Does a TI Require Old System to be up to Code?

10/4/2023

Does the IFC or NFPA standard dictate if a old system has to brought up to code if a new permit has been issued for a tenant improvement?

For example adding 5 flex drops to an existing system? Seismic , hanger support are the issue. Thanks in advance.

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14 Comments

Dan Wilder

10/4/2023 07:58:18 am

It depends....

NFPA specifically says 'No' per section 1.4 Retroactivity (with the option for the AHJ to override).

If the building had changes that specifically link back to the IBC/IFC, only the area within the scope of work should be considered. Without knowing the allowances or omissions provided at the time of the original install, the building "should" be considered adequate with respect to existing systems.

As a larger scope (egress, alarm notification, fire rating/separations) would be more a consideration that something smaller like a seismic brace not installed.

Should it be noted and addressed for remediation, for liability, yes (in my mind) where you as a contractor can provide a letter to the GC stating what has been noticed, the reason it doesn't comply, and if the owner wants to pursue fixing it...BUT, taking on an entire system worth of code compliance is a murky path. When we have run into this in the past, our letter simply states what we have noticed within our scope of work area and provides no guarantee that additional areas may or may not comply.

Previous Discussion - https://www.meyerfire.com/daily/code-basis-for-sprinkler-design-grandfathering

https://www.nfpa.org/News-and-Research/Publications-and-media/Blogs-Landing-Page/NFPA-Today/Blog-Posts/2022/05/27/Do-all-buildings-have-to-comply-with-the-latest-code

Glenn Berger

10/4/2023 08:25:03 am

The question can be interpreted to be -- when is a non-complying installation needs to be brought into compliance?

It does not matter the age of the system, a non-compliant system must be made compliant as soon as it is noticed. I have seen many instances when an occupant project (permitted or non-permitted) made changes to walls, ceilings, etc and they ignored sprinklers, lights, egress and other fundamental requirements.

Aaron Easter

10/4/2023 08:25:53 am

Chapter 11 of IFC is where I would start. That would likely lead to a deeper dive into IEBC. Diffrent Fire Protection requirements for diffrent Level Alterations i.e., improvements.

Julie

10/4/2023 12:42:52 pm

I saw your name and just had to ask, are you related to Barbara? :)

AB link

10/4/2023 08:26:24 am

Fire safety code compliance during tenant improvement projects... The burning question (pun intended) is whether an existing fire suppression system needs a makeover to meet current code standards when you're jazzing up your space with tenant improvements. Think new flex drops, seismic shakes, and hanger support drama.

First off, it's worth noting that this isn't a simple yes-or-no scenario. There are a few factors that come into play, and Dan Wilder's insights are spot on.

Let me break it down a bit further:

NFPA's Stance: The NFPA standards are an essential reference in fire safety matters, and they lean towards not requiring existing systems to be retroactively updated to meet the latest codes. However, there's a catch. The Authority Having Jurisdiction (AHJ) is like the sheriff, and they might decide to play the sheriff's card, "Override," in specific situations. So, it's crucial to have a chat with your AHJ to understand their perspective.

Scope of Work: The scope of your tenant improvement project is a major influencer. Typically, when it comes to code compliance, the focus should be on the specific components of the fire suppression system that are directly impacted by your renovations. For instance, if you add five flex drops, the AHJ will likely look closely at the seismic and hanger support for those new additions.

Existing System Adequacy: Now, here's an interesting point. If the existing system was compliant with the codes at the time of its installation and any allowances or omissions were granted, then, the rest of the system is usually considered adequate concerning current standards. This provides some breathing room.

Documenting for Liability: From a contractor's perspective, it's a smart move to document any non-compliance issues you come across and share them with the General Contractor (GC) in writing. This documentation should be crystal clear about what you've observed and why it doesn't comply, and it should indicate that the owner can choose to address it. However, it's essential to proceed with caution when taking on the responsibility for an entire system's code compliance.

Keep the Lines of Communication Open: Last but not least, communication is key. Regularly engage with your AHJ and General Contractors. A transparent dialogue can help address compliance matters proactively, prevent misunderstandings, and streamline the approval process.

And remember, every project is as unique as a unicorn with a kazoo; when you're navigating fire safety code compliance during tenant improvements, you're dealing with a multi-faceted puzzle. While the NFPA offers guidance, local codes and AHJ decisions carry a lot of weight. By considering the scope of your work, the adequacy of existing systems, documenting non-compliance, and fostering open communication, you'll be better equipped to ensure your project doesn’t turn into a fiery fiasco… did ya see that, the pun, yeah. I’m a nerd. Good luck.

James

10/4/2023 08:50:32 am

Sure sounds like my friendly GPT sarcasm a bit in here : )

Anthony

10/4/2023 08:53:31 am

Ha sure does.

AB link

10/4/2023 08:58:48 am

You know it... with as much personal reference I could squander, puzzle-pieced together with fluff to ensure my poor grammatical skills and inability to write proper sentences were disguised while still getting the point across.

But... the puns, all mine.

James

10/4/2023 09:19:37 am

Haha! The puns are the best part!

I lack the creativity (and humor) - so that tends to be what chatgpt pencils in for me... LOL

That's awesome, well done.

AB link

10/4/2023 09:29:28 am

Thanks man, all mine!

Seriously though, this is a great blog post to read on the topic:

https://www.nfpa.org/News-and-Research/Publications-and-media/Blogs-Landing-Page/NFPA-Today/Blog-Posts/2021/09/07/Modifications-To-Existing-Sprinkler-Systems

Anthony

10/4/2023 09:17:29 am

If you're looking at IFC then you'll need to know if the alteration is level 2. if the alteration hits level 2 ie walls and ceilings then you'll need the "work area" brought up to current standards or whole floor depending on building type and total area of work. This is a fairly regular code path that any architect or consulting engineer can help you with.

Permitting is a local requirement and not one directly address by NFPA or ICC both will say something to the effect "pay all required fees and fill out required forms per the AHJ"

Adding sprinklers will most likely change the hydraulic design thus requiring calcs and drawings.

Julie

10/4/2023 09:27:07 am

IFC: 2015 version

901.4 Installation. Fire protection systems shall be maintained
in accordance with the original installation standards
for that system. Required systems shall be extended, altered
or augmented as necessary to maintain and continue protection
where the building is altered, remodeled or added to.
Alterations to fire protection systems shall be done in accordance
with applicable standards.

[A] 102.3 Change of use or occupancy. Changes shall not
be made in the use or occupancy of any structure that would
place the structure in a different division of the same group or
occupancy or in a different group of occupancies, unless such
structure is made to comply with the requirements of this
code and the International Building Code. Subject to the
approval of the fire code official, the use or occupancy of an
existing structure shall be allowed to be changed and the
structure is allowed to be occupied for purposes in other
groups without conforming to all of the requirements of this
code and the International Building Code for those groups,
provided the new or proposed use is less hazardous, based on
life and fire risk, than the existing use.

[A] 102.4 Application of building code. The design and
construction of new structures shall comply with the International
Building Code, and any alterations, additions, changes
in use or changes in structures required by this code, which
are within the scope of the International Building Code, shall
be made in accordance therewith.

DAVE

10/5/2023 11:47:46 am

While the original question asks about "IFC or NFPA standard," individual Authorities Having Jurisdiction have different takes on this. For example at what threshold does the AHJ want all sprinklers upgraded to quick-response in light hazard. It becomes a “know your AHJ” kind of thing. My nearby colleagues are familiar with the local City who use T.I.'s (or at least used to use) as the opportunity to require upgrading all seismic bracing withing that tenant improvement. You only get burned on that once.

Julie

10/5/2023 12:09:11 pm

Dave this is a great point. I have worked for multiple municipalities and we all had trigger points for upgrading the building/system. Usually it was a square footage trigger but sometimes any TI could trigger it. Sometimes there are documented agreements in existing buildings where the AHJ makes them agree “the next time you do any TI, the system is to be fully brought up to code”. So you make an excellent point in the ultimately the deciding factor is the AHJ. It’s best to reach out and get their answer in writing before starting anything.

Does a TI Require Old System to be up to Code?

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