# Group M with upholstered furniture



## Rick18071 (Jan 21, 2020)

An office supply store just moved in where a dollar store use to be recently. It was not considered a change of occupancy and there was not any construction so no permit was required. I stopped there yesterday and they had some upholstered office chairs on display for sale. It's part of a old strip mall that is way over 5,000 sq. ft. and not sprinklered.

2015 IBC:
[F] 903.2.7 Group M. An automatic sprinkler system
shall be provided throughout buildings containing a Group
M occupancy where one of the following conditions
exists:
1. A Group M fire area exceeds 12,000 square feet
(1115 m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale
of upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).

Should I require a permit for a change of occupancy and require sprinklers in the whole strip mall building?


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## RLGA (Jan 21, 2020)

There're two ways of interpreting this:

The area of the Group M exceeds 5,000 sq. ft. and includes the display of upholstered furniture.
The area used for the display of upholstered furniture in a Group M exceeds 5,000 sq. ft.
The _Commentary _seems to suggest #2, but it's not a strong indication:

"Note that, as with Group F-1 occupancies, the criteria is written such that any Group M occupancy, not the fire area, over 5,000 square feet (464 m2) *used for
the display and sale of upholstered furniture and mattresses *shall be sprinklered throughout."​The _IBC Handbook_ is a little more specific about interpretation #2:

"The installation of an automatic sprinkler system is also mandated in any Group M occupancy that is used for the display and sale of upholstered furniture or mattresses *where the floor area devoted to such goods exceeds 5,000 square feet *(464 m2)."​I understand these are NOT (<edit) mandatory documents, but they could help sway an interpretation at the local level.


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## classicT (Jan 21, 2020)

I've fought this same battle. Unfortunately, for the situation I dealt with, a business license for a mattress store that exceeded 5000sf was issued. I worked with our fire marshal to notify the building owner and tenant that the building required fire sprinklers and that a change of occupancy was required (although the 'M' occupancy group went unchanged). Tenant ended up relocating to a new stand-alone building.

See 2015 IBC  definition below:

*[A] CHANGE OF OCCUPANCY. *A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.​


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## Rick18071 (Jan 21, 2020)

Usually the code want the most strictest requirement.

[A] 102.1 General. Where there is a conflict between a general
requirement and a specific requirement, the specific
requirement shall be applicable. Where in any specific case
different sections of this code specify different materials,
methods of construction or other requirements, *the most
restrictive shall govern.*

I'm not sure of the size of the the tenant space of the office supply store but the whole strip mall is M. No fire areas. 
Under F-1 it's manufacture of upholstered furniture not the sale and display which can be very different.

Does the commentary say anything different about upholstered furniture stored in a S-1 occupancy?


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## Rick18071 (Jan 21, 2020)

2015 IEBC
407.1 Conformance. No change shall be made in the use or
occupancy of any building unless such building is made to
comply with the requirements of the International Building
Code for the *use* or occupancy.


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## classicT (Jan 21, 2020)

Rick18071 said:


> Should I require a permit for a change of occupancy and require sprinklers in the whole strip mall building?



And as another thought, you would only need to require sprinklers in the area undergoing the change.

*1012.2.1 Fire Sprinkler System*
Where a change in occupancy classification occurs or where there is a change of occupancy within a space where there is a different fire protection system threshold requirement in Chapter 9 of the _International Building Code _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.

*[A] CHANGE OF OCCUPANCY. *A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code.​


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## steveray (Jan 21, 2020)

Storage is even tougher for some reason....

5. A Group S-1 occupancy used for the storage of upholstered furniture or mattresses exceeds 2,500 square feet (232 m2).

But I would go with Ron's #2 because it makes sense....Becomes an enforcement issue on the other end, but it is what it is...


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## JPohling (Jan 21, 2020)

I usually only see a small section of office chair displays in these stores.  
Typically a small fraction of the sales area.  I cannot imagine it is anywhere near approaching 5,000 SF? 
I would assume they would be able to get the area for this type of commodity below the threshold SF to trigger the sprinklers.

How about the storage component?
Are they being stored on a racking system in their packaging?  In a store room or out on sales floor?


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## Paul Sweet (Jan 22, 2020)

I've never seen mattresses in an office supply store, and there isn't nearly as much foam in an office chair as their is in an armchair or sofa.  I think the interpretation of 5000 SF of furniture is more reasonable.


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## Rick18071 (Jan 22, 2020)

Thanks RGLA. But that just makes it more confusing with the commendatory and hand book saying different things..

They are desk chairs but they are not just all together in one spot, they are spread out in the store. Does that make a difference?

A Group M occupancy used for the display and sale
of upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).

I don't see how you can add words to this section to interpret it to mean something else:

A Group M occupancy has an space or area that is used for the display and sale
of upholstered furniture or mattresses that exceeds 5,000
square feet (464 m2).

or

An area or space in a Group M occupancy used for the display and sale
of upholstered furniture or mattresses that exceeds 5,000
square feet (464 m2).

It doesn't say an area or space of the Group M occupancy, or an area or space with the upholstered furniture.
 It just says the Group M occupancy 



JPohling said:


> How about the storage component?
> Are they being stored on a racking system in their packaging? In a store room or out on sales floor?



I don't know, I did not go in the storage area. I just stopped in the store to buy something. I am not the code official here but just the 3rd party inspector here. I haven't decide what to recommend if anything to the code official yet.

It's interesting that the IFC goes by the High-Piled Storage area in square feet, not the occupancy. I would think that the IBC would say the upholstered furniture or mattresses display area in square feet if that is what it meant instead of the whole occupancy's square feet..


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## Rick18071 (Jan 22, 2020)

Paul Sweet said:


> I've never seen mattresses in an office supply store, and there isn't nearly as much foam in an office chair as their is in an armchair or sofa.  I think the interpretation of 5000 SF of furniture is more reasonable.



I never said they had mattresses. So how would you measure the furniture? My desk chair takes about 2 sq. ft.of floor space so they would need over 2,500 upholstered desk chairs to require fire sprinklers? Or do you also count the vertical sq. ft. of the back of the chairs also?


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## Rick18071 (Jan 22, 2020)

Looking in chapter 9 of the IBC I am looking for other sections that say something like 903.2.7. to get an interpretation.

Here it actually says the sq. ft. area in a S-1 occupation:.

[F] 903.2.9.2 Bulk storage of tires. Buildings and
structures where the area for the storage of tires
exceeds 20,000 cubic feet (566 m3) shall be equipped
throughout with an automatic sprinkler system in
accordance with Section 903.3.1.1.

Here it uses the word area again:

[F] 903.2.4.1 Woodworking operations. An automatic
sprinkler system shall be provided throughout all
Group F-1 occupancy fire areas that contain woodworking
operations in excess of 2,500 square feet (232
m2) in area that generate finely divided combustible
waste or use finely divided combustible materials.

and again:

[F] 903.2.1.5 Group A-5. An automatic sprinkler system
shall be provided for Group A-5 occupancies in the
following areas: concession stands, retail areas, press
boxes and other accessory use areas in excess of 1,000
square feet (93 m2).

So if these sections are saying "area" wouldn't 903.2.7 say the  In a Group M occupancy where an area used for the display and sale of upholstered furniture or mattresses exceeds 5,000 square feet requires sprinklers if it really meant a area used for the display and sale of upholstered furniture or mattresses 

please, I am interested in everyone option.


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## mtlogcabin (Jan 22, 2020)

If you follow the logic on this interpretation of an S-1 occupancy and upholstered furniture then every M occupancy with 5,000 sq ft and the first piece of upholstered furniture for sale will require sprinklers. 
I disagree and believe the sq ft applies to the display area and not the size of the store.

SECTION 903.2.9 2012 Edition IFC Interpretation 20-14 Issued 10-6-2014 FI_12_20_14 903.2.9 Group S-1. An automatic sprinkler system shall be provided throughout all buildings containing a Group S-1 occupancy where one of the following conditions exists: 1. A Group S-1 fire area exceeds 12,000 square feet (1115 m2). 2. A Group S-1 fire area is located more than three stories above grade plane. 3. The combined area of all Group S-1 fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2). 4. A Group S-1 fire area used for the storage of commercial trucks or buses where the fire area exceeds 5,000 square feet (464 m2). 5. A Group S-1 occupancy used for the storage of upholstered furniture or mattresses exceeds 2,500 square feet (232 m2). ● ● ● ● ● ● ● ● ● ●

 Q: The area of a self-storage warehouse is between 2,500 square feet and 12,000 square feet. Spaces are rented to individuals for the storage of personal household items (which could include incidental pieces of upholstered furniture and mattresses). Does item #5 require an automatic sprinkler system throughout the Group S-1 self-storage warehouse?

 A: Yes. This criteria is written such that any Group S-1 occupancy, not the fire area, over 2,500 square feet used for the storage of upholstered furniture and/or mattresses shall be sprinklered throughout the building. This is regardless of how much upholstered furniture and/or mattresses are actually stored.


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## JPohling (Jan 22, 2020)

Agree with MT


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## steveray (Jan 22, 2020)

I heard that was changing/ being clarified "just for" the self storage industry.....


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## steveray (Jan 22, 2020)

2018
[F] 903.2.7 Group M. An automatic sprinkler system shall
be provided throughout buildings containing a Group M
occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115
m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale of
upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).
The sprinkler threshold requirements for Group M
occupancies are identical to those of Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4).
The one exception is that Group M occupancies are
provided with an increased area for display of upholstered
furniture and mattresses of 5,000 square feet
(464 m2) versus 2,500 square feet (232 m2) required
for Group F-1 and S-1 occupancies. As noted in the
commentary for Group F-1 occupancies, upholstered
furniture and mattresses have the potential for rapid
growing and high-heat-release fires. This hazard is
increased substantially when there are numerous
upholstered furniture items or mattresses on display.
Such fires put the occupants and emergency
responders at risk. This requirement exists regardless
of whether the upholstered furniture has passed
any fire-retardant tests.


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## steveray (Jan 22, 2020)

sorry that was 2012


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## steveray (Jan 22, 2020)

[F] 903.2.7 Group M. An automatic sprinkler system shall
be provided throughout buildings containing a Group M
occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115
m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale of
upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).
The sprinkler threshold requirements for Group M
occupancies are identical to those of Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4).
The one exception is that Group M occupancies are
provided with an increased area for display of upholstered
furniture and mattresses of 5,000 square feet
(464 m2) versus 2,500 square feet (232 m2) required
for Group F-1 and S-1 occupancies. As noted in the
commentary for Group F-1 occupancies, upholstered


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## steveray (Jan 22, 2020)

furniture and mattresses have the potential for rapidly
growing and high-heat-release fires. This hazard is
increased substantially when there are numerous
upholstered furniture items or mattresses on display.
Such fires put the occupants and emergency
responders at risk. This requirement exists regardless
of whether the upholstered furniture has passed
any fire-retardant tests.
The code does not specifically address what constitutes
upholstered furniture, but by simple dictionary
definition, upholstered furniture has seats covered
with padding, springs, webbing and fabric or leather
covers. The code does not make any distinction
between levels of padding and upholstery provided
on furniture, which was intentional. The proponent’s
reason statement for code change F135-07/08
stated, in part, “the American Home Furnishings Alliance
(AHFA) and the National Home Furnishings
Association (NHFA) have examined proposals for
exempting vendors of certain constructions of furniture
and concluded that such exemptions would be
impractical for local code officials to enforce. This is
the case because the internal construction of furniture
cannot be established reliably without deconstructing
it.”
Note that, as with Group F-1 occupancies, the criteria
is written such that any Group M occupancy, not
the fire area, over 5,000 square feet (464 m2) used for
the display and sale of upholstered furniture and mattresses
shall be sprinklered throughout. This is
regardless of the quantity of upholstered furniture and
mattresses actually available for purchase. The reason
these requirements were placed into the code
and the IFC was based on a large fire in Charleston,
South Carolina, that killed nine fire fighters. The facility
was a combination furniture showroom and associated
storage area. The building did not provide an
automatic sprinkler system. See the commentary to
Section 903.2.9 for discussion of a formal interpretation
dealing with Group S-1 occupancies and applicability
to the code and the IFC.
Automatic sprinkler systems for mercantile occupancies
are typically designed for an Ordinary Hazard
Group 2 classification in accordance with NFPA
13. If high-piled storage (see Section 903.2.7.1) is
anticipated, additional levels of fire protection may be
required. Also, some merchandise in mercantile
occupancies, such as aerosols, rubber tires, paints
and certain plastic commodities, even at limited storage
heights, are considered beyond the standard
Class I through IV commodity classification assumed
for mercantile occupancies in NFPA 13 and may warrant
additional fire protection.


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## steveray (Jan 22, 2020)

Maybe not....

See the commentary for Group M and
Group F-1 definitions for more discussion on this
issue. Again, it is important to note that the threshold
is based on the square footage of the occupancy and
not on the size of the fire area. A formal interpretation
(IFC Interpretation 20-14) has been issued on this
section. The formal interpretation addresses self-storage
warehouses specifically and whether such a
facility between 2,500 and 12,000 square feet would
require an automatic sprinkler system. This is based
on the fact that upholstered furniture may be stored in
such units. The response provided noted that a sprinkler
system would be required given that the requirements
focus on the square footage of the occupancy
and are not based on fire area or the amount of
upholstered furniture or mattresses present.


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## RLGA (Jan 22, 2020)

I tried to go back and see what was submitted in regard to proposals that would limit the area to 5,000 sq. ft. during the 2009/2010 code development cycle. There were three proposals submitted that modified this particular part of Section 903.2.7: F69, F71, and F72. F69 added mattresses to the issue, F71 added an area limitation of 7,500 sq. ft., and F72 wanted the requirement for upholstered furniture deleted entirely.

F71 was disapproved and F72 was withdrawn by proponent. F69 (this proposal also included similar modifications for Groups F-1 and S-1) was initially "disapproved" but was changed to "approved as modified" during the public hearing, which kept the "mattresses" addition and added the 5,000 sq. ft. limitation. The reason given for the area limitation addition is as follows:

"The committee approved the proposal as they felt that Group F-1 and Group S-1 occupancies manufacturing and storing upholstered furnishings and mattresses pose the same hazard to occupants and firefighters that Group M occupancies displaying and selling such materials. *The proposal was modified to provide a reasonable threshold that would not penalize occupancies with very small amounts of such materials*. These thresholds were based on the thresholds in Chapter 23 of the IFC with regard to size of high piled storage areas." (emphasis added)​Based on the reason, it appears that the 5,000 sq. ft. limitation was intended to be applied to the actual area occupied by such materials and not to the entire Group M occupancy area; however, the language used does not clearly reflect that intent.


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## classicT (Jan 22, 2020)

RLGA said:


> I tried to go back and see what was submitted in regard to proposals that would limit the area to 5,000 sq. ft. during the 2009/2010 code development cycle. There were three proposals submitted that modified this particular part of Section 903.2.7: F69, F71, and F72. F69 added mattresses to the issue, F71 added an area limitation of 7,500 sq. ft., and F72 wanted the requirement for upholstered furniture deleted entirely.
> 
> F71 was disapproved and F72 was withdrawn by proponent. F69 (this proposal also included similar modifications for Groups F-1 and S-1) was initially "disapproved" but was changed to "approved as modified" during the public hearing, which kept the "mattresses" addition and added the 5,000 sq. ft. limitation. The reason given for the area limitation addition is as follows:
> 
> "The committee approved the proposal as they felt that Group F-1 and Group S-1 occupancies manufacturing and storing upholstered furnishings and mattresses pose the same hazard to occupants and firefighters that Group M occupancies displaying and selling such materials. *The proposal was modified to provide a reasonable threshold that would not penalize occupancies with very small amounts of such materials*. These thresholds were based on the thresholds in Chapter 23 of the IFC with regard to size of high piled storage areas." (emphasis added)​Based on the reason, it appears that the 5,000 sq. ft. limitation was intended to be applied to the actual area occupied by such materials and not to the entire Group M occupancy area; however, the language used does not clearly reflect that intent.


I'd state that part of the challenge in looking only at the area where the materials are stored is how to regulate.

Products for sale are typically not stocked until after CO, so verification is limited. Additionally, what happens as products cycle in and out; does the area encompassed by upholstered goods/mattresses change? If so, is that a change of occupancy that would trigger the need for fire sprinklers?

What happens when company A goes belly up, company B moves in and has a larger portion of the space dedicated to upholstered goods/mattresses?

From a code perspective, I believe that the only approach is to include the entire sales floor area when determining if greater or less than 5000sf. Stockrooms (if greater than 10%) would be classified as an S-1, and must meet the separate requirements therein. Offices/breakrooms/etc. need not be included in the area so long as there is reasonable cause (defined room, permanent fixtures, etc.) to show they will not be used for the sale of upholstered goods or mattresses.


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## JPohling (Jan 22, 2020)

You cannot be a mind reader for the future situations that may arise.
I would never base this on the total sales floor square footage, only on the SF where this commodity is being displayed.and stored.


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## classicT (Jan 22, 2020)

JPohling said:


> You cannot be a mind reader for the future situations that may arise.
> I would never base this on the total sales floor square footage, only on the SF where this commodity is being displayed.and stored.


And how would you determine where the commodity will be stored?

Commodity cant be stocked prior to CO, so when?


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## steveray (Jan 23, 2020)

Ty J. said:


> What happens when company A goes belly up, company B moves in and has a larger portion of the space dedicated to upholstered goods/mattresses?



You or the FM issue a violation.....



Ty J. said:


> Commodity cant be stocked prior to CO, so when?



Of course it can...If you are reasonable...



Ty J. said:


> And how would you determine where the commodity will be stored?



A floor plan that I assume you would get with the permit application...?


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## classicT (Jan 23, 2020)

Sure, code officials can let this go....but ask the contractor's insurance. Ask the owners insurance. Most likely, both will exclude coverage if stocked prior to CO.


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## steveray (Jan 23, 2020)

We often like to see spaces "set up" so they don't screw up egress and such with fixtures and furnishings....


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## JPohling (Jan 23, 2020)

In San Diego there are no issues with stocking commodities, furniture, computers etc prior to CO.  Just no employees working.  Agreed, Fire prefers it so they can ensure there are no issues.  And yes a floor plan within the permit documents would detail the area of display and storage.  I would guess that a Nordstrom Rack has a higher fire load with the dense clothing racks and shelves of shoes than an upholstered furniture store.


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## e hilton (Jan 23, 2020)

JPohling said:


> You cannot be a mind reader for the future situations that may arise.
> I would never base this on the total sales floor square footage, only on the SF where this commodity is being displayed.and stored.


Sorry, i disagree.  You might approve it based on say 15% of the area has upholstered furniture, but 6 months from now they might change their product line and go to 80% upholstered.  And <gasp> they might do it intentionally.


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## JPohling (Jan 23, 2020)

e hilton said:


> Sorry, i disagree.  You might approve it based on say 15% of the area has upholstered furniture, but 6 months from now they might change their product line and go to 80% upholstered.  And <gasp> they might do it intentionally.


So your saying you are a mind reader and your so good at it that you will force fire sprinklers on a project that per code that does not require it based upon the information that the owner has provided for your review?  And you wonder why the public has a problem with code officials overstepping?


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## classicT (Jan 23, 2020)

JPohling said:


> So your saying you are a mind reader and your so good at it that you will force fire sprinklers on a project that per code that does not require it based upon the information that the owner has provided for your review?  And you wonder why the public has a problem with code officials overstepping?


It is not overstepping, nor is it mind reading.

We all agree that the code language is vague and does not provide a clear definition of the delineation of the space. Based upon that, it is up to the BO to make an interpretation of the code.


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## mtlogcabin (Jan 23, 2020)

There where a lot of things that where wrong and went wrong with that South Carolina fire that drove this requirement. 
Not being allowed to divide a building into fire areas because of the contents that *may be* in the building to get the exception to sprinklers that is allowed in many other occupancy types is wrong and goes against the intent of the code regarding fire areas.


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## e hilton (Jan 23, 2020)

JPohling said:


> So your saying you are a mind reader and your so good at it that you will force fire sprinklers on a project that per code that does not require it based upon the information that the owner has provided for your review?  And you wonder why the public has a problem with code officials overstepping?


Yes, my friends call me Karnak. 
I am not a code official, i am on the construction side.  But i see people trying to game the system.  Some of them post here, trying to find justification for not building to the proper specs.  People are going to look for ways to reduce costs and increase profits.  If they can put a little spin on the plans or zoning application form that will allow them to avoid $50k in sprinkler costs ... they are going to jump on it.


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## Rick18071 (Jan 24, 2020)

This code section is too vague and seems impossible to enforce. There are a lot of large antique stores around my area. products change and are rearranged everyday. Also I don't see how it would be safer or be a less fire load if they pushed all the upholstered furniture together in one 5,000 sq. ft. area rather than have them spread throughout the occupancy. In fact with antiques having no fire-retardant gathered all together would seem to me to be more dangerous than if they were spread apart. It is obvious to me that if they were all pushed together if one would catch fire it would spread to the rest of the upholstered furniture, if they were spread out this would less likely to happen.


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## mtlogcabin (Jan 24, 2020)

Second hand stores are another, sometimes you find a couch or two sometimes there is no furniture. We have educated them and they no longer sell used mattresses.


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## steveray (Jan 24, 2020)

Less fire retardants in antiques but also less foam.....


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## Rick18071 (Jan 24, 2020)

Only needs to be 25 years old to be an antique


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## my250r11 (Jan 24, 2020)

Here the Fire guys & building do new Business license inspections. Fire guys do annual inspection on all sprinkled businesses and every other year on the smaller ones. Plbg. & mech also on new businesses with any food made or sold. This is to help control the what ifs that may happen. As well as if we are in the community on our free time we call the on call fire or bldg. guys if we see violations.


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## Rick18071 (Jan 27, 2020)

I finally talked to the AHJ (I'm just the 3rd party inspector) about this situation about upholstered furniture in this office supply store. I showed him the code:

A Group M occupancy used for the display *and* sale
of upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).

He said he did not see a problem. The code says "for the display *and* sale". The upholstered desk chairs in the store are only on display and not for sale. If you want a chair that is on display you have to buy one that is in storage to pick up or get delivered. So that makes the chairs in the stock room do not count too because they are only for sale and not on display.


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## mtlogcabin (Jan 27, 2020)

Do you buy the chair in the storage room or the display. Are they separated occupancies? if not it is all a mercantile use 
I thought I stretch it sometimes but this guy sounds like Gumby


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## e hilton (Jan 27, 2020)

Gumby is a nice way of putting it.  Putting on my Karnak hat again ... customer says he wants to buy that chair.  Salesperson says ok, but out of stock at the moment, wait 3-4 weeks.  But i can sell you the display chair as-is.  
And is the stock room out back, or at a different location?


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## JPohling (Jan 28, 2020)

So they are on display for what purpose?  they are for sale..................


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## Rick18071 (Jan 30, 2020)

JPohling said:


> So they are on display for what purpose?  they are for sale..................



The store told the AHJ that the office chairs in the store (M) are not for sale, they are only for display to be looked to help customers decide which one they want. When the customer decide to buy one like the displayed chair you get the number of it and take it to the cashier and then they will sell you one in the stock room (S1).


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## steveray (Jan 30, 2020)

Rick18071 said:


> The store told the AHJ that the office chairs in the store (M) are not for sale, they are only for display to be looked to help customers decide which one they want. When the customer decide to buy one like the displayed chair you get the number of it and take it to the cashier and then they will sell you one in the stock room (S1).



Yeah but then the S1 gets sprinklered at 2500 ft per my post #7......?


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## Rick18071 (Feb 3, 2021)

I feel like I'm the only one with problems with upholstered furniture.

A new tenant that sells used furniture will be moving into a 3,000 sq. ft. tenant space strip mall. The tenant space was already a M. There all ready is a 3,000 sq. ft. store selling furniture in the same strip mall. Building is not sprinklered and is mixed with M and B occupancies. Would this be considered a change of occupancy for the whole building and the whole strip mall would have to be sprinklered now?


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## classicT (Feb 3, 2021)

Rick18071 said:


> I feel like I'm the only one with problems with upholstered furniture.
> 
> A new tenant that sells used furniture will be moving into a 3,000 sq. ft. tenant space strip mall. The tenant space was already a M. There all ready is a 3,000 sq. ft. store selling furniture in the same strip mall. Building is not sprinklered and is mixed with M and B occupancies. Would this be considered a change of occupancy for the whole building and the whole strip mall would have to be sprinklered now?


Rick, is the IEBC in play? If so, check out the IEBC's definition of "Change of Occupancy" below. Make note of #3.

*[A] **CHANGE OF OCCUPANCY.* A change in the use of a building or a portion of a building that results in any of the following:​
A change of occupancy classification.
A change from one group to another group within an occupancy classification.
Any change in use within a group for which there is a change in application of the requirements of this code.
I have used the above definition before to justify the requirement for a sprinkler system wherein a storefront transitioned from a cellphone to mattress retailer. The space was greater than 2500sf, and no change in occupancy classification; however, a change in code requirements for a FS system could be enforced as a trigger for a change of occupancy.


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## Rick18071 (Feb 3, 2021)

These two furniture stores are in the same strip mall with a B occupancy in between. The two furniture stores will mean that there will be a total of  about 6000 sq. ft. of furniture in a building with some upholstered furniture mixed in. The amount of upholstered furniture will be always changing so I don't think I could only count on how much upholstered furniture will be in the stores. Each tenant space could be considered an occupancy but also the building can be considered one mixed occupancy. Since the two furniture stores are in the same building am I right to add them together? The code does not seem to care if there are any spaces, rooms, walls, other occupancies, or fire protected walls in between.


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## classicT (Feb 3, 2021)

If you read Section 903.2.7 carefully, you will notice how conditions 1-3 all clearly specify the fire area; however, condition 4 does not. It only indicates that where a Group M occupancy w/ upholstered furniture or mattresses exceeds 5000sf fire sprinklers are required. So even if in different fire areas (which would require presence of fire barriers), then the requirement stands. 

Now, you can take a more liberal read and hang-your-hat on the use of the word "a" in "Where a Group M occupancy ..." and suggest that each business is it's own occupancy. They share an occupancy classification, but are themselves separate occupancies. Thus, only if each tenant space is less than 2500sf, can fire sprinklers may be omitted.

Given that you indicated the the tenant space is 3000sf, I'd suggest requiring the sprinklers. That said, one could get even more creative, and classify 500sf or more of the building for use other than the display and sale of upholstered furniture or mattresses. This would not be hard to do; i.e. add an office and bathrooms to get the display/storage area to sub 2500sf.

*[F] 903.2.7 Group M*
An _automatic sprinkler system _shall be provided throughout buildings containing a Group M occupancy, where one of the following conditions exists:

A Group M _fire area _exceeds 12,000 square feet (1115 m2).
A Group M _fire area _is located more than three stories above _grade plane_.
The combined area of all Group M _fire areas _on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).
Where a Group M occupancy that is used for the display and sale of upholstered furniture or mattresses exceeds 5000 square feet (464 m2).


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## steveray (Feb 4, 2021)

I'm with CT....


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## Rick18071 (Feb 4, 2021)

S-1 buildings seem to have the same issue.
I know of a self storage large building (S-1) somewhere else that was allowed by th AHJ to be divided up by fire walls which makes separate "buildings". Each "building" was less than 2,500 sq ft. But is this intended by the code because all these "buildings" are still one occupancy? Even if the buildings were actually separated but still the same occupancy would this be different? 
Thoughts

[F] 903.2.9 Group S-1. An automatic sprinkler system
shall be provided throughout all buildings containing a
Group S-1 occupancy where one of the following conditions
exists:
A Group S-1 fire area exceeds 12,000 square feet
(1115 m2).
2. A Group S-1 fire area is located more than three stories
above grade plane.
3. The combined area of all Group S-1 fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group S-1 fire area used for the storage of commercial
motor vehicles where the fire area exceeds
5,000 square feet (464 m2).
5. A Group S-1 occupancy used for the storage of
upholstered furniture or mattresses exceeds 2,500
square feet (232 m2).

There must be a reason why the people that proposed this section about upholstered furniture in both S-1 and M to be limited in an occupancy rather a fire area like with commercial motor veicles in #4 above. It would help to know this in order to determin the intent of the code. Of course the building owner, AHJ and the architect may have their own understanding of what the intent of these code sections are which can make a plan reviewer's job nerve-racking. Maybe this was the intent of the code writers. By the way an AHJ here in PA which we call the Building Code Offical (BCO) does't need to know anything of the ICC codes, they only need to pass a test on the states administration law of building codes (replaced Chapter 1).
Of couse it would help if the IBC defined the word occupancy, the word is used many times in the IBC but no defintion. The IBC seems to use the word as a use of a space rather then a space itself. Merram-Webster has a few definitons but none of them is for a use of a space.


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## steveray (Feb 4, 2021)

In the 2018 IBC firewalls no longer get you out of sprinklers....


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## my250r11 (Feb 4, 2021)

Here is the 2015 Commentary:

[F] 903.2.7 Group M. An automatic sprinkler system shall
be provided throughout buildings containing a Group M
occupancy where one of the following conditions exists:
1. A Group M fire area exceeds 12,000 square feet (1115
m2).
2. A Group M fire area is located more than three stories
above grade plane.
3. The combined area of all Group M fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group M occupancy used for the display and sale of
upholstered furniture or mattresses exceeds 5,000
square feet (464 m2).
The sprinkler threshold requirements for Group M
occupancies are identical to those of Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4).
The one exception is that Group M occupancies are
provided with an increased area for display of upholstered
furniture and mattresses of 5,000 square feet
(464 m2) versus 2,500 square feet (232 m2) required
for Group F-1 and S-1 occupancies. As noted in the
commentary for Group F-1 occupancies, upholstered
furniture and mattresses have the potential for rapidly
growing and high-heat-release fires. This hazard is
increased substantially when there are numerous
upholstered furniture items or mattresses on display.
Such fires put the occupants and emergency
responders at risk. This requirement exists regardless
of whether the upholstered furniture has passed
any fire-retardant tests.
The code does not specifically address what constitutes
upholstered furniture, but by simple dictionary
definition, upholstered furniture has seats covered
with padding, springs, webbing and fabric or leather
covers. The code does not make any distinction
between levels of padding and upholstery provided
on furniture, which was intentional. The proponent’s
reason statement for code change F135-07/08
stated, in part, “the American Home Furnishings Alliance
(AHFA) and the National Home Furnishings
Association (NHFA) have examined proposals for
exempting vendors of certain constructions of furniture
and concluded that such exemptions would be
impractical for local code officials to enforce. This is
the case because the internal construction of furniture
cannot be established reliably without deconstructing
it.”
Note that, as with Group F-1 occupancies, the criteria
is written such that any Group M occupancy, not
the fire area, over 5,000 square feet (464 m2) used for
the display and sale of upholstered furniture and mattresses
shall be sprinklered throughout. This is
regardless of the quantity of upholstered furniture and
mattresses actually available for purchase. The reason
these requirements were placed into the code
and the IFC was based on a large fire in Charleston,
South Carolina that killed nine fire fighters. The facility
was a combination furniture showroom and associated
storage area. The building did not provide an
automatic sprinkler system. See the commentary to
Section 903.2.9 for discussion of a formal interpretation
dealing with Group S-1 occupancies and applicability
to the code and the IFC.
Automatic sprinkler systems for mercantile occupancies
are typically designed for an Ordinary Hazard
Group 2 classification in accordance with NFPA
13. If high-piled storage (see Section 903.2.7.1) is
anticipated, additional levels of fire protection may be
required. Also, some merchandise in mercantile
occupancies, such as aerosols, rubber tires, paints
and certain plastic commodities, even at limited storage
heights, are considered beyond the standard
Class I through IV commodity classification assumed
for mercantile occupancies in NFPA 13 and may warrant
additional fire protection.


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## my250r11 (Feb 4, 2021)

Here's the other:
Group F-1 and
S-1 occupancies (see commentary, Section 903.2.4):

[F] 903.2.4 Group F-1. An automatic sprinkler system shall
be provided throughout all buildings containing a Group F-1
occupancy where one of the following conditions exists:
1. A Group F-1 fire area exceeds 12,000 square feet
(1115 m2).
2. A Group F-1 fire area is located more than three stories
above grade plane.
3. The combined area of all Group F-1 fire areas on all
floors, including any mezzanines, exceeds 24,000
square feet (2230 m2).
4. A Group F-1 occupancy used for the manufacture of
upholstered furniture or mattresses exceeds 2,500
square feet (232 m2).
Group F-1 occupancies must meet several different
conditions as to when the fire area or occupancy
must be sprinklered. The first three conditions are
related to the difficulty of manually suppressing a fire
involving a large area. Therefore, occupancies of
Group F-1 must be protected throughout with an
automatic sprinkler system if the fire area is in excess
of 12,000 square feet (1115 m2); if the total of all fire
areas is in excess of 24,000 square feet (2230 m2); or
if the fire area is located more than three stories
above grade plane. This is one of the few locations in
the code where the total floor area of the building is
aggregated for application of a code requirement.
The stipulated conditions for when an automatic
sprinkler system is required also apply to Group M
(see Section 903.2.7) and S-1 (see Section 903.2.9)
occupancies. Condition 4 for sprinklering a Group F-1
occupancy relates to the requirement for Group F-1
occupancies in excess of 2,500 square feet (232 m2)
that are used for the manufacture of upholstered furniture
or mattresses. Note that this requirement is
based simply on the square footage of the Group F-1
occupancy and is not related to fire areas. Upholstered
furniture has the potential for rapid-growing
and high-heat-release fires. This hazard is increased
substantially when there are numerous upholstered
furniture or mattresses being manufactured. Such
fires put the occupants and emergency responders at
risk. This requirement exists regardless of whether
the upholstered furniture has passed any fire-retardant
tests. See the commentary for Section 903.2.7
for more discussion on the subject of upholstered furniture.
See the commentary to Section 903.2.9 for
discussion of the formal interpretation and applicability
to the code and the IFC.
The following examples illustrate how the criteria of
this section are intended to be applied:
• If a building contains a single fire area of Group
F-1 and the fire area is 13,000 square feet (1208
m2), an automatic sprinkler system is required
throughout the entire building; however, if this
fire area is separated into two fire areas and neither
is in excess of 12,000 square feet (1115
m2), an automatic fire sprinkler system is not
required. To be considered separate fire areas,
the areas must be separated by fire barriers or
horizontal assemblies having a fire-resistance
rating as required in Table 707.3.10.
• If a 30,000-square-foot (2787 m2) Group F-1
building was equally divided into separate fire
areas of 10,000 square feet (929 m2) each, an
automatic sprinkler system would still be
required throughout the entire building. Because
the aggregate area of all fire areas exceeds
24,000 square feet (2230 m2), additional compartmentation
will not eliminate the need for an
automatic sprinkler system. However, the use of
a fire wall to separate the structure into two
buildings would reduce the aggregate area of
each building to less than 24,000 square feet
(2230 m2) and each fire area to less than 12,000
square feet (1115 m2), which would offset the
need for an automatic sprinkler system.


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## Rick18071 (Feb 5, 2021)

So what definition does the ICC exactly use for "occupancy" so I know if it is for the whole building, multiple buildings on a site or just the tenant space?
Does a certificate of occupancy have to do with this?
There is a current certificate of occupancy for this group of buildings on this site (shopping center).
There is also a current certificate of occupancy for just the one building with several tenant spaces.
There is a current certificate of occupancy for this  one tenant space
There will be a certificate of occupancy for just this one tenant space or one for the whole building if sprinklers are required after it passes all inspections.
In this case would the most restrictive comply?

[A] 102.1 General. Where there is a conflict between a general
requirement and a specific requirement, the specific
requirement shall be applicable. Where, in any specific case,
different sections of this code specify different materials,
methods of construction or other requirements, the most
restrictive shall govern.


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