sprinklernotes
Guest Houses and NFPA 13D  

“I have a single-family residence with a detached garage with living quarters. 
I have designed a shared antifreeze system in South Lake Tahoe. The system will 
share one backflow device and one riser assembly. The plan reviewer is 
referencing CRC 313.3.3.3 stating that I cannot have more than one dwelling on 
one supply. I see this as one dwelling with two structures detached. What is 
your opinion?”

We have reviewed the 2019 California Residential Code and NFPA 13D, Standard 
for the Installation of Sprinkler Systems in One- and Two-Family Dwellings and 
Manufactured Homes, 2019 edition as the applicable standard. Our informal 
interpretation is that the garage structure would be considered a separate 
dwelling; however, a second supply would not be required, and sprinklers would 
not be required to be installed in the garage.

Per the 2019 California Residential Code (CRC) section 313.3.1, residential 
fire sprinkler systems are required to be installed in accordance with NFPA 13D 
or section 313.3. While the 2019 CRC requires sprinklers in detached garages, 
the 2019 edition of NFPA 13D explicitly states that sprinklers are not required 
in section 8.3.4.

Since the CRC gives you the choice, if you choose to design to NFPA 13D, then 
sprinklers may be omitted from the garage. The two structures would be 
considered separate dwelling per the definition provided in the standard.

3.3.4 Dwelling. Any detached building, or any part of a townhouse structure 
that is separated from the remainder of the townhouse structure with fire 
resistance rated assemblies in accordance with local building code, that 
contains no more than two dwelling units intended to be used, rented, leased, 
let, or hired out to be occupied or that are occupied for habitation purposes.

Since they are detached, the two structures would be considered separate 
dwellings, but this does not require a separate supply. This is scenario is 
addressed in section 6.2.3:

6.2.3* Where more than one dwelling unit is served by the same water supply 
pipe, each dwelling unit shall have an individual control valve that serves the 
fire sprinkler system in that dwelling unit and the owner shall have access to 
the valve that controls the sprinkler system in their unit.

The standard only requires a separate control valve so that the other system 
can be isolated and that the owner has access. This is not an issue as the two 
structures are under the control of a single owner which has been a standard 
practice used by NFPA 13, Standard for the Installation of Sprinkler Systems, 
to allow for a single supply to feed multiple structures under control of the 
same owner.

In my professional opinion, a single supply and control valve would suffice for 
this arrangement; however, provisions for guest houses are not specifically 
addressed in the 2019 edition of NFPA 13D, and we do not feel that the current 
language in the standard adequately addresses this issue. We have flagged this 
for further consideration in the 2025 edition of the standard as the revision 
cycle for the 2022 edition has closed. 

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