Magic Loophole that Justifies Omitting Fire Sprinklers?

[Enri Code]

Given these parameters:
- 200 ft. x 200 ft. (40,000sf area)
- Type 2B construction (pre-engineered metal building)
- F-1 occupancy building
- 30 feet tall (single story)

We understand that Table 506.2 limits the area of a non-sprinklered F-1 building to just 15,500 sf. so it needs to be sprinklered at 40,000 sf.

However, someone pointed out that if we were to use parts of IBC Section 903.2.11, specifically IBC Section 903.2.11.1.2, we can instead replace fire sprinklers with just adding openings within every 50 feet of the exterior wall on at least 2 of the exterior walls.

This effectively omits the need for fire sprinklers.

I read through IBC Section 903.2.11.1.2 and understood it as mainly to specify conditions in which Stories without Openings need sprinklers.

It was however explained to me that since the gist of the section actually says that you need to provide fire sprinklers if you do not have openings within every 50 feet of the exterior wall... then the reverse of then having those openings means you do not need to provide fire sprinklers!

I'm uneasy that it takes a bit of "gymnastics" and reversals to get to the point on how sprinklers can be eliminated.

Has anyone else encountered this? Is this logic or approach valid?

I have done quite a bit of research to this point and there is a big black hole on information about using this logic to eliminate fire sprinklers which is a big red flag for me.

I would sure appreciate the help and thoughts in processing this. Thank you.

 

[cda]

Given these parameters:
- 200 ft. x 200 ft. (40,000sf area)
- Type 2B construction (pre-engineered metal building)
- F-1 occupancy building
- 30 feet tall (single story)

We understand that Table 506.2 limits the area of a non-sprinklered F-1 building to just 15,500 sf. so it needs to be sprinklered at 40,000 sf.

However, someone pointed out that if we were to use parts of IBC Section 903.2.11, specifically IBC Section 903.2.11.1.2, we can instead replace fire sprinklers with just adding openings within every 50 feet of the exterior wall on at least 2 of the exterior walls.

This effectively omits the need for fire sprinklers.

I read through IBC Section 903.2.11.1.2 and understood it as mainly to specify conditions in which Stories without Openings need sprinklers.

It was however explained to me that since the gist of the section actually says that you need to provide fire sprinklers if you do not have openings within every 50 feet of the exterior wall... then the reverse of then having those openings means you do not need to provide fire sprinklers!

I'm uneasy that it takes a bit of "gymnastics" and reversals to get to the point on how sprinklers can be eliminated.

Has anyone else encountered this? Is this logic or approach valid?

I have done quite a bit of research to this point and there is a big black hole on information about using this logic to eliminate fire sprinklers which is a big red flag for me.

I would sure appreciate the help and thoughts in processing this. Thank you.

Always, or normally, the stricter of the code sections applies,

So if you have a building, because of sq ft, requires fire sprinklers, there is not an out,,,,, Normally.



Does that answer your question????????

 

[Enri Code]

Always, or normally, the stricter of the code sections applies,

So if you have a building, because of sq ft, requires fire sprinklers, there is not an out,,,,, Normally.



Does that answer your question????????

It answers my question in some ways because I'm with you on that. I've actually made the same argument that since Table 506.2 says that area of the building pushes for it to have sprinklers, then it should have them.

The judo move thrown my way is that: well the openings - which are at least 20 sf in area each - at within every 50 feet is a substitution for the fire sprinklers. The fire mitigation is not gone and only replaced by something else which is passive. So it supposedly complies.

 

[Enri Code]

This commentary from the Part 1 of the 2018 Code and Commentary document from the ICC (on page 9-19) was cited as well:

"If openings are provided on only one side, an automatic sprinkler system would still be required if the opposite wall of the story is more than 75 feet from existing openings. An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building. As long as the story being considered is not a basement, the openings on two sides can be greater than 75 feet from any portion of the floor. In basements, if any portion is more than 75 feet from the openings, the entire basement must be equipped with an automatic sprinkler system as indicated in Section 903.2.11.1.3. Providing openings on more than one wall allows cross ventilation to vent the products of combustion."

 

[Enri Code]

This image is also taken from the 2018 IBC Code and Commentary book which supposedly supports the idea of having openings instead of an automatic sprinkler system.

This just blows my mind. If this is true, this is a major loophole!​

 

[cda]

I understand openings

That is one instance where fire sprinklers are required,,,, Even if the building is under the Sq ft that requires them...


If you have a building over the sq ft requiring sprinklers,,

There is no Out!!!

 

[e hilton]

A pre-engineered steel building implies a warehouse or industrial building, with overhead doors. Maybe not. Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.

Providing openings on more than one wall allows cross ventilation to vent the products of combustion."

Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.

 

[cda]

A pre-engineered steel building implies a warehouse or industrial building, with overhead doors. Maybe not. Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.

Providing openings on more than one wall allows cross ventilation to vent the products of combustion."

Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.

One of those code technicalities

The require openings,,,,

Do Not have to be openable .

 

[Enri Code]

A pre-engineered steel building implies a warehouse or industrial building, with overhead doors. Maybe not. Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.

Providing openings on more than one wall allows cross ventilation to vent the products of combustion."

Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.

Egress is a separate thing. Number of egress doors will still be provided per code based on exit distances.

For simplicity's sake, consider all of these openings as swing doors for now.

So the concept is that providing all these swing man doors within 50 linear feet along the exterior walls can take the place of an automatic sprinkler systems!

It's true that some of them may be steel roll up doors but that is still supposedly acceptable. The thought here is that egress doors is separate and some of them will probably be egress doors.

What I understand from this is that most of the other doors are basically fireman's access doors or for firemen to be able to open and vent the building.

It's the venting that helps knock the fire down some or at least make it safe before the firemen have to go in.

So if it did come to it, even an overhead door may comply as long as it is at least 20 square feet in area and have a minimum width of 30 inches. The reason being is that it can be opened for venting.

 

[Enri Code]

One of those code technicalities

The require openings,,,,

Do Not have to be openable .

Sound odd but seems like if the criteria is to be able to vent the building from a fire fighting perspective, it may mean that they can be busted open with an axe, halligan bar or chainsaw. If they are lockable, a fireman accessible lockbox with the keys may also be provided.

 

[Enri Code]

I understand openings

That is one instance where fire sprinklers are required,,,, Even if the building is under the Sq ft that requires them...


If you have a building over the sq ft requiring sprinklers,,

There is no Out!!!

I wish it was that simple but the words from the ICC commentary are exactly: "An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building".

So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!

I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.

 

[cda]

I wish it was that simple but the words from the ICC commentary are exactly: "An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building".

So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!

I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.

Does not change any answer, but how are you connected with this, as in what do you do for a paycheck?

 

[cda]

I wish it was that simple but the words from the ICC commentary are exactly: "An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building".

So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!

I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.

102.10 Conflicting Provisions

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

 

[cda]

I wish it was that simple but the words from the ICC commentary are exactly: "An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building".

So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!

I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.

I agree with underlined,,,,

But if the same building is over the sq ft or other as per 903, than thou shall sprinkler

 

[cda]

You also need to read the section it applies to:::::::::::::::::


903.2.11 Specific Buildings Areas and Hazards

In all occupancies other than Group U, an automatic sprinkler system shall be installed for building design or hazards in the locations set forth in Sections 903.2.11.1 through 903.2.11.6.


READ the commentary for

903.2.11 Specific Buildings Areas and Hazards

 

[Enri Code]

102.10 Conflicting Provisions

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

The provisions do not conflict though because it gives an alternate method and not an exception.

 

[Enri Code]

You also need to read the section it applies to:::::::::::::::::


903.2.11 Specific Buildings Areas and Hazards

In all occupancies other than Group U, an automatic sprinkler system shall be installed for building design or hazards in the locations set forth in Sections 903.2.11.1 through 903.2.11.6.


READ the commentary for

903.2.11 Specific Buildings Areas and Hazards

Correct. Then it goes on to say under 903.2.11.1.2 that sprinklers are indeed required for buildings without openings at every 50 linear feet.
The logic is then applied that if we therefore provide those openings at every 50 linear feet... then we do not need to provide sprinklers.
Hence the diagram from the ICC commentary document showing a floor plan with the openings and the note: Automatic Sprinkler System Not Required.

 

[Enri Code]

You also need to read the section it applies to:::::::::::::::::


903.2.11 Specific Buildings Areas and Hazards

In all occupancies other than Group U, an automatic sprinkler system shall be installed for building design or hazards in the locations set forth in Sections 903.2.11.1 through 903.2.11.6.


READ the commentary for

903.2.11 Specific Buildings Areas and Hazards

I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.

The commentary says:

“Section 903.2.11.1 through 903.2.11.2 specify certain conditions under which an automatic sprinkler system is required, even in otherwise nonsprinklered buildings. As indicated, the listed conditions in the noted sections are applicable to all occupancies except Group U. Most structures that qualify as Group U do not typically have the type of conditions stipulated in Sections 903.2.11.1 through 903.2.11.1.3.”

My argument is that the intent of the section is to determine when sprinklers are needed and not when they are not.

However, I was presented with the argument that if no openings mean sprinklers are needed... then having the openings mean sprinklers are not needed.

Logic appears sound.

Having them show me the diagram from the commentary which I shared here was also hard to ignore.

 

[cda]

I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.

The commentary says:

“Section 903.2.11.1 through 903.2.11.2 specify certain conditions under which an automatic sprinkler system is required, even in otherwise nonsprinklered buildings. As indicated, the listed conditions in the noted sections are applicable to all occupancies except Group U. Most structures that qualify as Group U do not typically have the type of conditions stipulated in Sections 903.2.11.1 through 903.2.11.1.3.”

My argument is that the intent of the section is to determine when sprinklers are needed and not when they are not.

However, I was presented with the argument that if no openings mean sprinklers are needed... then having the openings mean sprinklers are not needed.

Logic appears sound.

Having them show me the diagram from the commentary which I shared here was also hard to ignore.

Does not change any answer, but how are you connected with this, as in what do you do for a paycheck?

 

[tmurray]

Typically, unless the code sections reference one another (usually through a notwithstanding clause), you need to comply with both.

Think about it like this:

506.2 No Sprinklers, 903.2.11 No Sprinklers = No Sprinklers Required
506.2 Requires Sprinklers, 903.2.11 Requires Sprinklers = Sprinklers Required
506.2 No Sprinklers, 903.2.11 Requires Sprinklers = Sprinklers Required
506.2 Requires Sprinklers, 903.2.11 No Sprinklers = Sprinklers Required

 

[cda]

Sorry

That is like saying

I am going to build a booze serving night club.

50000 sq ft

And an occupant load of 10000 people

AS LONG as I provide required openings,,,

I don’t have to install a fire sprinkler system

Very Wrong code application

 

[cda]

F-1 requires sprinklers over 12000 sq ft

 

[tmurray]

I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.

The commentary says:

“Section 903.2.11.1 through 903.2.11.2 specify certain conditions under which an automatic sprinkler system is required, even in otherwise nonsprinklered buildings. As indicated, the listed conditions in the noted sections are applicable to all occupancies except Group U. Most structures that qualify as Group U do not typically have the type of conditions stipulated in Sections 903.2.11.1 through 903.2.11.1.3.”

My argument is that the intent of the section is to determine when sprinklers are needed and not when they are not.

However, I was presented with the argument that if no openings mean sprinklers are needed... then having the openings mean sprinklers are not needed.

Logic appears sound.

Having them show me the diagram from the commentary which I shared here was also hard to ignore.

Yeah, no. You are treating this section like it overrules other sections requiring sprinklers, but what you posted just says it requires sprinklers in some buildings that otherwise don't require sprinklers.

 

[Enri Code]

Does not change any answer, but how are you connected with this, as in what do you do for a paycheck?

How am I connected to this?: professional skeptic in pursuit of knowledge
What do I do for a paycheck?: whatever it takes. LOL.​

Well I appreciate all your answers. I love the different points of view and I'm taking notes.

To make it clear, my personal position on this is that it feels a bit of a stretch as it is not very direct and calls for reverse logic to justify. I also don't feel comfortable that most of the underlying justification is not self evident and requires a deep dive into the ICC commentary.

That being said, I took it upon myself to put it into the acid test of people here at the Building Code Forum and see if holds any water.

For purposes of discussions for this forum, I have put aside my personal opinions and am taking the stand to present this alternative to sprinklers and arguments in support for it for everyone's consideration.

I am hoping that I get educated more on this and - depending on overall feedback - either come back to my team in full support of this alternative or be able to shoot it down quick.

Thank you to everyone who are sharing their knowledge.