Level 2/3 Alteration Trigger "Major Renovation?"

4/16/2026

I represent an AHJ in Massachusetts and have a potential tenant who reached out to my office about what sprinkler work might need to be done during an upfit, I don't have all the information on their plans or level of alterations.

My question includes MA 780 CMR (Mass building code) and MGL 148 S26G (sprinklers in buildings over 7500 sqft). The building is all business occupancies and is a 1892 build with 12,952 sqft. No current fire protection in the building.

The size brings into question 148 S26G, my question is would a level 2 alteration or level 3 alteration trigger 26g as "major renovation" and trigger the entire building needing sprinklers?

The shop in question might only account for 10% of the square footage, so would that be major in the context of the building?

If that doesn't trigger it, would the level 2 or 3 for B use group in the retail space that is smaller than 12,000 sqft itself, but part of a building that is 12,000+ trigger sprinklers in the renovated space?

Thanks for your insights.

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6 Comments

Respectful Opinion

4/16/2026 08:29:55 am

Tell them to hire an architect (let's assume qualified, competent, licensed, insured), have the architect complete a code analysis for the client, and then they can propose their interpretation of the codes/standards to the AHJ for approval. This doesn't seem like the type of thing that the AHJ should be deciding for a tenant unless you're going to accept the downstream implications (cost/time/liability) of the consultation you're providing.

4/16/2026 03:11:41 pm

The asking party has not rented the space yet and called first to the AHJ with the question. They were informed they would need a registered design professional to create and submit plans that were code compliant, but with the question being asked I wanted to educate myself on it and be better prepared for if/when they submit plans.

4/16/2026 08:48:40 am

I haven’t worked in Mass so I can’t speak to their local laws, so I’ll focus on the last question of the post.

From the perspective of the Mass Existing Building Code (EBC), sprinklers don’t appear to be required for the alteration being described.

It’s not clear if the work area involves ‘exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30’ (803.2.2), whether the building is a high-rise (803.2.1), whether the work area is on a windowless story (803.2.4), or whether the space includes one of the areas listed in Table 903.2.11.6 of the Mass Building Code (803.2.5). However, assuming that none of those criteria apply to the project, you’ve stated that the ‘shop’, which I’ll assume to be the full ‘work area’ as defined by the EBC, makes up less than 10% of the square footage (though it’s unclear if that is the square footage of a single floor or all floors of the building). Sprinklers are not required per 803.2.2 where the work area is less than 50% of the floor area. Furthermore, the project would not be classified as an Alt 3 unless the work area is equal to or greater than 50% of the entire building area.

EBC 603.1 Scope
Level 2 alterations include the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment, and shall apply where the work area is equal to or less than 50 percent of the building area.
Exception: The movement or addition of nonfixed and movable fixtures, cases, racks, counters and partitions not over 5 feet 9 inches (1753 mm) in height shall not be considered a Level 2 alteration.

EBC 803.2.2 Groups A, B, E, F-1, H, I-1, I-3, I-4, M, R-1, R-2, R-3, R-4, S-1 and S-2
In buildings with occupancies in Groups A, B, E, F-1, H, I-1, I-3, I-4, M, R-1, R-2, R-3, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where both of the following conditions occur:
1. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction.
2. The work area exceeds 50 percent of the floor area.
Exception: If the building does not have sufficient water supply for design of a fire sprinkler system available to the floor without installation of a new fire pump, work areas shall be protected by an automatic smoke detection system throughout all occupiable spaces other than sleeping units or individual dwelling units that activates the occupant notification system in accordance with Sections 907.4, 907.5 and 907.6 of the International Building Code.

Having said that, I agree with the previous post – it is the owner's responsibility to hire a qualified design professional to perform a code analysis to present to the AHJ.

4/16/2026 03:16:49 pm

Thanks MO, the space does not share corridors and doesn't meet the occupant load requirements set out in 803.2.2. Also the clarity I was looking for was building area vs tenant area which you touch on and answers my question about that. appreciate it

4/16/2026 09:07:04 am

Edit: Meant to include EBC 604.1 for Alt 3 definition.

604.1 Scope
Level 3 alterations apply where the work area exceeds 50 percent of the building area.

danefre

4/17/2026 11:50:44 am

I work in MA.

Have you reviewed the Advisory Memo regarding C. 148, S. 26G? Everything is explained there. Available on mass.gov

A specific consulting group in MA (can't name it) has tons of information if you google your question. It's a subjective call on "nature" of renovation and we don't know the cost of the building or proposed alterations. Professionals get paid to research and answer this question for each specific project.

Level 2/3 Alteration Trigger "Major Renovation?"

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