Sprinkler Age A Publication of the American Fire Sprinkler Association
The NFPA standards development process is often discussed in terms of public inputs, public comments, committee statements, certified amending motions, and votes at the NFPA Technical Meeting. Those steps are important, but the real impact of the process is seen later, when the language developed through that process is applied to an actual project. That is especially true when one NFPA standard brings another NFPA standard into the design through reference.
NFPA’s process gives contractors, designers, manufacturers, Authorities Having Jurisdiction, insurers, owners, and other stakeholders an opportunity to participate before the language becomes part of the next edition. Public inputs begin the process. Technical committees review those inputs and develop first revisions. Public comments provide another opportunity to address the proposed language. The second draft process follows, and any remaining certified amending motions may be presented to the NFPA membership at the Technical Meeting. Final action is then taken by the Standards Council. That process matters because changes made in one document do not always stay confined to that document.
A clear example is Chapter 27 of NFPA 13, Special Occupancy Requirements. This chapter directs users to additional requirements for occupancies and hazards that cannot be fully addressed by the general sprinkler requirements alone. These include ignitable liquids, aerosols, dry cleaning facilities, spray application using flammable or combustible materials, dipping and coating operations, laboratories using chemicals, compressed gases, LNG facilities, information technology equipment rooms, telecommunication facilities, ovens and furnaces, exhaust systems, mining operations, rail systems, sound stages, animal housing facilities, cooling towers, marine terminals, semiconductor fabrication facilities, hazardous materials, aircraft hangars, airport terminal buildings, aircraft engine test facilities, nuclear power plants, and other special conditions.
That list is important because Chapter 27 is not merely informational. It is part of NFPA 13. When a sprinkler system is required to be designed and installed in accordance with NFPA 13, the special occupancy requirements referenced by NFPA 13 must be reviewed and applied where applicable.
This is an issue that can be easy to overlook. A local building code or fire code may not specifically list every standard referenced in Chapter 27. However, that does not mean those standards can be ignored. NFPA 13 brings referenced documents into the sprinkler system design by reference. If the adopted code requires compliance with NFPA 13, then the applicable requirements referenced by NFPA 13 become part of the compliance path unless the adopting ordinance specifically modifies them.
It is also important to understand the relationship between NFPA 13 and the special occupancy standards. NFPA 13 provides the base installation requirements for sprinkler systems. The occupancy or hazard-specific standards provide additional requirements for conditions that require more detailed treatment. NFPA 30 addresses ignitable liquids. NFPA 33 addresses spray application. NFPA 45 addresses laboratories using chemicals. NFPA 75 and NFPA 76 address information technology and telecommunication facilities. NFPA 409 addresses aircraft hangars. NFPA 318 addresses semiconductor fabrication facilities.
Where those documents contain applicable requirements, they need to be followed. The more specific occupancy standard takes precedence over the general sprinkler provisions where the two overlap.
For contractors and designers, the practical takeaway is simple: identify special occupancies early. Do not wait until plan review, fabrication, or final inspection to discover that a project includes materials, processes, storage arrangements, equipment, or operations that trigger another NFPA standard. Ask the owner how the space will actually be used. Ask about commodities, quantities, future expansion, gases, liquids, and tenant operations that may not be obvious from the architectural drawings.
This is also why participation in the standards development process matters. A change to one referenced occupancy standard can affect sprinkler design criteria, system type, water demand, sprinkler selection, spacing, supervision, drainage, inspection access, and coordination with other protection systems. Those changes can reach a sprinkler project through NFPA 13 even if the local code does not separately list the occupancy standard by name.
As the NFPA Technical Meeting approaches this June in Las Vegas, be on the lookout for an AFSA voting guide addressing any Certified Amending Motions (CAMs) that will be moved at the meeting. At the time of publication, the Motions Committee had not yet published the full list of CAMs. Once that information is available, review it carefully. The standards development process only works when the industry shows up, understands the issues, and participates.
ABOUT THE AUTHOR: Kevin Hall, M.Eng., P.E., ET, CWBSP, PMSFPE, is the Director of Engineering for the American Fire Sprinkler Association (AFSA). He is a member of several National Fire Protection Association (NFPA) technical committees responsible for developing the model codes and standards, including, NFPA 1 Fire Code, NFPA 13/13R/13D Installation of Sprinkler Systems, NFPA 20 Installation of Stationary Fire Pumps for Fire Protection, NFPA 25 Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, and NFPA 200 Hanging, Bracing, and Anchorage of Water-Based Fire Protection Systems. He also represents AFSA on numerous UL technical committees responsible for revising and maintaining the product standards used in the sprinkler industry. He is a registered professional engineer in Delaware and Maryland, NICET III certified in water-based system layout, a certified water-based system professional through NFPA, and a professional member of the Society of Fire Protection Engineers (SFPE). He earned his Bachelor of Science and Master of Engineering degrees from the University of Maryland College Park in fire protection engineering. In 2021, he was recognized as one of SFPE’s “5 Under 35” award recipients. Prior to his association and committee work, he worked for Reliance Fire Protection in Baltimore, Maryland as a project manager overseeing projects of various sizes and complexity.