2nd Floor Sprinkler System

[Famine]

Hello all,

I am leasing a second floor of a historic building. It's been completely remodeled. I am shooting for A-2 assembly for a bar with a max occ around 80 people when I was hit by the city that we need to have a sprinkler system. This is due to the 903.2.1.2 code that states if the fire area is located on any other floor other than the level of discharge, must have a fire sprinkler. That's fine, until you realize that installing a commercial sprinkler system is a major undertaken if you have to tap into the main water line in the sidewalk.

Talking with others, it seems a risk based hazard analysis may be an option to avoid this. I was wondering if anyone could explain what that means in the context of this issue? Is that essentially having someone perform a risk analysis to prove such a system is not needed on the second floor? If so, anyone have any experience on how hard that is?

Currently, the recommendation is to shoot for 49 until a system can be installed if such a system can be installed at all being the costs alone seem high.

 

[Msradell]

Did they raise any issues about accessibility (ADA) since it will be on the 2nd floor?

 

[e hilton]

How can you achieve an occ level of 49 without reducing the footprint of the space? Or is that your intent? Wouldn’t that require building a wall to close off the unusable space?

 

[mtlogcabin]

IBC 2018
903.2.1.2 is not automatically required.
[F] 903.2 Where required.
Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.

All the requirements in section 903.2 are for new buildings so there has to be a code section that requires you to follow section 903.2. Believe me there are plenty out there that will do that and very few that may have an alternate to a sprinkler requirement.

The International Existing Building Code (IEBC) is where you need to start. Chapters 10, 12 and 13 will be the most helpful. Chapter 13 is the compliance chapter or "a risk based hazard analysis" that you mentioned. You will need a design professional to help you with this to get it correct. Sometimes a trade off of complete area wide smoke and heat detection along with occupancy notification versus a fire suppression system and your egress is over the code minimum requirements might be adequate.

It is all in what your AHJ will accept and any changes/amendments to your NC buildings

 

[Famine]

IBC 2018
903.2.1.2 is not automatically required.
[F] 903.2 Where required.
Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.

All the requirements in section 903.2 are for new buildings so there has to be a code section that requires you to follow section 903.2. Believe me there are plenty out there that will do that and very few that may have an alternate to a sprinkler requirement.

Can you explain this a little more in layman terms for me? Are you saying that we more than likely do not require a sprinkler system because it's not a new building? The building is like 100 years old and has been remodeled on our floor. New HVAC, new water pipes, new electric, the works. The only thing that is missing is obviously a dedicate water line for a sprinkler system and the sprinkler system itself.

We talked to an alternative water suppressent company in the city over from us. They told us we should be able to go to bigger and higher grade fire extinguishers to get a pass on the building permit as long as we do a sprinkler system at a later date. The inspector is asking for what code explains that.

 

[Famine]

I think I see what you're saying. Looking throughout the other chapters, I see many exceptions if you have an automatic sprinkler system. I assume you mean that if we are not compliant in other areas, it may be triggering the need for 903.2 with the sprinkler system.

 

[Famine]

Yours is a change of, or establishment of legal occupancy, where it has, as of yet verifiably not existed as an assembly (A). Moreover, the second floor of the building has been historically verified as a business occupancy 49 occupants max ).

This is essentially the reasoning for when asking about what code is triggering the 903.2 group. Is there anything we could do there in terms of fighting that when it comes to new building? I'm assuming he is saying that while it's not a new building, changing to assembly makes it trigger as if it's a new building.

 

[mtlogcabin]

Here is a link to the North Carolina Codes with amendments.

North Carolina Building Codes

View North Carolina building and construction codes. Code regulations are consolidated by state and city for easier navigation.

up.codes

This section is the compliance method that you referred to in your OP. If you choose to go this route make sure the fire and building official are on board with considering approving your project without meeting full compliance.

1401.1 Scope

The provisions of this chapter shall apply to the alteration, repair, addition and change of occupancy of existing structures, including historic and moved structures, as referenced in Section 301.1.3. The provisions of this chapter are intended to maintain or increase the current degree of public safety, health and general welfare in existing buildings while permitting repair, alteration, addition and change of occupancy without requiring full compliance with Chapters 5 through 13, except where compliance with other provisions of this code is specifically required in this chapter.

 

[Sifu]

NC 2015 EBC requires sprinklers if changing occupancy to a higher hazard. The entire building would be required to be sprinklered unless the new A-2 is separated by fire barriers and horizontal assemblies. If that is the case the sprinklers would only be required in the new occupancy. So, if for example, the previous use was a B, and you are proposing an A, sprinklers are required. Then it is just a matter of whether there are existing fire separations or you want to add them to reduce the scope of sprinkler coverage. Chances are you are moving to a higher hazard category and will be required to provide sprinklers to some extent.

1012.2 Fire protection systems. Fire protection systems
shall be provided in accordance with Sections 1012.2.1 and
1012.2.2.
1012.2.1 Fire sprinkler system. Hazard categories in
regard to fire sprinkler requirements shall be in accordance
with Table 1012.2.1.
TABLE 1012.2.1
HAZARD CATEGORIES AND CLASSIFICATIONS
1012.2.1.1 Change to higher hazard category. When
a change of use is made to a higher hazard category as
shown in Table 1012.2.1, the building shall be provided
with an automatic fire suppression system as required
by Section 903 of the North Carolina Building Code.
Exceptions: When an area of a building is changed
to a higher hazard category and the proposed use is
separated from the existing use(s) by assemblies that
meet the applicable fire rating in Table 508.4 of the
North Carolina Building Code, an automatic fire
suppression system as required above shall be
installed only in the area changed.

 

[Famine]

NC 2015 EBC requires sprinklers if changing occupancy to a higher hazard. The entire building would be required to be sprinklered unless the new A-2 is separated by fire barriers and horizontal assemblies. If that is the case the sprinklers would only be required in the new occupancy. So, if for example, the previous use was a B, and you are proposing an A, sprinklers are required. Then it is just a matter of whether there are existing fire separations or you want to add them to reduce the scope of sprinkler coverage. Chances are you are moving to a higher hazard category and will be required to provide sprinklers to some extent.

Unfortunately, this is what the inspector highlighted today is we are going from hazard of 6 to hazard of 2. This is what is triggering the sprinklers.

The company I talked to in my area told me the new 2020 code, which is what they use, states anything under like 100 people is not triggering automatic sprinklers. But, I guess I won't be able to get them to use the new 2020 code versus the 2018 code like they are using today could I?

He mentioned also that being it is historic, unless we changed 70% of the building, we should be able to fight for not having a sprinkler system, but it's up to the fire marshal to make that decision. So, that's what we are banking on along with pointing out the new 2020 code would allow us to not have a sprinkler system because we are only asking for 80 max occ.

 

[Famine]

One other question. If my city is using 2018 codes, when would they adopt the latest 2020 codes? I wonder if I had an argument that if it's possible they would adopt it next year (every 3 years) and the project to install a fire sprinkler system took around 6 months or so, could I get a pass because by the time it actually got installed, we would have been exempt by the new 2020 codes?

 

[mtlogcabin]

If the entire building is evaluated under Chapter 14 and it passes the scoring required then the building is compliant. Using Chapter 14 you score points + & - based on different factors, Exiting, size and height of the building, fire separations, etc. If you are close to passing some Officials will allow you to make improvements such as area wide smoke detection and occupant notification throughout the entire building that will provide the points you need to pass. Some will only accept the report based on what is presently in the building that is why I suggest you get the fire and building officials together and agree on what they will accept.

As you can see below, you as the applicant get to choose which method you use and only that method

301.1 General
The repair, alteration, change of occupancy, addition or relocation of all existing buildings shall comply with one of the methods listed in Sections 301.1.1 through 301.1.3 as selected by the applicant. Sections 301.1.1 through 301.1.3 shall not be applied in combination with each other

301.1.1 Prescriptive Compliance Method

Repairs, alterations, additions and changes of occupancy complying with Chapter 4 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

301.1.2 Work Area Compliance Method

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 5 through 13 of this code shall be considered in compliance with the provisions of this code.

301.1.3 Performance Compliance Method

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 14 of this code shall be considered in compliance with the provisions of this code.

 

[Sifu]

Not sure what 2020 codes you are referring to. NC is typically using the amended ICC code but typically not the most recent. They are usually one cycle behind as they amend the current ICC code to the NC codes. 2015 NC is the only one I had at my fingertips, but I am pretty sure the 2018 NC Building Code is the current code, which is based on the 2015 IBC. If nothing has changed since I was there, there would be no 2020 code, the next adopted code would probably be the 21 NC code, which would be based on the 2018 ICC code (but they may choose to skip a cycle). I think MT has it, your only path is performance based. I have only seen this done a couple of times but it did result in a favorable outcome.

But now you bring up "historical". If it is truly historical then you may have an easier path. But, if it's just historical in the eyes of the beholder, and not a registered historical building, it wouldn't matter. Not sure where the 70% (local AHJ?) number comes into play. If it is truly historic then a holistic evaluation would be done to determine a path.

2015 IEBC:
HISTORIC BUILDING. Any building or structure that
is listed in the State or National Register of Historic Places;
designated as a historic property under local or state designation
law or survey; certified as a contributing resource within
a National Register listed or locally designated historic district;
or with an opinion or certification that the property is
eligible to be listed on the National or State Register of Historic
Places either individually or as a contributing building
to a historic district by the State Historic Preservation Officer
or the Keeper of the National Register of Historic Places.

FWIW, I just checked the 2021 IEBC and IBC, there are no relevant changes that I can see that would provide a prescriptive path.

 

[Famine]

Not sure what 2020 codes you are referring to. NC is typically using the amended ICC code but typically not the most recent. They are usually one cycle behind as they amend the current ICC code to the NC codes. 2015 NC is the only one I had at my fingertips, but I am pretty sure the 2018 NC Building Code is the current code, which is based on the 2015 IBC. If nothing has changed since I was there, there would be no 2020 code, the next adopted code would probably be the 21 NC code, which would be based on the 2018 ICC code (but they may choose to skip a cycle). I think MT has it, your only path is performance based. I have only seen this done a couple of times but it did result in a favorable outcome.

Yes, they are using 2018. I was told about the 2020 code from a company that installs fire sprinkler systems. They were saying 2020 codes make us exempt because the total occ was lower than the threshold.

But now you bring up "historical". If it is truly historical then you may have an easier path. But, if it's just historical in the eyes of the beholder, and not a registered historical building, it wouldn't matter. Not sure where the 70% (local AHJ?) number comes into play. If it is truly historic then a holistic evaluation would be done to determine a path.

The building was built in the 1920's. I'm just making an assumption. It's basically 100 year old building. A friend of my bar manager, who installs sprinkler systems in California said that unless you change 70% of the building, which only the Fire Marshal can really rule on, then it should use the existing 1920 code. The fire expert I talked to about the 2020 code also said the same thing.

why I suggest you get the fire and building officials together and agree on what they will accept.

Absolutely. The two I talked to above said the same as you guys. I have set a meeting with the Fire Marshall, Jr Marshall, and Chief Inspector for next week. They were very polite and eager to come down to check out the building to give us direction. So, I'm hoping for the best!

 

[Famine]

But now you bring up "historical". If it is truly historical then you may have an easier path. But, if it's just historical in the eyes of the beholder, and not a registered historical building, it wouldn't matter. Not sure where the 70% (local AHJ?) number comes into play. If it is truly historic then a holistic evaluation would be done to determine a pat

Oh, I say historic because our building is in the historic district of downtown Durham. Essentially, we can be extremely flexible due to this.

 

[mtlogcabin]

We have a lot of older buildings in our downtown area. Water runs down only one side of main street which is a state DOT highway. They will not allow the highway to be dug up to install a water line across the highway. Hence we have to look at alternative methods to approve a project. Sometimes we can come to an agreement and sometimes we can't. The performance compliance method is an excellent and consistent method for documenting what ever the final decision is.

 

[Famine]

We have a lot of older buildings in our downtown area. Water runs down only one side of main street which is a state DOT highway. They will not allow the highway to be dug up to install a water line across the highway. Hence we have to look at alternative methods to approve a project. Sometimes we can come to an agreement and sometimes we can't. The performance compliance method is an excellent and consistent method for documenting what ever the final decision is.

That makes sense. I do have faith we will come to some sort of agreement. They inspector and fire marshals all seem super reasonable. The landlord also seems keen on paying for it. My issue is just the duration it takes with lower OCC. I still need to survive as a business until it's installed if that's the final verdict.