Group M with upholstered furniture

[Mr. Inspector]

An office supply store just moved in where a dollar store use to be recently. It was not considered a change of occupancy and there was not any construction so no permit was required. I stopped there yesterday and they had some upholstered office chairs on display for sale. It's part of a old strip mall that is way over 5,000 sq. ft. and not sprinklered.

2015 IBC:
[F] 903.2.7 Group M. An automatic sprinkler system
shall be provided throughout buildings containing a Group
M occupancy where one of the following conditions
exists:
1. A Group M fire area exceeds 12,000 square feet
(1115 m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale
of upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).

Should I require a permit for a change of occupancy and require sprinklers in the whole strip mall building?

 

[RLGA]

There're two ways of interpreting this:

1. The area of the Group M exceeds 5,000 sq. ft. and includes the display of upholstered furniture.
2. The area used for the display of upholstered furniture in a Group M exceeds 5,000 sq. ft.

The Commentary seems to suggest #2, but it's not a strong indication:

"Note that, as with Group F-1 occupancies, the criteria is written such that any Group M occupancy, not the fire area, over 5,000 square feet (464 m2) used for
the display and sale of upholstered furniture and mattresses shall be sprinklered throughout."
​

The IBC Handbook is a little more specific about interpretation #2:

"The installation of an automatic sprinkler system is also mandated in any Group M occupancy that is used for the display and sale of upholstered furniture or mattresses where the floor area devoted to such goods exceeds 5,000 square feet (464 m2)."
​

I understand these are NOT (<edit) mandatory documents, but they could help sway an interpretation at the local level.

 

[classicT]

I've fought this same battle. Unfortunately, for the situation I dealt with, a business license for a mattress store that exceeded 5000sf was issued. I worked with our fire marshal to notify the building owner and tenant that the building required fire sprinklers and that a change of occupancy was required (although the 'M' occupancy group went unchanged). Tenant ended up relocating to a new stand-alone building.

See 2015 IBC definition below:

[A] CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.​

 

[Mr. Inspector]

Usually the code want the most strictest requirement.

[A] 102.1 General. Where there is a conflict between a general
requirement and a specific requirement, the specific
requirement shall be applicable. Where in any specific case
different sections of this code specify different materials,
methods of construction or other requirements, the most
restrictive shall govern.

I'm not sure of the size of the the tenant space of the office supply store but the whole strip mall is M. No fire areas.
Under F-1 it's manufacture of upholstered furniture not the sale and display which can be very different.

Does the commentary say anything different about upholstered furniture stored in a S-1 occupancy?

 

[Mr. Inspector]

2015 IEBC
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.

 

[classicT]

Should I require a permit for a change of occupancy and require sprinklers in the whole strip mall building?

And as another thought, you would only need to require sprinklers in the area undergoing the change.

1012.2.1 Fire Sprinkler System
Where a change in occupancy classification occurs 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 that requires an automatic fire sprinkler system to be provided based on the new occupancy in accordance with Chapter 9 of the International Building Code, such system shall be provided throughout the area where the change of occupancy occurs.

[A] CHANGE OF OCCUPANCY. A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.​

 

[steveray]

Storage is even tougher for some reason....

5. A Group S-1 occupancy used for the storage of upholstered furniture or mattresses exceeds 2,500 square feet (232 m2).

But I would go with Ron's #2 because it makes sense....Becomes an enforcement issue on the other end, but it is what it is...

 

[JPohling]

I usually only see a small section of office chair displays in these stores.
Typically a small fraction of the sales area. I cannot imagine it is anywhere near approaching 5,000 SF?
I would assume they would be able to get the area for this type of commodity below the threshold SF to trigger the sprinklers.

How about the storage component?
Are they being stored on a racking system in their packaging? In a store room or out on sales floor?

 

[Paul Sweet]

I've never seen mattresses in an office supply store, and there isn't nearly as much foam in an office chair as their is in an armchair or sofa. I think the interpretation of 5000 SF of furniture is more reasonable.

 

[Mr. Inspector]

Thanks RGLA. But that just makes it more confusing with the commendatory and hand book saying different things..

They are desk chairs but they are not just all together in one spot, they are spread out in the store. Does that make a difference?

A Group M occupancy used for the display and sale
of upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).

I don't see how you can add words to this section to interpret it to mean something else:

A Group M occupancy has an space or area that is used for the display and sale
of upholstered furniture or mattresses that exceeds 5,000
square feet (464 m2).

or

An area or space in a Group M occupancy used for the display and sale
of upholstered furniture or mattresses that exceeds 5,000
square feet (464 m2).

It doesn't say an area or space of the Group M occupancy, or an area or space with the upholstered furniture.
It just says the Group M occupancy

How about the storage component?
Are they being stored on a racking system in their packaging? In a store room or out on sales floor?

I don't know, I did not go in the storage area. I just stopped in the store to buy something. I am not the code official here but just the 3rd party inspector here. I haven't decide what to recommend if anything to the code official yet.

It's interesting that the IFC goes by the High-Piled Storage area in square feet, not the occupancy. I would think that the IBC would say the upholstered furniture or mattresses display area in square feet if that is what it meant instead of the whole occupancy's square feet..

 

[Mr. Inspector]

I've never seen mattresses in an office supply store, and there isn't nearly as much foam in an office chair as their is in an armchair or sofa. I think the interpretation of 5000 SF of furniture is more reasonable.

I never said they had mattresses. So how would you measure the furniture? My desk chair takes about 2 sq. ft.of floor space so they would need over 2,500 upholstered desk chairs to require fire sprinklers? Or do you also count the vertical sq. ft. of the back of the chairs also?

 

[Mr. Inspector]

Looking in chapter 9 of the IBC I am looking for other sections that say something like 903.2.7. to get an interpretation.

Here it actually says the sq. ft. area in a S-1 occupation:.

[F] 903.2.9.2 Bulk storage of tires. Buildings and
structures where the area for the storage of tires
exceeds 20,000 cubic feet (566 m3) shall be equipped
throughout with an automatic sprinkler system in
accordance with Section 903.3.1.1.

Here it uses the word area again:

[F] 903.2.4.1 Woodworking operations. An automatic
sprinkler system shall be provided throughout all
Group F-1 occupancy fire areas that contain woodworking
operations in excess of 2,500 square feet (232
m2) in area that generate finely divided combustible
waste or use finely divided combustible materials.

and again:

[F] 903.2.1.5 Group A-5. An automatic sprinkler system
shall be provided for Group A-5 occupancies in the
following areas: concession stands, retail areas, press
boxes and other accessory use areas in excess of 1,000
square feet (93 m2).

So if these sections are saying "area" wouldn't 903.2.7 say the In a Group M occupancy where an area used for the display and sale of upholstered furniture or mattresses exceeds 5,000 square feet requires sprinklers if it really meant a area used for the display and sale of upholstered furniture or mattresses

please, I am interested in everyone option.

 

[mtlogcabin]

If you follow the logic on this interpretation of an S-1 occupancy and upholstered furniture then every M occupancy with 5,000 sq ft and the first piece of upholstered furniture for sale will require sprinklers.
I disagree and believe the sq ft applies to the display area and not the size of the store.

SECTION 903.2.9 2012 Edition IFC Interpretation 20-14 Issued 10-6-2014 FI_12_20_14 903.2.9 Group S-1. An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists: 1. A Group S-1 fire area exceeds 12,000 square feet (1115 m2). 2. A Group S-1 fire area is located more than three stories above grade plane. 3. The combined area of all Group S-1 fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2). 4. A Group S-1 fire area used for the storage of commercial trucks or buses where the fire area exceeds 5,000 square feet (464 m2). 5. A Group S-1 occupancy used for the storage of upholstered furniture or mattresses exceeds 2,500 square feet (232 m2). ● ● ● ● ● ● ● ● ● ●

Q: The area of a self-storage warehouse is between 2,500 square feet and 12,000 square feet. Spaces are rented to individuals for the storage of personal household items (which could include incidental pieces of upholstered furniture and mattresses). Does item #5 require an automatic sprinkler system throughout the Group S-1 self-storage warehouse?

A: Yes. This criteria is written such that any Group S-1 occupancy, not the fire area, over 2,500 square feet used for the storage of upholstered furniture and/or mattresses shall be sprinklered throughout the building. This is regardless of how much upholstered furniture and/or mattresses are actually stored.

 

[JPohling]

Agree with MT

 

[steveray]

I heard that was changing/ being clarified "just for" the self storage industry.....

 

[steveray]

2018
[F] 903.2.7 Group M. An automatic sprinkler system shall
be provided throughout buildings containing a Group M
occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115
m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale of
upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).
The sprinkler threshold requirements for Group M
occupancies are identical to those of Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4).
The one exception is that Group M occupancies are
provided with an increased area for display of upholstered
furniture and mattresses of 5,000 square feet
(464 m2) versus 2,500 square feet (232 m2) required
for Group F-1 and S-1 occupancies. As noted in the
commentary for Group F-1 occupancies, upholstered
furniture and mattresses have the potential for rapid
growing and high-heat-release fires. This hazard is
increased substantially when there are numerous
upholstered furniture items or mattresses on display.
Such fires put the occupants and emergency
responders at risk. This requirement exists regardless
of whether the upholstered furniture has passed
any fire-retardant tests.

 

[steveray]

sorry that was 2012

 

[steveray]

[F] 903.2.7 Group M. An automatic sprinkler system shall
be provided throughout buildings containing a Group M
occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115
m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale of
upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).
The sprinkler threshold requirements for Group M
occupancies are identical to those of Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4).
The one exception is that Group M occupancies are
provided with an increased area for display of upholstered
furniture and mattresses of 5,000 square feet
(464 m2) versus 2,500 square feet (232 m2) required
for Group F-1 and S-1 occupancies. As noted in the
commentary for Group F-1 occupancies, upholstered

 

[steveray]

furniture and mattresses have the potential for rapidly
growing and high-heat-release fires. This hazard is
increased substantially when there are numerous
upholstered furniture items or mattresses on display.
Such fires put the occupants and emergency
responders at risk. This requirement exists regardless
of whether the upholstered furniture has passed
any fire-retardant tests.
The code does not specifically address what constitutes
upholstered furniture, but by simple dictionary
definition, upholstered furniture has seats covered
with padding, springs, webbing and fabric or leather
covers. The code does not make any distinction
between levels of padding and upholstery provided
on furniture, which was intentional. The proponent’s
reason statement for code change F135-07/08
stated, in part, “the American Home Furnishings Alliance
(AHFA) and the National Home Furnishings
Association (NHFA) have examined proposals for
exempting vendors of certain constructions of furniture
and concluded that such exemptions would be
impractical for local code officials to enforce. This is
the case because the internal construction of furniture
cannot be established reliably without deconstructing
it.”
Note that, as with Group F-1 occupancies, the criteria
is written such that any Group M occupancy, not
the fire area, over 5,000 square feet (464 m2) used for
the display and sale of upholstered furniture and mattresses
shall be sprinklered throughout. This is
regardless of the quantity of upholstered furniture and
mattresses actually available for purchase. The reason
these requirements were placed into the code
and the IFC was based on a large fire in Charleston,
South Carolina, that killed nine fire fighters. The facility
was a combination furniture showroom and associated
storage area. The building did not provide an
automatic sprinkler system. See the commentary to
Section 903.2.9 for discussion of a formal interpretation
dealing with Group S-1 occupancies and applicability
to the code and the IFC.
Automatic sprinkler systems for mercantile occupancies
are typically designed for an Ordinary Hazard
Group 2 classification in accordance with NFPA
13. If high-piled storage (see Section 903.2.7.1) is
anticipated, additional levels of fire protection may be
required. Also, some merchandise in mercantile
occupancies, such as aerosols, rubber tires, paints
and certain plastic commodities, even at limited storage
heights, are considered beyond the standard
Class I through IV commodity classification assumed
for mercantile occupancies in NFPA 13 and may warrant
additional fire protection.

 

[steveray]

Maybe not....

See the commentary for Group M and
Group F-1 definitions for more discussion on this
issue. Again, it is important to note that the threshold
is based on the square footage of the occupancy and
not on the size of the fire area. A formal interpretation
(IFC Interpretation 20-14) has been issued on this
section. The formal interpretation addresses self-storage
warehouses specifically and whether such a
facility between 2,500 and 12,000 square feet would
require an automatic sprinkler system. This is based
on the fact that upholstered furniture may be stored in
such units. The response provided noted that a sprinkler
system would be required given that the requirements
focus on the square footage of the occupancy
and are not based on fire area or the amount of
upholstered furniture or mattresses present.

 

[RLGA]

I tried to go back and see what was submitted in regard to proposals that would limit the area to 5,000 sq. ft. during the 2009/2010 code development cycle. There were three proposals submitted that modified this particular part of Section 903.2.7: F69, F71, and F72. F69 added mattresses to the issue, F71 added an area limitation of 7,500 sq. ft., and F72 wanted the requirement for upholstered furniture deleted entirely.

F71 was disapproved and F72 was withdrawn by proponent. F69 (this proposal also included similar modifications for Groups F-1 and S-1) was initially "disapproved" but was changed to "approved as modified" during the public hearing, which kept the "mattresses" addition and added the 5,000 sq. ft. limitation. The reason given for the area limitation addition is as follows:

"The committee approved the proposal as they felt that Group F-1 and Group S-1 occupancies manufacturing and storing upholstered furnishings and mattresses pose the same hazard to occupants and firefighters that Group M occupancies displaying and selling such materials. The proposal was modified to provide a reasonable threshold that would not penalize occupancies with very small amounts of such materials. These thresholds were based on the thresholds in Chapter 23 of the IFC with regard to size of high piled storage areas." (emphasis added)
​

Based on the reason, it appears that the 5,000 sq. ft. limitation was intended to be applied to the actual area occupied by such materials and not to the entire Group M occupancy area; however, the language used does not clearly reflect that intent.

 

[classicT]

I tried to go back and see what was submitted in regard to proposals that would limit the area to 5,000 sq. ft. during the 2009/2010 code development cycle. There were three proposals submitted that modified this particular part of Section 903.2.7: F69, F71, and F72. F69 added mattresses to the issue, F71 added an area limitation of 7,500 sq. ft., and F72 wanted the requirement for upholstered furniture deleted entirely.

F71 was disapproved and F72 was withdrawn by proponent. F69 (this proposal also included similar modifications for Groups F-1 and S-1) was initially "disapproved" but was changed to "approved as modified" during the public hearing, which kept the "mattresses" addition and added the 5,000 sq. ft. limitation. The reason given for the area limitation addition is as follows:

"The committee approved the proposal as they felt that Group F-1 and Group S-1 occupancies manufacturing and storing upholstered furnishings and mattresses pose the same hazard to occupants and firefighters that Group M occupancies displaying and selling such materials. The proposal was modified to provide a reasonable threshold that would not penalize occupancies with very small amounts of such materials. These thresholds were based on the thresholds in Chapter 23 of the IFC with regard to size of high piled storage areas." (emphasis added)
​

Based on the reason, it appears that the 5,000 sq. ft. limitation was intended to be applied to the actual area occupied by such materials and not to the entire Group M occupancy area; however, the language used does not clearly reflect that intent.

I'd state that part of the challenge in looking only at the area where the materials are stored is how to regulate.

Products for sale are typically not stocked until after CO, so verification is limited. Additionally, what happens as products cycle in and out; does the area encompassed by upholstered goods/mattresses change? If so, is that a change of occupancy that would trigger the need for fire sprinklers?

What happens when company A goes belly up, company B moves in and has a larger portion of the space dedicated to upholstered goods/mattresses?

From a code perspective, I believe that the only approach is to include the entire sales floor area when determining if greater or less than 5000sf. Stockrooms (if greater than 10%) would be classified as an S-1, and must meet the separate requirements therein. Offices/breakrooms/etc. need not be included in the area so long as there is reasonable cause (defined room, permanent fixtures, etc.) to show they will not be used for the sale of upholstered goods or mattresses.

 

[JPohling]

You cannot be a mind reader for the future situations that may arise.
I would never base this on the total sales floor square footage, only on the SF where this commodity is being displayed.and stored.

 

[classicT]

You cannot be a mind reader for the future situations that may arise.
I would never base this on the total sales floor square footage, only on the SF where this commodity is being displayed.and stored.

And how would you determine where the commodity will be stored?

Commodity cant be stocked prior to CO, so when?