New Storage Tenant Need to Meet Current Code?

9/16/2025

If a warehouse is getting a new tenant, and the AHJ requires a new C of O, does the sprinkler system need to meet current standards (NFPA 13-2022) or can the original standards (NFPA 13-2007) be used?

Specifically looking at Group A plastic protection requirements here. Thanks in advance.

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10 Comments

Pete H

9/16/2025 06:09:01 am

This can depend on a number of things from local ordinances to the amount of building renovation the new tenant is doing within the warehouse.

Tom

9/16/2025 08:27:18 am

The new tenant/building owner needs to submit a storage/commodity report from a fire protection engineer. In short prove to me that the sprinkler system is adequate for what ever manufacturing or storage in intended for that building.

Dan Wilder

9/16/2025 08:33:05 am

AHJ and building specific.

Most of my AHJ's, in storage applications, would require a reevaluation of the water supply and system capabilities as the storage rules have changed so much over the years.

Perfect example is Speculative Warehouses were all designed to a 0.495/2000 (Class IV to 20', conventional pallets, high temp sprinklers), the current requirement is 0.60/2000 (Group A Plastics to 20', high temp sprinklers)....big jump. I know your question was for ESFR specifically but without knowing the original design vs current requirements, it could be an issue.

9/16/2025 08:43:28 am

Great question and lots to talk about here. There's another similar post from 2023 about this:

https://www.meyerfire.com/daily/did-removed-esfr-design-criteria-fail-testing

My take:

1) Change tenants doesn't require a system modification, but changing the use or process of the space may require system modification (even if it's the same tenant) because fire sprinkler systems are specifically designed for the use of the space being protected.
2) I know all states don't adopt NFPA 1, but NFPA 1, 2018 §13.3.3.4.1.6 "Changes in Occupancy, Use, Process, or Materials" addresses this.
3) Reading the "Purpose" and "Retroactivity" sections of NFPA 13 are useful in understanding what we're trying to do with fire sprinkler systems. If the requirements slightly changed between editions, you have the original fire sprinkler drawings and calculations, and you verify the water supply hasn't changed I think it's reasonable to talk to the AHJ and insurance company about allowing the old system to stay so if/when there's a fire everyone is on the same page.
4) If there are huge changes in the NFPA 13 requirements, it very possible that new fire testing showed the old requirements to be less effective than previously thought in which case I would not recommend holding the liability to say that the existing system is OK because it met 2007 requirements when it's not going to control an actual fire. Group A plastics have the highest heat release rate so this isn't something I would recommend endorsing because it's not "clearly evident that a reasonable degree of safety is provided".

NFPA 13, 2022 §1.2 Purpose
§1.2.1 The purpose of this standard shall be to provide a reasonable degree of protection for life and property from fire through standardization of design, installation, and testing requirements for sprinkler systems, including private fire service mains, based on sound engineering principles, test data, and field experience.
§1.2.2 Sprinkler systems and private fire service mains are specialized fire protection systems and shall require design and installation by knowledgeable and experienced personnel.

NFPA 13, 20221.4 Retroactivity.
The provisions of this standard reflect a consensus of what is necessary to provide an acceptable degree of protection from the hazards addressed in this standard at the time the standard was issued.
§1.4.1 Unless otherwise specified, the provisions of this standard shall not apply to facilities, equipment, structures, or installations that existed or were approved for construction or installation prior to the effective date of the standard. Where specified, the provisions of this standard shall be retroactive.
§1.4.2 In those cases where the authority having jurisdiction determines that the existing situation presents an unacceptable degree of risk, the authority having jurisdiction shall be permitted to apply retroactively any portions of this standard deemed appropriate.
§1.4.3 The retroactive requirements of this standard shall be permitted to be modified if their application clearly would be impractical in the judgment of the authority having jurisdiction, and only where it is clearly evident that a reasonable degree of safety is provided.

Todd E Wyatt

9/16/2025 08:52:31 am

Start with the International Existing Building Code (e.g. IEBC-2024) and go to …

Chapter 10 Change of Occupancy.
Section 1011 Change of Occupancy Classification
1011.2 Fire Protection Systems
1011.2.1 Automatic Sprinkler System
The installation of an automatic sprinkler system shall be required where there is a change of occupancy classification and Chapter 9 of the current International Building Code requires an automatic sprinkler system based on the new occupancy or where there is a change of occupancy within the space where there is a different fire protection system threshold requirement in Chapter 9 of the current International Building Code than exists in the current building or space. The installation of the automatic sprinkler system shall be required within the area of the change of occupancy and areas of the building not separated horizontally and vertically from the change of occupancy by a nonrated permanent partition and horizontal assemblies, fire partition, smoke partition, smoke barrier, fire barrier or fire wall.

If the automatic sprinkler system (ASPS) is required per it’s new Occupancy Classification (OC) per the adopted scoping Code (e.g. IBC-2024) per the following …

Chapter 9 Fire Protection and Life Safety Systems
Section 903 Automatic Sprinkler Systems
903.2 Where Required
Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.
903.2.1 Group A
903.2.2 Group B
903.2.3 Group E
903.2.4 Group F-1
903.2.5 Group H
903.2.6 Group I
903.2.7 Group M
903.2.8 Group R
903.2.9 Group S-1
903.2.10 Group S-2 Parking Garages
903.2.11 Specific Building Areas and Hazards

... then the existing ASPS is required to meet the referenced NFPA 13 edition (e.g. NFPA-2022) per the adopted scoping Code.

Brett

9/16/2025 09:54:09 am

The problem with this approach is that it isn't typically a change in occupancy. Usually it's an S-1 building being occupied by another tenant still using it as an S-1 occupancy. The second tenant might be stuffing it with higher hazard materials, but not hazardous enough to classify the space as group H.

Rick

9/16/2025 08:53:48 am

2007 to 2022 have major changes. Cartoned non-expanded group a plastics should be similar, but cartoned expanded and exposed non-expanded have bigger changes. I wouldn't group all "Group A plastics" together if you're looking into this.

Jose R Figueroa

9/16/2025 10:49:20 am

The new tenant may change the storage class, so we must perform a comprehensive engineering analysis. Relying solely on the existing code without a proper assessment could pose a risk of a catastrophic fire. I remember 50 years ago, a tissue paper storage facility burned to the ground despite having an “adequate” sprinkler system. The issue arose when the tissue rolls switched from paper to plastic wrapping.

Jesse

9/16/2025 01:32:10 pm

I'm going to defer to the AHJ on this. I would highly recommend them getting on board. At the very least I'd evaluate the extant protection and the water supply.

sean

9/18/2025 05:29:08 pm

if the building has lost the cert. of occupancy new regulations can apply

New Storage Tenant Need to Meet Current Code?

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