Only Sprinkler Protect One Suite in Strip Mall?

6/13/2022

I have a question that I have been pondering for a while. As an AHJ we have some strip malls (or similar construction where there are multiple businesses in different suites), and in a few instances I have come across a single suite that is sprinklered due to the occupancy type within that suite.

For example an older strip mall gets a casino to move into a single suite changing it to a Group A occupancy, which now requires sprinklers. They have been allowed to sprinkler just that suite as long as there is a 2-3 hour rated fire separation between the neighboring suites.

Is this in alignment with the code?

Are they considered “separate buildings” due to the fire separation provided between suites?

If so, how do we avoid confusion when our crews respond for a fire?

They see a PIV and FDC and connect, only to realize when they go inside that there aren’t even sprinklers in the suite on fire. It just doesn’t seem operationally sound to me. Do you have any thoughts on this?

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16 Comments

M.Newell

6/13/2022 08:30:12 am

This happens a lot in my opinion.

You will have an owner/ architect build the building in alignment with code but right under the gross sq ft requirements or occupancy requirements to omit sprinkler protection.

Then you have a bar or medical office or some other occupancy with a large enough capacity to need sprinklers per the IBC.

Then you will have a fire rated separation between the non-sprinklered and the to be sprinklered space.

I have done numerous projects where we have to run a new fire line to a building and sprinkler a 6k sq ft space in an otherwise non-protected structure.

So to answer the question per code this is allowed.

It may be worth bringing up to your local code enforcement agency that they amend the code to require all shell or new structure buildings be sprinklered. We have some code amendments like that in Texas that require to entire new shell space to be protected based on a smaller than code foot print to trigger the need for sprinkler protection.

As for location of the fire I believe they would likely still need a fire alarm system in a lot of buildings that are not sprinklered. They could have a notification device that would be triggered on the portion of the structure where the fire starts and the alarm system is triggered, could be one option.

Pete H

6/13/2022 08:35:00 am

Depends if the single suite protection was done in conjunction with an agreement with the local AHJ. As AHJ can supersede code (as is outlined in code).

If the AHJ viewed the unoccupied areas as unlikely to be a fire hazard and certainly unlikely to spread past the two-three hour fire barrier before fire department response / personal evacuation it is within their jurisdiction to only require sprinkler protection as to where they feel necessary under their discretion.

Joe

6/13/2022 08:38:07 am

In short, there are three ways to categorize Mixed-Occupancy buildings, under the IBC. There's Accessory (where there's only really one occupancy, but a secondary occupancy type makes up less than 10% of the building), there is Mixed-Occupancy Non-Separated, and there is Mixed-Occupancy Separated.

For Accessory buildings, the primary occupancy governs all the requirements (including alarm and sprinkler).

For Mixed-Occupancy Non-Separated, generally, the worst-case occupancy governs all requirements for the whole building. IBC Section 903.2 and 907.2 get into more detail there.

What you probably have here (if it's code compliant), is Mixed-Occupancy Separated. Under that scenario, if each occupancy in the building is properly separated (IBC Table 508.4), then each occupancy is generally considered individually. So the A occupancy could have sprinklers while a B occupancy next door might not, but they would need to be separated by a 2-hour fire barrier (from Table 508.4).

6/13/2022 08:39:40 am

Well from an AHJ standpoint if the occupancy goes through a change of use, then that space should be brought up to the applicable codes adopted by your area. As far as confusion goes from an emergency response standpoint, spaces like that probably needs to be pre-planned by the fire department to a heavy extent. I would recommend you place signage on the FDC stating something like "Casino Only", or what space the FDC is supplying. If good pre-plans are in place, and Company Officers/firefighters know these "abnormal" places exist in their first due, it should reduce the amount of confusion they should encounter during an emergency response. I think hooking up to the FDC and charging it would still be a good practice in the event there is an unprotected penetration through a firewall and fire enters into the sprinklered space it could probably controlled better. Just my thoughts on this, and something I would want to see or know about if it was in my first due response area.

Todd E Wyatt

6/13/2022 08:41:06 am

Depending on the applicable, adopted Code(s), these are the (2) ways a building is separated into "separate" buildings :

2021 IBC : Fire Walls (FW)
706.1.1 Party walls.
The fire-resistive rating (FRR) of the FW is based on the Occupancy Classifications (OC) per "Table 706.4 Fire Wall FRR".

2021 NFPA Life Safety Code : 2-hour or greater vertically aligned Fire Barrier (FB) wall.

Chapter 8 — Features of Fire Protection
8.2 Construction and Compartmentation.
8.2.1.3
Where the building or facility includes additions or connected structures of different construction types, the rating and classification of the structure shall be based on one of the following:
(1) Separate buildings, if a 2-hour or greater vertically aligned fire barrier wall in accordance with NFPA 221 exists between the portions of the building
(2) Separate buildings, if provided with previously approved separations
(3) Least fire-resistive construction type of the connected portions, if separation as specified in 8.2.1.3(1) or 8.2.1.3(2) is not provided

The scoping requirements for an automatic sprinkler system is per 2021 IBC “Section 903 Automatic Sprinkler Systems” based on the OC (e.g. Group M Mercantile) :

903.2.7 Group M
An automatic sprinkler system shall be provided throughout buildings containing a Group M occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115 m2).
2. A Group M fire area is located more than three stories above grade plane.
3. The combined area of all Group M fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).

903.2.7.1 High-Piled Storage
An automatic sprinkler system shall be provided in accordance with the International Fire Code in all buildings of Group M where storage of merchandise is in high-piled or rack storage arrays.

903.2.7.2 Group M Upholstered Furniture or Mattresses
An automatic sprinkler system shall be provided throughout a Group M fire area where the area used for the display and sale of upholstered furniture or mattresses exceeds 5,000 square feet (464 m2).

The design, installation, maintenance, and testing of the automatic sprinkler system is per the applicable NFPA 13 edition as referenced by the adopted Code(s).

Dan Wilder

6/13/2022 08:48:50 am

I have been apart of several of these types of retrofit conditions in both strip malls and multi suite offices from the contractor side. Others have provided the code sections above, my experience with these below. Most were based on 7 or 10 year agreements with the city about bringing properties up to current standards, mostly out of an event within the building.

Typically, there is some mandate from the AHJ about providing sprinklers as areas become available, which is then implemented in all public and BOH shared areas first (public entry/exit points, public RR, common exit corridors, shared loading docks, Security or Facilities offices...) and then as each suite is built out or changes owners/occupancies, we add in sprinklers to each suite.

We have provided signage on the exterior as to "Partially Sprinkler Building" at FDC and riser locations and have provided several colored maps to be installed at key ingress/egress points.

Chris

6/13/2022 08:53:47 am

In my experience (I am an installing contractor), these situations happen more to get sprinklers inside of existing buildings rather than follow a specific code. I once sprinkled 1 tenant space with the intent of allowing the system to expand into other spaces so that it could be added with each tenant turnover.

As far as the signage, you can determine the complexity level of the signage that will be required on the building for the FDC. If you think your team will need clarification that it is only a partially sprinkled building, have the installing contractor state exactly what suites the sprinkler serves on the FDC plaque. These plaques are usually around $50 to make, so it isn't a huge burden on any contractor.

Example: "Partially sprinkled building. FDC serves suite 101, 102"

Julie

6/13/2022 10:41:48 am

Thanks for the feedback! I’m curious, if the intent is to eventually expand the system to the rest of the building, how do you size the pipes? If you’re not sure of what the future build outs will be, how can you determine the size of the main for example or whether or not a fire pump will be required? In areas with low pressure, I could see this being an issue down the road with a trickier business type moving in.

6/13/2022 11:07:46 am

Depends on a number of things.

If you really are aiming for "Best Practice", do an OH2 calc at the most remote suite from your feed, include a floor control valve within the suite. Oversize your incoming service to make it so it can handle that without a pump. The main incentive for this extra work is that hopefully as you establish a rapport with the building owner, you would be the ones installing these additions/alterations to the system.

If someone wants to put in storage or extra hazard occupancies, they can pay for the pump as the client, don't put that on yourself or your current client, but an extra inch or three in your incoming service/main diameter could line you up with several jobs in the future.

Take advice with a grain of salt. It cost me nothing to say it, it would cost you more to follow it.

Eric R

6/13/2022 09:42:27 am

This is a pretty great topic!

Looks like most of the main points have been addressed, so I'll toss in a curve ball that has been effecting one of my projects lately.

A lot of the code references above are for new construction, but if the jurisdiction uses the "Existing Building Code" from the ICC then there could be a lot of extra rules in play.

In older editions of the IEBC a change of occupancy in which the new occupancy would require sprinkler protection per the IBC would require that sprinkler system to be extended to cover all adjacent non-separated areas. (As per Joe's comment above).

Now the 2021 IEBC has significantly changed how this section is worded, and states:

1011.2.1: Where a change in occupancy classification occurs or where there is a change of occupancy within a space where there is a different fire protection system threshold requirement in Chapter 9 of the International Building Code that requires an automatic fire sprinkler system to be provided based on the new occupancy in accordance with Chapter 9 of the International Building Code. 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 one of the following:
1. Nonrated permanent partition and horizontal assemblies.
2. Fire partition.
3. Smoke partition.
4. Smoke barrier.
5. Fire barrier.
6. Fire wall.

By this code you no longer need a 2 hour fire barrier to limit the area of the sprinkler protection. What has really thrown me for the loop is the option to use a non-rated partition!

So my curve ball question is what is the definition of a non-rated permanent partition? It doesn't seem to have a specific definition in IEBC Chapter 2.

Second question: An incredibly common existing building occupancy change is your standard main-street building that has ground level shops with upper level business offices that wants to turn the offices into residential rentals. Generally the entire building gets a sprinkler system because trying to install a 2 hour horizontal assembly in an old occupied building is not feasible.

However, following this new 2021 IEBC language can you count the apartment floor as a non-rated partition and not sprinkler the commercial space at all? And for extra credit, if you can exempt the commercial space can you then use 13R as the applicable standard for the residential system?

Robert Hughes

6/13/2022 10:15:35 am

Sadly, money talks, so safety walks.
The Code(s) allow WAY too much leeway for this separation nonsense when it comes to sprinkler-based fire protection.
NFPA states to sprinkler "entire premises".
To water this optimal requirement down, simply go upstream of NFPA into the building codes and look for separation loopholes, cost-prohibitiveness loopholes, etc. There's plenty.

Jesse

6/13/2022 10:17:20 am

Unfortunately, we see this a lot. Its not all that uncommon when IBC occupancy is the driver for protecting a space. Ideally, everything should be sprinkler protected.

Having spent the first 20 years of my career in the fire-service, the partially sprinklered issue should be address in the fire department's pre-incident planning. Signage could be something along the lines of "partially Sprinklered Building - Suites xxx zzz AS remaining suites NS"

6/13/2022 10:48:15 am

Thanks for your responses everyone, they’re quite helpful. Especially from different trades and areas of expertise. I’m the one who asked this question and I was curious because I came from one fire department where they wouldn’t allow this at all. My new department does allow it however and it seems odd to me. I agree it would be ideal to sprinkler the entire building. If you’re having to tear up the street and parking lot to add a main anyways, would the cost rise so much to sprinkler the entire thing? Perhaps it would, I’m not sure. I think I will be looking closer at our FDCs and their labeling. I don’t see the special requirements on new building plans. It just shows the FDC. Perhaps specific verbiage for the partially sprinklered building could be added to our local amendments. But…if there’s a 2 hour fire separation…is it really a “partially sprinklered building”? I think some will argue they’re actually separate buildings. Just a thought. Thanks everyone!

6/13/2022 11:44:52 am

Just remember that a 2-hour 'fire barrier' separation is not the same as either a Fire Wall(Party Wall) or the special horizontal building separation allowance per IBC 510.2 that would allow a single structure to be considered multiple distinct buildings. Both of which require 3-hour rated assemblies, and have additional requirements beyond just the hour rating.

6/13/2022 02:20:33 pm

Oh ok, thank you for the clarification!

Todd Wyatt

6/15/2022 08:12:37 am

Per 2021 IBC, the required fire-resistance rating (FRR) of Fire Walls (FW) are based on the Occupancy Classification(s) that are being separated as identified in Table 706.4. The FRR of FWs are either :
2-hours (F-2, S-2, R-3, R-4) or
4-hours (H-1, H-2), or
3-hours (all other OCs).

Only Sprinkler Protect One Suite in Strip Mall?

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