NFPA Journal - Spring 2021 - 34

In Compliance
NFPA 101

Life safety in new
and existing structures

Important sprinkler
changes for high-rise
apartments in the 2021
Life Safety Code 
By Kristin Bigda
n November, a fire
started on the 11th floor
of a high-rise apartment
building in San
Francisco. Five people
who lived in the unit where the fire
originated were injured. Three additional units sustained heavy damage as
a result of the fire. A total of 23 units
were determined to be uninhabitable
from either smoke or water damage.
Perhaps even more concerning is that
in 2018, 30 residents were displaced
from the same 22-story building due to
a fire that affected units on five floors.
The building did not have sprinkler
protection in the dwelling units. When
it was constructed, it was not required
to include total automatic sprinkler
coverage-it was required to have fire
sprinklers only in the basement storage areas, along with water hoses in
elevator lobbies. The building is one of
many that are grandfathered into legislation that allows them to continue to
be inhabited without requiring additional sprinkler protection. In response
to this recent fire, it was reported that
San Francisco will now likely seek to
change the law, requiring all high-rise
residential buildings, regardless of age,
to be retrofitted with automatic sprinkler protection.
The level of protection required
for high-rise buildings varies across
the country, a result of jurisdictions
adopting legislation that modifies
model codes with local ordinances.
While the trend seems to be moving
to more sprinkler mandates, there are

I

jurisdictions where either all existing
high-rise buildings, or a specific category of existing high-rise buildings
such as residential, remain unsprinklered. These high-rise buildings are
said to be grandfathered-a term not
recognized by the compliance approach
taken by NFPA 101®, Life Safety Code®-
into older legislation that permits
them to remain in use without sprinkler protection, even if more modern
sprinkler requirements are in place
for newer buildings. Resource allocation and the cost of retrofits are often
unfortunate factors in decisions where
building safety and sprinkler protection are set aside.

These high-rise
buildings are said to
be grandfathered-
a term not recognized
by the compliance
approach taken by
NFPA 101�, Life Safety
Code�-into older
legislation that
permits them to remain
in use without
sprinkler protection,
even if more modern
sprinkler requirements
are in place for
newer buildings.

Through the 2018 edition of NFPA
101, existing high-rise apartment occupancies have required full automatic
sprinkler protection unless one of two
alternatives is met: automatic sprinkler
systems are not required where every
dwelling unit has exterior exit access
(in accordance with 7.5.3 of the code),
or when buildings have an approved,
engineered life safety system (ELSS).
An ELSS is a custom building fire
protection system that is designed

to provide equivalent protection to
a full building sprinkler system. The
ELSS must include any or all of the
following: partial automatic sprinkler
protection, smoke detection systems,
smoke control systems, compartmentation, and other approved systems.
It is required to be developed by a
registered professional engineer specifically experienced in fire and life safety
system design and must be approved
by the authority having jurisdiction. During the planning phase, the
designer should meet with the AHJ to
determine whether an ELSS is acceptable in lieu of automatic sprinklers.
The 2021 edition of NFPA 101
includes a proposed change to the
sprinkler alternatives for existing high-rise apartment buildings:
there is no longer an option to introduce a new ELSS, although previously
approved ELSS developed in accordance with the appropriate provisions
can remain. Instead, existing high-rise
apartment buildings without a previously approved ELSS, or where every
dwelling unit does not have exterior
exit access (in accordance with 7.5.3 of
the code), must be protected throughout with sprinklers by January 1, 2033.
This change reflects the code's reliance
on, and strong support for, automatic
sprinkler protection as the preferred
and most effective method of life safety
during fire.
It is interesting to note that other
model codes, including NFPA 1, Fire
Code, have required sprinkler protection for all existing high-rise buildings,
regardless of occupancy, for several
editions. In the case of NFPA 1, an existing high-rise building is required to
be protected with a sprinkler system
within 12 years of adoption of the code.
Once implemented, ELSS cannot be
neglected and should not be altered
without analysis of the modifications
on their equivalent design and level of
protection. To help ensure that these
systems continue to achieve their
purpose, those previously approved
ELSS are now required to be maintained in accordance with the approved

34 | NFPA JOURNAL * S P R I N G 2 0 2 1

In Compliance_1Q_2021 DCS RVWD.indd 34

1/27/21 7:45 PM
NFPA Journal - Spring 2021

Table of Contents for the Digital Edition of NFPA Journal - Spring 2021
