When Are Sprinklers Required in Bathrooms?

I get this question all the time from architects - especially when working around apartment, hotel, senior and assisted living facilities. 

"Are sprinklers required in the bathrooms?"

I don't mind the question at all, because it has a relatively straightforward answer - they're either allowed to be omitted or not. The path to determine whether an exemption applies is actually fairly complex which I'll explore today. 

Note that this article covers requirements but also some helpful explanatory material pulled in from non-enforceable parts of codes and standards (such as the annex material). 

Side Note: Big Launch Coming

This is week 2 of my 3 part series in creating resources for sprinkler designers, engineers, inspector's, and contractors. Stay tuned for the big product launch coming in the next few weeks. Now back to the article -

Why Allow the Omission of Sprinklers in Small Bathrooms?

Typically, since bathrooms require regular cleaning and are subject to variable humidity, surfaces can often be ceramic or non-porous. These easily washable surfaces tend to also be less combustible than other building materials.

In studies of apartment fires where sprinklers were present, for instance, bathrooms were the area of fire origin in only 1% of total fires and resulted in no civilian deaths, civilian injuries or property loss (NFPA 101 Annex Material in A.30.3.5.4 & A.31.3.5.4).

From a risk perspective, small bathrooms present a relatively low risk for fire origin and growth as compared to other areas of a building.

Also, bathrooms in buildings with dwelling units also can comprise a major potential additional cost when they are repeated within each unit. Omitting sprinklers can offer a huge cost savings to these type projects.

For some residential occupancies, there can be significant cost savings to omitting sprinklers in small bathrooms throughout a building. Due to relatively lower risk of ignition, building codes and standards permit omissions for specific applications.
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Building Codes Overrule NFPA 13

Starting with the 1997 edition of NFPA 101, language was introduced into the code to override the requirements in NFPA 13 and NFPA 13R. NFPA 101 only overrides NFPA 13 for specific occupancies, which are outlined below.

The International Building Code also introduced provisions for omitting sprinklers in restrooms, beginning with the 2015 International Building Code. These sections are also reflected in the companion International Fire Codes.

If Small Bathrooms Omit Sprinklers, Is the Building Still Fully Sprinklered?

Yes; where NFPA 13 omits sprinklers the building is still sprinklered in accordance with NFPA 13 and is typically considered fully sprinklered.

Where omissions are allowed by NFPA 101, the building is also still typically considered to be protected throughout (reference NFPA 101-2015 A.11.8.2.1 or NFPA 101-2018 A.11.8.3.1, for instance).

Are Bathtub or Shower Enclosures included in the 55 sqft limitation?

Yes; they are typically considered part of the room as NFPA 13R-2002 introductory material clarifies.

If There’s Just a Toilet, is it Still a Bathroom?

Yes; annex material of NFPA 13 (2002 A.3.3.3, 2007-2018 A.3.3.2) clarifies that a toilet rooms is still considered a bathroom.

Also, two adjacent bathrooms are still considered separate rooms provided that they’re enclosed with the required level of construction.

If There’s No Door, is it a Bathroom?

Weird. This must be some kind of a HGTV renovation for hippy-people if you don’t have a door for some bathroom privacy. Oh and yes, a door is not required in order to omit sprinklers as long as the bathroom complies with the definition of a compartment (NFPA 13 2010-2016 A.8.15.8.1.1).

The Quick-Guide to Determine Permitted Bathroom Sprinkler Omissions:

Have trouble viewing? See the flow chart here.

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