# Fire Seperation M/S1/M



## hlfireinspector (Jan 7, 2010)

2006 IBC/IFC Type IIIB building 23,123 sq. ft  no sprinklers ( Strip center)

Local amendement 8,000 sq. foot sprinkler threshole for M & S-1

Local Fuinture store sold to new owner

New owner was tipped I was looking for CO's on  past expanisons into bays on both sides

No CO's found /Illegal expansions / Illegal mezzanines

New owner wants to start small. Brings store back to orginal CO and drops a bay on each side. Repairs teant seperation walls.

Now wants to use one bay on one side for storage

Strip from south end

M (Overstock Store) 3,500 sq.feet

Vacant bay given up by funiture store now to be S-1 /3,500 sq.feet

M (Funiture store) 7,500 sq. feet

Vacant bay given up by funiture store.

several vacant bays.

Walls 1 hr teant seperation to deck as far as I can tell.

New owner of funiture store wants to meet code.

S-1 will not meet accessory use option (he stated he would have no pentrations in wall and > 10%)

In table 508.3.3 I have never understood the M/S1 no seperation needed unless you exceed footnote b. This exceeds foot note b. What is the required seperation? (508.3.3.4.1) I have looked at calling it seperated (with 0 rated fire wall ? ) but the Fire Area would still require sprinklers. My call is sprinklers will reduce fire barrier to 1hr or fire barrier on both sides of S-1 of 2 hrs. Then we will deal with walls on other end of store when teants fill vacant bay. If we had adopted 09 by now this would be easy.


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## AegisFPE (Jan 7, 2010)

Re: Fire Seperation M/S1/M

It may also be worth noting that 2009 IFC specifically mandates sprinklers for Group M upholstered furniture spaces.  They may wish to gain current benefits of installing sprinklers in order to provide for future flexibility as well.


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## Glennman CBO (Jan 7, 2010)

Re: Fire Seperation M/S1/M

There is no separation required between M and S-1. The way I understand footnote b is that it only can apply to S-2 storage. Otherwise, there is no place in the table to go for M to S-1 separation since you would end up in the "N" designation in the table.

S-2 stroage then would be allowed w/ no separation if under 10% etc (as in the table) but would require separation if it is beyond the criteria in footnote b.


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## JBI (Jan 7, 2010)

Re: Fire Seperation M/S1/M

hl - Just checked the NYS BC to see what we have. Would you believe 3 hours if you exceed the footnote limits (those are the same as IBC)? Took a few minutes as we have the provisions in a different place... chapter 3, Use and Occupancy Classification. I know that's worthless outside of NYS...


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## kilitact (Jan 8, 2010)

Re: Fire Seperation M/S1/M

hlfireinspector wrote;



> he stated he would have no pentrations in wall and > 10%


The S-1 would be a separate tenant space with it's own exit(s)? whats the issue? you have a M occupant, less than 8000 sq ft and a S-1 occupant at 3500 sq ft, two separate tenant spaces. The same owner (tenant) having both spaces doesn't drive the requirement for fire barriers and or fire sprinklers.


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## Builder Bob (Jan 8, 2010)

Re: Fire Seperation M/S1/M

They have modified the ruling from 12,000 Sf Threshold to 8,000 SF Threshold, did they not also modify the rest of the requirements - such as total FA without sprinkers cannot exceed (unadmended code - 24,000 SF) which if they modifed the 8,000 SF, the combined Squarefootage of the Fire Areas could not exceed 16,000 SF -

Not to mention the mezzinines, which in unadmended code does not allow the fire area to exceed 24,000 SF

Since the S-1 and M do not have separations - the building would have to be non-seperated.


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## FyrBldgGuy (Jan 8, 2010)

Re: Fire Seperation M/S1/M

The project sounds like a non-separated mixed use occupancy that would require sprinkler protection.  I would also find out if the furniture store owner will be storing furniture with foam or similar stuffing at heights greater than 6 feet.  Storing a couch on end results in exceeding the 6 feet, which makes the storage space "High Pile".  Now more requirements are involved.


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## hlfireinspector (Jan 8, 2010)

Re: Fire Seperation M/S1/M

You are all hittin the nail on the head. The mezzanines were used to store matteress all the way to the roofline. The purlins made good seperators. If I use non-seperated because fire barriers are not rated or do not meet the proper rating I exceed the allowable height and area for the building type. M= 12,500 most restrictive / S1= 17,500/ B= 19,000 or can I go 12,500 M ,17,500 S1, and 19,000 B in the same non seperated building. Commentary (uck) says buildings in same group need no seperation.We could build a huge building this way. I do have frontage increase front and back(hate doing does calcs) Building was built before we had inspectors that looked at area and height.To answer BB question we did ammend the combined fire area to read 16,000 square feet. We also have ammended this wording" Mixed Occupancies= All buildings 8000 square feet or more gross floor area shall be sprinklered" and "For the purpose of sprinkler seperation footage, only four hour rated firewalls with fire rated assemblies protecting all openings will seperate building occupancies. Then it references IBC 705.1-705.3 without exceptions, then 705.5 without exceptions and 705.6 without exceptions. I try not to push these too far as I ususally end up on the carpet if I do.


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## texasbo (Jan 8, 2010)

Re: Fire Seperation M/S1/M

I'll ask the question that was asked before. You have an existing building, with B, S, and M occupancies, with one hour tenant separations and no openings between them, and none of the spaces exceed your amendment of 8000 square feet. What's the problem?


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## kilitact (Jan 8, 2010)

Re: Fire Seperation M/S1/M

texasbo, fire area exceeds 8000 sq ft, in accordance with the local amendement needs a 3 hour fire barrier or fire sprinklers for the bldg. This building wouldn't be required to have 1-hour separation. If the bldg. was in place before this local amendement than fire area could be 12000 sq ft.


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## texasbo (Jan 8, 2010)

Re: Fire Seperation M/S1/M

Last post says 4 hours:



> We also have ammended this wording" Mixed Occupancies= All buildings 8000 square feet or more gross floor area shall be sprinklered" and "For the purpose of sprinkler seperation footage, only four hour rated firewalls with fire rated assemblies protecting all openings will seperate building occupancies


So unless it is a four hour wall, according to local amendment, the building has to be sprinklered. But again, I ask: it's an existing building, the uses aren't changing, and the tenant spaces aren't being enlarged, what is the problem? What am I missing here?


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## Plans Approver (Jan 8, 2010)

Re: Fire Seperation M/S1/M

I'm also missing the point here.  Usually a new owner for an existing business does not kick in code requirements.  Consult with your legal beagle regarding vested rights, if any/applicable.


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## hlfireinspector (Jan 8, 2010)

Re: Fire Seperation M/S1/M

The S1 could be consider a change in occupancy. The last legal CO for this bay was a B but thats no a hill I would die on. When the funiture store had this bay it was a M with the S-1 in the back (really close to the 10% for incidental use without the illegal overhead storage). I guess my question is there a seperation req. between the S1 and the M and if not is the fire area defined by the teant seperation walls. It is a existing building and just the removal of the overhead storage by the "high pile" code will greatly improve the life safety.


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## texasbo (Jan 8, 2010)

Re: Fire Seperation M/S1/M

Ya, the change in occupancy might be grounds for kicking in requirements to comply with local amendments.  Does your jurisdiction require an existing non-sprinklered strip center to be sprinklered when an M occupies a space formerly occupied by a B?

You have already eliminated the pile storage, as well as the illegal combination of suites. The building is now essentially back to the way it was permitted originally, yes? For what little my opinion is worth, if I'm understanding all of the issues correctly, I would call it a day.


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## hlfireinspector (Jan 8, 2010)

Re: Fire Seperation M/S1/M

Even though we have the 4 hr fire wall seperation for sprinkler coverage I pertty much use the I-codes seperation reqs. and don't have to fight so many battles. I use the fire area to req. fire sprinklers. If the S1 was over 8000 sq feet we would be req. sprinklers. If the M breaks the firewall again  and the sq. footage is over 8000 that will drive the req. for sprinklers. If a use does not provide the proper fire seperation we use the combined footage of the uses in between the proper fire seperations and the most restrictive. I can not understand how you have no seperation req. for M/S1 and a 2hr seperation for a M/S2. It must be to protect the S2 from the M. I understand fire seperations are to protect uses of different hazards from each other not to break fire loads up.Thank you all for your help and making me look at things from a different view.


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## TJacobs (Jan 9, 2010)

Re: Fire Seperation M/S1/M

Mixed use separation is not the same as fire area separation.  My opinion is the new owner has to clear up all the illegal stuff and bring it down to something that complies w/o sprinklers, or provide fire area separation to stay under sprinkler threshold, or provide sprinklers.


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## Plans Approver (Jan 9, 2010)

Re: Fire Seperation M/S1/M

Area separation is one of the many problems with the 06 IBC.

2003 IBC - separation for separated use or area separation between M and S-1 would have been 3 hours. I believe that there is a code change proposal to bring Table 302.3.2 back in the 2012 code. I don't know how much traction that will have.

2006 IBC - The way I read it - separation for separated use is not required or area separation is not required until you reach sprinkler thresholds. Unless, you decide to apply Table 706.3.9 without noting its reference from code section 706.3.9. There are no individual references in any other section of the code to the table, only to the code section. But, the table heading does not say single occupancies only.







2009 IBC - separation for separated use is still not required. But, fire area separation goes back to 3 hours for M/S-1. Notice that the section name has been changed to "Fire Areas"


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## hlfireinspector (Jan 11, 2010)

Re: Fire Seperation M/S1/M

Update of project. Talked with Fire Chief and we are going with teant seperation walls(1 hr) to define the fire area and removal of all illegal mezzanines. Go to funiture store today and S1 has moved to bay on north side of funiture store. The pervious owner of the funiture store is the owner of the overstock store and over the weekend decided he needed two bays.( 7000 sq. feet without mezzanaies) I walked in overstock store and a 60 foot by 7 foot hole had been cut into the wall between the bays.    This wall is not structural but is load bearing the ceiling and the other 9 foot of wall over the 60 foot hole. The wall had dropped in the center and the ceiling grid was noticably lower in the center of the room. A crack in the sheet rock of about 3/4 of an inch in the center of the 60 foot hole was evident. No demo permits pulled. The BO was called and I stood against the outside walls while he inspected the damage.  :roll:


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## TJacobs (Jan 11, 2010)

Re: Fire Seperation M/S1/M



			
				Plans Approver said:
			
		

> Area separation is one of the many problems with the 06 IBC.


I'm not seeing the problem.  Separation or the lack therof is a designer choice.

*1999 BNBC*

_*709.2 Fire area:*_

_*A fire separation assembly which separates adjacent fire areas shall have a fireresistance rating of not less than the fireresistance rating required by Table 313.1.2 based on the use group of the fire areas which are separated.*_

BOCA used Section 313.1.2 and the associated table to define use group separation plus fire area separation.  One table...much simpler IMHO.



			
				Plans Approver said:
			
		

> 2003 IBC - separation for separated use or area separation between M and S-1 would have been 3 hours. I believe that there is a code change proposal to bring Table 302.3.2 back in the 2012 code. I don't know how much traction that will have.


_*901.7 Fire areas.*_

_*Where buildings, or portions thereof, are divided into fire areas so as not to exceed the limits established for requiring a fire protection system in accordance with this chapter, such fire areas shall be separated by fire barriers having a fire-resistance rating of not less than that determined in accordance with *__*Section 706.3.7.*_

Note fire areas was in 2003.  I don't have a 2000 IBC to check that cycle.  Note that this is identical to 2006 except for fire area section/table number.



			
				Plans Approver said:
			
		

> 2006 IBC - The way I read it - separation for separated use is not required or area separation is not required until you reach sprinkler thresholds. Unless, you decide to apply Table 706.3.9 without noting its reference from code section 706.3.9. There are no individual references in any other section of the code to the table, only to the code section. But, the table heading does not say single occupancies only.


_*901.7 Fire areas.*_

_*Where buildings, or portions thereof, are divided into fire areas so as not to exceed the limits established for requiring a fire protection system in accordance with this chapter, such fire areas shall be separated by fire barriers having a fire-resistance rating of not less than that determined in accordance with *__*Section 706.3.9.*_  Note that this is identical to 2003 except for fire area section/table number.



			
				Plans Approver said:
			
		

> 2009 IBC - separation for separated use is still not required. But, fire area separation goes back to 3 hours for M/S-1. Notice that the section name has been changed to "Fire Areas"


This appears to be an improvement because it reinforces horizontal as well as vertical separation, but otherwise does not change long-standing fire area and occupancy separation requirements.


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## mtlogcabin (Jan 11, 2010)

Re: Fire Seperation M/S1/M



> 2009 IBC - separation for separated use is still not required. But, fire area separation goes back to 3 hours for M/S-1. Notice that the section name has been changed to "Fire Areas"


Question: S-1 should be 3 hours but an M looks like 2 hours. Is a line missing in the Table between F-1, H-3 & S-1 and the rest in that row?


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## hlfireinspector (Jan 11, 2010)

Re: Fire Seperation M/S1/M

I know this is not M/S1 but it is pulled from the 2006 IBC commentary  :?  Step 2: Table 508.3.3 indicates that there is no separation requirement between Group B and Group S-1, since they are in the same grouping of occupancies in the table. *But when it come to fire areas* :TABLE 706.3.9 One of the alternatives available in addressing fire protection systems in many buildings is to divide the building into separate fire areas (see the definition of “Fire areas” in Section 702). Since many of the fire suppression system thresholds (see Section 903.2) are based upon fire area, separation of a single occupancy into small fire areas can be an acceptable method for avoiding the use of sprinklers. This is a classic type of design decision: sprinklers versus compartmentation. If the separation is provided, each fire area may be evaluated separately for purposes of determining the applicable provisions of the this code. Table 706.3.9 provides the minimum required fire-resistance ratings of the fire barrier wall or horizontal assembly *separating two fire areas of the same occupancy groups. Areas separated with fire barriers are not considered separate buildings*; they are considered separate fire areas. Two areas must be separated by a fire wall or exterior walls to be considered separate buildings. Two areas separated with fire barriers are still considered as part of a single building. This distinction is critical in determining compliance with allowable height and area and other code provisions.


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## Plans Approver (Jan 11, 2010)

Re: Fire Seperation M/S1/M



> I'm not seeing the problem. Separation or the lack therof is a designer choice.


I agree that it is the designer's choice.  In the original post the choice was to avoid installing sprinklers and the local threshold per fire area is 8000 sf rather than the 12,000 sf in the IBC. The combined space of M at 7500 sf and S-1 at 3500 sf exceeds the threshold. To avoid sprinklers, separated occupancies applies. 508.3.3.4 points to table 508.3.3 where no separation is required. Therein lies the first problem, we have a space exceeding the sprinkler threshold that requires no separation between the occupancies.  Next we go to 901.7 which points us to 706.3.9 which is for separation of single occupancies into fire areas. There is the second problem, there is no guidance for dividing mixed occupancies into fire areas, except 508.3.3.4.  Unless, you apply *Table* 706.3.9 without regard from where it is referenced or as a stand-alone, it doesn't make sense as historically separated mixed occupancies have been allowed at least since 1984 or 1987 BOCA.  If 901.7 just added the words "...and Table 706.3.9." that would have made the intent clear.

Yes, the BOCA separation table which was brought into the 2000 and 2003 IBC was very clear and simple to use. The change in 2009 will help clear up the problems above because it adds the sentence "The fire barriers or horizontal assemblies, or both, separating fire areas of mixed occupancies shall have a fire-resistance rating of not less than the highest value indicated in (2009) Table 707.3.9 for the occupancies under consideration."


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## TJacobs (Jan 12, 2010)

Re: Fire Seperation M/S1/M



			
				Plans Approver said:
			
		

> > I'm not seeing the problem. Separation or the lack therof is a designer choice.


I agree that it is the designer's choice.  In the original post the choice was to avoid installing sprinklers and the local threshold per fire area is 8000 sf rather than the 12,000 sf in the IBC. The combined space of M at 7500 sf and S-1 at 3500 sf exceeds the threshold. To avoid sprinklers, separated occupancies applies. 508.3.3.4 points to table 508.3.3 where no separation is required. Therein lies the first problem, we have a space exceeding the sprinkler threshold that requires no separation between the occupancies.  Next we go to 901.7 which points us to 706.3.9 which is for separation of single occupancies into fire areas. There is the second problem, there is no guidance for dividing mixed occupancies into fire areas, except 508.3.3.4.  Unless, you apply *Table* 706.3.9 without regard from where it is referenced or as a stand-alone, it doesn't make sense as historically separated mixed occupancies have been allowed at least since 1984 or 1987 BOCA.  If 901.7 just added the words "...and Table 706.3.9." that would have made the intent clear.

Yes, the BOCA separation table which was brought into the 2000 and 2003 IBC was very clear and simple to use. The change in 2009 will help clear up the problems above because it adds the sentence "The fire barriers or horizontal assemblies, or both, separating fire areas of mixed occupancies shall have a fire-resistance rating of not less than the highest value indicated in (2009) Table 707.3.9 for the occupancies under consideration."

The 1987 BOCA was the last BOCA that based sprinkler thresholds on building areas.  Fire area was in the 1987 BOCA but limited to B-M-R combinations in certain types of construction.  1990 BOCA began basing sprinklers on fire areas.

Since my jurisdiction has a zero square foot sprinkler amendment, I don't have to review separation much.  If I did, I would assume if you can separate a single occupancy into separate fire areas to avoid sprinklers, I would also assume you could do the same in a mixed use scenario with the same table.  It appears that the 2009 language clarifies that principal.  I hope it stays.


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## Glennman CBO (Jan 12, 2010)

Re: Fire Seperation M/S1/M

I see the problem here with mixed, non-separated occupancies (per table 508.3.3) and a single occupancy with regard to separating them into individual fire areas. If no separation is required between M and S-1, but the threshold for the fire area is exeeded (getting away from the original post and going hypothetical) and say is 12,500 sq. ft. (combined), then wouldn't it theoretically be a single occupancy with regard to fire area (requiring a fire area separation, due to the extra 500 sq.ft.)? How is this addressed in 707.3.9?

The problem seems to lie in the use of the term "single occupancy" in 707.3.9 ('09 IBC). The term doesn't fit an M, S-1 combined, non separated area. It seems to me that they need to come up with another way to describe the intent of the section such as "The fire barrier or horizontal assembly, or both, separating a single occupancy _or non separated mixed occupancy_ into different fire areas shall...".

Is this the point you are making Plans Examiner?


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## Plans Approver (Jan 12, 2010)

Re: Fire Seperation M/S1/M



			
				Glennman CBO said:
			
		

> Is this the point you are making Plans Examiner?


Kinda.

With nonseparated mixed uses, once you hit the threshold of 12,000 sf in a fire area, you require sprinklers by applying the most restrictive applicable provision of Chapter 9 (508.3.2.1). So I think that 2009 707.3.9 clears up the separated mixed occupancy problem.

But, throughout this discussion, I was reading instead of thinking.  While reading your post, I had a duh! moment.  :idea:  Place the fire separation 1 inch (more or less) into the M area and make the separation according to 2006 Table 706.3.9. The single occupancy M is separated according to code. So that the result is one fire area as M and another that is mixed occupancy of a very small M plus the S-1.

I feel better.


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## TJacobs (Jan 12, 2010)

Re: Fire Seperation M/S1/M



			
				Plans Approver said:
			
		

> \ said:
> 
> 
> 
> > Is this the point you are making Plans Examiner?


Kinda.

With nonseparated mixed uses, once you hit the threshold of 12,000 sf in a fire area, you require sprinklers by applying the most restrictive applicable provision of Chapter 9 (508.3.2.1). So I think that 2009 707.3.9 clears up the separated mixed occupancy problem.

But, throughout this discussion, I was reading instead of thinking.  While reading your post, I had a duh! moment.  :idea:  Place the fire separation 1 inch (more or less) into the M area and make the separation according to 2006 Table 706.3.9. The single occupancy M is separated according to code. So that the result is one fire area as M and another that is mixed occupancy of a very small M plus the S-1.

I feel better.     [/quote:3s24v7ci]

I agree.


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## Glennman CBO (Jan 12, 2010)

Re: Fire Seperation M/S1/M

Ooops. I realized I was quoting from the '06 but referencing the '09. I see that they did make a change in the wording in the '09 to include "mixed occupancies" in the text. I guess that does clear up some issues. I need to start weaning myself from the '06 soon anyway. Thanks Plans Approver.


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