Sprinklers, High-Piled Storage and Your Warehouse

A warehouse tour usually confirms that sprinklers exist. It does not confirm that they suit your operation. Fairfax County, Virginia's Fire Marshal puts the key idea plainly: the level of fire protection has to be adequate for the commodity types and storage arrangements actually in place. Protection requirements generally turn on the commodity, plus the height, quantity and arrangement of the storage.

That matters to a tenant because the prior occupant's use may tell you little. A building that served one operator stacking low-hazard goods at modest heights may not be ready for another operator running tall racks of plastic-packaged product. The ceiling height on a marketing sheet says what might physically fit. It does not say what the fire protection allows.

None of this is a broker's or an owner's call. A fire protection engineer evaluates the design, the local fire official enforces the adopted code, and your property insurer may set requirements of its own. Treat everything in this guide as a list of questions for those people, not as an answer to them.

High-piled storage is a defined term in many fire codes based on the International Fire Code, though each jurisdiction adopts its own edition and amendments. Fairfax County defines high-piled combustible storage as combustible materials in closely packed piles, on pallets, in racks or on shelves where the top of storage is greater than 12 feet. When the fire official requires it, the definition also reaches certain high-hazard commodities above 6 feet, such as rubber tires, Group A plastics, flammable liquids and idle pallets.

Seattle's fire department describes a similar line and names lithium-ion batteries among its high-hazard examples. Those are two local examples, not a national rule, and the numbers can change with a code update. Ask your own jurisdiction what applies at your address.

Commodity classification is where operators most often underestimate the issue, because the packaging counts. Fairfax County says commodities include the combination of products, packing materials and containers. Madison, Wisconsin's fire department adds the pallet, and it lists five International Fire Code classifications: Class I through Class IV and high-hazard. A harmless metal part shrink-wrapped in plastic on a plastic pallet may not be classified the way the metal part alone would be.

You will hear ESFR, which stands for early suppression fast response. NFPA Journal describes ESFR systems as fast-acting, high-volume sprinklers designed to protect the most challenging stored goods, including items with large amounts of highly combustible plastics. Listing brochures often present ESFR as a selling point, and it can be one. It is still not a blanket approval for anything you want to store.

NFPA 13, the sprinkler installation standard, restricts how close ESFR sprinklers can sit to nearby obstructions, including structural elements, duct work and lighting. So new high-bay lights, a mezzanine, ductwork or conveyors added under the sprinklers belong on the engineer's list. NFPA's discussion of idle pallet storage also shows how specific the protection schemes are: ESFR and control mode specific application (CMSA) sprinklers each have their own limits on pallet type, storage height and ceiling height.

Older or lower-hazard buildings may have other designs, and some storage arrangements use sprinklers within the racks as well as at the ceiling. Which one works for your layout is an engineering question. The practical point for a lease is simple: ask for the design basis of the existing system, not just its name.

Some jurisdictions require approved plans and an operating permit. Fairfax County requires a high-piled storage plan for new structures designed for this storage, for a change of occupancy or use, when the storage hazard of an existing arrangement increases, and when applying for an operational permit. Its operational permit applies above 500 square feet of high-piled storage area, and Seattle's handout uses the same area figure. Madison requires a High-Piled Storage Work Permit for existing buildings.

Three details affect a tenant directly.

• Permits may not travel with the building. Seattle says its permits are not transferable and that a change in use, occupancy, operation or ownership requires a new one. Do not assume the prior occupant's approval covers you.
• Changes can reopen the question. Seattle notes that a change in practice, process, materials or storage configuration may require compliance with the current fire code.
• The building itself may need work. Madison notes that certain high-piled facilities must have additional exterior doors for fire department access, and that shell buildings are often built without anyone knowing the final use, so those doors may not exist.

Fairfax County's listed causes of failed inspections are mostly day-to-day operations: storage that does not match the approved plan, narrowed aisles, blocked flue spaces, excess height and unapproved encapsulated goods.

Do this work during the letter of intent or due diligence period. Once the lease is signed, an upgrade becomes a negotiation with a landlord who already has your commitment.

1. Write down what you will store, including packaging, pallet type, encapsulation, top-of-storage height, rack layout and any lithium-ion batteries, aerosols, plastics or flammable liquids.
2. Ask the landlord for the sprinkler design information, recent inspection reports and any prior high-piled storage plan or permit.
3. Hire a fire protection engineer to compare your plan with the installed system and water supply, and to identify what would have to change.
4. Call the local fire prevention office and ask which code edition applies and whether a plan or permit is needed.
5. Send your commodity and layout description to your insurance broker, and ask whether the insurer has requirements beyond the code.
6. Price any required upgrades, get an estimated schedule, and bring both into the lease negotiation.

Many landlord forms make the tenant responsible for legal compliance arising from its particular use, which can put an upgrade cost on you. Read the compliance, alterations and permitted use clauses together and ask for clear answers to these questions.

• ✓Who pays if the existing system must be upgraded for our stated storage plan, and is that written into the work letter or the lease?
• ✓Does the landlord state the system's condition and working order at delivery?
• ✓If the code changes, or the system needs replacement rather than repair during the term, who pays?
• ✓Do we have the right to install racking and to modify sprinklers and lighting, and do those changes need to come out at the end of the term?
• ✓Can we walk away during due diligence if the permit or the engineer's review comes back unworkable?
• ✓Does the landlord agree to sign permit applications that require the owner's signature?

A Fire Protection Research Foundation report published by NFPA notes that changes such as moving from wood to plastic pallets, changing packaging or adding encapsulation may not even strike an operator as fire protection issues. Consider building that check into your operating routine as well as your lease. When TAG represents a tenant, we put the fire protection review on the search timeline early, so the engineer's findings can shape the comparison of buildings and the lease terms, not arrive after them.