NFPA 13R 4 story Hotel - Bldg official calling ASSEMBLY for breakfast seating area?

[cupcars]

4-story wood structure hotel with no retail or public spaces such as a restaurant or bar.
Building Official says the whole building has to be an NFPA 13 system because breakfast seating area
is considered "Assembly" and there is no horizontal fire barrier between the first & second floor.

They do have exceptions such as sqft & occupancy load. I believe
their max area was 735 sqft (15 sqft per person x 49 max occupancy load = 735 sqft) so their
solution was to make the breakfast area's smaller than 735 sqft, then it could be an NFPA 13R system.
I argued that this breakfast seating area is just part of a hotel.

They were not interested in what NFPA 13R says in Annex A (A.1.1)

THIS IS WHAT THEIR GOING BY:

SECTION 303 ASSEMBLY GROUP A

303.1 Assembly Group A. Assembly Group A occupancy includes, among others, the use of a building or structure, or a portion thereof, for the gathering of persons for purposes such as civic, social or religious functions; recreation, food or drink consumption or awaiting transportation.

Exceptions:

1. A building or tenant space used for assembly purposes with an occupant load of less than 50 persons shall be classified as a Group B occupancy.

2. A room or space used for assembly purposes with an occupant load of less than 50 persons and accessory to another occupancy shall be classified as a Group B occupancy or as part of that occupancy.

3. A room or space used for assembly purposes that is less than 750 square feet (70 m2) in area and accessory to another occupancy shall be classified as a Group B occupancy or as part of that occupancy.

4. Assembly areas that are accessory to Group E occupancies are not considered separate occupancies except when applying the assembly occupancy requirements of Chapter 11.

5. Accessory religious educational rooms and religious auditoriums with occupant loads of less than 100 are not considered separate occupancies.

Assembly occupancies shall include the following:

A-2 Assembly uses intended for food and/or drink consumption including, but not limited to:

Banquet halls

Night clubs

Restaurants

Taverns and bars




BUT THEN YOU HAVE THIS:

903.2.1.2 Group A-2. An automatic sprinkler system shall be provided for Group A-2 occupancies where one of the following conditions exists:

1. The fire area exceeds 5,000 square feet (464 m2).

2. The fire area has an occupant load of 100 or more.

3. The fire area is located on a floor other than a level of exit discharge serving such occupancies.



My question: Is the breakfast seating area really considered a part of the assembly code (IBC 303.1 Group A-2) or
should the space be incidental to the residential (R2) that the building is.

I've designed many NFPA 13R Hotels and this is a first...

Thanks!!

JC

 

[TravisMack]

First, verify if NFPA 13R is the applicable code. As in previous threads in this forum, it is not always cut and dry that a hotel less than 4 stories is 13R.

Did they take an area increase? If so, 13R not applicable.
Did they put in the proper draft stopping? If not, 13R may not be applicable.
Has there been other trade-offs that would mandate an NFPA 13 system?

So, before you take on this fight, make sure you are in the right in the first place. I know it should not be a sprinkler tech's position to determine the correct standard, but it often falls to us on that.

Based on what you posted above, it seems exception 2 or 3 could be used to say that it is just part of the R-2 occupancy, unless I am mis-understanding something in your post.


Travis Mack
MFP Design, LLC

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[cupcars]

Thank you for your reply!

Yes, there will be draft stops every 3000 sqft or two guest rooms per IBC.
The only thing in question is the City Code Official is saying the Breakfast seating
area is "Assembly" and the sqft of that space will determine if it is a NFPA13 or NFPA 13R.
Nothing else is in question as to which system type it can/cannot be.

This is the answer I received from NFPA:

As indicated in A.1.1, if the accessory or incidental occupancy is part of the predominant residential occupancy, NFPA 13R can be used throughout the entire building. The following paragraph indicates that NFPA 13 is only required when the residential portion is not the predominant occupancy within the building. If the residential portion comprises the majority of the building, NFPA 13R can be used in all locations for which it is applicable. The building would not be required to be sprinklered in accordance with NFPA 13.

I am not an expert on NFPA 101 or the building code so I cannot comment on the requirements in those documents, including whether the eating area would be classified as an assembly space. It is not the intent of Residential Sprinkler Technical Committee to require a NFPA 13 system throughout a predominately residential low rise building simply because of ancillary spaces for the primary occupancy.

Regards,

Audrey Goldstein
Fire Protection Engineer
National Fire Protection Association

 

[TravisMack]

Get your architect involved. He is the one that does the code study and determines occupancy types. Have him convince the AHJ that the breakfast area is not required to be an A occupancy based on your exceptions noted above. Also, show the AHJ your interp from NFPA.

I agree that it seems strange to force the entire hotel to be NFPA 13 due to this space.

Travis Mack
MFP Design, LLC

http://www.mfpdesign.com

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[cupcars]

Thanks again for the reply!!

We've already had a meeting at the City Code Official's office.
The Architect was there and he was no help. He would just assume
we install an NFPA 13 system in the building but the owner wants
an NFPA 13R. The Architect is trying to spend the owners money.....

I've done at least 20 hotels in the last 5 years and
all of them had a NFPA 13R system installed.

I have done some NFPA 13 Hotels but their usually 5+ stories.

Thanks again!

 

[stookeyfpe]

The IBC dictates when a NFPA 13 or NFPA 13R system is allowed - the NFPA sprinkler standards do not. Now I will grant you that there can be bleed-over between the IBC and NFPA sprinkler standards but at the end of the day the Building Official has the authority to make the decision. Plus, we're all at a little bit of a disadvantage without a drawing, knowing which edition of the IBC is adopted and, not knowing if the section was amended by the jurisdiction.

Under the IBC the jurisdiction is required to have a Board of Appeals. That may be an option. However, as written in the IBC, the BOA can only rule if the interpretation was correct or incorrect - they cannot waive code requirements.

 

[TravisMack]

Hey Scott....that is EXACTLY what I have been trying to get across to the architects and even some sprinkler contractors in the area. Just because 13R says residential and 4 stories or less, that doesn't mean that ALL of those buildings can be per 13R. As you state, the building code tells us which standard to use. This is hard to get some to understand, but it is critical.

Travis Mack
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[SprinklerDesigner2]

It is for this reason I have always required a written correspondence from the building design professional, usually the registered architect, telling me what standard I am to use. Never will I decide what standard to use.. thanks to many people here I can venture a pretty good guess but I would never advise or act upon what I came up with.

Does the OP understand that a single story apartment or motel might require a full 13 system depending on building construction type and size of footprint?

Some of em might not like it but that's their job and I make em do it. That's their (the architects) job, damn it!

 

[cupcars]

Thanks for the reply's.

Attached Bldg footprint is 12,571 sqft. Upper floors all guest
rooms and same sqft. IBC code 2009. City has not amended the code.

Their calling the breakfast & gathering area's assembly,
The meeting room as well. This is the only thing making
this Hotel an NFPA 13 system per the Building Official.

Thank you,

JC

 

[MatthewJWillis]

Is there a Code Summary Sheet?

R/
Matt

 

[cupcars]

Strangely...no. Not in the drawing set I was given.

 

[TravisMack]

You need that. How did you determine 13R was applicable without a code study sheet? You do realize that NFPA 13R is not applicable for all residential buildings 4 stories or less, right?

If that job is Type VB construction, the architect will have needed that fire sprinkler increase for area -> NFPA 13 required
If it is Type VA and no frontage increase is available -> NFPA 13 required

The architectural code study is critical to determine the design standard to be used. This is what we have been trying to get through. The AHJ may be reaching to require NFPA 13 just based on the assembly area there. But, you may also be reaching to apply NFPA 13R to a building where the IBC does not permit an NFPA 13R system.

We have to be able to know the right questions to ask in order to get the answers we need to do our jobs to design a system that meets the appropriate code. Remember, codes says when and what type of system. NFPA "standards" just tell you how to do what the building codes says you have to do.

Travis Mack
MFP Design, LLC

http://www.mfpdesign.com

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[MatthewJWillis]

Based on the limited information, and the whole assembly thing not withstanding, the footprint alone based on your description, mandates NFPA #13.
12k Sq. Ft. is max allowed for R-2 Type V-A, V-B (basically wood). You have stated you are @ 12.5k


I would request a Code Summary.

I was curious as to why the Arch was silent during the meeting....

R/
Matt

 

[TravisMack]

Matt:

There are also frontage increases that the architect can use to get an area increase. I believe it maxes around 70%. So, if it is VB, they can't get the area increase with frontage alone to get to 12.5k sq ft.

If it is VA, then they may be able to get the extra area with frontage increases.

There are other ways as to put fire area separation walls and things like that. But, without a code study plan, it appears that the OP is just stating NFPA 13R is applicable to all residential occupancies that are 4 stories or less. That is obviously not true.

Travis Mack
MFP Design, LLC

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[MatthewJWillis]

Yeah, I know it is a small increase and looks like what it may be. But, without the thought process...


R/
Matt

 

[fpst]

OK, this business about "how do you determine which standard to use" was confusing to me as well so I researched it.
It turns out, the IBC, IFC, and what your building official says is all just part of the story.

You need to think about this in terms of a hierarchy. Just because something has a title, like "international building code" doesn't mean that it's universally adopted or enforced. Even if it said "universal building code" it would not be so. You could go out to some rocky terrain sticking out of the ocean nearby but not within Antartica and build a building however you want, because there is no enforcement of the IBC/IFC there, for example.

Here is a handy map for the adoption of IBC, IFC, and related codes.

http://www.iccsafe.org/about-icc/overview/international-code-adoptions/

On the maps, you can see, for example, the IRC is not adopted in Wisconsin, and the IFC is not adopted in Florida and some others.

Now, it's also important to realize that there are different ways codes/standards are adopted and enforced. Some at the state level, some at the local level, with varying nuances by region.

Every state can have amendments for these codes as well.
Every county can have even more amendments, even down to the individual city level sometimes.
Here are some resources on that subject:

http://www.iccsafe.org/gr/Documents/AdoptionToolkit/CodeAdoptionProcessState.pdf

http://www.iccsafe.org/gr/Documents/AdoptionToolkit/HowStatesAdopt_I-Codes.pdf

Now, I only know about my state in any detail, and that is Georgia.
In Georgia the codes are adopted at the state level, with state level amendments to them. There may be local amendments as well in some localized areas.

Now, who ultimately decides what occupancy, standard, and layout etc. is acceptable within any U.S. region? It's the agency responsible for enforcing the adopted codes. This can change within a single project - for example, let's say in a local area you have a Warehouse that is locally enforced by a city building official, such as a fire department plans examiner, but then they add a stage and a bunch of seats for doing opera's in the warehouse and it elevates to a state-level job, in which case a fire marshal representative would be the enforcer of the adopted codes and standards.

So, which standards and codes do you have to obey? All of them up through the potential hierarchy. Obviously, no Georgia job is going to be enforced by a representative of the state of Florida, so you know you only need to worry about the hierarchy starting with the state-level of Georgia and working down to local areas.

However, where in any of these adopted codes and standards in any U.S. state does it permit anyone besides the designated code official (such as fire marshal or local code examiner) to determine what occupancy, standard (such as NFPA 13 vs. 13R), and layout is acceptable? None do. At the end of the day, unless you can get the local examiner overruled by a higher-up, or a fire marshal representative over-ruled by an actual fire marshal, or any of them over-ruled by a judicial body like the board of appeals, the law is that it's up to the interpretation of the AHJ what goes and what doesn't. The codes and standards are there to guide the AHJ and all involved so this process goes smoother, but no where does it say you or anyone but the AHJ or judicial body has the final say on what is correct or not. Therefore, when something is ruled not to be correct, your only hope is not to be directly financially responsible for the problem. The only way to achieve this is to have the architect, or someone else on the hierarchy above you, specify an occupancy and installation standard. If that is done, it's then your responsibility to correctly apply the related installation standards and regional rules to the design, installation, and testing of the sprinkler system.

From a legal standpoint, if the architect or EOR specifies something such as NFPA 13R which is wrong and does not say that you are liable for his mistakes on that subject, then he is liable for any mistakes in the eyes of whoever is paying for the job, which is all that matters when something needs to get fixed.

If the architect or EOR specifies something which is wrong and puts the liability on you to cover and mistakes, your only hope is to write to the AHJ and ask if it's correct before you even bid the job. If you don't get an answer back, your only out is to specify in the bid that your bid is based on what the architect specified, and that it may not be correct to the AHJ, even though you made every attempt to verify and clarify that, no response has been given and the bid due date is about to expire. Then, also specify that any change orders needed per the AHJ's final decision is not included in your bid price and should be expected if the architect or AHJ won't give you a solid answer, as you have no authority to claim a final decision on the occupancy or installation standard.

It's unfortunate that all of this needs to be said, but in my opinion it does and it's currently what I would do, even though I'm not in that position yet, and that may change as I learn more, but this is what I've gleaned so far from my mentor.

 

[stookeyfpe]

Based on the occupancy the IBC would require Type V-A construction.

And to the question of the code analysis, it's required by IBC Section 106 and Section 107.

 

[cdafd]

Looks like the "meeting room is assembly also

30x36 feet??


And the ""gathering zone"" possibly too??