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Enclosed parking garage without sprinklers 3

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richburton

Specifier/Regulator
Dec 11, 2009
19
It should seem reasonable that a stand-alone commercial garage with five or six parking bays will not have a sprinkler system. It should seem reasonable that it will not have a mechanical ventilation system.

IBC 903.2.10 would exempt any enclosed parking garage from being sprinkled if the fire area is less than 12,000 S.F. And we are not talking about a repair garage or the storage of commercial vehicles weighing more than 10,000 lbs each.

In other words, such a garage could be a basic plywood box without power, water, or heat. Add six overhead garage doors measuring 8 feet wide and we are done. Right?

Meanwhile, we take a look at NFPA 88A Standard for Parking Structures. Below is the relevant excerpt:

6.4.3 Automatic sprinkler systems shall be installed in enclosed parking structures located at or above grade, or within or immediately below a building used for another occupancy.

Exception: Enclosed parking structures described above, having an approved, supervised, automatic fire detection system and alarm system installed throughout the parking area in accordance with NFPA 72 and a mechanical ventilation system in accordance with 5.3.2.

6.6.2 An approved, supervised, automatic fire detection and alarm system shall be installed in enclosed parking structures having a mechanical ventilation system, located at or above grade, or within or immediately below a building used for another occupancy.

Exception: Enclosed parking structures described above in 6.6.2, having an approved automatic sprinkler system installed throughout in accordance with NFPA 13.

3.3.2.3 Parking Structures, Enclosed. Any parking structure that is not an open parking structure.

- - - end of NFPA 88 excerpts

Question:

I do not believe that a simple commercial garage needs a sprinkler system. I do not believe that it needs an alarm system. I do not believe that it needs a mechanical ventilation system. What exceptions (within the NFPA codes) are there for not requiring either a sprinkler system or an alarm system?

Thank you,

ICC Certified Plan Reviewer
NFPA Certified Fire Plan Examiner
 
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For the most part, NFPA are not codes but standards and there is a difference.

Does the governing building code in your area reference this particular section of NFPA?

If not, then it doesn't apply.
 
We enforce NFPA 1 Chapter 29 which makes reference to "parking garages" which defaults to NFPA 101 Life Safety Code Section 42.8.

Life Safety Code 42.8.1.4 Incidental parking to other occupancies... is not the basis for overall occupancy classification.

So far, I have found no square foot threshold or similar exception. So if you have three doctors who ride their mopeds to work and park all three mopeds in a single stall garage... SPRINKLE IT! Or add smoke detection and a mechanical exhaust system. We would all agree that this is ridiculous.

So I am still hoping to find an exception within the NFPA family of codes.
 
As stated above by Pedarrin2 to reference the governing building code and also to discuss it with your state fire marshal and your local fire department.
"... So if you have three doctors who ride their mopeds to work and park all three mopeds in a single stall garage... " is that the real situation in your case?
 
I have already given the relevant code references. And it seems to surprise folks that we enforce both the IBC and NFPA equally.
I am the Authority Having Jurisdiction who enforces the 2012 IBC with a few local amendments. And I share this responsibility with one other who specializes in the NFPA codes. But we are both a little stumped.
Although we have an entire bookcase of NFPA codes, we are looking for someone who knows more than we do.

No, I do not have three doctors riding around on mopeds. I say that to make my point. This is a relatively small parking structure. We have a lot of small commercial parking structures within our small community of 285,000 people.
More specifically, we are dealing with a five stall garage with the sixth bay converted into an office. Four of the six bays will have cars that are for sale. Therefore it will be considered a mercantile "M" occupancy. The fifth stall will be employee parking for the person selling those cars. And I have already mentioned that the sixth bay is an office. The office will be separated from the other five bays with a two-hour fire-rated barrier. Inside the office is a unisex restroom with one toilet and one sink. Does it help anyone answer this question if they know that this is not your average "parking structure"? No, it does not.

According to our study of the local regulations, the basic pages of NFPA point to more specific pages of other NFPA standards. So unless I can rip out pages that I don't like, I am forced to connect the dots along a pathway that leads me to a ridiculous conclusion.
My conclusion is that there is nobody within this forum that can help me find an exception within the NFPA standards. Meanwhile we will not require the used car salesman to add a fire sprinkler system to a 2,000 S.F. wood framed building. And we will not require smoke detection that triggers an alarm and a mechanical ventilation system. Despite the fact that the aforementioned codes would otherwise require one of these two options.

In search of relevant exceptions.

Thank you,

ICC Certified Plan Reviewer
NFPA Certified Fire Plan Examiner
 
Well your third post has a little more detail of what is going on.

Would have to look at NFPA 1 for definition of mercantile

You say it applies to a storage garage and office ? Unless it falls under showroom?
 
Ok not into 101 much

So a showroom does fall under Mercantile.

So four garages with one car in each space?? or are they bigger and can get more cars in them?

So if you call it a Mercantile, than this kicks in, and not enclosed parking::



36.3.5 Extinguishment Requirements.
36.3.5.1

Mercantile occupancies shall be protected by an approved automatic sprinkler system in accordance with 9.7.1.1(1) in any of the following specified locations:

(1)

Throughout all mercantile occupancies three or more stories in height
(2)

Throughout all mercantile occupancies exceeding 12,000 ft2 (1115 m2) in gross area
(3)

Throughout stories below the level of exit discharge where such stories have an area exceeding 2500 ft2 (232 m2) and are used for the sale, storage, or handling of combustible goods and merchandise
(4)

Throughout multiple occupancies protected as mixed occupancies in accordance with 6.1.14 where the conditions of 36.3.5.1(1), (2), or (3) apply to the mercantile occupancy


 
You have a simple option. Propose a local amendment to the governing body that adopts the local fire / building code. Get that amendment passed and put in that exempts these structures from requiring protection. Until then, you are stuck.

Is there a way to re-classify the occupancies?

By not enforcing the adopted codes / standards for the area, are you exposing your jurisdiction to problems should something bad happen? I get that it seems onerous to provide protection for these spaces. But, if that is what the adopted code / standard for the local area requires, then that's what they have to do. Have them hire a fire protection engineer to do some type of equivalency study to see if there are other things that can be done to eliminate the fire sprinkler requirements.

Travis Mack, SET, CWBSP, RME-G, CFPS
MFP Design, LLC
 
In this particular case, we chose to classify this as a small mercantile occupancy (they sell cars) in order to get away from any NFPA requirements related to a parking garage. But now our eyes are open to this NFPA 88A requirement and we have a lot of small commercial parking structures.

A better plan below:
 
 https://files.engineering.com/getfile.aspx?folder=f388b638-c8f8-430e-8616-141ea06c8402&file=FloorPlan.pdf
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