Finger Lakes Building Officials, Inc.

An Affiliated Member of the New York State Building Officials Conference

June 9, 2003

Re: Partial Fire Detection Systems
19 NYCRR 1225.1, FCNYS 2002, Sections 901.4.2, Chapter 34 - NFPA 72

This correspondence is in response to your letter of dissent to advisory letter #03-080 regarding the allowance of the installation of partial fire detection systems in buildings not otherwise required to have a detection system. Whereas the Division does understand your intentions for providing the highest level of health, safety, and security within your municipality, our opinion published in advisory letter #03-080 still stands.

Your letter states two different reasons for not permitting the installation of a partial fire detection system. The first is that you cite NFPA 72, 1999 edition Section 2-1.3.3 which refers to initiating device locations. The previous advisory letter addressed the coverage of the system, of which initiating devices are a part of. The Fire Code of New York State (FCNYS) Section 901.4.2 explicitly allows a non-required system to provide partial protection. Therefore, the initiating devices within the system should not be required outside the coverage area(s) proposed by the regulated party (i.e. building owner.) Furthermore, the term ‘authority having jurisdiction' is defined in Chapter 2 of the FCNYS. It states that "...authority having jurisdiction shall not include the local code enforcement official or the fire department." The definition gives the responsibility of the "authority having jurisdiction" in the State to the State Fire Prevention and Building Code Council which, in turn, delegates to this Division.

The second reason refers to NFPA 72 Section 2-1.3.3, which only deals with required partial detection systems. This Section is not applicable because the subject building is not required to have a partial detection system. You also refer to Appendix A of NFPA 72 which states that "if the are no detectors in the room of origin, the fire could exceed the design objectives before being detected by remotely located detectors." I do agree with this statement that there could be a delay. However, a fire detection system that is installed but not required is being installed as a benefit to the owner. It is his/her decision of the level of protection they would like to provide and not the code enforcement official, including committing coverage in portions of the building in question. Requiring the installation of complete fire detection systems versus partial fire detection systems can become a cost issue which, in turn, could cause buildings to have no fire detection instead of partial 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
Al03-129

Finger Lakes Building Officials Association, Inc.
3100 Atlantic Ave.
Penfield, NY 14526