Is the Term "Stored" Defined in NFPA 13?

11/17/2021

NFPA 13 (2022) states; "Sprinklers shall be installed under all exterior projections greater than 4 feet where combustibles are stored."

I have a retail building and the occupant desires to sell (combustible) merchandise outside their store, under the canopy.

The projection greater than 4 feet.

My question is related to the term "stored." Is this defined anywhere?

The combustible materials are under the canopy during business hours, but brought inside the store when the store is closed. Is the display of products under the canopy considering "storing" them?

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14 Comments

Pete H

11/17/2021 06:49:17 am

Best I can offer you is NFPA 101 (2018 ed.) 6.1.13.1 restates a part of chapter 3 in NFPA 101 that defines a storage occupancy as "An occupancy used primarily for storage or sheltering of goods, merchandise, products, or vehicles."

Dan Wilder

11/17/2021 06:52:19 am

This is one of those "choose your battles" moments, unless you're just playing middle man between an owner and the Fire Marshall.

The beginning of the Definitions section says that anything not specifically defined within that chapter shall use the "ordinarily accepted meanings within the context they are used" as shown within Merriam-Webster's Collegiate Dictionary (insert edition).

https://www.merriam-webster.com/dictionary/stored

In this case, there isn't a direct definition for the word, just many examples. IMO the intent is the same stuff that is being "stored" inside (requiring sprinklers) and the act of moving it to another location then requires the same protection, in this case an exterior overhang that exceeds 4'.

Make the projection 3'-11", make a separate detached canopy (that wouldn't trigger a protection requirement), or change the canopy to be considered open. You may also be able to have the discussion that the goods beneath are "transient" in nature and should not trigger the need for sprinklers (as discussed in the appendix 13-19 - A9.3.19.2)

I had a Fire Marshall tell me once (jokingly) that since they didn't amend their Fire Code to allow fires only during certain times or locations, that we would need to approach protection as all the time and all the places as required....this was more to a location that had a water supply degradation issue every 3 days for 8 hours at a time due to a water bottling facility down the street but the discussion made sense as to how they approached the NFPA grey areas.

Alex

11/17/2021 07:11:46 am

I think Dan has this spelled out perfectly. No, there is not a specific definition within NFPA that you can resort too. I would have to agree, shrink the canopy to be less than 4' or add protection.

The benefit for only having the storage out during business hours is the fact that someone is there, but that doesn't stop the fire from possibly occurring.

Jesse

11/17/2021 08:12:59 am

"Stored" isn't defined in 13 per se. However, we more or less universally consider combustible material present under a canopy or overhang 4-ft or greater to require protection. In this case, its a retail occupancy with a pretty constant fire load under the canopy.

Anthony

11/17/2021 08:16:49 am

GREAT write up here about that here: https://www.meyerfire.com/blog/are-fire-sprinklers-required-for-a-canopy

As that blog post says its a use best judgement situation. Hard definitions are difficult to come by in exposure protection not outlined my NFPA 15.

If you're talking a big box store where a few otherwise light hazard displays are I would say its not critical. It you're talking a car port or loading dock area then I would suggest you would need sprinklers. Also consider the number and distance of other exits.

See the annex of NFPA13 -- A.8.15.7 2016/2013 Ed for more clarification on this.

Mikr

11/17/2021 08:29:12 am

If it's not a transient load i.e. removed daily into the warehouse and stays repeatedly or overnight, it's storage. A loading Dock has transient loads that remain only temporarily.

CJ Bonczyk

11/17/2021 08:59:25 am

Since your projections are greater than 4', the projections are not separated from the building regardless if they are non combustible or combustible, by the black and white standard NFPA requirements, sprinkler protection is required. Rules of NFPA 13 9.3.19 specifically A.9.3.19.2 apply in this situation stating that you have to comply with NFPA 13-9.2.3 for exterior projections.

I have had different interpretations by different AHJ's over the years. Some require sprinklers regardless of the projection width even if they were non combustible, but yet the there was transient storage thus they required them. Some don't require them as long as it meets NFPA code. It will vary from AHJ to AHJ. I have had FM Global not require sprinklers under large canopies and loading docks since the storage was considered "transient" by their definition.

NFPA's Glossary of terms does not clearly define long term or transient combustibles exactly. It does define staging areas and general storage of specific occupancies. More often than not you will have to make your best judgment call on the items being stored & arrangement as well as the length of storage and justify as why or why not sprinklers are required in transient storage of combustibles. As always confirm with your local AHJ that you are on the same page with the owner use of these areas. The last thing you want to do is have to go back at the end of a project and install sprinklers through a finished building
to the exterior because you didn't clarify early on if they were required or not.

Ronnie Morales

11/17/2021 09:07:33 am

No. You must apply Merriam-Webster’s Collegiate Dictionary, 11th edition. Here's a link for future reference.

glossary_of_terms_2021.ashx (nfpa.org)

Brett

11/17/2021 09:09:45 am

Your best bet is to consult the AHJ. At the end of the day, they
will have the final say.

As an AHJ myself, with the limited information in your post, I would likely require them. Transient storage to us is not displays used to show and sell merchandise. Many home improvement stores use the areas under front canopy's to display and sell all kinds of combustibles and those items are there for a good twelve hours at a time. Additionally, those items are usually stored immediately adjacent to the main entrance/exit. If a fire were to occur here it could quickly enter the store and block the primary means of egress.

The other comments which mention loading docks are an example of something more in line with transient storage. Even then, there are plenty of loading docks I've seen which leave items out for long periods of time.

Franck

11/17/2021 10:22:49 am

Normally, if you ask the question, you already have the answer...
If you ask yourself, it it a storage ? It probably means that you consider that this represents a potential combustible load that could create a fire exposure, and this is why you probably need sprinklers.
I really liked the comment from Dan's Fire Marshall. If something can burn, it may burn at any time. If you have goods stored under your canopy, then it represents a hazard.
Remember that the only reason for not protecting storage if the canopy is less than 4 ft or considered open is not that in that case there is no hazard, but because the sprinklers would not operate properly.
This being said, if you have a few postcards in the area, this is not a real issue. But if you have kersosen used for temporary heating appliance, this is another story.
And having somebody near the storage during sales hours, is not a sufficient argument for not having an uncontrolled fire.

To come back to unloading docks, those that don't have sprinklers are normally the ones only used for the trucks, i.e., there is no storage in the area as the trucks need to come and leave the area. If you start to have an area where you store some goods, it becomes a storage area. And it needs sprinklers.
Transient storage need to be the exception.
If you have transient storage every day at the same area, this becomes a storage area (for transient goods, if you want...) and definetly need to be sprinkler rpotected, based on the worst expected storage arrangement you may find.

Todd Wyatt

11/17/2021 10:30:07 am

I have had AHJs identify waste receptacles that are under nonsprinklered exterior projections as "combustible storage" which would require sprinkler protection. The solution was to relocate the waste receptacles from under the projection.

Even if the current AHJ approves it, the subsequent future AHJ may not. Recommend getting any AHJ approval in writing.

Robert Bambino

11/17/2021 10:33:48 am

I would say if this "storage" is out under the canopy on a regular basis and between regular hours, than it get protected. I would go so far as saying even if it was used for loading and unloading, protect it. That is from an AHJ stand point.

Jon Nisja

11/17/2021 06:07:40 pm

I work for the Minnesota State Fire Marshal (MSFM( Division. We had an appeal a couple of years ago regarding trash containers in the corridor of apartment buildings pending their removal. Our state fire code prohibits combustible storage in corridors.

The appeal was based on the the definition of "storage". As others have pointed out, the dictionary definition was used. The MSFM denied the appeal and the applicant appealed that decision to an administrative law judge (ALJ).

The ALJ upheld the MSFM decision and this was appealed to the Minnesota Court of Appeals. The Court of Appeals upheld the ALJ decision and it was appealed to the Minnesota Supreme Court who refused to hear the issue.

Here are links to the rulings that you can read if you have interest:
https://mn.gov/oah/assets/9018-36602-valet-living-dps-minnesota-fire-marshal-unadopted-rule-order_tcm19-432909.pdf

https://mn.gov/law-library-stat/archive/ctapun/2021/OPa200817-030121.pdf

Although addressing a different issue than being discussed here (prohibition of storage in an egress corridor vs. protection of combustible storage under an eave overhang), the definition of "storage" is key and these rulings dealt with that issue.

11/19/2021 09:57:27 am

After the second time of asking nicely to remove the refuse cans from the hallway, the property owner and manager would be in cuffs heading to our local jail. Never overcomplicate issues that are not complicated in the first place, lol.

Is the Term "Stored" Defined in NFPA 13?

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