Article 115(1): where liquids may not be stored

No quantity of flammable or combustible liquid may be stored in corridors, passages, stair landings or under stairs, basements, lobbies and foyers open to everyone, escape routes, workrooms, or public premises such as restaurants and coffee houses. The list rules out the common habit of parking paint or cleaning stock "temporarily" under a stair.

Articles 115(2) and 115(3): maximum quantities

Two cases are defined for small-scale storage outside a warehouse. In both, the area is separated from other uses by walls and floors of at least 90 minutes fire resistance, and the liquids are kept in a cabinet resisting 200 °C for 10 minutes (115(2) also accepts a storage room).

In a shop both limits apply: 5 litres per square metre of floor area and the per-class ceiling. A 120 m² shop gets 600 litres from the area rule, so the 1000-litre IB–IIIA ceiling does not govern, while IA stays capped at 100 litres. The text does not say whether the 5 litres apply to the total or to each class; the safe reading is to apply it to the total.

Under Article 115(4), Class II and III liquids held in bulk follow the open-air storage (Article 119) and tank (Article 120) rules instead; see the aboveground tank and underground tank articles.

Article 115 in the Guide

The December 2024 Guide moves the 115(2) and 115(3) quantities into Table 113 under Article 113 and cites those paragraphs in the table footnotes (Guide p. 189). Its Article 115 page lists only paragraphs 1 and 4 (p. 190). The values match the 2015 text; only the layout differs. Check paragraph numbers against the text in force before quoting them in a report.

Which limit applies when?

1. Classify the liquid (Article 113, including the heated-liquid rule). See the liquid classes article.
2. Is the location banned? If it is on the Article 115(1) list, no storage at all.
3. Small-scale storage? With 90-minute separation and a rated cabinet, use the 115(2) or 115(3) table.
4. Warehouse? The 120-minute warehouse rules and Annex 12/A apply: Annex 12/A and 12/B article.
5. Notification and permit: compare the quantity with the Annex 11 range, excluding IIIA and IIIB.

Common mistakes

• Reading Annex 11 as a maximum. It triggers notification and permits; maximum quantities come from Article 115 and Annex 12.
• Ignoring the cabinet rating. Articles 115(2) and 115(3) require a cabinet resisting 200 °C for 10 minutes, not any steel cupboard.
• Skipping the 90-minute separation. Without it the Article 115 quantities cannot be used.
• Treating bulk stock as small quantities. Bulk Class II and III liquids fall under Articles 119 and 120.

Frequently Asked Questions

Are the Annex 11 values maximum storage quantities?

No. Under Article 114(1), exceeding the lower value of the Annex 11 range triggers notification; exceeding the upper value, or storing in a different location, also requires a fire brigade permit. Maximum quantities come from Article 115 and Annex 12.

Do Class IIIA and IIIB liquids need notification?

Article 114(1) sets the notification duty for liquids other than Classes IIIA and IIIB, so those two classes are outside the Annex 11 notification duty.

How much flammable liquid may a shop hold?

Under Article 115(3) the shop is separated by at least 90-minute walls and floors and the liquids are kept in original packaging inside a cabinet resisting 200 °C for 10 minutes. It may hold 5 litres per m² of floor area, capped at 100 litres for IA, 1000 litres for IB–IIIA and 2500 litres for IIIB.

When does a filling room need a fire brigade permit?

Article 114(2) requires a permit where Class I and II liquids are filled indoors at more than 200 litres per hour and more than 1000 litres of liquid are present at the same time.

Can paint or thinners be kept under a stair?

No. Article 115(1) lists under-stair spaces, stair landings, corridors, basements, escape routes and public premises among places where flammable and combustible liquids may not be stored.

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