# Retractable Canopy Create A Fire Area?



## Francis Vineyard (Mar 7, 2012)

The definition of Fire Area is reworded in 2009 to include roof that is not fire-resistances rated; how would you interpret the requirement for sprinklers or another story above if an awning or retractable canopy was installed on the roof deck?

http://www.litrausa.com/patiocoverscanopies-21.html

*[F] 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.

Thanks as always for all opinions

Francis


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## RLGA (Mar 7, 2012)

An awning is not a horizontal projection of the roof.


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## Papio Bldg Dept (Mar 7, 2012)

I have yet to find anything in the code that would suggest awnings, canopies or marquees are to be considered as part of the fire area.  I use Chapter 31 of the 2006 IBC.


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## texasbo (Mar 7, 2012)

Not to hijack, but just to be a little more specific for anyone who might want to give an opinion: Let's say you have a fully sprinklered A2, Type IIB, 7000 sq ft, with an attached canopy over a 1000 sq ft non-sprinklered dining area. Let's also say that one of the required exits from the building exits into this covered space.

Would your answers be different?


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## Papio Bldg Dept (Mar 7, 2012)

No. They still have to meet the NFPA 701 performance criteria, ASTM E 84 for flame spread, and be of non-combustible material.  They are structures defined in Chapter 31 to provide a weather barrier for an exterior space.  Other types of membrane structures are considered differently.  Those that are erected for periods of more than 180 days are handled by the IFC (in my case NFPA 101).


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## RLGA (Mar 7, 2012)

texasbo said:
			
		

> Not to hijack, but just to be a little more specific for anyone who might want to give an opinion: Let's say you have a fully sprinklered A2, Type IIB, 7000 sq ft, with an attached canopy over a 1000 sq ft non-sprinklered dining area. Let's also say that one of the required exits from the building exits into this covered space.Would your answers be different?


No, as it applies to fire area and sprinkler protection; however, I would question the location of the exit discharge:

- does it minimize accumulation of smoke and toxic gases?

- does it provide a direct and unobstructed access to the public way?


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## gbhammer (Mar 7, 2012)

texasbo said:
			
		

> Not to hijack, but just to be a little more specific for anyone who might want to give an opinion: Let's say you have a fully sprinklered A2, Type IIB, 7000 sq ft, with an attached canopy over a 1000 sq ft non-sprinklered dining area. Let's also say that one of the required exits from the building exits into this covered space.Would your answers be different?


That door may not count as a horizontal exit, I would also take another look at their fixture count but still apply chapter 31.


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## Francis Vineyard (Mar 7, 2012)

I should be better at phrasing my questions, I'm basing my definition of canopies as a roof with this interpretation shown below. If a retractable type canopy see the link in my OP; is installed on a roof deck would this create a new fire area and another story on top of an existing occupiable roof deck?

Francis


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## Papio Bldg Dept (Mar 7, 2012)

Francis, are you focusing on the section that states, "if such areas are included within the horizontal projection of _the roof or floor next above_?


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## Francis Vineyard (Mar 7, 2012)

Papio Bldg Dept said:
			
		

> Francis, are you focusing on the section that states, "if such areas are included within the horizontal projection of _the roof or floor next above_?


Yes!!!!!!! I've been given it thought how this changes things adding to an existing building when before it only counted if it was a rated horizontal projection.


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## Papio Bldg Dept (Mar 7, 2012)

Sounds like a definition issue.  Sorry I couldn't be of more help.

*1502.1 Roof Assembly.*  A system designed to provide weather protection and resistance to design loads.  The system consists of a roof covering and roof deck or a single component serving as both the roof covering and the roof deck.  A roof assembly includes the roof deck, vapor retarder, substrate or thermal barrier, insulation, vapor retarder and roof covering.

*3105.3 Retractable Awning. * A retractable awning is a cover with a frame that retracts against a building or other structure to which it is entirely supported.


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## gbhammer (Mar 7, 2012)

The over hang of a roof does not count towards building area unless there is an occupied space above the over hang (as in a cantilevered floor space that creates an overhang), neither does the area of an awning because it is not occupied above nor even defined as a part of the roof of the building.


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## texasbo (Mar 7, 2012)

The narrative in the Change Significance posted by Francis actually addresses the question I posted in the thread, and it in fact references canopies. I think this could lead to some significantly different interpretations of these types of outdoor areas than we have seen in the past.

Note that the code says nothing about occupied space above the overhang.

Note also, that Ch 31 requires awnings and canopies to be designed for wind and live loads per Ch 16, and Ch 16 lists awnings and canopy design loads under the category of "Roofs'.


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## Francis Vineyard (Mar 7, 2012)

Attached link is the comments during the code change proposal; see the second page; FS7-06/07 702.1 (IFC 902.1) and IFC interpretation Number 25-05

Does the Fire Area in question leaves the discretion to the designer and AHJ?;

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.

As a refresher Codegeek had a question on this new definition too*: *Sprinklers required?

PcInspector1 had asked; “Does a patio area need to be part of the occupant load calc?” then Fire Area



I don't think this was the intent of the new definition if you didn't have to exit through the building and agree with the dessentors opinion it is too broad otherwise open garages would become an issue if it wasn't already codified.

About retractable canopies should they remain permanently extended above an occupiable roof; is it another story or would you still agree Chapter 31 similarly to tents on the roofs; not a fire area?

Texabo good points!

Francis


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## Papio Bldg Dept (Mar 8, 2012)

texasbo said:
			
		

> I think this could lead to some significantly different interpretations of these types of outdoor areas than we have seen in the past.Note that the code says nothing about occupied space above the overhang.
> 
> Note also, that Ch 31 requires awnings and canopies to be designed for wind and live loads per Ch 16, and Ch 16 lists awnings and canopy design loads under the category of "Roofs'.


I couldn't agree more, and I am not sure ICC made the issue any clearer, even with their commentary.  It seems like they could have provided a definition of roof that would define a fire area.  I don't see the revision changing anybody's minds, especially when ICC courses were being taught as late as last year using gbhammer's interpretation.  Interesting.  Thanks.


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## Papio Bldg Dept (Mar 8, 2012)

Interesting topic Francis, thanks.  I found George Mann's especially interesting, and given the committee disapproved the proposed change, it was still approved as submitted.  Me thinks I need to watch more of the testimony next time.

Public Comment 2:

George Mann, representing the Code Administrators Association of Kentucky, requests Disapproval.

_I ask, how does the interpretations committee arrive at the conclusion that the building area is to be used to determine the fire area if the building has no exterior walls. The definition of fire area specifically states that a fire area has to be enclosed and bounded by exterior walls. This is where I believe the interpretation is flawed and in error. The interpretation makes statements of fact that do not exist. No where in the definition of fire area does it speak to using the building area or definition of building area to determine sprinkler requirements. The definition of building area and fire area are not interchangeable. If they were meant to be then Chapter 9 would base sprinkler systems on building area bounded by fire barriers or fire walls. No where in Section 903 does it read that a sprinkler system shall be provided when the building area exceeds a specified threshold. Again, we are supposed to determine fire area based on the area of the building enclosed and bounded by exterior walls, fire wall, fire barriers or fire-resistance-rated horizontal assemblies. Therefore, if we are looking at a building without exterior walls (column and roof only) we have no fire area and never have. This proposed change is attempting to merge 2 totally different definitions into one definition._

_Second flaw with this proposed code change is in the application of the definition if approved. It reads that “areas 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 above”. I read this as meaning that the area under the store front canopy, a roofed over area across the front of a retail establishment and the canopy over a loading / unloading dock would all have to be added to the area calculated within the exterior walls in order to determine sprinkler requirements. Even worse, I would include the area under the eave of the roof for it is a horizontal projection of the roof. Why would any of this be necessary?_

_Third flaw is implying that it is not clear from the definition of a fire area that building areas without surrounding walls are included in the fire area. The printed definition of fire area specifically reads “enclosed and bounded by fire walls, fire barriers, exterior walls”. I apologize but this would seem to be clear in the intent and application. What has confused the issue is the flawed interpretation that was produced last year._

_Finally, the proponent proclaims that there is no increase to the cost of construction. Sprinkler system design, installation, maintenance and monitoring is not free. If this proposed change is approved, many community picnic shelters, theme park picnic shelters, open air flea markets which line every highway across the country, lumber storage shelters, open air concert venues with roofed over spectator seating (such as River Bend in Cincinnati) would be subject to sprinkler requirements that in the past would not been a_

_consideration. Under this proposed code change, there is no threshold that would grant an exemption from sprinklers for these types of roofed over structures; such as if the roof over the spectator seating were 40 feet above the floor level or if the flea market vendors &_

_tables were arranged such that the general public could not actually step under the roof only shelter._


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## texasbo (Mar 8, 2012)

Papio Bldg Dept said:
			
		

> I couldn't agree more, and I am not sure ICC made the issue any clearer, even with their commentary.  It seems like they could have provided a definition of roof that would define a fire area.  I don't see the revision changing anybody's minds, especially when ICC courses were being taught as late as last year using gbhammer's interpretation.  Interesting.  Thanks.


It gets worse. Although the definition of Fire Area removed the words "fire resistance rated" from horizontal assembly, the definition of Horizontal Assembly in Chapter 7 STILL CONTAINS the words "fire resistance rated"...

Here's the problem: I agree with RLGA and your posts when talking about the typical little fabric covered, metal framed awnings or canopies. However, what about the guy that builds the 1000 square foot metal "canopy", with shoulder to shoulder dining next to the 7000 square foot restaurant? Is it just a canopy? Why or why not?

Chapter 31 should give us some additional criteria to allow awnings/canopies if the intent is to not apply "building", "Fire Area" or "roof" requirements to them.

Lastly, in looking at definitions in Ch 15, "Roof Assembly" says that the definition only applies in the context of Ch 15, leading you to believe that it therefore DOES NOT apply to awnings/canopies in Ch 34 (as RLGA, you, I and others have stated). Great, no problem, except we're left with the same dilemma as described above; some guy builds a massive "canopy" over an A occupancy, and claims he is exempt from being part of a Fire Area.


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## Papio Bldg Dept (Mar 8, 2012)

Yeah, Chapter 31 doesn't really address anymore than the construction requirements, when it, or another Chapter could easily clarify the position.  Francis's thread reminds of the retractable dome in Seattle, and it has a retractable wall as well.  Do we consider the playing field a portion of the fire area as well (not my area of expertise)?  The comments for the code change proposal discuss big box stores with outdoor storage under canopies or roof structures without walls as having large fire loads and often MOEs that go back into the building.  I certainly don't have the answer.  Would be interested to hear what RLGA's thoughts are.

Canopies on a roof might take us back to the occupied roof as a story thread, but still interesting.


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## gbhammer (Mar 8, 2012)

Papio Bldg Dept said:
			
		

> Canopies on a roof might take us back to the occupied roof as a story thread, but still interesting.


Please no more roof stories


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## Papio Bldg Dept (Mar 8, 2012)

gbhammer said:
			
		

> Please no more roof stories


yeah, that was a rough one.  didn't we all agree to disagree...again?


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## steveray (Mar 8, 2012)

Great discussion!...I was thinking along the same lines as PBD last post...is the area in a stadium not counted under the "roof" canopy...unfortunately I believe the whole thing is open to a bunch of interpretation (for better or worse).....when we were discuusing the roof thread, my concept was a 1000 occupant A use roof area on an unspinklered building, in theory it could happen, not likely, but the idea just rubs me terribly wrong...


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## gbhammer (Mar 8, 2012)

Papio Bldg Dept said:
			
		

> yeah, that was a rough one.  didn't we all agree to disagree...again?


That thread gave you memory loss too? We agreed on nota


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## texasbo (Mar 8, 2012)

Yes, strangely, I recall it as a contentious thread.


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## texasbo (Mar 8, 2012)

The problem is that it needs some resolution. In some parts of the country, it's probably not a big deal. But with the mild climate around here, half the restaurants, and many of the retail have huge "roofed" outdoor areas. It is difficult to get your hands around from a building code perspective, and when the FD gets involved, well, you can guess...


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## Papio Bldg Dept (Mar 8, 2012)

texasbo said:
			
		

> The problem is that it needs some resolution. In some parts of the country, it's probably not a big deal. But with the mild climate around here, half the restaurants, and many of the retail have huge "roofed" outdoor areas. It is difficult to get your hands around from a building code perspective, and when the FD gets involved, well, you can guess...


I guess I would be less concerned with the restaurants as long as MOE is addressed (i.e. emergency lighting, signage, clear widths of aisles/accessways, travel distances, etc.) and does not go back through the building.  Chapter 31 requires the construction to provide fire-resistance and I am not sure what additional benefit considering an exterior canopied dining space as a fire area would provide.  I look forward to hearing from RLGA, mark handler, brudgers and other RDPs on this topic as well (hopefully we don't fall into the sprinklered tents discussion again).

Fenced in Mercantile and Storage occupancies might require additional considerations.  Could Gas Station Canopies be considered as part of the fire area as well?


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## gbhammer (Mar 8, 2012)

Not much chance or under many circumstances that a sprinkler head will be affective under an outdoor canopy or awning.


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## RLGA (Mar 8, 2012)

First, read the definitions of _awning _and _canopy _carefully.  Roofs over stadiums do not come close to being considered either of those two; so there should be no confusion.

As for outdoor eating areas or any other areas (except storage), canopies and awings do not present the same risk that a building roof or floor structure presents. _ Fire area _includes the horizontal projection of the roof or floor above.  For floors, a fire underneath the projection presents a hazard to the occupants on the floor above.  For projecting roofs, the structural system is probably tied back to a point in the building, provides structural support for portions of the roof that are over enclosed areas of the building, or provides a path for fire and smoke to travel from outside to inside.  Thus, a fire on the outside underneath the projecting roof creates a hazard for occupants inside.

Canopies and awnings have none of those hazards, beyond the immediate hazard to occupants directly under the canopy or awning.  Therefore, I do not consider them part of the fire area.

However, if attached to the building, NFPA 13 (2010 edition) requires that canopies and similar projections be sprinklered if they exceed 4 ft.  (Section 8.15.7).  There are exceptions, such as being constructed of noncombustible materials, limited-combustible materials (a NFPA-specific term), or fire-retardant-treated wood.  Sprinklers are required in canopies and other projections that are greater than 2 ft. and are over stored materials--no exceptions are given.


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## texasbo (Mar 9, 2012)

RLGA said:
			
		

> First, read the definitions of _awning _and _canopy _carefully.  Roofs over stadiums do not come close to being considered either of those two; so there should be no confusion.As for outdoor eating areas or any other areas (except storage), canopies and awings do not present the same risk that a building roof or floor structure presents. _ Fire area _includes the horizontal projection of the roof or floor above.  For floors, a fire underneath the projection presents a hazard to the occupants on the floor above.  For projecting roofs, the structural system is probably tied back to a point in the building, provides structural support for portions of the roof that are over enclosed areas of the building, or provides a path for fire and smoke to travel from outside to inside.  Thus, a fire on the outside underneath the projecting roof creates a hazard for occupants inside.
> 
> Canopies and awnings have none of those hazards, beyond the immediate hazard to occupants directly under the canopy or awning.  Therefore, I do not consider them part of the fire area.
> 
> However, if attached to the building, NFPA 13 (2010 edition) requires that canopies and similar projections be sprinklered if they exceed 4 ft.  (Section 8.15.7).  There are exceptions, such as being constructed of noncombustible materials, limited-combustible materials (a NFPA-specific term), or fire-retardant-treated wood.  Sprinklers are required in canopies and other projections that are greater than 2 ft. and are over stored materials--no exceptions are given.


I agree with all of the above. However, when is the structure under consideration a canopy, and when is it a roof? I think it's easy to distinguish when we're talking about a fire retardant fabric over a frame. However, when the covered area is constructed out of steel channels with a metal deck, is it fair to call that a canopy, just because it isn't constructed exactly the same as the roof of the rest of the building? We have seen the code change, and the reason for the change posted by Francis, so we know the INTENT of the change was to consider these areas as part of the building fire area. That's what I'm struggling with.


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## FM William Burns (Mar 9, 2012)

RGLA said:
			
		

> Canopies and awnings have none of those hazards, beyond the immediate hazard to occupants directly under the canopy or awning. Therefore, I do not consider them part of the fire area.However, if attached to the building, NFPA 13 (2010 edition) requires that canopies and similar projections be sprinklered if they exceed 4 ft. (Section 8.15.7). There are exceptions, such as being constructed of noncombustible materials, limited-combustible materials (a NFPA-specific term), or fire-retardant-treated wood. Sprinklers are required in canopies and other projections that are greater than 2 ft. and are over stored materials--no exceptions are given.


Been waiting for that......thanks!


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## Francis Vineyard (Apr 4, 2012)

The roof of an occupancy regardless of construction material as long as it complies with the construction type permitted is included as a fire area.

http://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_03_104_05.pdf

Thanks,

Francis


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## Papio Bldg Dept (Apr 4, 2012)

Francis Vineyard said:
			
		

> The roof of an occupancy regardless of construction material as long as it complies with the construction type permitted is included as a fire area.  http://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_03_104_05.pdf
> 
> Thanks,
> 
> Francis


That is based upon 2003 definitions is it not? Haven't those definitions changed substantially in the last 6-7 years (and I would assume the interpretations/justifications as well)?


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## Francis Vineyard (Apr 5, 2012)

Papio Bldg Dept said:
			
		

> That is based upon 2003 definitions is it not? Haven't those definitions changed substantially in the last 6-7 years (and I would assume the interpretations/justifications as well)?


Definitions and code sections have been added and change for clarity; other than exceptions for sprinklers when it applies and applicable sections in chapter 4 for instance; is there anything to the contrary to the 2003 interpretation in the code?

Francis


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## Papio Bldg Dept (Apr 5, 2012)

Francis Vineyard said:
			
		

> Definitions and code sections have been added and change for clarity; other than exceptions for sprinklers when it applies and applicable sections in chapter 4 for instance; is there anything to the contrary to the 2003 interpretation in the code?Francis


Per the discussion, I did not know if the 2012 or 2015 proposals would vary, or offer anything contrary, as we do not have 2012 books.

I am in the 2006, and don't believe the definitions are contrary to those offered in the opinion, but I was unable to reach your conclusion of

"_the roof of an occupancy regardless of construction material as long as it complies with the construction type permitted is included as a fire area. _" based upon the opinion referenced.


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## Francis Vineyard (Apr 5, 2012)

Papio I researched as time permitted in the 2012 Free Codes and search state interpretations such as NY and NC among others and it baffled me to see pictures of what appeared to be light transmitting plastic wall panels that is prohibited in restaurant "fire areas" in their bulletins; but that of course is their prerogative and it added to my confusion finding stuff like that online.  

For those of us inexperience and with very small staffs it is to our advantage to post here for any help with these interpretations.

Francis


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## Papio Bldg Dept (Apr 5, 2012)

Francis Vineyard said:
			
		

> Papio I researched as time permitted in the 2012 Free Codes and search state interpretations such as NY and NC among others and it baffled me to see pictures of what appeared to be light transmitting plastic wall panels that is prohibited in restaurant "fire areas" in their bulletins; but that of course is their prerogative and it added to my confusion finding stuff like that online.  For those of us inexperience and with very small staffs it is to our advantage to post here for any help with these interpretations.
> 
> Francis


I completely agree.  I was confused/curious as to whether the 2003 opinions were consistent with the 2012 code language, and how that interpretation yields a 'regardless of construction' conclusion.  Regardless of mental shortcomings today, as always, thank you for posting.  I have always found your posts helpful and informative.


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## Papio Bldg Dept (Apr 5, 2012)

Papio Bldg Dept said:
			
		

> Regardless of (my) mental shortcomings today, as always, thank you for posting.


Editing posts is one of the perks for donations correct?


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