So the reviewer wants you to put sprinklers below the roof to protect against a 
potential hazard ABOVE the roof?

What would those sprinklers be protecting?  I’ve seen combustible roofing hit 
by lightning and on fire.  Amazon has had more than one occasion of a roof on 
fire in a fully sprinklered bldg.  The building sprinklers did nothing so 
adding sprinklers to this assembly would also accomplish nothing.  The issue is 
when the combustibles are within the occupied space or in connection wit the 
occupied space.  Above the roof is not within that space.

This is a common built-up roofing system used on all kinds of buildings where 
the space directly below is unsprinklered often because the space directly 
below is a ceiling cavity not requiring sprinklers.

Your argument should be based around 8.15.7.3 specifically keying in on the 
highlighted section since the materials of construction exposed within the 
occupiable area in this case all meet the conditions of being non-combustible.
8.15.7.3 Sprinklers shall be permitted to be omitted from below the exterior 
projections of combustible construction, provided the exposed finish material 
on the exterior projections are non-combustible, limited-combustible, or fire 
retardant–treated wood as defined in NFPA 703,

Also, did you get a data sheet on the insulating material to verify that it is 
combustible and not a limited-combustible?

Craig Prahl | Jacobs | Fire Protection SME – Special Hazards | 
[email protected]<mailto:[email protected]> | 
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From: Matt Grise <[email protected]<mailto:[email protected]>>
Sent: Thursday, July 20, 2023 7:28 AM
To: 
[email protected]<mailto:[email protected]>
Subject: [Sprinklerforum] canopy construction

Caution: This email originated from outside your organization. Please take care 
when clicking links or opening attachments.

We have a non-combustible, light hazard building where a steel pan roof deck 
(with some non-combustible architectural finishes on the underside) forms a 
balcony over a patio. The steel roof deck has a drainage slope on top formed 
from combustible rigid insulation that is covered with non-combustible roofing 
material – forming a noncombustible-combustible-noncombustible sandwich. There 
are no exposed combustible materials or combustible concealed spaces since all 
of the materials are in direct contact.

We typically see these considered non-combustible construction and exempt from 
sprinklers per NFPA 13 2016 ed 8.15.7.2, however a plans reviewer has expressed 
concerns that the presence of the combustible middle layer voids the 
‘non-combustible construction’ consideration.

It seems that the code allows for the presence of some combustible materials in 
the assembly based on NFPA 13 2016 ed 8.15.7.3 allowances for combustible 
construction with non-combustible finishes. However, this specific construction 
does not meet any of the specifically listed exemptions.

Has anyone seen anything similar to this?

Matt

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