Attic System Removed if NFPA 13R Now Allowed?

1/9/2024

Can an assisted living facility that installed a an NFPA 13 compliant system which was only required to be a 13R now remove the dry attic part of the system?

They have had corrosion issues and leaks they are wanting to avoid. The only reason they installed the 13 system is initially they envisioned possible adding a skilled care section which is now not happening.

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13 Comments

Dan Wilder

1/9/2024 07:11:14 am

You'll run into several issues and questions:

Did the building occupancy change or is it being reclassified? Was it an R-4 with a provision for Condition 1 or 2 or was it classified with I-1 prior?

Were there building allowances taken for being "fully sprinklered"? These would become void by removing the attic space protection, items like allowable floor areas, separation requirements, allowable # of floors, construction type and protection, possibly mechanical/smoke system changes.

For an AHJ to accept the reduction there would be much more than just saying the proposed expansion isn't happening and the installed fire protection is being removed.

On another note, are the corrosion issues due to a bad install, bad maintenance, or a mix of both? Addressing those with preventative measures (dry air or N2 supply) along with a consistent maintenance schedule may be an option.

Anthony

1/9/2024 07:48:48 am

Yes you can remove the system if the attic protection was above and beyond code requirement. Make sure you have all your ducks in a row as Dan mentioned, this may not be as cut and dry(puns intended) as you think.

Chad

1/9/2024 11:17:42 am

Not if NFPA 1 applies. Non-required systems stay unless permitted by the AHJ.

Glenn Berger

1/9/2024 08:15:33 am

Proceed with caution on this subject. Need to do a full code analysis on the exact conditions of this specific facility. I have been to several assisted living facilities and they are more than your basic apartment style buildings.

James

1/9/2024 08:27:10 am

I agree with emphasis on needing the "full code analysis" part.

Have someone well-versed in the building code and ALL of the code tradeoffs for an NFPA 13 system look at all the different aspects of the building, build a code path, and put in writing that removing the system is allowed by code. I wouldn't want that liability as a contractor (or really as an engineer either). Imagine the immediate lawsuits (right or wrong) if a fire happened in the attic where a sprinkler system was removed.

Nelson

1/9/2024 08:59:09 am

I agree that a "full code analysis" will be needed.

According to the International Fire Code (2021) Section 901.6, Nonrequired systems shall be either maintained or removed. So, you must PROVE that it is nonrequired.

My first question would be..."Why would a NFPA 13 system be installed here in the first place?" My first guess would be that they exceeded their allowable area for their construction type; thereby gaining a 300% increase in area by adding the NFPA 13 system (IBC Chapter 5).

My next question would be to understand the occupancy type and determine what type of system is required by IFC/IBC Section 903, & 903.3.1.1/903.3.1.2.

Remember, a NFPA 13 system protects life and property while a NFPA 13R system protects property only.

Nelson

1/9/2024 09:05:15 am

Correction........13R is for life safety only. Sorry for the typo.

Todd E Wyatt

1/9/2024 08:54:48 am

Q : Can an assisted living facility that installed a an NFPA 13 compliant system which was only required to be a 13R now remove the dry attic part of the system?
A : It depends on the nature of the attic per the scoping Code (e.g. IBC-2021 903.3.1.2.3 Attics) and the nature of the “residents” (e.g. Condition 1 or 2).

EXPLANATION
An assisted living facility (ALF) is classified as a Group R-4 Residential occupancy. ALL Group R occupancies are required to be protected by an automatic sprinkler system (ASPS) per IBC-2021 903.2.8.

Depending on the “care” provided and the nature of the “residents” … custodial care & capable of responding in an emergency (Condition 1) versus custodial care & requiring assistance in an emergency (Condition 2) … a Group R-4 Condition 1 requires an ASPS which is permitted to meet NFPA 13D (IBC-2021 Section 903.3.1.3) for R-4 Condition 1 or a Group R-4 Condition 2 requires an ASPS which is permitted to meet NFPA 13R (IBC-2021 Section 903.3.1.2). Regardless of these “permissions”, a NFPA 13 ASPS was installed including protection of the attic.

The scoping Code (e.g. IBC-2021) determines WHERE an ASPS is required (e.g. based on Occupancy Classification = Group R-4, Condition 1 or 2) and WHERE an ASPS can be omitted.

“IBC-2021 903.3.1.2.3 Attics” identifies (3) parameters WHERE attic protection by an ASPS is required. If this existing building does not meet 1-3, attic protection by an ASPS is NOT required. If the building is classified as Group R-4, Condition 2 occupancy, 903.3.1.2.3 (4) permits the omission of ASPS attic protection “not required by Item 1 to have sprinklers shall comply with one of the following” … see a, b, c, or d in REFERENCES below. If the building is classified as Group R-4, Condition 1 occupancy, only 1-3 of 903.3.1.2.3 is required to be followed.

Modification of an existing ASPS will require submission of Drawings to the local AHJ. Additionally, since this facility may be licensed by a state agency, this ASPS modification may/should be forwarded to them for their review and approval.

REFERENCES
IBC-2021
Chapter 9 Fire Protection and Life Safety Systems
Section 903 Automatic Sprinkler Systems
903.2 Where Required
Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.
903.2.8 Group R
An automatic sprinkler system installed in accordance with Section 903.3 shall be provided throughout ALL buildings with a Group R fire area.
903.2.8.2 Group R-4, Condition 1
An automatic sprinkler system installed in accordance with Section 903.3.1.3 shall be permitted in Group R-4, Condition 1 occupancies.
903.2.8.3 Group R-4, Condition 2
An automatic sprinkler system installed in accordance with Section 903.3.1.2 shall be permitted in Group R-4, Condition 2 occupancies.

903.3 Installation Requirements
Automatic sprinkler systems shall be designed and installed in accordance with Sections 903.3.1 through 903.3.8.
903.3.1.1 NFPA 13 Sprinkler Systems
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. Four stories or fewer above grade plane.
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. The floor level of the lowest story is 30 feet (9144 mm) or less below the lowest level of fire department vehicle access.
4. The number of stories of Group R occupancies constructed in accordance with Sections 510.2 and 510.4 shall be measured from grade plane.
903.3.1.3 NFPA 13D Sprinkler Systems
Automatic sprinkler systems installed in one- and two-family dwellings; Group R-3; Group R-4, Condition 1; and townhouses shall be permitted to be installed throughout in accordance with NFPA 13D.

903.3.1.2.3 Attics
Attic protection shall be provided as follows:
1. Attics that are used or intended for living purposes or storage shall be protected by an automatic sprinkler system.
2. Where fuel-fired equipment is installed in an unsprinklered attic, not fewer than one quick-response intermediate temperature sprinkler shall be installed above the equipment.
3. Where located in a building of Type III, Type IV or Type V construction designed in accordance with Section 510.2 or 510.4, attics not required by Item 1 to have sprinklers shall comply with one of the following if the roof assembly is located more than 55 feet (16 764 mm) above the lowest level of fire department vehicle access needed to meet the provisions in Section 503.
a. Provide automatic sprinkler system protection.
b. Construct the attic using noncombustible materials.
c. Construct the attic using fire-retardant-treated wood complying with Section 2303.2.
d. Fill the attic with noncombustible i

Todd E Wyatt

1/9/2024 08:55:40 am

REFERENCES continued ...

4. Group R-4, Condition 2 occupancy attics not required by Item 1 to have sprinklers shall comply with one of the following:
a. Provide automatic sprinkler system protection.
b. Provide a heat detection system throughout the attic that is arranged to activate the building fire alarm system.
c. Construct the attic using noncombustible materials.
d. Construct the attic using fire-retardant-treated wood complying with Section 2303.2.
e. Fill the attic with noncombustible insulation.

Chapter 3 Occupancy Classification and Use
Section 310 Residential Group R
310.5 Residential Group R-4
Residential Group R-4 occupancy shall include buildings, structures or portions thereof for more than five but not more than 16 persons, excluding staff, who reside on a 24-hour basis in a supervised residential environment and receive custodial care. Buildings of Group R-4 shall be classified as one of the occupancy conditions specified in Section 310.5.1 or 310.5.2. This group shall include, but not be limited to, the following:
Assisted living facilities

310.5.1 Condition 1
This occupancy condition shall include buildings in which all persons receiving custodial care, without any assistance, are capable of responding to an emergency situation to complete building evacuation.
310.5.2 Condition 2
This occupancy condition shall include buildings in which there are any persons receiving custodial care who require limited verbal or physical assistance while responding to an emergency situation to complete building evacuation.

Pete H

1/9/2024 09:48:04 am

Agreeing with everyone else, it theoretically can, but if the architect used anything that required the building to be NFPA 13 or fully sprinklered for ICC code compliance, you've now opened that can of worms by changing the system.

On the bright side, if you're repairing a system with corrosion issues that is now 13R, decent odds you can get CPVC pipe to work which Lubrizol keeps assuring me is better at resisting/mitigating corrosion.

Jesse

1/9/2024 10:21:27 am

I would recommend doing a full analysis of applicable code. There's a reason the original install was full 13 and not 13R.

Todd E Wyatt

1/10/2024 08:43:23 am

"The only reason they installed the 13 system is initially they envisioned possible adding a skilled care section which is now not happening."

"Skilled care" would result in the building being classified as a Group I-2 IF the patients (versus residents) are incapable of self-preservation without assistance. Group I-2 buildings are required to be protected by NFPA 13 sprinkler systems.

Sean

1/10/2024 07:26:56 pm

Removal of systems is difficult, time consuming, and does not always work out.

Don't make this the building / fire department issue. Prove your thesis then present it.

Attic System Removed if NFPA 13R Now Allowed?

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