NFPA 101 Chapter 43 Rehabs and Sprinkler Requirements.

[admiralArchArch]

I could use some help interrupting 43.6.4.2 with respect to reconstruction. Paraphrased below:

On any story with rehabilitation work areas involving over 50 percent of the area of the story, a sprinkler system shall be provided throughout the story in accordance with the requirements of other sections of this Code applicable to new construction for the occupancy.

My interpretation is this is not a blanket statement requiring for sprinklers in all occupancies no matter what, but if your occupancy type has a specific requirement for automatic fire sprinklers that this requirement in 43.6.4.2 applies. So for instance if I have a reconstruction project of a existing business occupancy that is over 50% of the total building area, I go to chapter 38 for New Business Occupancies, go to 38.3.5 Extinguishment Requirements, and read that I am only to provide fire extinguishers and not fire sprinklers (which doesn't make any sense compared to IBC requirements). Am I correct? Or am i missing something in the other 200+ NFPA documents that is requiring fire suppression?

 

[rktect 1]

The IBC chapter 903 applies. So, if the building is an A-1 over 12,000 or occupant load greater than 300 or one of the other two conditions AND 50% or more is reconstruction (see definitions especially area of rehabilitation) then they would need to install the fire sprinkler.

That is how I apply it.

 

[Paul Sweet]

Admiral Arch, that sounds reasonable to me. Are you in a jurisdiction that has IBC as the building code and NFPA 101 as the fire code? It would be best to run it past the fire marshal before going too far in case they interpret it differently.

 

[mtlogcabin]

A sprinkler requirement would be in the IEBC not the IBC with regards to which method is chosen for the renovation/reconstruction.

 

[admiralArchArch]

A sprinkler requirement would be in the IEBC not the IBC with regards to which method is chosen for the renovation/reconstruction.

Thank you. They are requiring the whole building to be fire sprinklered, not just the work areas. Is that correct? They are citing 2018 IEBC 904.1.4 and 803.2.2.
Our existing building is S-1 occupancy (motor vehicle repair shop), single story. My understanding is only the work areas would need to be sprinkled unless I'm missing something.

About 2/3 of the total building is being worked on, the other 1/3 is outside the scope but will have some incidental work. This 1/3 area only has a fire barrier on one side that is directly adjacent to one work area, the other work area adjacent to this out of scope area does not have a proper fire barrier.

 

[mtlogcabin]

Is this a repair or an alteration? It makes a huge difference in the application and use of the IEBC.

[A] REPAIR. The reconstruction, replacement or renewal of any part of an existing building for the purpose of its maintenance or to correct damage.

[A] ALTERATION. Any construction or renovation to an existing structure other than a repair or addition.

 

[mtlogcabin]

IEBC CHAPTER 4 REPAIRS

SECTION 403
FIRE PROTECTION

403.1 General.
Repairs shall be done in a manner that maintains the level of fire protection provided.

They cannot make you add a fire suppression system.

 

[mtlogcabin]

SECTION 503
ALTERATIONS

Prescriptive Compliance Method
503.1 General.
Except as provided by Section 302.4, 302.5 or this section, alterations to any building or structure shall comply with the requirements of the International Building Code for new construction. Alterations shall be such that the existing building or structure is not less complying with the provisions of the International Building Code than the existing building or structure was prior to the alteration.

A fire suppression system cannot be required if this is just alteration under Chapter 5.

The square footage of the S-1 fire area is a major factor in answering your question under the work compliance method.

Chapters 6 thru 12 are the Work Area Compliance Method
This method may trigger a fire suppression system if the fire areas exceed the allowable square footage amounts. You can create additional fire areas within the building to avoid sprinklers.
IEBC
904.1.4 Other required automatic sprinkler systems.
In buildings and areas listed in Table 903.2.11.6 of the International Building Code. I do not find automotive repair, or an S-1 required in this Table.

Sprinkler system requirements as set forth in Section 903.2.11.6 of the International Fire Code. You may have a use within this table that may require a sprinkler system.
803.2.2 Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2.
In buildings with occupancies in Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where both of the following conditions occur:

1. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction.

IBC
[F] 903.2.9.1 Repair garages.
An automatic sprinkler system shall be provided throughout all buildings used as repair garages in accordance with Section 406, as shown:

1. Buildings having two or more stories above grade plane, including basements, with a fire area containing a repair garage exceeding 10,000 square feet (929 m2).

2. Buildings not more than one story above grade plane, with a fire area containing a repair garage exceeding 12,000 square feet (1115 m2).

3. Buildings with repair garages servicing vehicles parked in basements.

4. A Group S-1 fire area used for the repair of commercial motor vehicles where the fire area exceeds 5,000 square feet (464 m2).

As a designer you choose the method you want to use not the AHJ.

 

[admiralArchArch]

Admiral Arch, that sounds reasonable to me. Are you in a jurisdiction that has IBC as the building code and NFPA 101 as the fire code? It would be best to run it past the fire marshal before going too far in case they interpret it differently.

Yes unfortunately we adopt both. They are requiring the whole building to be sprinkled, citing NFPA 43.6.4 and IEBC 803 and 904. See my other post.

SECTION 503
ALTERATIONS

Prescriptive Compliance Method
503.1 General.
Except as provided by Section 302.4, 302.5 or this section, alterations to any building or structure shall comply with the requirements of the International Building Code for new construction. Alterations shall be such that the existing building or structure is not less complying with the provisions of the International Building Code than the existing building or structure was prior to the alteration.

A fire suppression system cannot be required if this is just alteration under Chapter 5.

The square footage of the S-1 fire area is a major factor in answering your question under the work compliance method.

Chapters 6 thru 12 are the Work Area Compliance Method
This method may trigger a fire suppression system if the fire areas exceed the allowable square footage amounts. You can create additional fire areas within the building to avoid sprinklers.
IEBC
904.1.4 Other required automatic sprinkler systems.
In buildings and areas listed in Table 903.2.11.6 of the International Building Code. I do not find automotive repair, or an S-1 required in this Table.

Sprinkler system requirements as set forth in Section 903.2.11.6 of the International Fire Code. You may have a use within this table that may require a sprinkler system.
803.2.2 Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2.
In buildings with occupancies in Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where both of the following conditions occur:

1. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction.

IBC
[F] 903.2.9.1 Repair garages.
An automatic sprinkler system shall be provided throughout all buildings used as repair garages in accordance with Section 406, as shown:

1. Buildings having two or more stories above grade plane, including basements, with a fire area containing a repair garage exceeding 10,000 square feet (929 m2).

2. Buildings not more than one story above grade plane, with a fire area containing a repair garage exceeding 12,000 square feet (1115 m2).

3. Buildings with repair garages servicing vehicles parked in basements.

4. A Group S-1 fire area used for the repair of commercial motor vehicles where the fire area exceeds 5,000 square feet (464 m2).

As a designer you choose the method you want to use not the AHJ.

Very detailed response thank you. We are alteration level III since our work area exceeds 50% of the building area. I think the ones that are going to trigger are.

• The building exceeds the allowable area for NS in the IBC by a small amount with full frontage increases.
• 903.2.9.1 (2). The two fire areas exceed 12,000 SF.
• 903.2.9.1 (3). This probably applies as well.

NFPA 43.6.4 seems to be pretty clear on this, requiring us to sprinkle all work areas including areas out of scope and this is what the code official is referencing.

43.6.4.1 In a building with rehabilitation work areas involving over 50 percent of the aggregate building area, automatic sprinkler systems shall be provided on the highest floor containing a rehabilitation work area and on all floors below in accordance with the requirements of other sections of this Code applicable to new construction for the occupancy.

43.6.4.2 On any story with rehabilitation work areas involving over 50 percent of the area of the story, a sprinkler system shall be provided throughout the story in accordance with the requirements of other sections of this code applicable to new construction for the occupancy.

 

[mtlogcabin]

After looking at NFPA 101 I believe it is a POS.
No where did I find an occupancy group other than "B" for your use.

So for instance if I have a reconstruction project of a existing business occupancy that is over 50% of the total building area, I go to chapter 38 for New Business Occupancies, go to 38.3.5 Extinguishment Requirements, and read that I am only to provide fire extinguishers and not fire sprinklers

So, I believe you are 100% correct in your application of NFPA 101.
The existing business category states the same.

39.3.5 Extinguishment Requirements​

Portable fire extinguishers shall be provided in every business occupancy in accordance with Section 9.9.

4.4.2 Prescriptive-Based Option​

4.4.2.1​

A prescriptive-based life safety design shall be in accordance with Chapters 1 through 4, Chapters 6 through 11, Chapter 43, and the applicable occupancy chapter, Chapters 12 through 42.

​

1.1.9 Areas Not Addressed​

The Code does not address the following:

1. *General fire prevention or building construction features that are normally a function of fire prevention codes and building codes

​

 

[admiralArchArch]

After looking at NFPA 101 I believe it is a POS.
No where did I find an occupancy group other than "B" for your use.

So, I believe you are 100% correct in your application of NFPA 101.
The existing business category states the same.

Yes, it is a POS! I absolutely loath NFPA 101. So what we are reading here is 43.6.4.1 and .2 both say to sprinkler per other sections of this code, but the other sections of this code for new business and new industrial (for the repair shop) only require portable fire sprinklers. 1.1.9 is implying that other codes (not 101) address fire prevention even though chapter 14 for New Educational Occupancies lists when fire sprinklers are required.

NFPA Chapter 9.7 has nothing stating when fire sprinklers are required, and I can't find anything in either NFPA 1 or NFPA 13 prescribing fires sprinklers unless I'm missing something.

 

[mtlogcabin]

I believe you have it correct.