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Change of use Fire Sprinkler requirement?

J

Jay E.

Registered User
Joined
Jan 6, 2022
Messages
7
Location
Oregon
Hello. I am a newbie and have been tossed a curve that I cannot figure out.
I am restoring a former commercial sawmill building that was closed in 1973. It is 24000 sq ft single story. It has no sprinklers. Its use has been classified as F1, low hazard factory, and it will be only used for storage and display of the old sawmill equipment. Construction is V-B There is no public use.
In one corner of it (2 exterior walls) I was hoping to put a residence of 1500 sq ft R3. There are multiple egress points along all the walls, in the worst case from the farthest room, to the farthest egress, it is 60'. The planning department has approved the use and so we went to building. Unfortunately the building officials have insisted that I sprinkle the entire 24000 sq ft with a commercial sprinkler system because of the change of use!
This is what they sited, saying it says "Shall":



[F] 903.2.8 Group R

An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout all buildings with a Group R fire area.

[F] 903.2.8.1 Group R-3

An automatic sprinkler system installed in accordance with Section 903.3.1.3 shall be permitted in Group R-3 occupancies.

[F] 903.2.8.2 Group R-4, Condition 1

An automatic sprinkler system installed in accordance with Section 903.3.1.3 shall be permitted in Group R-4, Condition 1 occupancies.

[F] 903.2.8.3 Group R-4, Condition 2

An automatic sprinkler system installed in accordance with Section 903.3.1.2 shall be permitted in Group R-4, Condition 2 occupancies.


This seems ridiculous, because if the building were on fire, you would simply walk out.
My engineer insists that they are not applying the code correctly, but also say that they do not do code analysis, so cannot supply me with references to supply to the county. So I am stuck.
I have been reading a lot of the prior threads and can see that there seems to be a lot of grey areas concerning this. Can someone please point me in the the right direction so I can help my engineers to prepare a rebuttal to this requirement?
We even offered to put a residential sprinkler system intothe R3 portion, but they rejected that as well.

Here is one reply from a prior thread, and there are many others. I just don't know where to begin. Thank you in advance.

Interesting....I don't spend much time in the IFC....That section does read a lot like the prescriptive compliance part of the IEBC....But in the IEBC there may be some additional relief with work area or performance...

407.1 Conformance. No change shall be made in the use or
occupancy of any building unless such building is made to
comply with the requirements of the International Building
Code for the use or occupancy. Changes in use or occupancy
in a building or portion thereof shall be such that the existing
building is no less complying with the provisions of this code
than the existing building or structure was prior to the change.
Subject to the approval of the building official, the use or
occupancy of existing buildings shall be permitted to be
changed and the building is allowed to be occupied for purposes
in other groups without conforming to all of the
requirements of this code for those groups, provided the new
or proposed use is less hazardous, based on life and fire risk,
than the existing use.
 
Storage and display indicates the public will be in the building
What will the new use be classified?
They need to provide the code path that requires the entire building to have a fire suppression system installed and be reminded the section they are referring to is for new construction not existing. You do not get to 903.2.8 unless the requirement of 903.2 is met first.. There might be a local or state amendment that maybe different but they should provide it to you if asked

2018 IFC
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.

903.2.8 Group R.
An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout all buildings with a Group R fire area.


You should be able to separate the dwelling from the remainder and only sprinkle the "R" portion if the other use does not require a sprinkler system also

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mtlogcabin said:
Storage and display indicates the public will be in the building
Click to expand...
The use will be private use and storage. Becasue of ADA requirements, there is no possible way to invite the public into the building. We specifically pointed out that the building would not be used by the public in the planning application. There may be some posibility that I may be abvle to operate the machinery at some time as my own hobby, but it could never be used commercially.
 
mtlogcabin said:
You should be able to separate the dwelling from the remainder and only sprinkle the "R" portion if the other use does not require a sprinkler system also
Click to expand...
Can you describe what "separate " means? To the County, it means that it cannot be under the same roof. The engineer put in a 2 hour fire wall on all adjacent interior sides.
 
mtlogcabin said:
You should be able to separate the dwelling from the remainder and only sprinkle the "R" portion if the other use does not require a sprinkler system also
Click to expand...
Current the commercial building does not require a fire sprinkler system. But now they say that they required it because of the change of use of the interior partitioned section. If I understand you correctly, you are saying that I only need to sprinkler the R3 section? This is very odd, because we inserted the language of 903.3 private residence fire sprinkler system into the plans. How do I show that this and a firewall is enough?
[F] 903.3 Installation Requirements
Automatic sprinkler systems shall be installed in accordance with Sections 903.3.1 through 903.3.8.
AUTOMATIC SPRINKLER SYSTEM. An automatic sprinkler system, for fire protection purposes, is an integrated system of underground and overhead piping designed in accordance with fire protection engineering standards. The system includes a suitable water supply. The portion of the system above the ground is a network of specially sized or hydraulically designed piping installed in a structure or area, generally overhead, and to which automatic sprinklers are connected in a systematic pattern. The system is usually activated by heat from a fire and discharges water over the fire area.
 
2018 IFC, Section 102.1, states that the "construction and design provisions" of the code would only apply to the extent as required by IFC Chapter 11 for existing buildings. Section 102.2 states that the "administrative, operational and maintenance provisions" apply to new and existing conditions and operations.

Section 903 of the IFC is not an "administrative, operational and maintenance" provision. Thus, it would not apply to an existing building. There are no sprinkler provisions in IFC Chapter 11 for Group R-3. Therefore, the provisions of the IEBC would take precedence. If the IEBC points back to either IBC or IFC Chapter 9, then the sprinkler provisions may be applicable depending on the reference.

IEBC Section 1011.1.1 has provisions for changes of occupancy with and without separation. If you provide the separation per IEBC Section 1011.1.1.2, then the sprinkler is limited to only the change of occupancy area and is not required throughout the building.
 
Jay E. said:
Can you describe what "separate " means? To the County, it means that it cannot be under the same roof. The engineer put in a 2 hour fire wall on all adjacent interior sides.
Click to expand...

fatboy said:
That is separated.
Click to expand...
Because the roof is 20 feet tall in the mill building, the enginer built a 2 hour box around the interior structure. Sides, and lid. The roof is still the roof of the original mill. Should this suffice or do I need to build some huge partition walls?
 
IEBC

1011.1.1.2 Change of occupancy classification with separation.
Where a portion of an existing building is changed to a new occupancy classification or where there is a change of occupancy within a space where there is a different fire protection system threshold requirement in Chapter 9 of the International Building Code, and that portion is separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the International Building Code for the separate occupancy, that portion shall comply with all of the requirements of Chapter 9 of this code for the new occupancy classification and with the requirements of this chapter.
 
Thjank you to everyone that has responded. You have given me some points to discuss with my engineer and hopefully we can find a way forward in the Oregon Codes.
 
IEBC Chapter 14 Performance Compliance Method for change of use avoids sprinklers? (though Mass has an amendment for only up to 7500 ft2)
 
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