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Adaptive re-use for transitional housing program - Fire Sprinklers Required?

JSKeppers

SAWHORSE
Joined
Oct 23, 2024
Messages
2
Location
Duluth, MN
I am working on a project in Wisconsin for a nonprofit that wants to use an existing building as a transitional living center for homeless families and single women. It will be configured as a group living facility, with 15-20 residents sharing two kitchens. Residents will stay for longer than 30 days, so they will be considered a non transient.

The code requirements are pretty straightforward to deal with except for one: the requirement for fire sprinklers. Obviously this is a very large expense which the client would like to avoid if possible. I believe my code analysis shows that fire sprinklers are not required, but the analysis is kind of sticky, so I’d like some feedback on whether my analysis is correct.

The existing building was once a triplex but in recent years has been used as an up/down duplex. Two stories, slab on grade with loadbearing brick exterior walls and wood framing elsewhere. Ground floor is 1,953 sq. ft., Upper floor is 1,817 sq. ft., therefore 3,770 sq. ft. overall floor area.

The previous use as a duplex would be covered under the Wisconsin Dwelling Code (not based on the IRC), but the proposed use is classed as a community-based residential facility with more than 8 unrelated adults, so my understanding is that it would need to be evaluated under the commercial codes.

Governing codes would then be the 2015 IBC and the 2015 IEBC, both with Wisconsin amendments.

I'd classify this as VB construction; possibly IIIB, but I'm not sure if the exterior walls meet a 2-hour fire rating requirement.

Occupancy classification would ideally be R-2, since it is proposed to be a Congregate Living Facility (non transient) with more than 16 occupants (IBC 310.4). However, I believe the client needs to limit it to 16 or fewer residents to have it classified as an R-3 in order to avoid a fire sprinkler requirement.

I'm evaluating the building per the IEBC work area compliance method, per IEBC 301.1.2.

This would be a Section 505 Level 3 alteration, since at least minor plan changes will be happening throughout the building. This would invoke Section 904.1, which in turn refers to a requirement in Section 804.2.2 that requires fire sprinklers in Group R-2 but not in Group R-3.

So this would avoid the sprinkler requirement if occupancy is limited to 16 or fewer occupants so that it is Group R-3.

It would also be a Section 506 Change of Occupancy. This requires a fire sprinkler system only “where there is a different fire protection system threshold requirement in Chapter 9 of the International Building Code.” And per IBC 903.2.8 as modified by the Wisconsin edits, an automatic sprinkler system "shall be provided throughout all buildings with a Group R fire area.” So since the sprinkler requirement is the same for all residential uses, this also would not trigger a fire sprinkler requirement.

Am I correct here that fire sprinklers would not be required if there are 16 or fewer residents? I’d appreciate your feedback.
 
@JSKeppers,
Please bear in mind that the IEBC cannot be applied to a building that was not a commercial building. Since the building is currently governed by the Wisconsin Uniform Dwelling Code (UDC), the proposed change of occupancy to an R-3 will need to comply with IBC for new construction. Perhaps the AHJ will recognize the previous use as a triplex (R-2). My significant experience in Wisconsin would suggest they will not.

SPS 366.0101(2) Change of occupancy to a public building occupancy.
(a) Except as provided in par. (b), where a building or portion of a building that has not been previously occupied or used as a public building or place of employment is to be changed to an occupancy or use that constitutes a public building or place of employment, the building or portion of a building shall comply with the IBC for new construction.
If the subject building is a qualified historic building, IEBC may be used.
SPS 366.0101(2)(b)
1. Under par. (a) the IBC rules for new construction do apply to the properties of existing building materials.
2. An alteration or a change of occupancy in a qualified historic building which has not been previously occupied or used as a public building or place of employment may utilize the provisions of the IEBC as modified by this subchapter.

If the building must be brought into compliance with the IBC, every aspect of the building will need to be evaluated for compliance and potentially upgraded.

Some relief exists for providing the building with an automatic sprinkler system:
IBC 2015 s.903.2.8.1 Group R-3.
An automatic sprinkler system installed in accordance with Section 903.3.1.3 (NFPA 13-D) shall be permitted in Group R-3 occupancies.

That would likely be a less expensive solution.
 
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