Author(s): Ron Cote. Published on November 4, 2014.

SPRINKLER SYSTEMS PLAY a key role in the level of life safety provided by compliance with the requirements of NFPA 101®, Life Safety Code®. NFPA 101 remains true to its role as a code by setting the thresholds under which sprinkler protection is required and by establishing alternatives to prescriptive life safety requirements that can be safely offered in a sprinklered building. The code’s requirements are written in deference to the expertise provided by NFPA 13, Installation of Sprinkler Systems. NFPA 101 avoids extracting or otherwise duplicating the provisions of NFPA 13. Instead, it mandates the use of NFPA 13 as a condition for achieving compliance.

The 2015 edition of NFPA 101 mandates the use of the 2013 edition of NFPA 13. The retroactivity statement in NFPA 13 explains that its provisions are meant for application to new sprinkler system work. Yet, NFPA 101 applies both to new construction and to existing installations. NFPA 101 provides guidance for meshing its requirements with those of a referenced installation standard so as to avoid misapplication to an existing situation. It permits an existing installation that does not comply with provisions of a referenced standard to be continued in use, provided that the lack of conformity does not present a serious hazard to the occupants, as determined by the authority having jurisdiction (AHJ).

For example, a sprinkler system installed 25 years ago in a business occupancy building (i.e., a light hazard occupancy for purposes of applying NFPA 13) has standard response sprinklers. Travel distance exceeds the 200-foot (61-meter) limitation applicable to nonsprinklered business occupancy buildings, but is within the 300 feet (91 meters) permitted for buildings sprinklered in accordance with NFPA 13. Since 1999, NFPA 13 has required that sprinklers in light hazard occupancies be quick response (QR). The sprinkler system in this example does not comply with the QR requirement of the currently referenced edition of NFPA 13. Even so, it is allowed to continue in use, as the lack of QR sprinklers does not present a serious hazard to the occupants, as judged by the AHJ.

NFPA 101 also clarifies in its introductory text that where the requirements of a referenced standard differ from those of the code, the requirements of the code govern. For example, NFPA 101 permits sprinklers to be omitted from bathrooms of individual living units in an apartment building, provided the bathroom does not exceed 55 square feet (5.1 square meters). NFPA 13 has a similar exemption for hotel and dormitory bathrooms that imposes the same size limitation and also regulates the combustibility of the wall and ceiling surfaces.

But NFPA 13 offers no similar exemption for apartment unit bathrooms. The NFPA 101 exemption trumps the sprinkler requirement of NFPA 13. NFPA 101 annex text advises the user that the exemption differs from NFPA 13 because fire data shows that, in apartment fires where sprinklers were present, bathrooms were the area of fire origin in 1 percent of the total fires and resulted in no civilian deaths or injuries, or property loss.

The guidelines under which an NFPA occupancy-based document, such as NFPA 101, is permitted to deviate from the requirements of an installation standard like NFPA 13 are well understood, and they are effectively utilized by the technical committees within the NFPA code development process. The creation of the advisory annex text that explains the rationale for the deviation is an important part of the process for producing codes and standards that work together without conflict.

Ron Coté, P.E., is principal life safety engineer at NFPA.