# 2012 IBC Section 903.2.8 vs. Table 508.4 Non-sprinklered Residential Occupancies



## CodePrincess (Oct 4, 2013)

Please someone unconfuse my head:

Section 903.2.8 says that a sprinkler system shall be provided in all buildings with a Group R fire area.  Table 508.4 gives the required separation for mixed use buildings containing an R occupancy.  It does not say NP in all cases, implying that you could have a non-sprinklered, mixed use building containing an R occupancy.  Note, this is not the table for creating separate buildings with fire walls (Table 706.4), this is the table for "buildings" with mixed use including R.

My confused brain wants to know, if you must sprinkler all "buildings" with a group R fire area, then under what circumstances can you have an IBC, mixed use, non-sprinklered "building" with a group R fire area per Table 508.4?

Thank you in advance!!


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## mtlogcabin (Oct 4, 2013)

When you create separate fire areas *and* building for the "R" occupancy.


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## cda (Oct 4, 2013)

Welcome

Like the name

We have a door guru

Maybe R on first floor and rear above it with separation

Not a building type person, but maybe combining two sections when they should be looked as two separate requirements

SECTION 508 MIXED USE AND OCCUPANCY

508.1 General. Each portion of a building shall be individually classified in accordance with Section 302.1. Where a building contains more than one occupancy group, the building or portion thereof shall comply with the applicable provisions of Section 508.2, 508.3 or 508.4, or a combination of these sections.


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## steveray (Oct 4, 2013)

The note for that table only applies to 13 systems.....not 13R...which may be allowable elsewhere in the code....


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## RLGA (Oct 4, 2013)

If the building contains a Group R fire area, then it must be sprinklered throughout the building--even if it is a mixed-use building.  The type of sprinkler system used depends on the type of building and which system is permitted for the type of building per Section 903.3.1.

The only way to avoid sprinklering a complete structure is to divide the building using a fire wall.  Then only the building on the side of the fire wall with the Group R occupancy is required to be sprinklered.


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## CodePrincess (Oct 4, 2013)

Me again.  I agree with you guys who say you have to create separate buildings in order to not sprinkler the other occupancy.  So, that's where I'm confused by Table 508.4.  Table 508.4 is not used in order to separate into separate buildings like a fire wall would. Table 508.4 provides required separation used for applying the requirements for separated mixed use within a building, and yet the table provides for separation between and R occupancy and other occupancies in a non-sprinklered (NS) building.  The table provides a required separation between R and F-1/2, S-1/2, U, B, and M for NS buildings.

My guess so far relates to what steveray said, and maybe the required separation applies when the R occupancy has a 13R system rather than a 13 system, but that still seems incomplete somehow, or is it?


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## RLGA (Oct 4, 2013)

I see what you're saying.  Yes, if the building is sprinklered per NFPA 13R or 13D, then the nonsprinklered (NS) value must be used, since the footnotes specifically require a NFPA 13 system for the sprinklered values.


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## mtlogcabin (Oct 4, 2013)

The table is the same as prior to the requirement that all "R" occupancies be sprinkled. Because of state amendments you can have up to 8 residential units before sprinklers are required in MT. So I am glad the table addresses the mixed uses.

The I-Codes where written with trade offs when sprinklers are installed. I believe it is a good idea to keep the trade offs in the codes and not assume that the local AHJ's will adopt all the sprinkler requirements.

Look what happened in the IRC. Sprinklers are required and townhouse common walls went from a 2 hour requirement to a 1 hour requirement. Now if an AHJ chooses not to adopt the sprinkler requirements and are not paying attention to other portions of the code they may end up with townhouses that do not have a 2 hour common wall requirement.


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## Frank (Oct 7, 2013)

The nonsprinklered values were left in the separation tables for existing nonsprinklered buildings that are altered.


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## CodePrincess (Oct 7, 2013)

Thanks, only now I have another concern.  If an existing non-sprinklered building undergoes a change of occupancy so that part of the building is an existing business, and part is converted to apartments, then is the whole building required to be sprinklered?  I'm referencing Section 3408 (2012 IBC) where it says that no change in occupancy shall be made unless the building is made to comply with the requirements of the code.  I'm not questioning two buildings with a fire wall between.  I'm questioning a building with two occupancies.


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## RLGA (Oct 7, 2013)

Since the apartments are new, that is considered a change of occupancy and the entire building will need to be sprinklered.  If the business areas are not accessory to the residential, then the sprinkler system must comply with NFPA 13.


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## mtlogcabin (Oct 7, 2013)

That is contrary to the IEBC

1012.2 Fire protection systems.

Fire protection systems shall be provided in accordance with Sections 1012.2.1 and 1012.2.2.

1012.2.1 Fire sprinkler system.

Where a change in occupancy classification occurs 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, such system shall be provided throughout the area where the change of occupancy occurs.

However that seems to contradict IEBC Sections 1012.1.1.1 & 1012.1.1.2. Any thoughts on that?

1012.1.1 Compliance with Chapter 9.

The requirements of Chapter 9 shall be applicable throughout the building for the new occupancy classification based on the separation conditions set forth in Sections 1012.1.1.1 and 1012.1.1.2.

1012.1.1.1 Change of occupancy classification without separation.

Where a portion of an existing building is changed to a new occupancy classification and that portion is not separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the International Building Code for the separate occupancy, the entire building shall comply with all of the requirements of Chapter 9 applied throughout the building for the most restrictive occupancy classification in the building and with the requirements of this chapter.

1012.1.1.2 Change of occupancy classification with separation.

Where a portion of an existing building that is changed to a new occupancy classification and that portion is separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the International Building Code for the separate occupancy, that portion shall comply with all of the requirements of Chapter 9 for the new occupancy classification and with the requirements of this chapter.


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## RLGA (Oct 7, 2013)

mtlogcabin:

That is only if the "Work Area Compliance Method" is used.  If using Chapter 34 of the IBC or the "Prescriptive Compliance Method" in the IEBC, then the entire building needs to be brought into compliance.  IEBC Section 1012.1.1, as you pointed out, seems to contradict the later Section 1012.2, but the "Chapter 9" it is refering to is Chapter 9 of the IEBC--not the IBC.  Chapter 9 of the IEBC covers Level 3 Alterations.

For the "Prescriptive Compliance Method," IEBC Section 407.1 or IBC Section 3408.1 states the following:  "No change shall be made in the use or occupancy of any building that would place the building in a different division of the same group of occupancy or in a different group of occupancies, unless *such building is made to comply *with the requirements of [the _International Building Code _(IEBC text)] [this code (IBC Text)] for such division or group of occupancies." (emphasis mine)  Here the code requires the entire building to comply, thus a sprinkler system would be required throughout.

However, if the "Work Area Compliance Method" is used, other requirements may still trigger a fire sprinkler.  Even though there's a change of occupancy classification, there are also floor plan changes and other modifications, which need to comply with the various levels of alteration as I mentioned above (i.e. the reference to IEBC Chapter 9).  Alteration Levels 2 and 3 will require a sprinkler system in all work areas if required by the IBC (IEBC Sections 804.2.2 and 904.1).  Fire barriers separating the change of occupancy areas from other areas may limit the application of sprinkler requirements to the other areas, provided the items I discuss below are not applicable.  If no fire barriers are provided, then the entire building would require a sprinkler system, since the entire building would be considered part of the "work area" per IEBC Section 1012.1.1.

But, even if the business areas that are remaining as business areas are separated from the Group R with fire barriers, if business areas are still being altered, then they are still part of the "work area." Thus, they may be required to be sprinklered if 1) the work area is required to be sprinklered by the IBC for new construction  (in this case it would be), and 2) if the work area exceeds 50% of the floor area--both are necessary to require a sprinkler system in the work area.  Group R under three stories is exempted, but, because it's a change of occupancy and not an existing Group R, a sprinkler system would still be required in the Group R area.

Personally, I think the IEBC is still a little messy with lots of ambiguity that can easily be interpreted in different ways--especially within the requirements for the Work Area Compliance Method.


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## Glennman CBO (Oct 7, 2013)

Suppose you have no change of occupancy consisting of a business occupancy on the main level of a building, but the developer wants to change the second floor to residential units? It would appear that the the IEBC sections that mtlogcabin referenced would require a horizontal separatation consisting of an assembly that would resemble section 510 (Special Provisions) with Type I A construction, 3 hr separation, etc. Otherwise, there is no such thing as a horizontal fire barrier that would adequately separate the upper residentail units from the lower business or merchantile without sprinklering the business level as well. In this case they would need to sprinkler the new residential units and the existing business areas with a 13 system throughout. However, section 508.4.4.1 (2012 IBC) states that horizontal assemblies do provide a complete separate occupancy. Does a horizontal assembly satisfy the separation provision of 1012.1.1.2 IEBC?

1012.1.1.2 Change of occupancy classification with separation.

Where a portion of an existing building that is changed to a new occupancy classification and that portion is separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the International Building Code for the separate occupancy, that portion shall comply with all of the requirements of Chapter 9 for the new occupancy classification and with the requirements of this chapter.


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## RLGA (Oct 7, 2013)

I would think a horizontal assembly would suffice.  A 1-hour horizontal assembly is required anyway to separate dwelling units from other occupancies per IBC Section 420.3 (2012 IBC).

To achieve the horizontal building separation per IBC Section 510.2 (2012 IBC) would likely require extensive modification of the existing first story to achieve the Type IA construction (if not already Type IA).  It might be less expensive to just sprinkler the story than to upgrade the entire story to Type IA.


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## mtlogcabin (Oct 7, 2013)

I don't think separation is required for the 2 story R over a B occupancy under the "Work Compliance Method"

1012.1.1.1 Change of occupancy classification without separation.

Where a portion of an existing building is changed to a new occupancy classification and that portion is not separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the International Building Code for the separate occupancy, the entire building shall comply with all of the requirements of Chapter 9 applied throughout the building for the most restrictive occupancy classification in the building and with the requirements of this chapter.



904.1 Automatic sprinkler systems.

Automatic sprinkler systems shall be provided in all work areas when required by Section 804.2 or this section.

804.2.2 Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2.

In buildings with occupancies in Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where all of the following conditions occur:

1.	The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction; and

2.	The work area exceeds 50 percent of the floor area.

Exceptions:



1.	Work areas in Group R occupancies three stories or less in height.

2.	If the building does not have sufficient municipal water supply for design of a fire sprinkler system available to the floor without installation of a new fire pump, work areas shall be protected by an automatic smoke detection system throughout all occupiable spaces other than sleeping units or individual dwelling units that activates the occupant notification system in accordance with Sections 907.4, 907.5 and 907.6 of the International Building Code.

Glenman's example is only 2 stories so no sprinklers required and no separation? 

What am I missing this does not seem correct?


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## RLGA (Oct 8, 2013)

Section 1012.1.1.1 requires that the entire building comply with the requirements for Level 3 Alterations (this also means compliance with Levels 1 and 2, too).  Per Section 804.2.2, a sprinkler system is required when required by the IBC (this example does) and the work area exceeds 50% of the floor area (the second floor is 50% of the floor area, but Section 1012.1.1.1  requires that the entire building must comply with IEBC Chapter 9, thus the entire building [100%] is part of the work area).

The exception for Group R occupancies in Section 804.2.2 would apply to existing Group R occupancies--the change of occupancy requirements requires that the Group R comply with the IBC, thus a sprinkler system would be required throughout the Group R.  If no work is done on the first story, then a 1-hour horizontal assembly can be provided to separate the Group R from the Group B to comply with Section 1012..1.1.2 for change of occupancy classification with separation.  The 1-hour horizontal separation is required between the Group R and the Group B below, so the separation would be provided anyway and a sprinkler would not be required on the first story.


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