Code Basis for Sprinkler Design "Grandfathering"?

6/23/2020

Design criteria for storage occupancies have changed substantially over the years from pipe schedules to the NFPA 231's to NFPA 13, 2016. Everyone talks about "grandfathering" old system designs, but no one can ever point out any specific codes, standards, or formal documents that give any solid guidance on this matter.

In our state, this situation varies by jurisdiction, but the opinions are all over the place and usually wind up at the classic "ask the AHJ". This is very time consuming and often times not very helpful since most of them enforce the newest NFPA editions when unless you can provide as-built documentation which we can't do 95% of the time for old buildings. We all know that it depends on the situation, but there has to be some level of formalized consistency out there to start with.

As a NICET certified Fire sprinkler designer, I have my own professional opinions on the matter based on my understanding of the intent of grandfathering and my own project experiences.

That said, can anyone point me to specific codes, standards, or formal documents that I can utilize to create a formalized opinion that can be submitted to local AHJ's for a more "standardized" understanding?

I'm pretty well versed in NFPA 13 so I'm really looking for IBC, NFPA 101, NFPA 1 references, but all feedback is appreciated.

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Dan Wilder

6/23/2020 08:30:26 am

Section 102 of Applicability goes to when the currently adopted building code can be enforced. Specifically 102.6 of the IBC (2018 ed), and 102.1 of the IFC (2015) that I have sitting in front of me.

Greg

6/23/2020 10:08:21 am

Also, even if they are doing work on the building, the existing building code (IEBC) has provisions about when they need to bring the system up to code or maintain the existing level of protection.

Jesse

6/23/2020 10:13:30 am

I've been asked this a lot. I've worn a lot of hats. Fire Dept, insurance high protected risk engineer, and now design manager.

Codes are derived from loss experience. AHJs are typically governmental agencies and they're painstakingly slow. Its takes a tremendous amount of time and work to get a council, board, or governing body to enact policy. Often, when they do, that iteration of code has been supplanted. But, that's why they are "model" codes.

One issue I'm always cautious about, is that even though an AHJ may have adopted a certain version of 13 - say 2010 - do we design to that code knowing that there are three subsequent more restrictive iterations out there? If we design AS for storage to 2010 NFPA 13 but know that 2016 NFPA 13 would have changed how we identified commodity class and in turn, how we designed protection - are we really serving our customer?

The customer's insurance carrier will always use the most recent edition of 13. As such, when 2016 NFPA 13 as released, a lot of warehouses protected by control mode AS were suddenly hydraulically inadequate.

The fact is, fire and loss doesn't care if its "grandfathered".

I have a current project in an AHJ under 2010 NFPA 13. I met with the AHJ and got approval to design it to 2016 NFPA 13 to better protect the client.

Austin Sealey

6/24/2020 10:21:46 am

I agree with 100%. I am my city’s fire marshal, and I have submitted a proposal of adoption for the 18 IFC. I’m going on six months now with no word on it. As far as the statements on other edition codes, we are on the 15 I-codes making us utilize the 13/14 editions of NFPA. When I am presented with the request of designing/installing to a newer edition, I am 100% for it so long as it is equal to or greater than the edition I enforce.

MAX

6/23/2020 10:19:48 am

"As a NICET certified Fire sprinkler designer" - id prefer "layout tech instead of designer. Because liability and all.

john p malescio

6/23/2020 10:19:57 am

I just came across this issue for a recent warehouse project in CT. The approach we typically use utilizes the Existing Buildings Code, according to the adopted code for the location. In my example, I used the IEBC to determine the alteration level (Eg. Level 1, 2 or 3). Once the alteration level is determined, depending on the occupancy of the space, the code determines the level of modification of the fire protection systems as applicable to new construction. More often than not, anything at ALT Level 2 requires the fire protection systems to be brought up to current adopted codes. Check out chapter 8 of the IEBC.

Justin Milne

6/23/2020 10:23:44 am

NFPA 25 Section 4.1
NFPA 101 Chapter 43, 4.6.5
IBC 102.6
IFC Chapter 11
IEBC 101.4.7

Todd E Wyatt

6/23/2020 10:28:02 am

I agree with Greg ... the "scoping" Code which is typically the IEBC will determine if the project is defined as a repair, an alteration (Level 1, 2, and/or 3), a change of occupancy, and/or an addition. Each of these "categories" have distinct compliance requirements for "fire protection" which in turn will point to a reference standard such as NFPA 13 and explain which aspects of the existing and new fire protection systems have to meet past or currently adopted standards.

William Cosey

6/26/2020 09:17:07 pm

"Grandfathering" is just a choice of word in application. "Code of Record (COR)" is the same.
There are no specific definitions of "Code of Record" (which I recently discovered and am working to remedy with both NFPA and ICC - the current Model consensus Codes, by majority).

There is one and only NFPA standard that calls out specifically the term coined - Code of Record (NFPA 805).

There are government entities which are in the process of publishing a Best Practice using the terms, but these would only be something to discuss with your AHJ, not as governing documentation.

Just because the ITM code & standards change, or the system design or installation requirements change doesn't necessarily require the system to change - unless the local jurisdiction or the requirements are stated as retroactive. The existing codes and standards in place at the time of the design approval are the governing requirements - for life of the system.

The facts remain:
1. a system has a date of design for which it was built.
2. that date of approved design is the "Code of Record", the "grandfather date", and the Code & Standard record date established for the requirements of installation invoked by one of the model Codes adopted by the jurisdiction / AHJ for system installation or otherwise as directed to be installed by AHJ request (without Code requirement)
3. this date is also used to establish the accompanied ITM requirements for inspection, test, and maintenance including corrections and repairs.
4. When there are changes (next paragraph) that may affect the designed system's ability to protect/function/or otherwise require another design, based on these change(s) and current Code & Standards, the system is required update due to the building/protection requirement/condition changes made or as the AHJ requires. The system corrections (not the entire system, unless AHJ required) must be made under the newer applicable design/design change to the newer applicable Code & Standards. This can result in the case where there may be multiple COR's for an existing system, based on system history (additions, design changes, etc., to a legacy system), and AHJ requirements. The AHJ can require the entire system be brought current and the system modified to the current or Code & Standards requested.

Examples of changes in the hazard(s) (some of these are prescriptively called out in consensus Codes & Standards): what's in the location, how much, material hazard class/categories, etc.; protection (renovations, surround walls or partition, adding levels, etc.); and/or occupancy/use.

No matter what, it is still an AHJ call, with the approval of the design, installation, acceptance testing, and ITM, repairs and corrections of the system. If working for the AHJ, the evaluation is theirs to consider in the approval.

This is like the application of other engineered systems.

Say for example, the car (bear with me here and take in the concept, not necessarily the way each and every car or state works - or doesn't).
The early cars had emission challenges greater than those of today. We can still drive them (if you are fortunate enough to have one), but they are not designed to meet the requirements of today. You maintain it according to the way it was built. Even having to condition the fuel used, possibly to meet the old requirements. Now comes the AHJ, even though the building owner (car owner wants to stay "as is" with the emission conditions - the DMV inspects the car and requires it to meet emission standards thus the car must have a system (COR) change to update it as required by the AHJ. If a major system breaks, there is a decision to be made to keep that system in the old way or bring it up current code & standards (update it).

To round off this point:
There is no such thing or "Grandfathering" or "Code of Record (COR)", except one lone standard NFPA 805.
Several references, like the Model building code of the ICC - IBC, are close in description, but not specific (using terms you are familiar with such as not retroactive, existing code or building code, etc.).

I hope when changes come to both NFPA and ICC applicable codes and standards arrive - you will comment during the Public Comment stages,

I also hope this made sense and helps, Including to edify that you're not the only one that has labored to find these terms and words. Let's do something about it.

Best regards,

Code Basis for Sprinkler Design "Grandfathering"?

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