I've had this conversation with state agencies in CA and we're all square on the interpretation as I stated it. I have spoken with fire and building officials from other states about this over the years and I'm pretty sure that your issues are regional because we're not hearing about a wave of sprinklered non-combustible attics industry-wide. The exemptions in 903.3.1.1.1 go beyond the language of NFPA 13, which is why they are codified, but as written they do not supersede the exceptions in 13. If it was the intent of the code to unconditionally require sprinklers in any area not equipped with detection, that provision would be in the NFPA 13 standard by now. Taking another look at 903.3.1.1, I would also proffer that if it was the intent of the code to require sprinklers in non-combustible concealed spaces and attics, those would be specifically listed in 903.1.1.1 but they are conspicuously not addressed, because it's not the intent of that section to undo the exceptions in 13 (903.1.1) for those spaces.
This is likely an excellent section to propose amending in the next code cycle, because the way it's written, it gives some credence to the interpretation you've seen from "some building departments..." [cid:image005.jpg@01D65A95.D028F3A0] From: Anthony [mailto:anth...@archerconstruction.com] Sent: Wednesday, July 15, 2020 10:38 AM To: Steve Leyton <st...@protectiondesign.com>; sprinklerforum@lists.firesprinkler.org; 'Cary Webber' <cweb...@reliablesprinkler.com> Subject: RE: Uprights in non combustible concealed space Steve, In the PNW it has been an issue ever since the 2006 edition came out. Some building departments and or the fire prevention department has made comments on our plans review stating that based on this section in the code unless some type of detention is installed in this Area then sprinklers would be required. We have had to take the steps to qualify in our sprinkler bids that we assume these areas are being protected by a detection system and thus sprinklers are not included in these areas. Thanks Anthony Carrizosa Project Manager | Fire Protection 7855 S 206th St Kent, WA 98032 Cell: 206-679-5283 | Office: 253-872-7222 [cid:image001.jpg@01D65A95.0CA27A50] https://archerconstruction.com<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2farcherconstruction.com%2f&c=E,1,Wdb65AWzMgSBzW3HDw91SfcRQCtxDUQKoJf-UowQ-WnB_WMosgG-8W7eLePJ42PwWQvLiQx16Pls052VqwHO7tKm-_u5AnWly0ewkNiMkxn-AjQb1JI,&typo=1> From: Steve Leyton <st...@protectiondesign.com<mailto:st...@protectiondesign.com>> Sent: Wednesday, July 15, 2020 10:30 AM To: sprinklerforum@lists.firesprinkler.org<mailto:sprinklerforum@lists.firesprinkler.org>; 'Cary Webber' <cweb...@reliablesprinkler.com<mailto:cweb...@reliablesprinkler.com>> Cc: Anthony <anth...@archerconstruction.com<mailto:anth...@archerconstruction.com>> Subject: RE: Uprights in non combustible concealed space Anthony: The code has never been enforced this way - sprinklers are required to be installed per NFPA 13, with its exceptions noted. (Regarding attics, the term "Attic" is defined in the IBC as, "The space between the ceiling framing of the top story and the underside of the roof." An attic is not a room in that regard.) I think you're "reading further than necessary". 903.3.1.1 states that where sprinklers are required to be installed per this section, sprinklers shall be installed per NFPA 13. 13 includes very specific exceptions for non-combustible concealed spaces such as attics and floor/ceiling interstitial spaces. So, where sprinklers are required, follow 13 and the building is considered "fully sprinklered" per the code. 903.3.1.1.1 goes further, and clarifies the language in both 13 and the IBC that states "all areas" of the building must be protected with sprinklers. In that context, this section expands on the rooms and areas where sprinkler protection can be excluded, but ONLY if detection is provided. I don't believe it has ever been the intent of 903.1.1.1 to supersede the exceptions in 13 for non-combustible concealed spaces. If that was the intent, we would have been putting sprinklers into concealed spaces for years and the NFPA 13 committee would have already harmonized the standard with the code. [cid:image002.jpg@01D65A95.0CA27A50] From: Sprinklerforum [mailto:sprinklerforum-boun...@lists.firesprinkler.org] On Behalf Of Anthony via Sprinklerforum Sent: Wednesday, July 15, 2020 6:57 AM To: 'Cary Webber' <cweb...@reliablesprinkler.com<mailto:cweb...@reliablesprinkler.com>>; sprinklerforum@lists.firesprinkler.org<mailto:sprinklerforum@lists.firesprinkler.org> Cc: Anthony <anth...@archerconstruction.com<mailto:anth...@archerconstruction.com>> Subject: RE: Uprights in non combustible concealed space All, in the IBC it says in section 903.3.1.1 NFPA 13 sprinkler systems. Where the provisions of this code require that a building or portion thereof be equipped throughout with an automatic sprinkler system in accordance with this section, sprinklers shall be installed throughout in accordance with NFPA 13 except as provided in Sections 903.3.1.1.1 and 903.3.1.1.2. 903.3.1.1.1 Exempt locations. Automatic sprinklers shall not be required in the following rooms or areas where such rooms or areas are protected with an approved automatic fire detection system in accordance with Section 907.2 that will respond to visible or invisible particles of combustion. Sprinklers shall not be omitted from a room merely because it is damp, of fire-resistance-rated construction or contains electrical equipment. 4.Rooms or areas that are of noncombustible construction with wholly noncombustible contents. This non combustible area above the ceiling is not required to be sprinklered per NFPA 13 but as mentioned in the IBC it's only if the area is protected with approved automatic fire detection system. You could check to see if this area has any smoke detectors and if not use this section to show that the upright protection of a non-combustible area is required per the IBC. Anthony Carrizosa Project Manager | Fire Protection 7855 S 206th St Kent, WA 98032 Cell: 206-679-5283 | Office: 253-872-7222 [cid:image001.jpg@01D65A95.0CA27A50] https://archerconstruction.com<https://linkprotect.cudasvc.com/url?a=https%3a%2f%2farcherconstruction.com%2f&c=E,1,Wdb65AWzMgSBzW3HDw91SfcRQCtxDUQKoJf-UowQ-WnB_WMosgG-8W7eLePJ42PwWQvLiQx16Pls052VqwHO7tKm-_u5AnWly0ewkNiMkxn-AjQb1JI,&typo=1> From: Cary Webber <cweb...@reliablesprinkler.com<mailto:cweb...@reliablesprinkler.com>> Sent: Thursday, June 18, 2020 11:29 AM To: sprinklerforum@lists.firesprinkler.org<mailto:sprinklerforum@lists.firesprinkler.org> Subject: RE: Uprights in non combustible concealed space On the downside, if all areas above the ceilings are not protected, it may give a false sense of security. On the upside, more sprinklers are better, and even if not required they can act as detectors in the space. Bottom line is that the AHJ has ultimate decision making authority. Cary Webber CFPS Director, Technical Services Reliable Automatic Sprinkler Co., Inc. 1470 Smith Grove Road, Liberty, SC 29657 Tel: 864-843-5161 [https://www.reliablesprinkler.com/sites/default/files/image001.png]<http://www.reliablesprinkler.com/> From: Sprinklerforum <sprinklerforum-boun...@lists.firesprinkler.org<mailto:sprinklerforum-boun...@lists.firesprinkler.org>> On Behalf Of John Irwin via Sprinklerforum Sent: Thursday, June 18, 2020 2:21 PM To: sprinklerforum@lists.firesprinkler.org<mailto:sprinklerforum@lists.firesprinkler.org> Cc: John Irwin <jir...@quickresponsefl.com<mailto:jir...@quickresponsefl.com>> Subject: Uprights in non combustible concealed space CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you can confirm the sender and know the content is safe. We installed temporary upright Protection in a partially occupied building during a major renovation. We then came back and dropped pendent heads in the new ceiling. We left the uprights above the new ceiling. Fire inspector says we need to remove the uprights now. Is there a basis for removing these? I realize they are not required but are they permitted to remain? John Irwin
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