Interpretation #: CEB-2019-15-2014 IFC-910.4

Building or Fire Safety Law Interpreted

Issue

Whether manually operated smoke exhaust fans are required in high pile storage buildings equipped with ESFR automatic fire suppression systems, under Section 910.4 of the 2014 Indiana Fire Code.

Interpretation of the State Building Commissioner

Section 910.4 of the 2014 Indiana Fire Code does not require manually operated smoke exhaust fans in high pile storage buildings equipped with ESFR automatic fire suppression systems.

Rationale

The text of Section 910.4 does not require the installation of manually operated smoke exhaust fans. It merely states that in buildings protected by automatic sprinkler systems these fans "may" be utilized for fire department operations. It then continues, describing minimum required performance characteristics of any such devices that are installed.

Further, high pile combustible storage is a specialized occupancy with its own requirements. It is addressed both in Section 910.2.2, and more comprehensively in its own chapter, 32.

Section 910.2.2 (a subsection of Section 910.2, a section which describes under what circumstances smoke and heat removal systems are required, without regard to whether the system is manual or automatic) discusses high pile combustible storage specifically. This section simply states that such systems shall be installed when required by Section 3206.7.

Section 3206.7 states the smoke and heat removal devices shall be installed where indicated in Table 3206.2, and that they shall be installed in accordance with Section 910 (addressed above).

While Table 3206.2 indicates smoke and heat removal systems are required in high pile storage of specific commodity classes (again, without regard to whether they are automatic or manual systems), it also includes two condition statements about the requirement. The first is a reference to Section 3206.7, which, as noted above, states such devices shall be provided in accordance with Section 910; the second is the Table's footnote "J", which states smoke and heat removal devices are not required when the storage area is protected by ESFR sprinklers installed in accordance with NFPA 13.