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The opinions below are based on the information provided and a consensus agreement by members of the IFIA Codes & Professional Development Committee and is non-binding. A formal opinion may be obtained by directly contacting NFPA.

My bureau is reviewing sprinkler plans for  a building that is converting a 1 story store front to a live/work unit. The building does have  2 hour fire separation between it and neighboring  buildings. The village has adopted IBC 2009 edition.  Section 419 of the IBC states that live/work unit shall be classified as an “R-2”. We have a sprinkler contractor who wants to put in a 13D system.  I believe because it’s an “R-2” they should be using 13R to design the system. We have several of these live/work units popping up and a definitive answer would assist with reviews – is it 13D or 13R?

Concerning your email it is the committee’s opinion that the correct sprinkler standard would be NFPA 13R. The Live/Work occupancy is listed in the IBC as an R-2, along with apartment houses, boarding houses, convents, dormitories, fraternities, sororities, hotels, motels, monasteries and vacation time share properties.


A research of the IBC 2009-2015 commentaries was conducted. The 2009 IBC 419.5 commentary is wishy-washy, referring to all 3 standards and notes an exception in the IRC to use 13D, but then refers to 903.3.1.3 for single family, duplexes and townhouses. The 2012 IBC 419.5 commentary removes all comments regarding 13D, stating NFPA 13 or 13R applies to live/work occupancies.


Based on the above, Live/Work occupancies would not be considered to be covered by NFPA 13D, whose scope covers one and two-family homes and manufactured homes. However, NFPA 13R scope does cover residential occupancies up to 4 stories, not exceeding 60 feet in height.


Further, IBC (and IFC) Sections 903.3.1.2 and 903.3.1.3 state the same NFPA 13R and 13D scope requirements.


The above opinion assumes that the Live/work occupancy meets the requirements of IBC Section 419, including:


  1. The unit can be no larger than 3000 sq ft; and

  2. The nonresidential cannot exceed 50% of the unit.

  3. A max of 5 nonresidential workers or employees.

  4. No High Hazard or Storage occupancies are permitted to be live/work

  5. Aggregate area of storage cannot exceed 10% of the nonresidential portion of the unit.


Please note that the exception in Section 419.1 states that if the work area is an office, and it is less than 10% of the dwelling unit, the occupancy would not be considered a Live/Work occupancy.


Questioning Continues...

What is an acceptable safety factor for NFPA 13, 13r, and 13d systems – I believe some of the system reviews I’m getting do not have an adequate safety factor  - example 2psi/5% for a 13d - 3 story townhouse?

Neither NFPA 13, 13D or 13R require a safety factor for the water supply used to design a sprinkler system.


Further, on page 27 of the 2016 edition of the Automatic Sprinkler Systems Handbook, the FAQ in the side margin states that a safety factor is not required to be applied to either the water supply or the system demand. It goes on to state that it is good to have a safety factor (but it is not required by the body of the standard). It also goes on to state that when comparing the system demand to the available water supply, the designer should determine the reasonable worst-case available supply.


However, the committee firmly believes that a safety factor should be applied to the water supply. Even though there is no NFPA 13 requirement there are some AHJs that have adopted a required safety margin. This is typically done by adding the provision into your building code.


One fairly normal provision is to require 10% of the available pressure at the system demand including hose streams – and if there is a fire pump, the cushion for the pump performance needs to be 5% since NFPA 25 does not require that an owner “do anything” until his pump performance degrades to 95% during annual flow testing.


Designing systems with no cushion results in under designed systems down the road.


I have a question on pathways for AES/Keltron radio networks, and how I test a secondary pathway. Are the secondary pathways programed into the network software, or is there a way of testing the main and secondary pathways? I am wondering, when I perform an acceptance test of a new radio, (Keltron), do I have to test the secondary pathway or do I just ask for a report such as a netcom report, showing pathways and signal strengths? I guess I just need to be educated a bit if you don’t mind.

When testing a Keltron or AES Private One-Way radio the best way of determining if the radio is properly communicating with other radios is to get a copy of the NetCon report from the operator of the radio network which shows the typical level of connectivity for the particular radio.  This connectivity may vary from minute to minute but on a robust, properly managed network there should not be a connectivity issue.  An issue can exist for the radio itself being able to transmit and receive signals based on its antenna location.  The provider of the radio should be able to provide a test (there is equipment for this) of the radio to verify that the antenna is located such that the radio’s signals can communicate with other radios on the network.  The receiving equipment and software for the radio network (located at the monitoring point/supervising station) should alert when any radio has less than the minimum connectivity level required.

I have a vehicle photo booth to be installed in the bay/repair area of a car dealership. My question is does this need to be sprinklered inside the booth or is the existing coverage above the booth adequate? 


NFPA 13 is very clear that “drop out” (or melt away) ceilings must be specifically listed and subsequently installed in accordance with their listing (NFPA 13 2016 section 8.15.15)
So, the real question is: is this material UL listed for such?  If the answer is no, then a sprinkler is required. We did not note any evidence of a UL listing. You should see if they have additional information of the UL listing number. Further, it appears that the booth rotates which would make the installation of a sprinkler improbable.

I have a townhome subdivision which I received the annual NFPA 72 annual inspection report. The original skipped detectors currently in the attics. I returned the report and stated it was incomplete because not all devices were tested as required by code. There are 23 buildings in the complex and some buildings there are one attic detector, some there are 2-4 attic detectors, depending on the size of the building. I received a returned report which I have enclosed, where they say they shorted the zone wires below the attic (see last page). Please let me know if this is a standard and /or accepted practice and to weather I accept it or not, or just laziness. These are not new structures and the devices have been tested in the past as far as I can tell. 

Chapter 14 of NFPA 72 - 2016 standard requires both heat and smoke detectors to be tested annually. For fixed temperature nonrestorable type heat detectors, test functionality mechanically and electrically (not tested with a heat gun) and the loop resistance must be recorded and compared to acceptance test results. Changes from the acceptance test must be investigated. Shorting out a loop before the detectors does not satisfy this requirement for testing. 

You may reference Table of NFPA 72 (page 72-89). Also note that Table, after 15 years requires fixed temperature spot type heat detectors to be replaced or have 2 of the detectors per 100 laboratory tested.”

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