All:

I was just approved by NFPA Standards Council to represent AFSA on the 420.   I 
do not yet have a copy of the first draft (it’s not available on the 420 web 
page or through free access), but I’ve requested and will look over the fire 
protection systems design criteria, which I believe consists of nothing 
tangible at this moment.

Since my firm is located in SoCal, we’ve done several grows and each one has 
been different.   We’ve designed for an open warehouse with fixed lighting 
mounts that simply go up and down.  We’ve had to contend with a fixture that’s 
about 4’ wide and can be moved up/down/left/right.   We’ve done two-tier grows 
and three-tier grows and we’ve also dealt with the pre-fab grow rooms.   Within 
those grow rooms we’ve seen fixed tables and the sliding ones alluded to in 
this thread.   To say it’s the Wild West out here is an understatement.

Especially in CA, many fire officials have simply hit the HPS button and called 
it a 24’ (three tiers of mature plants) of Class 3 or 4 on racks in the open 
rooms, but I have issues with that since mature plants are 85% water.   The 
growing medium that is fast becoming industry standard is Class A material 
(rock wool), it’s kept wet, and doesn’t require a container, so the commodity 
ISN’T that hazardous.   What complicates things is the presence of the solid 
shelving, and that gets even more complicated by the sliding fixtures that can 
be nested up to four across, which is a 16’ wide solid obstruction in some grow 
rooms, and sometimes there are two or three of those shelving levels.

I don’t have any specific answers right now but I am hopeful that we can point 
the code development conversation down a reality-based path, that being the 
fact that this commodity isn’t all that hazardous (well, if the munchies aren’t 
considered a hazard), and the shelving (which is plastic or polymer composite) 
makes up a very small percentage of the overall volume of the storage space.   
Yes, there are obstructions to sprinkler discharge, but we have that in other 
storage arrays as well, so absent any clearer prescription, it’s hard to argue 
with the shielded fire load approach and use EH2.  But if it’s only a single 
tier, then I’m probably back in the OH2 camp, although as I said before, it 
almost seems like there are no two growing facilities that are alike and the 
system designer is going to have to flex to what the AHJ is requiring and what 
the specific conditions of that particular facility would dictate.


The foregoing is my opinion only and does not represent NFPA or the NFPA 420 
Technical Committee, nor intended to serve as an interpretation of the standard.

Protection Design and Consulting
Steve Leyton, President
T  |  619.255.8964 x 102  |  
www.protectiondesign.com<http://www.protectiondesign.com/>
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Fire Protection System Design | Consulting | Planning | Training







From: Fpdcdesign <[email protected]>
Sent: Monday, May 13, 2024 8:52 AM
To: Discussion list on issues relating to automatic fire sprinklers 
<[email protected]>
Subject: [Sprinklerforum] Re: Cannabis growing

The array of tables are about 1000 sqft each

Todd G Williams, PE
Fire Protection Design/Consulting
Stonington, CT
860-535-2080<tel:860-535-2080> (ofc)
860-554-7054<tel:860-554-7054>  (fax)
860-608-4559<tel:860-608-4559> (cell)



On May 13, 2024 at 10:42 AM, <Spencer 
Tomlinson<mailto:[email protected]>> wrote:
I’m in the 2019 edition, but sections 9.5.5.3.1.5 and 9.5.5.3.2 may help 
provide guidance.  They do not up the hazard level due to an obstruction in 
place, I like the idea of taking into effect a shielded fire, especially with 
the size of some of these grow ops these days, but there are certain provisions 
that would suggest otherwise….

Spencer Tomlinson, PE
Owner, Fire Protection Engineer

[red logo]
   Cell: 620-955-7293

From: Fpdcdesign <[email protected]<mailto:[email protected]>>
Sent: Monday, May 13, 2024 9:32 AM
To: Discussion list on issues relating to automatic fire sprinklers 
<[email protected]<mailto:[email protected]>>
Subject: [Sprinklerforum] Re: Cannabis growing

Travis, The definition of EH2 and section 19.3.3.1.5 both deal with protection 
where there are unprotected spaces adjacent or within. The big difference is 
the word “extensive” in the EH2 definition. From what I have seen below grow 
tables it is a very wet environment with most of the combustibles being water 
and non-water filled PVC pipe. I’m not sure that would rise to extensive. The 
other argument if below the tables can be considered  a “concealed space”. 
Since there is no NFPA definition, we need to go to a dictionary definition. My 
dictionary say the definition of conceal is “to hide from view”. Nothing that 
talks about physical separation. I think this would meet that criteria.

Todd G Williams, PE
Fire Protection Design/Consulting
Stonington, CT
860-535-2080<tel:860-535-2080> (ofc)
860-554-7054<tel:860-554-7054>  (fax)
860-608-4559<tel:860-608-4559> (cell)




On May 13, 2024 at 10:07 AM, <Travis Mack<mailto:[email protected]>> wrote:
The 3000 sq ft is specifically for unprotected concealed combustible spaces. So 
I don’t see how that could be used as you don’t have that from what you 
describe.


Travis Mack, SET

M.E.P.CAD |

181 N. Arroyo Grande Blvd. #105 I Henderson, NV 89074

www.mepcad.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.mepcad.com_&d=DwMFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=SMKi3MpB_L04QTNOI8wsXTbQAi8Ov0kr5kJ9QWv4K58&m=Rt2Ku0kdmBZShB-fHbPlOHh8rfl-aQkPP6VbfAr-e7kT2fRmXYAjbMGp_kV4Nqy3&s=UpVuXPq25y_S_GAXByMhUQqOZrb0zMeyhfjGV8qVydo&e=>
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________________________________
From: Fpdcdesign <[email protected]<mailto:[email protected]>>
Sent: Monday, May 13, 2024 7:05:28 AM
To: Discussion list on issues relating to automatic fire sprinklers 
<[email protected]<mailto:[email protected]>>
Subject: [Sprinklerforum] Re: Cannabis growing

Travis, What I have run into out here is that the grow tables are not fixed in 
place. Consequently, they become “furniture” and protection is not installed 
underneath. (I am trying to get that information). If they are not fixed, does 
the 3000 sqft area increase apply or do we go to EH2?

Todd G Williams, PE
Fire Protection Design/Consulting
Stonington, CT
860-535-2080<tel:860-535-2080> (ofc)
860-554-7054<tel:860-554-7054>  (fax)
860-608-4559<tel:860-608-4559> (cell)




On May 13, 2024 at 9:25 AM, <Travis Mack<mailto:[email protected]>> wrote:

What unprotected concealed combustible spaces are you referencing?  The 3000 sq 
ft is for that.  Typically with grow houses, we have put sprinklers under the 
racks of tables, if I am understanding correctly what you are describing.



These houses are definitely a unique protection scheme and it seems the ways of 
the growers changing things to maximize product growth is ever changing and 
does need a constant review.



I have seen some where the tables slid along a racking system.  It was similar 
in concept to movable rack storage.  Since we couldn’t put sprinklers below the 
table areas, the AHJ said to protect as a heavily shielded fire and do the 
overhead system as EH2.  I’m not sure if that is the best method, but it did 
get it through in that particular jurisdiction.





Travis Mack, SET

M.E.P.CAD | Instructor / Support

181 N. Arroyo Grande Blvd. #105 I Henderson, NV 89074

www.mepcad.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.mepcad.com_&d=DwMFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=SMKi3MpB_L04QTNOI8wsXTbQAi8Ov0kr5kJ9QWv4K58&m=Rt2Ku0kdmBZShB-fHbPlOHh8rfl-aQkPP6VbfAr-e7kT2fRmXYAjbMGp_kV4Nqy3&s=UpVuXPq25y_S_GAXByMhUQqOZrb0zMeyhfjGV8qVydo&e=>
 | m: 480.547.9348| Whatspp: +14805479348

Email: [email protected]<mailto:[email protected]>



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From: Fpdcdesign <[email protected]<mailto:[email protected]>>
Sent: Monday, May 13, 2024 4:49 AM
To: Sprinklerforum 
<[email protected]<mailto:[email protected]>>
Subject: [Sprinklerforum] Cannabis growing



I know that NFPA 420 is coming but I believe has not been issued yet. I have 
been asked to look at a new growing facility. NFPA 13 calls out agriculture 
facilities os OH2, which make sense for this occupancy. My question comes from 
the tables. The tables are portable so sprinklers are required underneath. 
However, does the 3000 sqft demand area for unprotected spaces come into play? 
I would like to do something that is at least close to what 420 will be 
recommending.



Todd G Williams, PE

Fire Protection Design/Consulting

Stonington, CT

860-535-2080<tel:860-535-2080> (ofc)

860-554-7054<tel:860-554-7054>  (fax)

860-608-4559<tel:860-608-4559> (cell)
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