# Fire Sprinklers at  covered canopy with temporary enclosure?



## Truck3capt (Nov 18, 2019)

We have a fairly new strip center with an Assembly Occupancy (bar/restaurant) in the last tenant space.  The entire strip center was fully sprinklered when constructed in anticipation of tenant spaces that would require them based on their occupancy and I also .  Shortly after the bar in question opened they applied for a permit to put a fabric covered canopy over a metal frame to cover an outdoor seating area.  The outdoor seating area was open on 3 sides  and was accessed by an additional non-required  exit from the bar.  At the time of that application we did not require them to extend the fire sprinkler coverage to the  covered area because the building roof did not project over the seating area (just the applied non-combustible canopy framing and fabric ), the exit to the seating area from the bar was not a required exit (they already had two additional for the calc. occ load of 68), and the seating area was open on three sides allowing for sufficient exiting.  

Flash forward to November and now they want to enclose the seating area with a tent structure and put portable heaters under it.  My thought process is that it meets the definition of a fire area once it's completely enclosed and will need to have the sprinkler coverage extended to protect the newly enclosed seating area. Am I all wet ? referencing 2012 ICC  Thanks


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## classicT (Nov 18, 2019)

Sounds to me as if it is a temporary structure.

*Section 108 Temporary Structures and Uses*
*108.1 General*
The _building official _is authorized to issue a _permit_ for temporary structures and temporary uses. Such _permits_ shall be limited as to time of service, but shall not be permitted for more than 180 days. The _building official _is authorized to grant extensions for demonstrated cause.

*108.2 Conformance*
Temporary structures and uses shall conform to the structural strength, fire safety, _means of egress_, accessibility, light, ventilation and sanitary requirements of this code as necessary to ensure public health, safety and general welfare.​
That said, as noted under _IBC 108.1_, it must still comply with certain provisions of the code. Get decent egress (2 exits) and keep ignition sources away from the tent structure.


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## cda (Nov 18, 2019)

It should have been done when added

Under NFPA 13 canopy over 4 feet, with stuff under it.

And since it will get cold next year and they want to wrap it again 

The sprinklers will be there

one or two or sidewalls should do, less piping


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## TheCommish (Nov 18, 2019)

sprinkler, especially with  heating appliance under the cover


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## steveray (Nov 19, 2019)

I'm with cda...This is what happens when you allow something you shouldn't and then try to backpedal.....Fire area has nothing to do with walls and then you have the whole NFPA 13 piece to deal with on "overhangs" or however they write it....

FIRE AREA. The aggregate floor area enclosed and
bounded by fire walls, fire barriers, exterior walls or horizontal
assemblies of a building. Areas of the building not provided
with surrounding walls shall be included in the fire area
if such areas are included within the horizontal projection of
the roof or floor next above.


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## Truck3capt (Nov 19, 2019)

steveray said:


> I'm with cda...This is what happens when you allow something you shouldn't and then try to backpedal.....Fire area has nothing to do with walls and then you have the whole NFPA 13 piece to deal with on "overhangs" or however they write it....
> 
> FIRE AREA. The aggregate floor area enclosed and
> bounded by fire walls, fire barriers, exterior walls or horizontal
> ...



Believe me we had this discussion at length when this went in originally because we were having the request at several locations.  The  "Areas of the building not provided
with surrounding walls shall be included in the fire area if such areas are included within the horizontal projection of *the roof **or floor next above*" language was batted back and forth between our office and the building department.  I realize the commentary isn't enforceable but the fire area definition was the debate that came up based on the definitions and the commentary.  The commentary shows a gable roof on a building that extends past the exterior wall over a patio area.  It also shows a floor above cantilevering over an area below.  The designer contended that the intent of the language meant that the actual building roof or floor structure needed to extend over the area in question to be included in the fire area unless  it was enclosed with walls. 

Then you also have the code language and definition of a canopy as well as the commentary on how it is to be constructed. I'm not trying to back pedal anything but I'm also not inclined to require something just because if they can show me some language or reasoning for why they don't think it's required.  That said, I suspected that this very thing would happen once it got cold and they would want to enclose it. I tried to get them to just punch a couple dry heads through the wall when they originally proposed the canopy.  The designer balked due to a fairly elaborate gyp ceiling detail that they didn't want to open up in order to add the heads and the whole fire area discussion above.  I was ultimately over ruled based on that discussion.

I also have issue that the sprinklers, while provided in the structure, are a non-required system. So while NFPA 13 requires the over hangs over 4 feet be protected I have to have building or fire code language to require the system in the first place before I can apply the NFPA standard for installation, correct?  I'm inclined to require the heads and move on but I wondered if anyone had ever had this discussion concerning the fire area and canopy definitions.  Thanks for all the input.


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## mtlogcabin (Nov 19, 2019)

What is the occupant load of the outdoor seating area?


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## cda (Nov 19, 2019)

Truck3capt said:


> Believe me we had this discussion at length when this went in originally because we were having the request at several locations.  The  "Areas of the building not provided
> with surrounding walls shall be included in the fire area if such areas are included within the horizontal projection of *the roof **or floor next above*" language was batted back and forth between our office and the building department.  I realize the commentary isn't enforceable but the fire area definition was the debate that came up based on the definitions and the commentary.  The commentary shows a gable roof on a building that extends past the exterior wall over a patio area.  It also shows a floor above cantilevering over an area below.  The designer contended that the intent of the language meant that the actual building roof or floor structure needed to extend over the area in question to be included in the fire area unless  it was enclosed with walls.
> 
> Then you also have the code language and definition of a canopy as well as the commentary on how it is to be constructed. I'm not trying to back pedal anything but I'm also not inclined to require something just because if they can show me some language or reasoning for why they don't think it's required.  That said, I suspected that this very thing would happen once it got cold and they would want to enclose it. I tried to get them to just punch a couple dry heads through the wall when they originally proposed the canopy.  The designer balked due to a fairly elaborate gyp ceiling detail that they didn't want to open up in order to add the heads and the whole fire area discussion above.  I was ultimately over ruled based on that discussion.
> ...





Nooooooo

My opinion and argument is

Once you invoke NFPA 13 you SHALL follow it.

So if a canopy under NFPA 13 is required protection you shall do it.


Otherwise if the argument is a sprinkler system is not required, than they can do what they want

Ok sprinkler, one twenty feet away, another four feet from that one, nah I don’t need to install all those sprinklers,,,

just a few??

HUH?


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## mtlogcabin (Nov 19, 2019)

Tent no way, membrane structure if they follow the regs. 

SECTION 3102
MEMBRANE STRUCTURES
3102.1 General.
The provisions of Sections 3102.1 through 3102.8 shall apply to air-supported, air-inflated, membrane-covered cable and membrane-covered frame structures, collectively known as membrane structures, erected for a period of 180 days or longer. Those erected for a shorter period of time shall comply with the International Fire Code. Membrane structures covering water storage facilities, water clarifiers, water treatment plants, sewage treatment plants, greenhouses and similar facilities not used for human occupancy are required to meet only the requirements of Sections 3102.3.1 and 3102.7. Membrane structures erected on a building, balcony, deck or other structure for any period of time shall comply with this section.

3102.6 Mixed construction.
Membrane structures shall be permitted to be utilized as specified in this section as a portion of buildings of other types of construction. Height and area limits shall be as specified for the type of construction and occupancy of the building.
3102.6.1 Noncombustible membrane.
A noncombustible membrane shall be permitted for use as the roof or as a skylight of any building or atrium of a building of any type of construction provided it* is not less than 20 feet (6096 mm) above any floor, balcony or gallery.*
3102.6.1.1 Membrane.
*A membrane meeting the fire propagation performance criteria of NFPA 701* shall be permitted to be used as the roof or as a skylight on buildings of Types IIB, III, IV and V construction, *provided it is not less than 20 feet (6096 mm) above any floor, balcony or gallery.*


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## steveray (Nov 19, 2019)

Mixed use separated or not? You say "strip center", what is the OL and did it bump up with the patio?


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## Truck3capt (Nov 19, 2019)

mtlogcabin said:


> What is the occupant load of the outdoor seating area?


36. Which is another discussion that came out of these outdoor  seating areas and the whole fire area discussion. If the outside occ load has it's own independent exiting (when installed it was open on three sides) and none of that occ load has to exit back through the bar/restaurant (it's occ load is 68) then is it added to the occ load of the bar if they have enough exits without having to exit through the bar?


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## cda (Nov 19, 2019)

Normally the stricter of codes or standards applies.


Once a building has a fire sprinkler system installed, unless there is an exception in the IBC or IFC,,,,, NFPA 13 wins.

So canopy/ patio cover, what ever over four feet shall have fire sprinkler protection. 


Not an uncommon requirement, for the outdoor covered, attached patios, enclosures, whatever it is called.


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## Truck3capt (Nov 19, 2019)

steveray said:


> Mixed use separated or not? You say "strip center", what is the OL and did it bump up with the patio?


Separated but I did a little more research on the original shell permit and it looks like they were bumping up against the area limitations for Type 5B construction and provided the sprinklers in the whole building to get  an area modification so I believe it is actually a required system. 

The occ load of canopy area was 36 and open on three sides.


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## Truck3capt (Nov 19, 2019)

cda said:


> Nooooooo
> 
> My opinion and argument is
> 
> ...



Cda , looks like a moot point.  After further research, I think the sprinklers were required due to an area modification for a type 5 construction type.  We're kinda headed down a different rabbit hole with the required vs. non-required systems but it's kinda related and it comes up frequently.
_901.4.2 Nonrequired fire protection systems. Any fire
protection system or portion thereof not required by this
code or the International Building Code shall be allowed to
be furnished for* partial or complete protection* provided
such installed system meets the applicable requirements of
this code and the International Building Code._

Full agreement that if you provide a non-required system in a space that the system design density , spacing, required water supply etc will be in accordance with NFPA 13 or the appropriate standard.  The discussion that came up recently came up due to the partial or complete  protection language above and the associated  commentary *"the extent of the protection would not be regulated" .  *Again it's from the commentary but what do we think that means?  My example is a restaurant/bar that was sprinklered and is now a being remodeled into a bank (B use) and they want to add a covered drive through.  The bank would like to keep the sprinkler system but  prefer not to extend coverage to the drive canopy or build it from non-combustible material.  Given the level of demolition they are also considering removing the existing system entirely if we require them to extend the protection to the canopy.  I'm always going to be a proponent of fire sprinklers but I also don't want to encourage an owner to remove a perfectly operational system from the rest of the building if that's not what the intent of the non-required system language.  Sorry long winded and it's probably a discussion for another thread but kinda related.* *


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## steveray (Nov 19, 2019)

[F] 903.2.1.2 Group A-2. An automatic sprinkler system
shall be provided for fire areas containing Group
A-2 occupancies and intervening floors of the building
where one of the following conditions exists:
1. The fire area exceeds 5,000 square feet (464.5
m2).
2. The fire area has an occupant load of 100 or
more.
3. The fire area is located on a floor other than a
level of exit discharge serving such occupancies.

Indoors....outdoors....all the same fire area unless separated by fire barriers....


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## cda (Nov 19, 2019)

So does it look similar to this:::

Yes they have drop curtains for cold wet days::











Yes sprinklers are there


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## cda (Nov 19, 2019)

What is the total occupant load of the restaurant/bar??


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## Truck3capt (Nov 19, 2019)

cda said:


> So does it look similar to this:::
> 
> Yes they have drop curtains for cold wet days::
> 
> ...


The canopy structure is similar, aluminum frame and a fabric that met 701.  No sides at all currently, essentially shade and rain protection.  They called the mechanical inspector about what type of heater they can use to heat the space when they enclose the side with a membrane from a local tent manufacturer. He referred them to our office for direction.


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## Truck3capt (Nov 19, 2019)

cda said:


> What is the total occupant load of the restaurant/bar??


68 at the bar.  36 in the patio area.


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## cda (Nov 19, 2019)

Over 100???


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## cda (Nov 19, 2019)




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## Truck3capt (Nov 19, 2019)

steveray said:


> [F] 903.2.1.2 Group A-2. An automatic sprinkler system
> shall be provided for fire areas containing Group
> A-2 occupancies and intervening floors of the building
> where one of the following conditions exists:
> ...



In this case the cumulative occ load exceeding 100 of the _fire area_ drives the sprinkler (outside of the area modification I think they took) requirement and I understand that completely.  The challenge we had posed to us was based on the definition of fire area in the 2012 IBC. 

_FIRE AREA. The aggregate floor area enclosed and
bounded by fire walls, fire barriers, exterior walls or horizontal
assemblies of a building. *Areas of the building not provided
with surrounding walls shall be included in the fire area
if such areas are included within the horizontal projection of
the roof or floor next above.*_

This definition and the associated commentary was the basis of their disagreement.  They didn't agree that the covered area was part of the fire area for the building because based on this definition, the canopy wasn't a horizontal projection of the building roof or floor above and also didn't meet the definition of  a horizontal assembly, therefore it wasn't to be included in the fire area for the bar which kept the occ load under the 100 # that kicks in the sprinkler requirement.  Maybe it should have been more of a discussion of what the definition of a fire area is?  Maybe the definition in the IBC could be better?  

If they intend to enclose the thing with walls then it absolutely meets the definition of a a fire area and requires the sprinkler extension.  whew...sorry.  I'm not trying to be difficult but maybe I should have asked the question differently.
This


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## Truck3capt (Nov 19, 2019)

cda said:


> View attachment 6138


cda, 
I've read the commentary and I'm not trying to be difficult with you but what do you think they mean by "The extent of the protection provided would not be regulated."  The example earlier  in that paragraph mentions "certain areas".  It sounds like they are acknowledging that a building owner could provide a non-required system in any space of a structure and it's acceptable as long as the installation of that system, ie. spacing, piping, inspection, monitoring, materials, testing, maint, water supply . etc would need to meet the requirements of NFPA 13 or 13R.  Is it just bad language in the commentary?


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## classicT (Nov 19, 2019)

Truck3capt said:


> In this case the cumulative occ load exceeding 100 of the _fire area_ drives the sprinkler (outside of the area modification I think they took) requirement and I understand that completely.  The challenge we had posed to us was based on the definition of fire area in the 2012 IBC.
> 
> _FIRE AREA. The aggregate floor area enclosed and
> bounded by fire walls, fire barriers, exterior walls or horizontal
> ...


Well, if they do not want to treat it as a portion of the existing building, then remind them of what is required for fire separation distance between buildings/structures. Imaginary lot line between the existing building and the tent structure; fire separation distance and rated exterior walls will kill it.


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## cda (Nov 19, 2019)

Truck3capt said:


> cda,
> I've read the commentary and I'm not trying to be difficult with you but what do you think they mean by "The extent of the protection provided would not be regulated."  The example earlier  in that paragraph mentions "certain areas".  It sounds like they are acknowledging that a building owner could provide a non-required system in any space of a structure and it's acceptable as long as the installation of that system, ie. spacing, piping, inspection, monitoring, materials, testing, maint, water supply . etc would need to meet the requirements of NFPA 13 or 13R.  Is it just bad language in the commentary?




Have no clue

But in the beginning to me it says if installed shall meet 13

plus the base language supports it.


And that section is not exclusive to fire sprinkler systems


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## mtlogcabin (Nov 19, 2019)

I agree with them a structurally independent membrane structure is a separate fire area because it it not a projection of the horizontal roof of the building
Should it be sprinkled or not I am undecided


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## classicT (Nov 19, 2019)

mtlogcabin said:


> I agree with them a structurally independent membrane structure is a separate fire area because it it not a projection of the horizontal roof of the building
> Should it be sprinkled or not I am undecided


If it is a separate fire area, is it a separate structure? If a separate structure, how does it comply with fire separation distances?


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## cda (Nov 19, 2019)

Truck3capt said:


> The canopy structure is similar, aluminum frame and a fabric that met 701.  No sides at all currently, essentially shade and rain protection.  They called the mechanical inspector about what type of heater they can use to heat the space when they enclose the side with a membrane from a local tent manufacturer. He referred them to our office for direction.





OK FOR CLARIFICATION

Is this whatever attached to the building???? 

Like in the pictures I posted 

Or is it stand alone say at least one foot away from the building????


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## Truck3capt (Nov 19, 2019)

cda said:


> OK FOR CLARIFICATION
> 
> Is this whatever attached to the building????
> 
> ...


It's attached on one side to the end of the building.


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## jar546 (Nov 19, 2019)

OK, if you want to let them know you are serious, have the plumbing inspector request a new plumbing fixture count based on the new occupant load.  This must be done regardless and may require them to add fixtures which may nix your problem.  Just another thought outside the fire code.


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## cda (Nov 19, 2019)

Truck3capt said:


> It's attached on one side to the end of the building.




Ok than stick with my statements

IBC /IFC have NO exceptions to omitting sprinklers for this area.

NFPA 13 does require sprinkler protection for overhangs over four feet.


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## Truck3capt (Nov 19, 2019)

cda said:


> Ok than stick with my statements
> 
> IBC /IFC have NO exceptions to omitting sprinklers for this area.
> 
> NFPA 13 does require sprinkler protection for overhangs over four feet.



Thanks for your patience cda and everyone else's.


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## tmurray (Nov 20, 2019)

jar546 said:


> OK, if you want to let them know you are serious, have the plumbing inspector request a new plumbing fixture count based on the new occupant load.  This must be done regardless and may require them to add fixtures which may nix your problem.  Just another thought outside the fire code.


We do this with any of the seasonal patios here.


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## mtlogcabin (Nov 20, 2019)

Ty J. said:


> If it is a separate fire area, is it a separate structure?


No you can have multiple fire areas with a single building. Fire areas can be used in lieu of fire suppression requirements.


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## classicT (Nov 20, 2019)

mtlogcabin said:


> No you can have multiple fire areas with a single building. Fire areas can be used in lieu of fire suppression requirements.


Sure, if separated by a fire barrier. Are they separated by a fire barrier?

Per T707.3.10, it would be required to be of 2-hr fire-resistance.

*707.3.10 Fire Areas*
The _fire barriers _or _horizontal assemblies_, or both, separating a single occupancy into different _fire areas _shall have a _fire-resistance rating _of not less than that indicated in Table 707.3.10. 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 Table 707.3.10 for the occupancies under consideration.

​


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## VillageInspector (Nov 20, 2019)

Truck3capt said:


> 68 at the bar.  36 in the patio area.



This is a bit off topic but how does your sanitary facilities count work out with the increase in the patio area ?


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## my250r11 (Nov 20, 2019)

FWIW, the tent area can not function with out the the brick and mortar A2. Tell them no sprinklers they can not serve customers or occupy the area without proper separation.


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## Truck3capt (Nov 20, 2019)

VillageInspector said:


> This is a bit off topic but how does your sanitary facilities count work out with the increase in the patio area ?


 I'll have to check. It's not typically my discipline.  I think the building department plumbing inspector reviewed it when they added the canopy.  I know the fixture count has come up before on similar projects.


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## steveray (Nov 21, 2019)

The "use" of the roof makes it a roof to me...If you are "occupying" it and it is intended to make an area "occupiable"...It's part of the building. If it is to get you out of the rain as you enter the building, then not so much....Might want to check height and area for this "addition" as well...A pavillion has a fire area, a stadium has a fire area....one might have walls, one might have a roof...

[A] BUILDING. Any structure used or intended for supporting or sheltering any use or occupancy.


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## Builder Bob (Nov 23, 2019)

Be sure to Look at the Fire Codes -


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