FLBOA Finger Lakes Building Officials Association, Inc.
  An Affiliated Member of the New York State Building Officials Conference

May 28, 2003

This letter is in response to your inquiry regarding several questions pertaining to Appendix K of the Building Code of New York State, 2002 edition (BCNYS)[19 NYCRR 1221.1]. Due to the multiple questions posed, I have answered them separately.
1. We are proposing to replace an existing fire detection system with new detection and notification equipment. The system is going to provide the same level of coverage as well as provide notification devices to meet accessibility requirements. What level of work, under Appendix K, does this proposal fall under?
This type of work is an alteration. Since the trigger for an alteration, per the definition, needs to meet one of the four conditions and the proposed work meets two of them, this classification is appropriate.

2. Does exception 2 of BCNYS Section K601.3 apply to fire alarm and fire detection systems?
No. This section is applicable to power requirements throughout a building and does not apply to systems that are covered under NFPA 72.

3. Does a replacement of an existing fire detection system in a group B building require that the new system meet the coverage requirements in BCNYS Section 907.2.2.1.
No. In a more general context, the voluntary replacement of the fire detection system alone does not trigger any of the location requirements in BCNYS Section 907.2. However, the new fire detection system shall provide the same level of coverage as the existing system if a fire detection system is required in new construction.

4. Per BCNYS Section 907.2.2.1, what level of coverage, as defined in NFPA 72, is required in a group B building?
BCNYS Section 907.2.2.1 states areas of a group B that are not sprinklered and have an occupant load of more than 100 persons shall be protected with an automatic smoke or heat detection system. Since the BCNYS does not state that automatic fire detection is only required in certain areas when specified for a whole use group (i.e. public spaces, common spaces, etc.), the system shall be installed for complete coverage.

This advisory opinion is rendered based upon the information provided. Administration and enforcement of the code are within the jurisdiction of the local authority. If you have any questions or wish to discuss this matter further, please call me at (518) 474-4073.

Sincerely,
Daniel E. Nichols
Fire Protection Engineer I
Division of Code Enforcement and Administration
Al03-082


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