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Fire reviews vs. building reviews

Sifu

SAWHORSE
Joined
Sep 3, 2011
Messages
2,809
I do not conduct fire reviews, because I am not qualified to do so. Those reviews are conducted by the local fire agency in every AHJ in which I have worked except one. In that one, the building department had it's own fire plans staff.

So I work concurrently but entirely separate from the local fire agency, who conducts a review of the same plans I do on the same permit, but they have requirements for additional permits and plans that I never see for sprinklers and alarms. The plans very rarely have any technical details for alarms and sprinklers. I try to determine the appropriate systems knowing those systems will be examined by the fire authority separately.

I have always taken the approach that I work from the IBC, which scopes those systems, and they work from the IFC & NFPA for the technical provisions. For example, from a given plan reviewing from the IBC I can determine that a building is not suitable for a proposed NFPA 13R system based on construction type and occupancy classification from ch. 5 and allowable area. My reviews examine the building for all relevant requirements of the entire IBC. It seems their reviews only look at IFC ch. 9 and NFPA 13R. My conclusion is that I look at whether a building fits into the allowable area for using a 13R system first, then 903.3.1.2 could be applied if the building is four stories or less. If my conclusions are wrong, then I need to go back to the drawing board. If they are right, read on.

Sometimes (as in this case) my comments reflect that the proposed 13R system is not approved, and why. So no matter what, from the start, they can't be approved.

Enter the fire authority, that apparently looks only at the provisions of ch. 9 of the IFC, and NFPA 13R. IBC 903.3.1.2 tells me a 13R system can be installed in an R2 up to and including a 4 story building, (and I assume that relies on the allowable area limitations of IBC ch. 5). NFPA 13R 1.1. says the same thing. So both the IBC ch. 9 and IFC ch. 9 scope the same thing. But if only using the IFC and NFPA 13R, there is no allowable area analysis as far as I can tell.

The result is the fire authority "approving" the building as designed with a 13R system, while I reject the same building. The applicant sees competing reviews, one is approved, the other is rejected.

Many fire authorities I overlap only look through the magnifying glass of IBC/IFC ch. 9 and the NFPA. Some also look somewhat more closely and ch. 10, but even that is rare. Only one I have worked for had reviewers that had an understanding and/or inclination to look at the other relevant portions of the IBC, and we would collaborate and present consistent comments.

Most of the time I will reject a plan for issues like this, and include multiple issues with EATD, CPET, door swing, hardware etc. The same plans will be approved by the fire authority with a canned comment to make sure they secure their sprinkler and alarm permits. I rarely ever see any comments that coincide with mine for issues outside of IBC/IFC ch. 9.

By the time my review comments are returned with a rejection, the applicant has been sitting on an "approved" plan from the fire department for a couple of weeks. They resubmit to me with a new proposal, whether they resubmit to the FD I never know, however MANY times they do not.

If my supposition that the allowable area must be satisfied first and then 903.3.1.2 is applied is correct, would it be beneficial for IBC/IFC 903.3.1.2 to include a reference that they can be installed up to and including 4 stories when meeting the allowable area provisions of ch. 5? That is something I have inferred (hopefully correctly), but is not expressed in the code.

The system I have described is common in the areas in which I work. I can't change it. I can't impose my views on the fire authority. That is why I wonder if adding that small section to IBC/IFC 903.3.1.2 might help.

In this one case that prompted this post, the architect details that the allowable area is exceeded, but that they can still use a 13R system because 903.3.1.2 tells them they can. One of us is wrong. Gosh I hope it's not me.
 
Where I work, the Fire Marshal only looks at the IFC (and the referenced NFPA standards) -- the FM doesn't open the IBC or IRC.

However -- the NFPA standards for sprinkler systems and alarm systems are reference documents in the IBC, so the Building Official has overlapping jurisdiction with the Fire Marshal. I don't review the actual sprinkler calculations, because in this state that's covered in FM training and BOs are instructed to leave that for the FMs. Plus, the actual design calcs are typically at the shop drawing stage, not the building permit review stage. That said, I review for adequacy of water supply, and our plumbing inspector will review the basic water supply, sprinkler control room, risers, etc.

Worse, if someone wants to do a 13D system -- such projects under our statutes are not under the FM's jurisdiction at all, so the building department has to do any review of a 13D system (or a 13R system in IRC townhouses) without the FM.
 
The building code trumps a standard (NFPA) every time. The 2021 codes basically makes it very difficult for a 13-R system to be used in a 4 story building.

[F] 903.3.1.2 NFPA 13R sprinkler systems.

Automatic sprinkler systems in Group R occupancies shall be permitted to be installed throughout in accordance with NFPA 13R where the Group R occupancy meets all of the following conditions:
  1. 1.Four stories or fewer above grade plane.
  2. 2.The floor level of the highest story is 30 feet (9144 mm) or less above the lowest level of fire department vehicle access.
  3. 3.The floor level of the lowest story is 30 feet (9144 mm) or less below the lowest level of fire department vehicle access.
The number of stories of Group R occupancies constructed in accordance with Sections 510.2 and 510.4 shall be measured from grade plane.

 
IBC Table 504.3 specifically notes which occupancies can increase the allowable height based on a 13R or 13D sprinkler system. Only R occupancies can increase heights for anything other than a full NFPA 13 system.

For area, again 13R and 13D systems appear only in the R occupancies in Table 506.2. For R1 and R-2, 13D isn't even mentioned, and 13R doesn't get you any increase over non-sprinklered. A full NFPA 13 system does increase the allowable area. For R-3, area doesn't change whether it's non-sprinklered or fully sprinklered. For R-4, a 13R or 13D system doesn't gain any allowable area over non-sprinklered, but a full NFPA 13 system allows significant increases.

If my supposition that the allowable area must be satisfied first and then 903.3.1.2 is applied is correct, would it be beneficial for IBC/IFC 903.3.1.2 to include a reference that they can be installed up to and including 4 stories when meeting the allowable area provisions of ch. 5? That is something I have inferred (hopefully correctly), but is not expressed in the code.

Isn't this addressed by Table 504.3? (Maybe I don't understand your question.)

IIRC, the current requirements are a change. It used to be that a 13R system didn't allow any increase to height or area -- to increase either required a full NFPA 13 system.
 
IBC Table 504.3 specifically notes which occupancies can increase the allowable height based on a 13R or 13D sprinkler system. Only R occupancies can increase heights for anything other than a full NFPA 13 system.

For area, again 13R and 13D systems appear only in the R occupancies in Table 506.2. For R1 and R-2, 13D isn't even mentioned, and 13R doesn't get you any increase over non-sprinklered. A full NFPA 13 system does increase the allowable area. For R-3, area doesn't change whether it's non-sprinklered or fully sprinklered. For R-4, a 13R or 13D system doesn't gain any allowable area over non-sprinklered, but a full NFPA 13 system allows significant increases.



Isn't this addressed by Table 504.3? (Maybe I don't understand your question.)

IIRC, the current requirements are a change. It used to be that a 13R system didn't allow any increase to height or area -- to increase either required a full NFPA 13 system.
Often, I find it is the question that needs improvement, not the answer. In this case I think you understand the question, even as poorly as I phrased it. I too believe the allowable area is covered by t504.2, and stands alone before you get to 903.3.1.2 but I have had two DP's ignore that and assume...I guess.... that 903.3.1.2 throws a blanket over any building 4 stories or less regardless of size. That is not the way I have always understood 903.3.1.2. I guess changing the code is probably a bridge that doesn't need crossed for my two DP's. I am pasting the most recent example here in case anyone really wants to dive in: (Note-The more I read this, the less I understand what they are trying to say.)

This is the justification in their code analysis for exceeding the allowable area (they do not present equation 5-2 anywhere). Note the "however" reference to 903.3.1.2:

1713382378300.png

I don't even know what to say about this one. I think they are showing the math for equation 5-1, but they call it 5-5, for the allowable area. They plug in the tabular area for a 13 system instead of a 13R system for equation 5-1, and then use the NFPA 13 tabular area instead of NS tabular area in the equation.
(They seem to call it frontage equation 5-5 but the actual math is allowable area equation 5-1, which should be 5-2)

1713382412045.png
I believe this entire code analysis was generated using some sort of AI, or some other canned tool, and this is why I don't believe the folks who say our days as plans examiners are numbered.....but I digress. I personally have never seen anything like it.

My math using equation 5-2 (frontage is .75)
At=[Aa+(NSxIf)]xSa
At=[7,000+(7,000x.75)]x3
At=[7,000+(5,250)]x3
At=12,250x3
Aa=36,750sf² *no single plate can exceed 12,250sf²

Both the single floor plate and the overall area are exceeded by my reckoning.

There are 9 full 24x36 pages of regurgitated code analysis like this, much of which is not applicable to this project. My head is spinning.
 
2018 IFC

901.4.1 Required fire protection systems.
Fire protection systems required by this code or the International Building Code shall be installed, repaired, operated, tested and maintained in accordance with this code. A fire protection system for which a design option, exception or reduction to the provisions of this code or the International Building Code has been granted shall be considered to be a required system.
 
Both the single floor plate and the overall area are exceeded by my reckoning.

There are 9 full 24x36 pages of regurgitated code analysis like this, much of which is not applicable to this project. My head is spinning.

You have my sincere sympathy. We routinely deal with a PE who likes to play architect, who is prone to filling up the "construction" documents with irrelevant garbage to mask the fact that he doesn't have a clue what he's blathering about. When I started my current job almost three years ago, both the Building Official and the Fire Marshal warned me about the guy. Yes, those people do give you headaches -- literally.
 
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