Shoppers walk through a multi-level shopping mall

Special Provisions for Mall Structures

Even though online shopping has become the norm in today’s digital age, many people have still been inside a shopping mall. While most shoppers have probably never experienced a mall fire firsthand, a quick google search shows that mall fires are actually fairly common—not just in the United States but also across the globe. 

In June, a fire broke out in the Somerset Mall in Troy, Michigan. The fire started in the kitchen of a Capital Grille. Since then, there have been a number of other fires in malls, including two in October. One occurred on the upper floor of a mall in Islamabad, Pakistan, while another occurred in exhaust ventilation ductwork in a mall in Honolulu, Hawaii. Although a number of issues were reported in the Islamabad fire, such as obstructions to the means of egress, no one was killed in either of these incidents. 

So how does NFPA 101®, Life Safety Code®, work to protect occupants in malls? Well, there are provisions specific to mall structures that can be found in 36/37.4.4 of the 2021 edition of NFPA 101.

What is a mall?

Often, the term “mall” is unofficially used to describe several different types of structures, including strip malls, enclosed malls, or even city-like malls that span millions of square feet. The Life Safety Code has particular definitions, though, meaning a structure may be described as a “mall” but not technically considered a mall per the code. Below are some key definitions from the Life Safety Code to review before diving into the requirements.

Mall structure

A mall structure is defined by NFPA 101 as “a single structure enclosing a number of tenants and occupancies wherein two or more tenants or tenant buildings have a main entrance into one or more mall concourses.” The code goes on to say that “anchor buildings shall not be considered as a part of the mall structure.” That definition uses the term anchor building, which is also defined by NFPA 101. 

Anchor building 

An anchor building is “a building housing any occupancy having low or ordinary hazard contents and having direct access to a mall structure, but having all required means of egress independent of the mall concourse.” A good example of an anchor building would be a department store that connects to a mall but that has its own dedicated entrances/exits. Again, the code definition of an anchor building uses another term—mall concourse. So what is a mall concourse?

Mall concourse

According to the code, a mall concourse is “a common pedestrian area within a mall structure that serves as access for two or more tenants and does not exceed three levels that are open to each other.” 

A mall concourse can be open or enclosed. In order to be considered open, one of two conditions needs to be met. The first is that at least 50 percent of the total area of the perimeter walls and roof of the concourse are open to the atmosphere. The openings need to be evenly distributed over the length of the concourse and cannot be concentrated in one particular area. The second condition is that an engineering analysis shows that the smoke layer interface is at least 6 feet (1,830 millimeters) above the highest walking level surface open to the mall concourse. That minimum 6-foot (1,830-millimeter) smoke layer interface height must be maintained for 1.5 times the calculated egress time, or 20 minutes, whichever is longer.

A mall can have multiple concourses, but each of those concourses can be open to no more than three levels. If a building has a concourse that connects more than three levels, it cannot be considered a mall concourse, which means the requirements and allowances in 36/37.4.4 cannot be applied. 

Protecting a mall

The provisions of 36/37.4.4 are only applicable to mall structures that are three or fewer stories in height. If a building meets the definition of a mall, then a designer may choose to utilize 36/37.4.4 but is not required to. The other option would be to protect the building as a multiple occupancy building in accordance with 6.1.14. The special provisions of 36/37.4.4, however, are intended to address the common design challenges and unique features of mall structures, such as travel distance, plastic signs, kiosks, smoke control, occupant notification, and automatic sprinklers. 

Let’s take a closer look at some of the select requirements for new mall structures. 

Travel distance

Travel distance can be a challenge in mall structures, particularly on the mall concourse. The travel distance within the tenant space must comply with the occupancy chapter; the travel distance within these spaces is measured to an exit or to the mall concourse. An additional 200 feet (61 meters) of travel for enclosed mall concourses, or 300 feet (91 meters) of travel for open concourses, is permitted provided certain criteria is met. The criteria include requirements for minimum clear width for the mall concourse, minimum widths for exits, automatic sprinklers, construction of walls between tenants, and smoke control for mall concourses connecting more than two levels. 

Many malls utilize exit passageways to help them comply with the travel distance requirements. An exit passageway is a protected path of travel with strict limitations placed on what openings, penetrations, and equipment is permitted in the exit passageway. If you were to take an exit stair enclosure and rotate it 90 degrees, so instead of running vertically, it ran horizontally, you would have an exit passageway.

Plastic signs

Unique to malls is the number of plastic signs present. To minimize the contribution of plastic signage to fuel load and fire growth, a number of restrictions are placed on plastic signs. Plastic signs are permitted to cover no more than 20 percent of the wall area facing the mall concourse. There are also maximum sizes for signs, minimum distances between signage and adjacent tenant spaces, and restrictions on the types of materials permitted.


Another unique feature of malls is the presence of kiosks. Kiosks, whether temporary or permanent, are considered tenant spaces and must comply with several requirements. There are requirements related to the construction materials of combustible kiosks, horizontal separation distances between kiosks, or groups of kiosks, and other structures, and a maximum area of 300 square feet (27.8 square meters) for each kiosk, group of kiosks, or similar structure.

A kiosk inside a shopping mall
Roboshields via Wikipedia 

Smoke control

A smoke control system is required for all new enclosed mall concourses that connect more than two stories. While a smoke control system is required, there are options in how the system is designed. It could be a completely separate mechanical exhaust system, or it could be a mechanical exhaust system in conjunction with HVAC systems. Another option would be automatically or manually released gravity roof vent devices. The designer may choose to combine any of those types of systems or could choose another engineered system.

Occupant notification

At any time the mall concourse is occupied, the fire alarm system, once initiated, must either activate a general alarm in accordance with 9.6.3 (positive alarm sequence is permitted) or use voice communication or a public address system in accordance with It should be noted that visible signals are not required in mall concourses.

Automatic sprinklers

A supervised automatic sprinkler system is required throughout all mall structures and all anchor buildings. The sprinkler system must be capable of having any portion of the system serving tenant spaces taken out of service without affecting the operation of the portion of the system that serves the mall concourse. Any shades, canopies, awnings, or similar structures in an open mall concourse must be protected with automatic sprinklers. Kiosks or similar structures within enclosed mall concourses must be protected throughout with automatic sprinklers.


The special provisions of 36/37.4.4 are there as an option for designers to use to help address the unique features of a mall. However, it is imperative that before utilizing these requirements, designers ensure the structures do in fact meet the definitions associated with mall structures.

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Valerie Ziavras
Technical Services Engineer, supporting product and content development throughout the association.

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