Local Law 26/04: Fire Sprinkler Requirement
Office buildings 100 feet or taller must be fully sprinklered by 2019. Here’s what property owners and managers need to know.
What is Local Law 26/04
Following the terrorist attacks of September 11, 2001, the New York City Department of Buildings (DOB) convened the World Trade Center Building Code Task Force to investigate the existing building codes and make recommendations for comprehensive safety measures to better protect the occupants of high-rise buildings during a fire.
Among its findings, the task force identified fire safety and sprinkler mandates from preceding Local Laws 5 of 1973 and 16 of 1984 as inadequate for fire protection.
Based on the task force’s recommendations, the New York City Building Code and Fire Prevention Code were amended to include a number of retroactive and prospective provisions, otherwise known as Local Law 26 of 2004 (LL 26/04).
Sprinklers Requirement
One of the provisions of LL 26/04 is a 15-year plan that requires owners of office buildings 100 feet or taller to install a full system of automatic sprinklers by July 1, 2019. In addition, interim reports prepared by a New York State architect or engineer must be filed with the DOB, and a final report also prepared by an architect or engineer must be submitted certifying that the installation of the sprinkler system is fully compliant.
Buildings Affected
Buildings subject to LL 26/04 are Occupancy Group E high-rise buildings 100 feet tall or greater in height. This classification includes office buildings, banks, civic administration buildings, radio and television stations not classified as places of assembly or as equipment rooms, telephone exchanges, barber and beauty shops, automotive service stations, neighborhood family care centers, and medical offices or group medical centers.
Buildings 100 feet or taller that are converted into office space must also undergo a full sprinkler installation at the time of conversion.
Exemptions
Buildings in which sprinkler installation may not be feasible due to structural conditions or because of designation as an interior landmark by the New York City Landmarks Preservation Commission may be considered for exemption.
Filing Deadlines
Unless all work has been completed and the final report has been submitted, filing interim reports is a requirement under LL 26/04. Previous deadlines were for the owner’s affidavit (2005) and a 7-Year Report (2011).
The remaining filing deadlines are as follows:
- 14-Year Report due July 1, 2018
- Final Report due July 1, 2019
Report and Implementation Plan
The 14-year report must include a certification by an architect or engineer of the percentage of the building in which sprinklers have been installed, along with an implementation plan detailing when and how the remaining portions of the building will be made fully compliant.
The final report must contain a certification by an architect or engineer that the building is fully compliant.
Extensions
Owners who are unable to comply by the final deadline because of undue hardship may be granted an extension as long as they have met all previous filing deadlines; obtained all the required applications, permits, and plans; have made a good faith effort to complete the required work; and are able to substantiate the claim of undue hardship.
Project Timeline
The length of a fire sprinkler system project, from the initial decision to proceed, until completion and final approval of the installation, depends on the size of the space to be sprinklered and the specifics of the building.
As a rule of thumb, the design phase of a building-wide sprinkler system can take up to six months. After drawings specifications, and a bid package have been compiled, a competitive bid process to select a qualified contractor will take place. The bid solicitation/review process, including negotiating a contract with the chosen contractor, typically takes several weeks. After installation, the system must be tested and inspected before final approval is given by the New York City Fire Department and DOB.
The entire sprinkler project can take up to a year or more, so owners should start planning well in advance to meet the July 1, 2019 deadline.
Special Inspections
As part of the final approval process by the DOB, sprinkler systems must be inspected by a registered Special Inspection Agency. Special Inspectors who work for the engineering or architectural firm that designed the sprinkler system are more likely to have a comprehensive understanding of the design, which should improve the quality and efficiency of the inspections.
Cost
The cost of installing or upgrading an automatic fire sprinkler system depends on the size of the space to be sprinklered and the specifics of the building construction/layout/use. The source of the water supply for the system also has a direct bearing on cost, depending on whether there is an existing water supply that can be tapped into or if a new one needs to be installed.
Sprinkler Maintenance and Care
Sprinkler systems must be periodically inspected, tested, serviced, and maintained in good working order in accordance with the Fire Code. Records of all system inspections, tests, servicing, and other maintenance must be maintained on the premises for a minimum of three years.
Questions?
For more information on Local Law 26/04 and sprinkler systems, please contact RAND at 212-675-8844, info@randpc.com.