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Code Considerations During Design of Renovations and Additions to Existing Buildings

When architects, engineers, and building owners plan renovations to older buildings, there is often confusion regarding requirements for life safety, egress, and fire protection systems. A common problem facing design teams is whether or not sprinklers are required in a renovation or addition to buildings that are either partially provided with fire sprinkler protection or are not provided with fire sprinkler protection. This issue can be particularly confusing because building renovations are unique in many ways. Furthermore, many states have imposed additional requirements beyond what is required by the International Existing Building Code.

There are often multiple codes, amendments, and statutes – both state and local that must be reviewed to determine what level of protection is required for a renovation or addition. The level of protection can range from no sprinkler protection to full building sprinkler protection, even in areas outside of the renovation. Improperly identifying the applicable requirements in the early conceptual phases of a project can:

  1. Result in costly change orders

  2. Raise unexpected budget implications

  3. Delay permitting and / or occupancy

  4. Develop frustration between owner and design / construction team

Practical Example

Although the current statute has been on the books in Massachusetts since 2010, an often overlooked and misunderstood regulation in the Commonwealth of Massachusetts is MGL c. 148 §26G. The statute requires any building or structure with an aggregate square footage of 7,500 SF or more undergoing a “major” renovation or addition to be provided with full sprinkler coverage. There are some exceptions to the regulation, most notably that it does not apply to buildings or additions used for residential purposes. Additionally, the statute does not apply if the owner does not have access to a source of water supply with adequate pressure to supply the sprinklers. While the term “major” is not defined in the statute, the Automatic Sprinkler Appeals Board has published guidance to assist in the determination of whether an alteration is “major”. Although there are many nuances to the guidance, generally an addition or renovation is considered “major” if it exceeds 33% of the aggregate area or 33% of the assessed building value.


Seeking a professional

It is important for the owner and design team to know what life safety and fire protection requirements apply when planning an addition or renovation to an existing building. While the building code in both state and local regulations provide a legally-mandated minimum level of safety, it is imperative to consider whether additional protection should be provided. Having a licensed fire protection engineer involved in the feasibility and planning stages of a project helps provide expert insight into complex building, fire, and life safety regulations and can help avoid frustrating and costly change orders and permitting issues, ensuring a successful project.


Fitzemeyer & Tocci has Fire Protection Engineers on staff that are licensed in all New England states. We are ready to assist with any fire protection, life safety, or code consulting questions you or your team may have.  Please feel free to reach out to Fitzemeyer & Tocci’s Life Safety & Fire Protection Project Engineer, Steve Southard, PE by email or phone (781) 285-2298.

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