The summer of 2017 saw a number of deadly high-rise fires, including the Grenfell Tower fire and the Marco Polo fire. While deadly incidents like these are usually the result of a combination of failures, these buildings had one major thing in common: they were both unsprinklered. These events led to a review of the high-rise sprinkler requirements for the 2021 edition of NFPA 101, Life Safety Code. While a blanket retroactive sprinkler requirement for high-rise buildings still isn’t proposed, a number of technical committees did modify the requirements for their respective occupancies. These proposed changes include:
- The installation of sprinklers is required in all existing high-rise ambulatory health care occupancies within 12 years of the adoption of the Code.
- Existing apartments, without a previously approved engineered life safety system, must be sprinklered by January 1, 2033.
- The installation of sprinklers or the installation of an engineered life safety system is required in all existing high-rise industrial occupancies within 12 years of the adoption of the Code.
The technical committees responsible for the changes noted above carefully considered the impact retroactive requirements have on existing buildings. Sometimes, as is the case with retroactive sprinkler requirements, the benefits far outweigh the costs.
A common misconception is that NFPA 13, Standard for the Installation of Sprinkler Systems, dictates which buildings must have sprinklers. However, the requirement for a building to be sprinklered will be dictated by a code such as a building code, life safety code, or fire code and the standard (NFPA 13) will tell you how to install the sprinklers. When determining if a building is required to be sprinklered it is important to review the requirements from all applicable codes in your jurisdiction. Just because one of the codes doesn’t require sprinklers, doesn’t mean the same is true of the others. In the case of differing requirements, the most restrictive of the codes would apply. As each of these codes serves a different purpose and has a different scope, it can lead to the difference in requirements.
We’ll look a little more closely at how the sprinkler requirements for high-rise buildings differ between the current editions (2018) of NFPA 1, Fire Code and NFPA 101. High-rise buildings are defined by NFPA 1 and NFPA 101 buildings where the floor of an occupiable story is greater than 75 ft above the lowest level of fire department vehicle access. When looking at your local requirements, it is important to verify how your jurisdiction defines a high-rise building as many jurisdictions may modify the definition.
2018 Fire Code, NFPA 1
The Fire Code is intended to address firefighter life safety and building protection in addition to occupant life safety. The high-rise building sprinkler requirements are straightforward. All new high-rise buildings must be protected with sprinklers throughout and all existing high-rise buildings must be sprinklered within 12 years of the adoption of the Code.
2018 Life Safety Code, NFPA 101
The Life Safety Code is primarily concerned with occupant life safety. Like the Fire Code, the Life Safety Code requires that all new high-rise buildings be protected with sprinklers throughout. The differences between the codes arise in existing high-rise buildings. Instead of a blanket requirement retrofit requirement, the Life Safety Code relies on the individual occupancies to determine the extent of, if any, sprinkler protection that is required. If an existing occupancy chapter requires sprinkler protection, the requirement will be found in either the “Extinguishment Requirements” subsection (XX.3.5) or the “Special Provisions” section (XX.4). Many existing occupancy chapters specifically require high-rise buildings to be sprinklered:
- Health care
- Detention and correctional
- Hotel and dormitories
- Residential board and care - large facilities
Although mercantile does not specifically call out existing high-rise buildings, there is a good chance they would be required to be sprinklered based on the general sprinkler requirements.
Ambulatory health care, apartments, and business occupancies require either a sprinkler system or an engineered life safety system. An engineered life safety system (ELSS) must provide a similar level of safety as an automatic sprinkler system. It can include protection features such as a partial sprinkler system, smoke detection, compartmentation, or other types of fire and life safety systems. It must be developed by a professional engineer and approved by the Authority Having Jurisdiction (AHJ).
Others, such as industrial and storage occupancies do not require sprinklers or an engineered life safety system due to the relatively low occupant load that is typical of these occupancies. (maybe add a sentence reminding readers about 101 mandating sprinklers only when they are installed for the protection of people not property)
The high-rise sprinkler requirements in the Fire Code and the Life Safety Code are an example of two Codes with differing requirements. To summarize, both require all new high-rise buildings to be sprinklered throughout. The Fire Code requires all existing buildings to be sprinklered within 12 years of its adoption date while the Life Safety Code is occupancy specific. As mentioned above the differences can be attributed to the different scopes and purposes.
A number of cities have passed legislation independent of the codes requiring the retrofit of some or all high-rise buildings with sprinklers. Has your city? Are you interested in learning more about retrofit? If so, let us know in the comments section!
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