Discussion Draft

To: Tom Brace - State Fire Marshal, Mary Nachbar - Bureau Chief

Cc: Nyle Zikmund - MSFCA, Bill Yorkson - NFSA

From: Jon Nisja, Bureau Chief

RE: Residential Sprinkler Task Force

Earlier today, I met with representatives of the Minnesota State Fire Chiefs Association (MSFCA) and National Fire Sprinkler Association to discuss ways to encourage the installation of residential sprinkler systems. As you know, MSFCA and the Fire Marshals Association of Minnesota (FMAM) have been trying to implement strategies to get more residential sprinkler systems installed.

The focus of today's discussions was on removing or reducing barriers posed by regulation and enforcement. The following are some comments and possible options for implementing. It should be noted that this memo is intended as a discussion draft and is not intended to address all of the issues involved.

1. ALLOW HOMEOWNER INSTALLATION:

At the present time, a literal reading of the statute and related rules would preclude homeowner installation of a residential sprinkler system (see MN § 299M.03, subdivision 1, and Minnesota Rules, part 7512.0400, subparts 1 and 2). This is contrary to the philosophy of other trades (most notably construction, plumbing, and electrical) which allow homeowners to do work on owner-occupied structures.

Possible Remedies:

Amend statute and rules to allow homeowners to install residential sprinkler systems in owner-occupied structures,

Maintain requirements for design to be by a licensed professional (fire protection engineer or fire protection contractor),

Maintain requirements for permit and inspection. MSFCA and FMAM will attempt to encourage fire officials and municipalities to keep these costs to a minimum.

2. REQUIREMENTS FOR FIRE DEPARTMENT CONNECTIONS:

There appears to be some confusion on the part of local fire and building officials concerning fire department connections (FDC) on residential systems. NFPA 13-D, which is the installation standard for one-and two-family dwellings does not require FDCs to be installed. NFPA 13-D was developed under the philosophy that these were "life-safety systems" and would not need to be supported by fire department apparatus. As such, the standard only requires a 10-minute water supply with a maximum design of two sprinklers flowing. Whereas no FDC is required, similarly there is no requirement for a 2 hour, 200 PSI hydrostatic test that is required of systems having a FDC.

Remedies:

The State Fire Marshal (SFM), MSFCA, and FMAM need to do a better job educating local fire and building officials as to the installation requirements for NFPA 13-D systems.

SFM adopt a policy or interpretation not requiring either FDCs or the hydrostatic test for NFPA 13-D systems. This policy or interpretation could then be the basis for future appeals through the Fire Marshal Code Advisory Panel (FMCAP).

3. SPRINKLER FLOW ALARMS:

It appears that there is a great deal of confusion concerning what type of water flow alarm is required on NFPA 13-D systems. NFPA 13-D, Section 3-6 requires either local water-flow alarms or automatic smoke detectors. Whereas the state fire and building codes require smoke detectors in both new and existing residences, the exception would prevail in most cases.

There is some logic in having an interior flow alarm so that the occupant(s) know that sprinkler flow is occurring. Most contractors install audible flow alarms as a normal part of installation. An exterior flow alarm is, in my opinion, not necessary for most installations. The intent of exterior alarms is so that neighbors or passersby would hear the alarm and initiate rescue or call the fire department.

Given climatic conditions in Minnesota and the frequency of windows being kept closed for great portions of the year, this is probably an unreasonable expectation. We have even discussed relaxing the requirements for exterior flow alarms under certain conditions during our code development deliberations.

Even more distressing is having local municipalities impose requirements for central station monitoring. Aside from the higher initial installation costs, there are monthly monitoring fees that must be paid. Bear in mind that in almost all cases these are voluntary systems; if the owner decided not to install the sprinkler protection, none of these additional requirements would be imposed.

Remedies:

SFM adopt a policy or interpretation not requiring exterior water-flow alarms and/or central station monitoring,

SFM, MSFCA, and FMAM educate and inform code officials as to the requirements for alarms,

Amend Minnesota Uniform Fire Code (MUFC) and State Building Code (SBC) so that it is clear that exterior water-flow alarms and central station monitoring are not required (the present codes do not reference NFPA 13-D but do contain flow alarm requirements which appear to conflict with NFPA 13-D; see UFC Section 1003.3.2 and UBC Section 904.3.2).

4. CONNECTION TO MUNICIPAL WATER SUPPLY:

At the present time, most municipalities require that the sprinkler connection to the municipal water supply must occur after the water meter. This creates a few problems:

1. Most existing standard or typical residential water meters are not designed or intended to handle the types of flows which are seen for sprinkler systems,

2. The pressure loss through standard 5/8 or ¾ inch water meters can be exorbitant. It is not unusual to have 15-25 PSI of friction loss through a standard-sized meter. The friction loss can be substantially reduced by going to a larger size meter but that can affect the cost of installation and the minimum monthly water fee (some municipalities charge a fee based on the size of the meter),

3. The State Plumbing Code discourages connections prior to the water meter by requiring that a licensed plumber only install this portion of the water supply.

Remedies:

Amend state statute and State Plumbing Code to allow sprinkler contractors to connect ahead of the water meter in an effort to reduce friction loss, especially in existing residences that may have older, marginal water supplies.

5. DEFINE APPROPRIATE DESIGN STANDARD:

For years, fire and building code officials developed a certain "comfort level" from dealing with commercial-type sprinkler systems. These types of systems had many built-in redundancies and required complete building coverage. With the movement toward residential sprinkler systems, the philosophy has changed from one of property protection to one of life safety. As such, the standards contemplated low cost installation and exemption of certain areas where fire frequency is small.

The first of the installation standards for residential occupancies was NFPA 13-D (one- and two-family dwellings) which was developed in the mid to late 1970s. In the late 1980s, NFPA 13-R (apartments and hotels, up to four stories in height) was developed.

Although similar in their design approaches, NFPA 13-D and 13-R contain some different requirements. For example, NFPA 13-D does not require a FDC; with a few rare exceptions, NFPA 13-R requires a FDC.

At the present time, the state building and fire codes do not recognize NFPA 13-D systems. This is probably because neither of these model codes requires that single family residential occupancies be sprinklered. Without a recognized referenced standard, many code officials rely on a closely related standard; in this instance, it may be NFPA 13 or NFPA 13-R. As such, there is a tendency to impose requirements from the standard even though they were never intended to apply to that application.

Another point of confusion relates to which is the appropriate standard to use in the case of townhomes and similar occupancies. An interpretation issued by NFPA in 1980 seems to indicate that NFPA 13-D can only be used for one- and two-family dwellings (single family homes and duplexes). Occupancies which are larger than these thresholds need to be in accordance with NFPA 13-R or NFPA 13. For reasons of economy, NFPA 13-D is the preferred installation standard for these types of occupancies but this would seem to be contrary to NFPA's interpretation.

Remedies:

Amend the state fire and building codes to reference NFPA 13-D as the appropriate design standard for one- and two-family residential occupancies,

Amend the state fire and building codes to allow the use of NFPA 13-D as the appropriate design standard for townhouse, four-plexes and similar occupancies provided that the following conditions exist:

1. Each residential unit is fire-separated from adjacent units,

2. Separate water supplies are provided for each residential unit,

3. There are no common interior spaces, such as egress systems, recreational uses, storage or utility rooms.

6. PROVIDE OTHER INCENTIVES THROUGH THE CODES:

Historically, there has been a reluctance to allow additional code incentives for sprinkler protection. This is especially true for new construction; fire officials tend to give more incentives for protecting existing buildings. In addition to the typical incentives given by code officials for sprinklering single family homes and developments (site access modifications, greater hydrant separation distances, etc.), I suggest or recommend that the following items be explored:

Reduce the requirements for smoke detectors if sprinklers are provided. Presently, the Uniform Building Code (UBC) requires hard-wired smoke detectors in each sleeping room and in the common areas outside of sleeping rooms in new construction. In addition, the UBC requires that smoke detectors have battery back up and that they be audible in all sleeping areas (the latter typically requires that they be electrically interconnected to satisfy this requirement). These requirements could be amended to only require hard-wired smoke detectors in the common areas and not in each sleeping room if the building is sprinklered. This level of protection would be consistent with former editions of the UBC.

Reduce the required egress window size from sleeping rooms in sprinklered buildings. Presently, the UBC requires egress windows of 5.7 square feet for basements and other stories up to the fourth story. Above the fourth story, the building code contemplates that escape by this method is impractical and assumes that the building will probably be sprinklered. This philosophy would also be consistent with other nationally used model building codes (including the International Building Code Draft) which allow the egress window requirements to be waived if the building is sprinklered. If this change were adopted, the only requirement for window size could be based on the UBC's light and ventilation requirements, not egress requirements.

Thank you in advance for the opportunity to address these issues. Whereas this document was intended to illicit comment and discussion, I would be most interested in hearing your thoughts, concerns and comments. If you have any questions or need additional information, please feel free to contact me.