Compliance w/ New 2025 Group A Requirements?

12/11/2025

I have a class IV product stored in a HDPE hard body package. With the changes from NFPA 13 2016, edition to the 2025 edition, there are significant changes to the ability to store Group A plastics in legacy warehouses.

What compliance strategies are available to the FP community to remain in compliance while storing in these legacy buildings?

A typical warehouse I'll see will have K16.8 @52 psi. This used to be acceptable for group A, but now it is not an option per the newer standard. Typically we're looking at structures over 35 ft.

Thanks in advance.

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11 Comments

Pete H

12/11/2025 06:36:22 am

Expanded or Nonexpanded Group A?

What type of racks are we looking at, if any?

Me, for nonexpanded: I'd probably be sticking along the ESFR sprinklers and go with the 22.4 heads for newer installations, 12 hds @ 75 min. operating pressure as long as I can maintain the clearances for new construction.

Chad

12/11/2025 08:03:05 am

There are no good compliance options for "legacy" buildings once the storage use changes from the original design. Often its a pump, and occasionally a tank. Not to mention bigger pipe throughout. Especially with taller structures.

Although its expensive and complicated, its necessary. As you are likely aware, storage is the largest dollar loss for insurance, typically.

Only the largest and/or most progressive AHJ's are on top of this. Routinely, I find high pile storage inadequately protected in existing high bay warehouses. The tenant complains their insurer (never FM though) was just there and saw no issue. Its unsettling that their risk managers have no idea what they are looking at.

Blaine

12/11/2025 08:10:09 am

Has anyone seen any testing for the hard shell boxes like pelican, Hardigg, or the like. Given their shape and characteristics, I’ve wondered if they behave differently than other plastics. I see a lot of military equipment stored in these transport containers, often incorrectly.

Glenn Berger

12/11/2025 08:15:46 am

There are no one size fits all solutions when needing to bring existing sprinkler system up to compliance with current standards.

Brett

12/11/2025 08:16:49 am

NFPA 13 isn't retroactive so if you aren't changing your operations or commodities stored then most jurisdictions won't make you re-evaluate your storage just because there's a new edition of NFPA 13 out.

For existing installations that are changing out the commodity stored or a new tenant is moving in then two options come to mind:

1) Rip everything out and replace. Depending on the commodity the pressure requirements go way up. It seems like you're dealing with exposed nonexpanded group A which is a very demanding commodity. Even the existing underground piping can be a limitation.

2) Use the in-rack design schemes that are independent of ceiling level sprinklers. There are two schemes that allow 30 ft vertical spacing of in-racks to protect exposed expanded group A plastics.

Brett

12/11/2025 08:17:37 am

Meant to say two schemes that allow 30 ft vertical spacing of in-racks *with no horizontal barriers*.

12/11/2025 08:19:16 am

Great question. Huge Issue.

There is no clear guidance on this at this time, but the change comes from this FM Global technical report:

https://www.fm.com/-/media/project/publicwebsites/fm/files/resources/research-technical-reports/nfpa-13.pdf

Existing buildings with no change of use/occupancy/process/materials have “a reasonable degree of safety is provided” per NFPA 13 chapter 1 since they were installed to the standard of the time, but there is no guidance on what to do when there is a change of use/occupancy/process/material. You can 1) provide the AHJ all of the past approved as-built documents to "grandfather" the design (if you have all of the approvals on record as required by NFPA 25) or 2) to bring the existing system up to the newest adopted standard (ceiling protection upgrade, false ceiling, in-racks, new fire pump, etc)

We need more fire testing (same commodities at lower storage heights), an allowance for existing systems (similar to the CMDA chapters), or clear guidance that the old designs do not provide “a reasonable degree of safety is provided” per NFPA 13 chapter 1 and need to be upgraded to provide consistent guidance to the industry.

Jesse

12/11/2025 08:26:44 am

There aren't a lot of great options.

Like one comment said, NFPA 13 isnt retroactive, so its doubtful the AHJ will require a chnage.

The insurance carrier is another thing altogether. There was a huge change on commodity class assessment from the 2013 to the 2016 revisions. Insurers always use the most recent edition and suddenly a lot of warehouses that were deemed adequate under earlier version were now written with huge probabler maximum loss scenarios.

A lot of insurers were wanting these system hydraulically reinforced to the newer standard and I think that will be the case here.

Robert Morgan

12/11/2025 09:17:02 am

A am the Fire Marshal of a small suburb of a metropolitan area and we have numerous mega warehouses (20+) that are always changing tenants and storage commodities and configurations. Unfortunately, we/I do not have the level of expertise (or often even know when things change in these buildings), to evaluate and determine if the sprinkler protection is adequate. The new changes requiring larger K-factors to adequately protect the materials in legacy buildings are an issue that is not easy to solve. If you could formerly store the same items/configuration in that building, how do we navigate this and tell them they no longer can without an expensive system upgrade.

Chad

12/11/2025 10:10:44 am

As others stated, NFPA 13 is not retroactive. If it was properly designed for a particular commodity and arrange, you can continue to use it for that same commodity and arrangement.

Depending on what state you are in, if you have NFPA 1, you can require a permit for high pile storage. You don't need a fee associated it with it. You can just require a permit, unless there are intervening laws or amendments. And as part of that permit you issue, they cannot change commodity or storage arrangement without a new inspection/permit. Although that does not stop them from just changing it, at least you have paper on it and that makes inspections easier for people to understand.

2021 NFPA 1-

1.12.1

The AHJ shall be authorized to establish and issue permits, certificates, and approvals pertaining to conditions, operations, or materials hazardous to life or property pursuant to Section 1.12.

Permits shall be required in accordance with Table 1.12.8(a) through Table 1.12.8(d).

from the table-

High-piled combustible storage... To use any building or portion thereof as a high-piled storage area exceeding 500 ft2

I imagine the IFC has something similar?

Jack G

12/11/2025 10:28:57 am

All municipalities have this catch phase similar to NFPA 1. Easy when going from high piled storage down to ordinary or light hazards but difficult in the other direction.
The catch phrase is “ when changing occupancies, the system shall be brought up to the current code”!
So a tear out and install new with pumps and or tank may not be a stretch if the current system is found deficient.

Compliance w/ New 2025 Group A Requirements?

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