BCAB #1863

June 1, 2021

Re: Spatial Separation, NFPA 13D, “Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes,” Exemptions

Project description

The project is a two-storey single-family dwelling with an attached garage, located on a property where the fire department response time is expected to exceed 10 minutes in 10% or more of all calls to the subject site. In order not to reduce the limiting distance to half of the actual limiting distance as required by Sentence 9.10.15.3.(1), the building will be sprinklered in conformance with the applicable edition of NFPA 13D, “Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes.”

Applicable Code requirements

The definition of “sprinklered” in Article 1.4.1.2. and Sentence 1.5.1.2.(1) in Division A, and Sentences 3.2.5.12.(1) and (3), 9.10.1.3.(8), and 9.10.15.3.(1) of Division B of the 2012 British Columbia Building Code.

Sprinklered (as applying to a building or part thereof) means that the building or part thereof is equipped with a system of automatic sprinklers.

1.5.1.2.(1) In case of conflict between the provisions of this Code and those of a referenced document, the provisions of this Code shall govern.

3.2.5.12.(1) Except as permitted by Sentences (2), (3) and (4), an automatic sprinkler system shall be designed, constructed, installed and tested in conformance with NFPA 13, “Installation of Sprinkler Systems.” (See Note A-3.2.5.12.(1).)

3.2.5.12.(3) Instead of the requirements of Sentence (1), NFPA 13D, “Installation of Sprinkler Systems in One- and Two-Family Dwellings and Manufactured Homes,” is permitted to be used for the design, construction and installation of an automatic sprinkler system installed

a) in a building of residential occupancy throughout that contains not more than 2 dwelling units, or

b) in a building of care occupancy, provided

i) it contains not more than 2 suites of care occupancy,

ii) it has not more than 5 residents throughout, and

iii) a 30-minute water supply demand can be met.

(See Note A-3.2.5.12.(2).)

9.10.1.3.(8) Sprinkler systems shall be designed, constructed and installed in conformance with Articles 3.2.5.12. to 3.2.5.15. and 3.2.5.17.

9.10.15.3.(1) Except for the purpose of applying Sentences 9.10.15.2.(2), 9.10.15.4.(3) and 9.10.15.5.(13), a limiting distance equal to half the actual limiting distance shall be used as input to the requirements of this Subsection, where

a) the time from receipt of notification of a fire by the fire department until the first fire department vehicle arrives at the building exceeds 10 min in 10% or more of all calls to the building, and

b) any storey in the building is not sprinklered.

(See Note A-3.2.3. and A-3.2.3.1.(8))

Decision being appealed (local authority’s position)

The local authority has determined the attached garage is required to be protected by sprinklers.

NFPA 13D exempts attached garages from requiring sprinkler protection. The local authority considers this exemption to conflict with the spatial separation requirements in Article 9.10.15.3. as this exemption is not specifically identified.

Appellant's position

The appellant maintains NFPA 13D, including the exemption for sprinkler protection in attached garages, complies with the requirements of Article 9.10.15.3 to apply the actual limiting distance for a sprinklered building.

Appeal Board decision #1863

It is the determination of the Board that the attached garage does not require sprinkler protection as per the exemptions contained in NFPA 13D.

Reason for decision

The Board does not consider a conflict exists between Article 9.10.15.3. and the referenced standard NFPA 13D. The Article does not specify additional sprinkler protection beyond that required by NFPA 13D.

Attached garages and other areas in buildings are exempt from sprinkler protection by NFPA 13D. The Board considers both storeys of the building, including the storey the garage is part of, to meet Code definition of “sprinklered”.

The Board acknowledges the NFPA 13D standard may have shortcomings in its application for spatial separation, however those must be identified specifically and adopted within the BC Building Code to be applicable (such as in Sentence 3.2.5.12.(6)). The Board understands a code change request related to this matter may be under review.

Lyle Kuhnert

Chair, Building Code Appeal Board