Fire Pump Separation

[MDTA]

Just ran into a code issue. Curious what other's thoughts are. We have a fully sprinklered building (ESFR). Tilt concrete construction. The fire pump room is located on an exterior wall, and the only door into the pump room is from the exterior. We have 1-hr rated construction separating the fire pump room from the rest of the building per IBC/IFC and NFPA 20. The fire marshal is telling us that the exterior wall and door also have to be rated. I responded by pointing out the fire pump is required to be protected from the surrounding building, and that separation is not required from the exterior, so exterior wall and door do not have to be rated. Fire marshal disagrees and pointed to NFPA 20 4.14.1.1.2, which does not specifically state separation is required from the rest of the building, although 4.14.1.1.1 right before it does make that distinction. We have solid concrete walls that are inherently fire rated construction, so typically I would just say ok and label them rated. The issue is we are required to have ventilation in the pump room per NFPA 20, so we have a makeup air louver in the exterior wall. If we rate the wall, then my understanding is we will have to put a F/S damper on that louver, which is added cost and unnecessary in my opinion. Is your understanding that all walls have to be rated as the fire marshal is saying, or just the walls between pump room and rest of building?

 

[tmurray]

I've always interpreted it as you suggest.

 

[Inspector Gadget]

Just ran into a code issue. Curious what other's thoughts are. We have a fully sprinklered building (ESFR). Tilt concrete construction. The fire pump room is located on an exterior wall, and the only door into the pump room is from the exterior. We have 1-hr rated construction separating the fire pump room from the rest of the building per IBC/IFC and NFPA 20. The fire marshal is telling us that the exterior wall and door also have to be rated. I responded by pointing out the fire pump is required to be protected from the surrounding building, and that separation is not required from the exterior, so exterior wall and door do not have to be rated. Fire marshal disagrees and pointed to NFPA 20 4.14.1.1.2, which does not specifically state separation is required from the rest of the building, although 4.14.1.1.1 right before it does make that distinction. We have solid concrete walls that are inherently fire rated construction, so typically I would just say ok and label them rated. The issue is we are required to have ventilation in the pump room per NFPA 20, so we have a makeup air louver in the exterior wall. If we rate the wall, then my understanding is we will have to put a F/S damper on that louver, which is added cost and unnecessary in my opinion. Is your understanding that all walls have to be rated as the fire marshal is saying, or just the walls between pump room and rest of building?

I can see where your FMO is coming from, and am inclined to agree.

4.14.1.1.2
Except as permitted in 4.14.1.1.3, indoor fire pump rooms in non-high-rise buildings or in separate fire pump buildings shall be physically separated or protected by fire-rated construction in accordance with Table 4.14.1.1.2.

I'm of the view that the absence of information is vital: the language is "fire-rated construction ... " not "isolated from the rest of the building by a one-hour fire-rated assembly."

Search of the interwebs did not reveal anything interesting. Will be interesting to see what others have to say ...

The only thought I have is whether your local codes provide relief. In one of the cases I read, the requirement for a two-hour passageway was overturned at a tribunal hearing because the empowering Code stated that "in case of conflict between this code and any other code or standard, this code shall prevail."
(FYI: https://www2.gov.bc.ca/gov/content/...eal-board-decisions/bcab-1809?keyword=NFPA 20)

 

[mtlogcabin]

[A] 102.4.1 Conflicts.
Where conflicts occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.

[A] 102.4.2 Provisions in referenced codes and standards.
Where the extent of the reference to a referenced code or standard includes subject matter that is within the scope of this code or the International Codes listed in Section 101.4, the provisions of this code or the International Codes listed in Section 101.4, as applicable, shall take precedence over the provisions in the referenced code or standard.

 

[RLGA]

What is the fire separation distance between the exterior wall and the lot line (or imaginary lot line)?

According to NFPA 20, Table 4.14.1.1.2, it is required to be a one-hour rating or 50-foot separation.

However, I am in agreement with @mtlogcabin. Since the term used is "fire-rated construction," they have not established the specifics of what that constitutes; thus, it defaults to the referencing document for clarity: the IBC in this case. In the IBC (and even NFPA 5000), fire-resistance-rated exterior walls are treated differently than interior fire-resistance-rated assemblies. Openings may be unprotected up to a point in exterior walls.

The explanatory material in Annex A does not shed any light on the issue, either.

I guess it will be a matter of interpretation and what you can convince the fire marshal* to accept.

* Thank you for using "marshal" with one "l" and not two (i.e., "marshall"). The latter would marginally be acceptable if the fire marshal's name is "Marshall." You do not know how many times I see this title used incorrectly.

 

[tmurray]

I can see where your FMO is coming from, and am inclined to agree.

4.14.1.1.2
Except as permitted in 4.14.1.1.3, indoor fire pump rooms in non-high-rise buildings or in separate fire pump buildings shall be physically separated or protected by fire-rated construction in accordance with Table 4.14.1.1.2.

I'm of the view that the absence of information is vital: the language is "fire-rated construction ... " not "isolated from the rest of the building by a one-hour fire-rated assembly."

Search of the interwebs did not reveal anything interesting. Will be interesting to see what others have to say ...

The only thought I have is whether your local codes provide relief. In one of the cases I read, the requirement for a two-hour passageway was overturned at a tribunal hearing because the empowering Code stated that "in case of conflict between this code and any other code or standard, this code shall prevail."
(FYI: https://www2.gov.bc.ca/gov/content/industry/construction-industry/building-codes-standards/building-code-appeal-board/building-code-appeal-board-decisions/bcab-1809?keyword=NFPA 20)

I'm not sure I would agree with the BC tribunal ruling. The intention of the access and fire separation requirements in NFPA 20 are to ensure the room can be accessed by firefighting personnel to ensure the fire pump remains operational, which is critical to firefighting operations.

The requirements for general service rooms are to compartmentalize fire, delaying early fire growth to ensure occupants can escape the building and assist in suppression.

I don't see these requirements as being in conflict.

 

[steveray]

I'm in the "don't rate the outside unless there is a building closer than 50'" camp.....the room is 3/4 protected by a FR separation and 1/4 protected by distance....

 

[Inspector Gadget]

I'm not sure I would agree with this ruling. The intention of the access and fire separation requirements in NFPA 20 are to ensure the room can be accessed by firefighting personnel to ensure the fire pump remains operational, which is critical to firefighting operations.

The requirements for general service rooms are to compartmentalize fire, delaying early fire growth to ensure occupants can escape the building and assist in suppression.

I don't see these requirements as being in conflict.

Not sure whether you're referring to the NFPA 20 interp - which this discussion has led to a clear need for clarification on intent (never seen f/r doors on exterior wall unless spatial separation issues are at hand), or if you're referring to the BC codes tribunal ruling in the link. Those folks spit out some odd rulings every now and then. From what I've seen, most Canadian AHJs do not want to see spurious electrical outlets in an exit shaft. I know the FMO in our province is of the same mind - but the BC tribunal said "meh."

 

[tmurray]

Not sure whether you're referring to the NFPA 20 interp - which this discussion has led to a clear need for clarification on intent (never seen f/r doors on exterior wall unless spatial separation issues are at hand), or if you're referring to the BC codes tribunal ruling in the link. Those folks spit out some odd rulings every now and then. From what I've seen, most Canadian AHJs do not want to see spurious electrical outlets in an exit shaft. I know the FMO in our province is of the same mind - but the BC tribunal said "meh."

I was referring to the BC codes tribunal ruling. I have edited my original post for clarity.

On the application of NFPA 20, If the fire fighters in the fire pump room need 2 hours from the outside (where their egress is) then they have a serious issue.

 

[MDTA]

I appreciate the responses. My understanding of the 1-hr or 50' rule is that if the pump is in a separate enclosure outside of the building, that enclosure either has to be 50' away from the building or it has to be 1-hr rated construction. So distance to lot line doesn't matter if the pump room is in the building. NFPA 20 4.14.1.1.1 specifically states that in a high rise, the pump shall be separated from the surrounding building. In my opinion, 4.14.1.1.2 only modifies that requirement for non-high rise buildings, so intent is the same, it's just the rating that changes. The way the IBC/IFC is organized makes this clear, and the commentary for IBC 913.2.1 states that the requirements in that section correlate with NFPA 20. I sent the commentary to the FM in my initial push-back, but they still disagreed. I'm reaching out to the owner to see if they want me to continue pushing, or just pay for a F/S damper and be done with it. Still bugs me just based on principle.

 

[north star]

@ ~ @

MDTA, I believe that this Forum agrees with your interpretation
& the applicable Codes & Standards.........As you already know, the FM
has the final word, unless his gets over-ruled by the AHJ "powers-that-be".
Anyhoo, you get kudos for trying and providing the correct Code sections.
Keep on, keeping on !

@ ~ @