# Magic Loophole that Justifies Omitting Fire Sprinklers?



## Enri Code (Apr 17, 2020)

Given these parameters:
- 200 ft. x 200 ft. (40,000sf area) 
- Type 2B construction (pre-engineered metal building)
- F-1 occupancy building
- 30 feet tall (single story)

We understand that Table 506.2 limits the area of a non-sprinklered F-1 building to just 15,500 sf. so it needs to be sprinklered at 40,000 sf.

However, someone pointed out that if we were to use parts of *IBC Section 903.2.11*, specifically I*BC Section 903.2.11.1.2,* we can instead replace fire sprinklers with just adding openings within every 50 feet of the exterior wall on at least 2 of the exterior walls.

This effectively omits the need for fire sprinklers.

I read through *IBC Section 903.2.11.1.2 *and understood it as mainly to specify conditions in which *Stories without Openings *need sprinklers.

It was however explained to me that since the gist of the section actually says that you need to provide fire sprinklers if you do not have openings within every 50 feet of the exterior wall... then the reverse of then having those openings means you do not need to provide fire sprinklers!

I'm uneasy that it takes a bit of "gymnastics" and reversals to get to the point on how sprinklers can be eliminated.

Has anyone else encountered this? Is this logic or approach valid? 

I have done quite a bit of research to this point and there is a big black hole on information about using this logic to eliminate fire sprinklers which is a big red flag for me.

I would sure appreciate the help and thoughts in processing this. Thank you.


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## cda (Apr 17, 2020)

Enri Code said:


> Given these parameters:
> - 200 ft. x 200 ft. (40,000sf area)
> - Type 2B construction (pre-engineered metal building)
> - F-1 occupancy building
> ...




Always, or normally, the stricter of the code sections applies,

So if you have a building, because of sq ft, requires fire sprinklers, there is not an out,,,,, Normally. 



Does that answer your question????????


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## Enri Code (Apr 17, 2020)

cda said:


> Always, or normally, the stricter of the code sections applies,
> 
> So if you have a building, because of sq ft, requires fire sprinklers, there is not an out,,,,, Normally.
> 
> ...



It answers my question in some ways because I'm with you on that. I've actually made the same argument that since Table 506.2 says that area of the building pushes for it to have sprinklers, then it should have them.

The judo move thrown my way is that: well the openings - which are at least 20 sf in area each - at within every  50 feet is a substitution for the fire sprinklers.  The fire mitigation is not gone and only replaced by something else which is passive. So it supposedly complies.


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## Enri Code (Apr 17, 2020)

This commentary from the Part 1 of the 2018 Code and Commentary document from the ICC (on page 9-19) was cited as well:

"If openings are provided on only one side, an automatic sprinkler system would still be required if the opposite wall of the story is more than 75 feet from existing openings. *An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building.* As long as the story being considered is not a basement, the openings on two sides can be greater than 75 feet from any portion of the floor. In basements, if any portion is more than 75 feet from the openings, the entire basement must be equipped with an automatic sprinkler system as indicated in Section 903.2.11.1.3. *Providing openings on more than one wall allows cross ventilation to vent the products of combustion*."


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## Enri Code (Apr 17, 2020)

This image is also taken from the 2018 IBC Code and Commentary book which supposedly supports the idea of having openings instead of an automatic sprinkler system.

This just blows my mind. If this is true, this is a major loophole!​


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## cda (Apr 17, 2020)

I understand openings

That is one instance where fire sprinklers are required,,,,    Even if the building is under the Sq ft that requires them...


If you have a building over the sq ft requiring sprinklers,,

There is no Out!!!


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## e hilton (Apr 17, 2020)

A pre-engineered steel building implies a warehouse or industrial building, with overhead doors.  Maybe not.  Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.  

*Providing openings on more than one wall allows cross ventilation to vent the products of combustion*."

Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.


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## cda (Apr 17, 2020)

e hilton said:


> A pre-engineered steel building implies a warehouse or industrial building, with overhead doors.  Maybe not.  Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.
> 
> *Providing openings on more than one wall allows cross ventilation to vent the products of combustion*."
> 
> Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.




One of those code technicalities 

The require openings,,,,

Do Not have to be openable .


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## Enri Code (Apr 17, 2020)

e hilton said:


> A pre-engineered steel building implies a warehouse or industrial building, with overhead doors.  Maybe not.  Anyway, i dont think overhead doors would satisfy the egress requirements, they would have to be swinging doors with proper hardware.
> 
> *Providing openings on more than one wall allows cross ventilation to vent the products of combustion*."
> 
> Yeah, but that doesnt do anything to knock the fire down to allow occupants time to escape.


Egress is a separate thing. Number of egress doors will still be provided per code based on exit distances. 

For simplicity's sake, consider all of these openings as swing doors for now.

So the concept is that providing all these swing man doors within 50 linear feet along the exterior walls can take the place of an automatic sprinkler systems!

It's true that some of them may be steel roll up doors but that is still supposedly acceptable. The thought here is that egress doors is separate and some of them will probably be egress doors.

What I understand from this is that most of the other doors are basically fireman's access doors or for firemen to be able to open and vent the building. 

It's the venting that helps knock the fire down some or at least make it safe before the firemen have to go in. 

So if it did come to it, even an overhead door may comply as long as it is at least 20 square feet in area and have a minimum width of 30 inches. The reason being is that it can be opened for venting.


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## Enri Code (Apr 17, 2020)

cda said:


> One of those code technicalities
> 
> The require openings,,,,
> 
> Do Not have to be openable .



Sound odd but seems like if the criteria is to be able to vent the building from a fire fighting perspective, it may mean that they can be busted open with an axe, halligan bar or chainsaw. If they are lockable, a fireman accessible lockbox with the keys may also be provided.


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## Enri Code (Apr 17, 2020)

cda said:


> I understand openings
> 
> That is one instance where fire sprinklers are required,,,,    Even if the building is under the Sq ft that requires them...
> 
> ...


I wish it was that simple but the words from the ICC commentary are exactly:  "*An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building". *

So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!

I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.


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## cda (Apr 17, 2020)

Enri Code said:


> I wish it was that simple but the words from the ICC commentary are exactly:  "*An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building". *
> 
> So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!
> 
> I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.




Does not change any answer, but how are you connected with this, as in what do you do for a  paycheck?


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## cda (Apr 17, 2020)

Enri Code said:


> I wish it was that simple but the words from the ICC commentary are exactly:  "*An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building". *
> 
> So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!
> 
> I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.






*102.10 Conflicting Provisions*

Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable. Where, in a 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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## cda (Apr 17, 2020)

Enri Code said:


> I wish it was that simple but the words from the ICC commentary are exactly:  "*An alternative to providing the automatic sprinkler system would be to design openings on at least two sides of the exterior of the building". *
> 
> So yes it requires sprinklers... but it seems that I can swap sprinklers for openings!
> 
> I would also like to err on the side of caution but the ICC code commentary is presenting a case that is hard for me to ignore.





I agree with underlined,,,,

But if the same building is over the sq ft or other as per 903,  than thou shall sprinkler


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## cda (Apr 17, 2020)

You also need to read the section it applies to:::::::::::::::::


*903.2.11 Specific Buildings Areas and Hazards*

In all occupancies other than Group U, an _automatic sprinkler system_ shall be installed for building design or hazards in the locations set forth in Sections 903.2.11.1 through 903.2.11.6.


READ the commentary for 

*903.2.11 Specific Buildings Areas and Hazards*


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## Enri Code (Apr 17, 2020)

cda said:


> *102.10 Conflicting Provisions*
> 
> Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable. Where, in a specific case, different sections of this code specify different materials, methods of construction or other requirements, the most restrictive shall govern.



The provisions do not conflict though because it gives an alternate method and not an exception.


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## Enri Code (Apr 17, 2020)

cda said:


> You also need to read the section it applies to:::::::::::::::::
> 
> 
> *903.2.11 Specific Buildings Areas and Hazards*
> ...



Correct. Then it goes on to say under 903.2.11.1.2 that sprinklers are indeed required for buildings without openings at every 50 linear feet. 
The logic is then applied that if we therefore provide those openings at every 50 linear feet... then we do not need to provide sprinklers.
Hence the diagram from the ICC commentary document showing a floor plan with the openings and the note: Automatic Sprinkler System Not Required.


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## Enri Code (Apr 17, 2020)

cda said:


> You also need to read the section it applies to:::::::::::::::::
> 
> 
> *903.2.11 Specific Buildings Areas and Hazards*
> ...



I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.

The commentary says:

“Section 903.2.11.1 through 903.2.11.2 *specify certain conditions under which an automatic sprinkler system is required, even in otherwise nonsprinklered buildings. *As indicated, the listed conditions in the noted sections are applicable to all occupancies except Group U. Most structures that qualify as Group U do not typically have the type of conditions stipulated in Sections 903.2.11.1 through 903.2.11.1.3.”

My argument is that the intent of the section is to determine when sprinklers are needed and not when they are not.

However, I was presented with the argument that if no openings mean sprinklers are needed... then having the openings mean sprinklers are not needed.

Logic appears sound.

Having them show me the diagram from the commentary which I shared here was also hard to ignore.


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## cda (Apr 17, 2020)

Enri Code said:


> I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.
> 
> The commentary says:
> 
> ...





Does not change any answer, but how are you connected with this, as in what do you do for a paycheck?


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## tmurray (Apr 17, 2020)

Typically, unless the code sections reference one another (usually through a notwithstanding clause), you need to comply with both.

Think about it like this:

506.2 No Sprinklers, 903.2.11 No Sprinklers = No Sprinklers Required
506.2 Requires Sprinklers, 903.2.11 Requires Sprinklers = Sprinklers Required
506.2 No Sprinklers, 903.2.11 Requires Sprinklers = Sprinklers Required
506.2 Requires Sprinklers, 903.2.11 No Sprinklers = Sprinklers Required


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## cda (Apr 17, 2020)

Sorry

That is like saying

I am going to build a booze serving night club.

50000 sq ft

And an occupant load of 10000 people

AS LONG as I provide required openings,,,

I don’t have to install a fire sprinkler system

Very Wrong code application


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## cda (Apr 17, 2020)

F-1 requires sprinklers over 12000 sq ft


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## tmurray (Apr 17, 2020)

Enri Code said:


> I did read that commentary. I've actually used it to argue against using section 903.2.11.1.2.
> 
> The commentary says:
> 
> ...


Yeah, no. You are treating this section like it overrules other sections requiring sprinklers, but what you posted just says it requires sprinklers in some buildings that otherwise don't require sprinklers.


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## Enri Code (Apr 17, 2020)

cda said:


> Does not change any answer, but how are you connected with this, as in what do you do for a  paycheck?



How am I connected to this?: professional skeptic in pursuit of knowledge
What do I do for a paycheck?: whatever it takes. LOL.​
Well I appreciate all your answers. I love the different points of view and I'm taking notes. 

To make it clear, my personal position on this is that it feels a bit of a stretch as it is not very direct and calls for reverse logic to justify. I also don't feel comfortable that most of the underlying justification is not self evident and requires a deep dive into the ICC commentary.

That being said, I took it upon myself to put it into the acid test of people here at the Building Code Forum and see if holds any water.

For purposes of discussions for this forum, I have put aside my personal opinions and am taking the stand to present this alternative to sprinklers and arguments in support for it for everyone's consideration.

I am hoping that I get educated more on this and - depending on overall feedback - either come back to my team in full support of this alternative or be able to shoot it down quick.

Thank you to everyone who are sharing their knowledge.


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## Enri Code (Apr 17, 2020)

tmurray said:


> Yeah, no. You are treating this section like it overrules other sections requiring sprinklers, but what you posted just says it requires sprinklers in some buildings that otherwise don't require sprinklers.



Any thoughts on the other parts of my message? 

Any thoughts about the argument that if not providing openings require sprinklers then having the openings then mean we can do without the sprinklers? 

Have you seen the diagram I posted from the official IBC code and commentary by ICC showing that such a configuration does not require automatic sprinklers? (I'm posting it here again for you).

Thoughts? Thank you.


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## Enri Code (Apr 17, 2020)

tmurray said:


> Typically, unless the code sections reference one another (usually through a notwithstanding clause), you need to comply with both.
> 
> Think about it like this:
> 
> ...



Definitely agree with going with more stringent path but not sure this is the clear case here. This feels more like:

506.2 Requires Sprinklers, 903.2.11 Requires Sprinklers (but alternative to sprinkler is allowed which are openings every 50 feet) = Sprinklers Required... but can be switched to openings every 50 feet????

The alternative - which is stated in an ICC commentary - is being ignored. 

If I am to understand correctly, we should choose to ignore alternates to active fire protection in general because active fire protection should always be treated as more stringent than passive fire protection?


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## cda (Apr 17, 2020)

Enri Code said:


> Any thoughts on the other parts of my message?
> 
> Any thoughts about the argument that if not providing openings require sprinklers then having the openings then mean we can do without the sprinklers?
> 
> ...





Yes i have seen the diagram,, It has been code for YEARS.

You do not seem to get this section:::

*102.10 Conflicting Provisions*

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

*
Plus this section 

F-1 requires sprinklers over 12000 sq ft


And this is the example you are trying to say does not require fire sprinklers::


Given these parameters:
- 200 ft. x 200 ft. (40,000sf area)
- Type 2B construction (pre-engineered metal building)
- F-1 occupancy building
- 30 feet tall (single story)




GO ahead and present it to an AHJ, sounds like you are on the design side, along with your opening proposal,,,,,

If the AHJ has a 1/4 code knowledge, hopefully they are Professional and do not laugh in your face.


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## Enri Code (Apr 17, 2020)

cda said:


> Sorry
> 
> That is like saying
> 
> ...



Definitely wrong application and dangerous to boot but a potential loophole is a loophole. 

Similar to how a disturbing number of schools - lots of assembly spaces - have not sprinklers in this country.

How do most school's get out of this... openings... windows specifically... 

Should this disturb us, hell yes. But is this being allowed... the fact that there are schools without sprinklers... what do you think?

I digress though.

This is why I really want to understand this deeply knowing the possible stakes.

Thanks.


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## Enri Code (Apr 17, 2020)

cda said:


> Yes i have seen the diagram,, It has been code for YEARS.
> 
> You do not seem to get this section:::
> 
> ...




If this was an F-2.
Same thoughts?

Just to be clear. You seem to be ignoring that I actually said from my very first post that it does require a sprinkler, even mentioned why and I am presenting what I was told was an alternate to sprinklers.

Your mind is definitely already set and what I may say next may blow your mind:

There had been projects in the past that were presented this way and were accepted by AHJ. Mostly in the power industry. 

So yes, outside of your knowledge and experience, this had been accepted before for years.


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## e hilton (Apr 17, 2020)

Enri Code said:


> How am I connected to this?: professional skeptic in pursuit of knowledge
> What do I do for a paycheck?: whatever it takes. LOL..​




Ok, here’s my 2 cents.  I’m on the construction side, not the enforcement side.  I’m seeing you as a troll, stirring the pot to see what kind of a reaction you can get.  Apparently you don’t have a vested interest in the situation you describe, you’re enjoying seeing your name in print.  
I could be wrong, I was wrong once, but it was a tuesday ...​


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## cda (Apr 17, 2020)

Enri Code said:


> If this was an F-2.
> Same thoughts?
> 
> Just to be clear. You seem to be ignoring that I actually said from my very first post that it does require a sprinkler, even mentioned why and I am presenting what I was told was an alternate to sprinklers.
> ...




My mind is not set

If someone provides a code provision proving up there project, I have no problem.

When a design is submitted and they cherry pick the code book, and not design to the entire code book,,,, that is when I pick the book up and throw it at them.

No in 30 years I have not seen the opening code used like that or even proposed like that.

As I say if you can get the ahj to let it fly, more power to you, my name is not on it and I will not be live at five.


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## Enri Code (Apr 17, 2020)

e hilton said:


> Ok, here’s my 2 cents.  I’m on the construction side, not the enforcement side.  I’m seeing you as a troll, stirring the pot to see what kind of a reaction you can get.  Apparently you don’t have a vested interest in the situation you describe, you’re enjoying seeing your name in print.
> I could be wrong, I was wrong once, but it was a tuesday ...​


Yes, you are wrong. 

If you actually have an opinion on the topic, I'd appreciate it. 

If being a troll means stirring the pot to see what kind of reaction you can get...  what's the point of you calling me a troll and accusing me of not having a vested interest in the situation and just enjoying to see my name in print?

Nice how you just jumped in to have your name shown here and give your 2 cents. 

Thank you.


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## Enri Code (Apr 17, 2020)

cda said:


> My mind is not set
> 
> If someone provides a code provision proving up there project, I have no problem.
> 
> ...



cda, thank you for all your input. 

Apologies for implying that your mind is already closed on this. Poorly chosen words. Hard to gauge someone from text alone and you were pretty strong in your answers. My bad as I am new here. I now recognize it as passion and I appreciate it.

I am the same, if someone provides information that must lead me to change my position, I need to respect that. This is the reason why I am here as I had mentioned earlier. 

To be honest, I had already written a stern letter a couple of weeks back to my team basically poopooing the interpretation and they were actually for reasons very much the same as you have stated. 

It reared its ugly head again this week though which prompted me to offer it up here for discussion. I feel strongly that my position - which is same as yours - is correct but I tried my best to see it from the other side to really wrap my head around it and as I said... opened myself to be swayed one way or the other based on the strength of arguments.

I am an architect by profession  so yes, your wisdom holds true... I do have a design background - but am now in management but do get involved in engineering and construction as needed and interface with building code officials.

I'm not involved in the project directly but am vested in always improving my team.

To cut to the chase, even as I played devil's advocate, looks like the majority here has overwhelmingly supported my personal belief that this is a "loophole" best kept closed... actually not to be considered at all.

I really appreciate all the constructive and informative inputs. I am a bit shocked about some of the ad hominems by some but then again this is the internet and I really shouldn't be surprised should I? 

Thank you.


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## cda (Apr 17, 2020)

Well a lot of us have been on this forum along time.

Yes we do throw mud at each other every so often,,

But we do it nicely and respect others opinions.

Anyway come on back, we will not block you.


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## e hilton (Apr 17, 2020)

Enri Code said:


> Nice how you just jumped in to have your name shown here and give your 2 cents.


You’re welcome.  
What helps form my opinion is you have been given several credible responses the point out why you’re wrong, and like a petulant child you keep ignoring them and coming back with sophomoric responses. Now that you have said you are an architect ... i see oart of the problem.  “It works on paper”.


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## ICE (Apr 17, 2020)

903.2.11.1 Stories without openings. An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet (139.4 m2) and where the story does not comply with the following criteria for exterior wall openings:

So if a building has a floor area greater than 1500 square feet it shall be sprinkled. ...And any story of any building of any square footage that does not comply with the 20 sq.ft. opening in every 50' shall also be equipped with a sprinkler system.  It's hard to know if that makes any sense...but it reads that way easy enough.

It seems counter intuitive to ventilate a fire through a bunch of doors unless you're intent on collecting insurance.  The idea behind sprinklers is to beat down the fire before the fire dept rolls.

I haven't read all of the posts so forgive me if I ask an answered question.  Have you asked the local departments?  

I noticed that the opening shall be unobstructed.  The openings are expressly stated as being for the fire dept.  So it's definitely a door that they can count on getting through in under a minute.  But here again the purpose is for rescue....because the sprinklers did the bulk of the work.

903.2.11.1.1 Opening dimensions and access.

Openings shall have a minimum dimension of not less than 30 inches (762 mm). Access to such openings shall be provided for the fire department from the exterior and shall not be obstructed in a manner such that fire fighting or rescue cannot be accomplished from the exterior.


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## Enri Code (Apr 17, 2020)

e hilton said:


> You’re welcome.
> What helps form my opinion is you have been given several credible responses the point out why you’re wrong, and like a petulant child you keep ignoring them and coming back with sophomoric responses. Now that you have said you are an architect ... i see oart of the problem.  “It works on paper”.



When you're in a better mood, I invite you to actually read my responses. May come off different... maybe not.

I've actually spent a great deal of time on the field. Actually mixed concrete down to sweeping trailer floors. Got a lot of respect for people on the construction side because I've lived it.

I'm pretty bummed that you seem to have bought into the whole design vs construction rhetoric. I found that things work better when both side respect what each other do. 

Then again, to be honest, I probably have a bunch of construction jokes myself and the bashing on each side can be comedy gold.

Nature of the business... LOL.

Be well.


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## Enri Code (Apr 17, 2020)

ICE said:


> 903.2.11.1 Stories without openings. An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet (139.4 m2) and where the story does not comply with the following criteria for exterior wall openings:
> 
> So if a building has a floor area greater than 1500 square feet it shall be sprinkled. ...And any story of any building of any square footage that does not comply with the 20 sq.ft. opening in every 50' shall also be equipped with a sprinkler system.  It's hard to know if that makes any sense...but it reads that way easy enough.
> 
> It seems counter intuitive to ventilate a fire through a bunch of doors unless you're intent on collecting insurance.  The idea behind sprinklers is to beat down the fire before the fire dept rolls.



Yes, very counterintuitive indeed. One of the arguments I used against this was that the building will truly be dependent on the local fire fighters' response time and to some degree the employees themselves. Basically, an overall downgrade and riskier.

The construction side put a lot more value into cost savings versus expense for a sprinkler so you can see why attention was given towards this. I know... shocking. 

Good that you put up the text to the section but you left out the troublesome criteria. I've posted it on a separate post for clarity's sake.


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## Enri Code (Apr 17, 2020)

For the curious, here's the whole thing with the criteria included:

_903.2.11.1 Stories without openings. *An automatic sprinkler system shall be installed throughout all stories*, including basements, of all buildings *where the floor area exceeds 1,500 square feet and where the story does not comply with the following criteria for exterior wall openings:*_

_1. Openings below grade that lead directly to ground level by an exterior stairway complying with Section 1011 or an outside ramp complying with Section 1012. Openings shall be located in each 50 linear feet or fraction thereof, of exterior wall in the story on not fewer than one side. The required openings shall be distributed such that the lineal distance between adjacent openings does not exceed 50 feet._

*2. Openings entirely above the adjoining ground level totaling not less than 20 square feet in each 50 linear feet, or fraction thereof, of exterior wall in the story on not fewer than one side. The required openings shall be distributed such that the lineal distance between adjacent openings does not exceed 50 feet. The height of the bottom of the clear opening shall not exceed 44 inches measured from the floor.*

So the argument as presented to me was that if we then *do comply* with criteria #2, then we don't need to install the automatic fire sprinkler.

This was the logic hell I had to deal with...


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## cda (Apr 17, 2020)

Enri Code said:


> For the curious, here's the whole thing with the criteria included:
> 
> _903.2.11.1 Stories without openings. *An automatic sprinkler system shall be installed throughout all stories*, including basements, of all buildings *where the floor area exceeds 1,500 square feet and where the story does not comply with the following criteria for exterior wall openings:*_
> 
> ...




They need to learn,,,

You have to read and apply the entire code book.


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## tmurray (Apr 20, 2020)

Enri Code said:


> For the curious, here's the whole thing with the criteria included:
> 
> _903.2.11.1 Stories without openings. *An automatic sprinkler system shall be installed throughout all stories*, including basements, of all buildings *where the floor area exceeds 1,500 square feet and where the story does not comply with the following criteria for exterior wall openings:*_
> 
> ...


For it to link back to 506.2 the way you are suggesting, it would need to say:

"Notwithstanding 506.2, Stories without openings. An automatic sprinkler system shall be installed throughout all stories, including basements, of all buildings where the floor area exceeds 1,500 square feet and where the story does not comply with the following criteria for exterior wall openings..."

Like my previous post said, 506.2 may require sprinklers in isolation. 903.2 may require sprinklers in isolation. There is no interaction between these two sections. As CDA has pointed out multiple times, most restrictive applies.

It is not mental gymnastics. It is not a loophole. You are misinterpreting the code.


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## Paul Sweet (Apr 20, 2020)

903.2.11.1 requires sprinklers in many cases where 506.2 doesn't.  The exception in 903.2.11.1.2 applies to those instances only.  It does NOT override 506.2.

If I remember correctly from long ago, the reason for the 75 ft. limit and the exception for openings on 2 sides was so the fire could be fought from outside the building.


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## classicT (Apr 20, 2020)

Now that this post has settled down...

I am going to throw my voice in with those of sound judgement and state that the requirements of 506.2 are not overridden by 903.2.11.1.2. If that were the case, 506.2 would include a footnote referencing  903.2.11.1.2.

Building must meet the size limitations of 506.2 first and foremost. Ch. 9 provide additional requirements where required given a particular use.


This is not a loop-hole. This is a total misconception and demonstrates a lack of basic code understanding, and in my opinion, shows disrespect to ones own profession.


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## cda (Apr 20, 2020)

I think he was trying to argue someone else’s point of view.

Not what he believes the code to be.


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## Enri Code (Apr 20, 2020)

cda said:


> I think he was trying to argue someone else’s point of view.
> 
> Not what he believes the code to be.


Exactly.


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## Enri Code (Apr 20, 2020)

Ty J. said:


> Now that this post has settled down...
> 
> I am going to throw my voice in with those of sound judgement and state that the requirements of 506.2 are not overridden by 903.2.11.1.2. If that were the case, 506.2 would include a footnote referencing  903.2.11.1.2.
> 
> ...



Good reasoning about 903.2.11.1.2 not being in the footnote of 506.2 and shall we say vice versa. That's a good argument.


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## Enri Code (Apr 20, 2020)

Here's a curve ball:

For people that missed out on my sharing that I was told that Section 903.2.11.1.2 had been used successfully in projects for power plants... I had asked for more information on that. 

It was mentioned that some industrial projects (F occupancies) are Special Purpose Industrial Occupancies... such as power plants.

The provision being that they are exempt from the area or height limitations of Table 506.2.

In fact, some would say they can then totally ignore Table 506.2 in its entirety.

I'm not certain that it can be in fact ignored in total. Wouldn't it just mean that there is no height or area limitation but thresholds for needing fire sprinklers should still apply?

I am being told different. That Table 506.2 should be totally ignored if it is a Special Purpose Industrial Occupancy.

Then... this opens the door to Section 903.2.11.1.2 without any area limitations... 

Not sure if this necessitates another thread but this is an interesting take that I'm not certain of.


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## cda (Apr 20, 2020)

Not into special purpose 

I think I have seen a couple before they got labeled that.

For sprinklers I would say depends on what is going on in the building.

There is always the argument that sprinklers so far off the ground would more than likely never activate,,,, propose an alternative.


One I remember, not sure how high, but high,
There was a conveyor system for metal car bodies, and that was it.
Been to long, but I think they did heats or beams.


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## classicT (Apr 20, 2020)

Enri Code said:


> Here's a curve ball:
> 
> For people that missed out on my sharing that I was told that Section 903.2.11.1.2 had been used successfully in projects for power plants... I had asked for more information on that.
> 
> ...


Typically this type of building will have a Fire Protection Engineer (FPE) who will model smoke and fire. Alternate systems can be used.

As an example, the AHJ that I am with, has an incredibly large freezer that utilized a reduced oxygen environment in-place of sprinklers.


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## steveray (Apr 20, 2020)

Magnesium places hate sprinklers too....


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## TheCommish (Apr 20, 2020)

The ICC has a code  _Performance Code for Buildings and Facilities_. that can be used as an alternative method of protecting buildings and occupants, it is a bit of a process, that weights goals, functional objectives, performance criteria, verification methods, and acceptable solutions. this method could be used for large high spaces, possibly generation plants.

It has companion documents in the NFPA and Society of Fire Protection  Engineers. 

Using it is a detailed process with modeling of fire and people's behavior in structures to achieve the goals,  risks, and costs the stakeholders are willing to accept and maintain.


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## Enri Code (Apr 22, 2020)

Ty J. said:


> Typically this type of building will have a Fire Protection Engineer (FPE) who will model smoke and fire. Alternate systems can be used.
> 
> As an example, the AHJ that I am with, has an incredibly large freezer that utilized a reduced oxygen environment in-place of sprinklers.



I am familiar with hypoxic systems or ORS (Oxygen Reduction Systems). Had experienced using it on a high bay automated storage system. I can see how it make sense in a large freezer where water is not ideal. For it to use ORS, I am assuming it is a fully automated operation because it would need to be otherwise unoccupied hence I see how it can slide into the special industrial occupancy classification.

For the freezer warehouses I've been involved in which had people operated forklifts, we just used a pre-action dry system.

Overall, it goes to show how there is space for alternate to fire sprinklers but of course it needs to be justified and ideally worked on by an FPE with the AHJ as you had illustrated.

Thanks for the insight.


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## Enri Code (Apr 22, 2020)

steveray said:


> Magnesium places hate sprinklers too....



Those water reactive elements are tricky for sure. That's why sometimes the answer is not "just sprinkler" because that's what the code says. There are nuances and the code does offer room for alternatives to fire sprinklers in recognition of different scenarios.

This is why I had some issues just blindly accepting responses that totally discount alternatives and appreciated responses that delved more into reasons on why the alternative may not be acceptable.


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## Enri Code (Apr 22, 2020)

TheCommish said:


> The ICC has a code _Performance Code for Buildings and Facilities_. that can be used as an alternative method of protecting buildings and occupants, it is a bit of a process, that weights goals, functional objectives, performance criteria, verification methods, and acceptable solutions. this method could be used for large high spaces, possibly generation plants.
> 
> It has companion documents in the NFPA and Society of Fire Protection  Engineers.
> 
> ...



Thanks for the reference.

I do find that the NFPA tend to delve deeper into specific issues and tend to define things into more details. 
It's funny then that I often encounter the question from people: "So what do we follow? IBC or NFPA? Building official or fire marshal?"

I see them as complementary to each other. But yes, there may be times when they may conflict or one may address something that the other doesn't.

When in doubt use the more restrictive then? In practice though, I do see how people lean on the IBC more by default and only ever touch on NFPA if something comes up with the fire marshal.


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## Enri Code (Apr 22, 2020)

cda said:


> Not into special purpose
> 
> I think I have seen a couple before they got labeled that.
> 
> ...




This is very true about the dilemma of having great ceiling heights and having an effective sprinkler. 
We would usually go deluge or mist if applicable. In-rack if there are storage racks (high pile storage provisions...).

Definitely, depending on what's going on inside or what's in it, an alternative is appropriate... even one that's not a sprinkler.

For example, for a large garage or aircraft hangers with fuel, if may be a foam.


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## mtlogcabin (Apr 22, 2020)

We just did a 24,000 sq ft fertilizer storage building all wood no fire suppression system at all. 300 feet clear space around the entire building and if it catches fire the fire department will stand by and watch it burn as adding water will be a pollution nightmare. Owners are a large corporation that are self insured and the loss of the building and product is minuscule in relation to the environmental cleanup cost if water is added to the fertilizers.


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## cda (Apr 22, 2020)

Enri Code said:


> Thanks for the reference.
> 
> I do find that the NFPA tend to delve deeper into specific issues and tend to define things into more details.
> It's funny then that I often encounter the question from people: "So what do we follow? IBC or NFPA? Building official or fire marshal?"
> ...




Normally the ahj is only allowed to enforce what codes/ standards are adopted.

The i codes allow other codes to be used, as approved by ahj


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## cda (Apr 22, 2020)

mtlogcabin said:


> We just did a 24,000 sq ft fertilizer storage building all wood no fire suppression system at all. 300 feet clear space around the entire building and if it catches fire the fire department will stand by and watch it burn as adding water will be a pollution nightmare. Owners are a large corporation that are self insured and the loss of the building and product is minuscule in relation to the environmental cleanup cost if water is added to the fertilizers.




Guess it is not miracle grow, otherwise the runoff would make greener grass and very large tomatoes.


I thought you were going a different way,,, one owner said,,, insurance is cheaper, than the fire protection you want me to install.


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## Enri Code (Apr 24, 2020)

cda said:


> Guess it is not miracle grow, otherwise the runoff would make greener grass and very large tomatoes.
> 
> 
> I thought you were going a different way,,, one owner said,,, insurance is cheaper, than the fire protection you want me to install.





mtlogcabin said:


> We just did a 24,000 sq ft fertilizer storage building all wood no fire suppression system at all. 300 feet clear space around the entire building and if it catches fire the fire department will stand by and watch it burn as adding water will be a pollution nightmare. Owners are a large corporation that are self insured and the loss of the building and product is minuscule in relation to the environmental cleanup cost if water is added to the fertilizers.



Well it happens more than people think. Sometimes the fire sprinkler cost or the maintenance for one isn't something the owner, developer on construction people are keen on spending on. In some cases, it's just all about minimizing the loss by compartmentalizing the bigger area into smaller fire zones with fire walls - not necessarily required by code - which are more known as MFL walls or "Maximum Foreseeable Loss" walls... where they take the chance that the building will burn but controlling how much goods will be potentially lost so that it squares with insurance or risk tolerance of the company. 

Environmental concern... also very valid.


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## Enri Code (Apr 24, 2020)

cda said:


> Normally the ahj is only allowed to enforce what codes/ standards are adopted.
> 
> The i codes allow other codes to be used, as approved by ahj



Who the AHJ are also wildy varies sometimes depending on where a project is. I've had projects where the AHJ is outsourced, or not really a building official, or solely the fire marshal, or even the owner themselves and what they say goes!


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