Carbon Dioxide Codes Explained: What Fire Inspectors Are Actually Looking For

CO2-related citations are becoming more common across a wide range of facilities, particularly in industries where CO2 is used for beverage systems, enrichment, or industrial processes.

If your location has been cited, the notice likely outlines a specific issue. However, many operators find that these citations are not isolated problems. They often reflect broader patterns that inspectors consistently identify across facilities.

Understanding these patterns can help not only resolve the immediate issue, but also identify other areas that may require attention.

CO2 Citations Are Rarely One-Off Issues

In many cases, a citation is not the result of a single oversight.

Instead, it is one of several compliance gaps that may exist at the same time. The inspection process often brings the first issue to light, while additional items may become apparent during follow-up.

For example, a facility cited for missing a CO2 monitor may also have:

• No active or current permit
• Incomplete sensor coverage in adjacent areas
• No documentation of system testing or calibration
• No plan for ongoing recertification

Addressing only the cited issue may not resolve the full scope of the system.

How CO2 Citations Are Referenced

Across enforcement cases, notices often reference specific sections of the International Fire Code (IFC), along with internal case or incident tracking identifiers.

Commonly referenced sections include:

• IFC Section 105.3 – Operational permits for systems above defined threshold quantities
• IFC Section 112.2 – Violations and enforcement procedures when requirements are not met
• IFC Section 312.2 – Inspection authority for verifying compliance conditions
• IFC Section 5303.5 – Requirements related to compressed gas systems and storage design

In addition, citations may be associated with incident or case numbers (e.g., 25-425382, 25-516129, 25-517115), which serve as internal records for tracking inspection findings and follow-up actions.

Once documented, these records may be referenced during re-inspection or ongoing compliance reviews.

The Most Common CO2 Citations Across Facilities

While requirements vary by jurisdiction and AHJ interpretation, several types of citations appear consistently.

Missing or Invalid Permits

Facilities operating above applicable CO2 thresholds may be required to maintain operational permits, depending on jurisdiction. Citations are commonly issued when permits were never filed, have expired, or do not reflect current system configurations.

Lack of Required CO2 Monitoring

One of the most direct citations is the absence of a monitoring system where one may be required based on system size, design, or code interpretation.

This is often seen in facilities where CO2 systems were installed without a full compliance review.

Improper System Design or Coverage

Even when monitoring systems are installed, inspectors may identify gaps in coverage.

This can include:

• Incorrect sensor placement
• Insufficient number of sensors
• Areas not being monitored where CO2 may accumulate

Because CO2 is heavier than air, it can collect in low-lying or enclosed areas, which must be considered when designing monitoring systems.

No Record of Testing or Recertification

Inspectors typically expect systems to be maintained over time, not just installed.

If there is no documentation demonstrating testing, calibration, or ongoing verification, the system may be treated as non-compliant during inspection.

Incomplete or Missing Documentation

Documentation plays a critical role in demonstrating compliance.

If permits, plans, or system records are not accessible at the time of inspection, this may result in a citation regardless of whether the system is physically present.

Unverified System Functionality

A system that has not been tested under real conditions may not meet compliance expectations.

Inspectors may verify:

• Alarm activation
• Relay functionality
• System response under test conditions

If functionality cannot be demonstrated, it may be cited.

Why These Citations Continue to Occur

These issues persist because CO2 compliance is often handled in separate stages rather than as a coordinated process.

Common scenarios include:

• Equipment installed without evaluating permitting requirements
• Responsibilities split across multiple vendors
• Assumptions that another party addressed specific requirements
• No centralized tracking of ongoing obligations

For multi-location operators, this becomes more complex as each site may have been set up differently over time.

What Happens After a Citation Is Issued

Once a citation is issued, the process typically shifts to resolution.

Depending on the jurisdiction, this may include:

• Correcting the identified issue
• Providing documentation demonstrating compliance
• Completing a follow-up inspection

However, resolving only the cited item may not be sufficient. Additional issues may be identified during re-inspection if the system has not been evaluated as a whole.

Looking Beyond the Initial Citation

The most effective approach is to treat a citation as an opportunity to review the entire CO2 setup, not just the item listed on the notice.

This includes evaluating:

• Permit status and applicability
• Monitoring system design and placement
• System functionality and testing
• Documentation and recordkeeping
• Ongoing maintenance and recertification

Addressing these elements together helps reduce repeat citations and creates a more consistent approach across locations.

A More Predictable Approach to Compliance

Facilities that avoid repeated citations often follow a structured approach.

Rather than reacting to individual issues, they:

• Apply consistent standards across locations
• Maintain visibility into system status
• Keep documentation organized and accessible
• Track recurring requirements such as inspections and recertification

This reduces uncertainty and makes inspections more predictable over time.

Get Ahead of Your Next Inspection

If your facility has been cited, or you want to better understand how your system aligns with current requirements, taking a more complete view of your CO2 setup is a practical next step. 

Evaluating the full scope early can help reduce repeated corrections and improve consistency across locations.

At Aerosphere, we work with operators to bring structure to CO2 compliance across facilities. From permitting and system design to installation, documentation, and ongoing recertification, our approach consolidates these requirements into a single, coordinated process.

Get a free assessment with us today to get started today!