sprinklernotes
Apartment Closets vs. NFPA 101®, Life Safety Code®

“Under NFPA 13 Section 9.2.4.2 for closets and pantries, it specifies that 
sprinklers are not required in dwelling unit closets less than 24 ft2 in hotels 
and motels, therefore it is assumed that sprinklers are required in closets of 
new apartment buildings as they are not under current hotel and motel category. 
Appendix D in D.1.1.6 for new apartment buildings specifies that closets less 
than 12 ft2 in area in individual dwelling units shall not be required to be 
sprinklered. How is this addressed?” 

We have reviewed NFPA 13, Standard for the Installation of Sprinkler Systems, 
2019 edition as the applicable standard. Our informal interpretation is that 
while NFPA 13 requires sprinklers in closets of apartments and it is good 
practice, sprinklers can be omitted in small closets of new apartment buildings 
per NFPA 101®, Life Safety Code®, if it is adopted in your jurisdiction.

Where there is a conflict between an adopted code and a referenced standard, 
the code takes precedence. The NFPA 101®, Life Safety Code® and NFPA 13 differ 
on protection for closets. Since the 1976 edition, NFPA 101 has allowed 
sprinklers to be omitted from closets of limited sizes, but NFPA 13 indicates 
that unless the closets are located in the dwelling units of hotel or motel 
occupancies, sprinklers must be installed. In permanent residential 
occupancies, the closets typically have a higher fuel load and are always 
protected. The natural exception is when NFPA 13R, Standard for the 
Installation of Sprinkler Systems in Low-Rise Residential Occupancies, or NFPA 
13D, Standard for the Installation of Sprinkler Systems in One- and Two-Family 
Dwellings and Manufactured Homes is applied. There is a conflict with NFPA 
101®, Life Safety Code® that allows for small closets in new apartment 
buildings to omit sprinklers in closets that are limited in size. The NFPA 
101®, Life Safety Code® applicability needs to be reviewed to determine whether 
it has been adopted in your area. It should be noted that the 2010 edition of 
NFPA 13 moved this information to Annex D in an attempt to avoid the 
misperception that it is an allowance by NFPA 13. The bottom line is that the 
protection of apartment closets is required by the standard but can be omitted 
based on the adopted and amended codes in your jurisdiction.

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