Understanding concealed space sprinkler requirements
BY MATT KLAUS
ONE OF THE CHALLENGING THINGS about the codes and standards world is that there can be varied interpretations on how a standard is applied. Sometimes our interpretations vary geographically or depending on the role we play in the fire protection and life safety community. While the NFPA technical committees do a painstaking job in making sure the language is clear and can be enforced only in the manner that the technical committee intended, in some cases there are issues where not everyone is on the same page.
One such case is the idea of providing automatic sprinkler protection in attics. NFPA 13, Installation of Sprinkler Systems, the standard for the installation of automatic sprinkler systems, never specifically addresses whether or not an attic requires sprinkler protection. The starting point to determining if attics require sprinkler protection is Section 8.1, which basically says to protect all spaces unless there is a specific exemption somewhere in the standard. Since there is no specific “attic sprinkler exemption” in NFPA 13 (as there is in NFPA 13R and NFPA 13D), many people think that all attics require sprinklers.
The real answer requires going a bit deeper. Since there is no exemption for "attics,” users of the standard must navigate its various sections on concealed spaces to determine whether or not their particular attic can be considered a concealed space that doesn’t require sprinklers. Therefore, whether an attic space requires automatic sprinklers is not dependent on the fact that it has been labeled an attic on the plans, but rather upon the construction of the space, the contents of the space, access to the space, and the ability to occupy the space.
Currently, there is some confusion on whether or not attics can even be considered concealed spaces. This is largely because NFPA 13 does not declare attics to be concealed spaces since not all attics are created equally from a fire development and fire spread perspective. Therefore, the standard allows the hazards present for an attic space to determine whether it can be considered concealed and whether or not sprinkler protection should be provided.
Since there is no blanket declaration that attics are (or are not) considered concealed spaces, the rules of paragraph 220.127.116.11 .1 would allow for the omission of sprinklers provided the specific criteria in the relevant subsection is met. Adding to the confusion are two different staff interpretations issued by NFPA staff members in the last five years. The first interpretation stated that attics cannot be considered concealed spaces and therefore always require sprinklers. The subsequent staff interpretation attempts to clarify this issue (much in the same way that this article is attempting to do), stating that attics can be concealed spaces and therefore do not always require sprinkler protection.
Rather than looking at how the space is labeled on the plans, the sprinkler system designer and reviewing authority should consider the following: What are the materials of construction? Can the space be occupied? Are goods stored in the space? What is the quantity of combustible material? What level of access is provided to the space? In answering these questions, the sprinkler system designer and AHJ will be able to determine if one of the permissible sprinkler omissions for concealed spaces in paragraph 18.104.22.168 can be applied. For more on this issue, join the discussion on Xchange, NFPA’s online community site.