# Group M Furniture Sales



## Glennman CBO (May 12, 2010)

IFC 903.2.7 #4

Does the sprinkler requirement for group M sales and display of upholstered furniture seem a bit restrictive?

I understand how it came to be, but it seems to be a knee jerk reaction only.

I cannot see this remaining as a requirement long, as the commentary seems to allude.

The strict enforcement of this requirement is not going to be very user friendly for those in the furniture business, ma and pa operations, antique stores, second hand, etc etc.

What kind of discussions have you all had on this? Thanks...


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## FM William Burns (May 12, 2010)

Why?

Not according to the empirical data developed by UL and NIST (1983 -2007). 

The issue is; historically systems were designed with .10 to .15 densities for a light hazard occupancy which was discovered and historically known by some of us anyway, that it was not a proper design for the hazard. 

The requirements have now been revised to actually protect the hazard associated with the material and prevent increased loss substantiated by that same empirical data not just a single event.


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## High Desert (May 12, 2010)

It is overly restrictive. There is no threshold on the quantity or the fire area. As the current code section ss written, you could have one piece of upholstered furniture on display for sale and be required to provide sprinklers regardless of the fire area. A small 500 sq. ft. building is now required to be sprinklered if they display and sell one chair.


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## AegisFPE (May 12, 2010)

City of Spokane has submitted a state code amendment to adopt the threshold of 5,000SF from ICC 2009 Final Action Agenda - Proposed Changes to 2009 Editions, being heard in Texas next week.  This proposed Washington State amendment is up for a vote by the Fire Code Technical Advisory Group today.

The new ICC language also adds a 2,500SF threshold for automatic sprinklers in F-1 and S-1 occupancies with upholstered furniture.


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## Gene Boecker (May 12, 2010)

Glenman, you're right.

The requirement for upholstered furniture in M occupancies is a knee "jerk" reaction and needs to be fixed. It makes no sense as it is written. I spoke loudly against this at the code hearings but to no avail. There's no question that the material can be a real hazard in large qualtities such as those found in wharehouses and stockroom areas in furniture stores. But the issue with the requirement is the "M" portion of the store - not the "S" portion. Here's why it's broken:


It sets a threshold of "one" for requiring suppression. This is an unreasoanble number on it's face value. If there is a risk, set the threshold at that level where a risk exists. If it's density, use that. If it's the material, use that. Full scale fire tests by the Underwriters Laboratories show that cotton batting and textiles do not pose the same risk yet those are also "upholstered" by definition. With the greening of America we may see a return to these materials over the pertroleum based materials currently so popular.

The threshold of "one" for sale or display begs the question why there isn't a requirement for every facility to be sprinklered. If "one" is a hazard, then any place which could possibly have upholstered furniture could pose a risk. If there are *three* chairs on display there must be sprinklers provided.  Yet if there is all wooden furnture for sale but *16* upholstered chairs at the sales desks, that's OK. Explain the logic if you can.

The intial proposal used a threshold of percentage of sales area which was better but still required the fire inspector to bring a calculator and tape measure to figure it out - an impractical solution.  The response was anecdotal and not based on any scientific study.  If density is an issue then set the threshold based on tests performed to see where suppression at a lower density fails for a given area and density of upholstry material. Currently the UL is setting up guidlines for testing polyurethane foam material. The full scale tests so far show that the material burns with a fierceness and produces copious quantities of smoke. But when fire retardants are added to the foam the ignition is delayed. How about a requirement for fire retardants as a basis for setting a threshold?

If the problem is that upholstered furniture is overpowering the sprinkler system, the problem isn't in the threshold, it's in the sprinkelr system design. So, it's and NFPA 13 committee issue - not and ICC issue.

The text needs to be changed but we'l have to wait another few years before getting a chance at that.  The solution must be based on science and experience; by practical to apply and enforce; and address the hazard - not percieved hazards.  Following the logoc in the code, every auto showroom should be required to be sprinklered because of the amount of upholstery in the vehicles - and the vehicles equipped with internal suppression systems as well.


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## FM William Burns (May 12, 2010)

So let's Punt?

I have no issues with thresholds, quantities or percentages and that makes sense.  The issue as pointed out by Gene is #4.  The issue is with the design of the protection for the area where these types of materials are displayed and stored. 



*Example:* Your typical strip mall with a tenant space of….. let’s say 1800 to 2800 s.f. with mixed uses throughout the building A, B and M.  The wine shop closes and Bubba’s Wonder Foam Mattress and Furnishings moves in and their storage is their sales floor so it’s viewed as M.  Where is one’s ability to address the improper sprinkler design discovered, in the IFC since (901.4 and 903.6) can’t get you there? 



Meanwhile the existing light hazard system for the building is not designed to protect the new hazard now occupying the tenant space.


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## Gene Boecker (May 12, 2010)

Go straight to 109.1:

_It shall be unlawful for a person, firm or corporation to erect, construct, alter, repair, remove, demolish, or utilize a building, ocucpancy, premisis, or system regulated by this code, or cause same to be done, in conflict with or in violation of any of the provisions of this code._

IMHO, once they "utilize" the "premisis" for a function without the proper sprinkler density, that is in violation of the code.

It's also a "change in occupancy" by definition so there is a requirement to submit for a new permit.


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## Glennman CBO (May 12, 2010)

Good responses. I'll be out of town 'till friday. I'll check in again then.

Thanks...


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## FM William Burns (May 12, 2010)

Gene,



I understand the rationale of using 109.1 but in the appellate world we face and in my historic experience; the definition for *“change of occupancy”* would not apply so well due to the jurisdiction’s interpretation of *“purpose or level of activity within a building”*.  



In the previously listed example used; the determination of the jurisdiction was that the building space was still “M” and could not be re-classified as an “S” as supported by the BO since the items were essentially displayed for sale regardless of quantity on the sales floor.  In another jurisdiction using another code body’s document, the issue may be addressed by changes of hazards of contents and associated protection criteria for the change in content classification.  



I’m not trying to imply the "X" versus "Y" scenario here but I’m really looking for a specific direction in the IFC that would deal with a more hazardous content change then what was found previously in a mercantile occupancy.


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## Gene Boecker (May 13, 2010)

Sorry to hear that the BO didn't handle it right.  What you mention is certainly a change in occupancy.  The defininition is:


_*A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.*_

Since the change from one level of protection to another is included in the concept it does not require a shift from M to S.  Case in point: If an old warehouse that was used for furniture sales is converted into a big box with racks, it's still an M occupancy but is certainly a "change in occupancy" since the "purpose or level of activity" has changed.  Accordingly, since the code requires that the buidling be protected in accordance with NFPA 13 in order to consider the building as sprinklered throughout, the change in occupancy requires a second look at the sprinkler design.  Since the hazard level increased, the sprinkelr design must change to accomodate it.  It's still an M occupancy Group classifictaion but it's definitely a "change in occupancy."  teh same thing can and shoudl be done for upholstered furniture - including mattresses.
​


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## FM William Burns (May 13, 2010)

I would agree "should" is the key here.  I made those same or very similar arguments in defense with no avail since there was not a direct link to the hazard classification versus the items being displayed for sale.

Anyway to not beat up on this, I agree with the issue being a 13 one and newer protection criteria as you mentioned is being developed to provide acceptable protection schemes.  Oh well I'm 1 for 1 on the related matter.  500% is not that bad and I'de be earning millions if I could do it for the Cardinals  

Shall we get into manfacturers oversight with compliance with whatever CFR of 2007  what a crock ..... you may watch yourself.


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## Gene Boecker (May 13, 2010)

Given the last 10 games the Cards have played, they'll gladly take you.


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## AegisFPE (May 13, 2010)

With regard to "catching" the presence of a new hazard, I think it will be a similar challenge to any S-1 warehouse that changes commodities.  It's still an S-1, but the storage arrangement and/or sprinkler requirements may differ, even though there is not a change of use or alteration to the building.  Perhaps a high-piled storage permit (IFC 105.6.22) helps with tracking just such a scenario.  Perhaps a Upholstered Furniture permit could be made part of your local process.

Another note is that the 2012 Edition addresses "furniture or mattresses" while the 2009 Edition only references "furniture."  Apparently the CFR does not define mattresses as furniture, so the 2012 closes this apparent loophole!


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## FM William Burns (May 13, 2010)

S-1

AFPE,



You’re right there regarding the S-1.  



Found a GP Warehouse that was a lumber facility and now an Automotive Distribution Center.  They couldn’t understand why we required a renovation of the sprinkler system since the commodity went from lumber to L2, L3 and flammable liquids above and under the Mezzanine and IIIB on racks.  Thankfully we won this one with no assistance from our partners in the building department who didn’t want to get involved (political) and we will be witnessing the FP acceptance test and inspection of addendum #6 for the rack scheme soon.


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## brudgers (May 13, 2010)

Sounds like there should be different occupancy groups within M based on the hazard.

Then a kludge wouldn't be required.

Too bad there's no such thing as a code written around occupancy.


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## Insurance Engineer (May 15, 2010)

FM William Burns said:
			
		

> AFPE,
> 
> You’re right there regarding the S-1.
> 
> ...


Commodity change is something we see everyday, and is the number 1 recommendation we have when we visit a warehouse. I assume the sprinkler system is not going to do the job when I visit a warehouse, most times that turns out to be true. As per NFPA 13 just 10 pallets loads of a higher commodity in a 40K warehouse can change the overall commodity classification of the warehouse. That is not a lot of stuff when you think of how much can be in a 40K with 40' storage! Look and you shall find.


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