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FIR-8.05 - Sprinkler Requirement in Existing A2 Occupancies

Administrative Rule Adopted by Portland Fire & Rescue Pursuant to Rule-Making Authority



A.  This policy is established January 30, 2009.

B.  The purpose of this policy is to provide guidelines for when to require fire sprinklers in existing unsprinklered A2 occupancies undergoing alterations or additions. This policy does not apply to nightclubs with an occupant load greater than 100. Nightclubs with an occupant load greater than 100 must comply with FMO Policy FIR 8.09.

C.  Background:

1.  A2 occupancy is defined as Assembly uses intended for food and/or drink consumption including, but not limited to: Banquet halls, Night clubs, Restaurants, Taverns, and Bars.

2.  Effective April 1, 2007 the threshold for requiring fire sprinklers in A2 occupancies was reduced from an occupant load of 300 to 100 primarily based on code changes submitted after “The Station” fire.

3.  Oregon Structural Specialty Code (OSSC) 3403.1. Existing building or structures. Additions or alterations of any building or structure shall comply with the requirements of the code for new construction. Additions or alterations shall not be made to an existing building or structure that will cause the existing building or structure to be in violation of any provisions of this code. Portions of the structure not altered and not affected by the alteration are not required to comply with the code requirements for a new structure.

4.  OSSC 3403.3 Nonstructural. Nonstructural alterations or repairs to an existing building or structure are permitted to be made of the same materials of which the building or structure is constructed, provided that they do not adversely affect any structural member or the fire-resistance rating of any part of the building or structure.

5.  OSSC 3406.1 Conformance. No change shall be made in the use or occupancy of any building that would place the building in a different division of the same group of occupancy or in a different group of occupancies, unless such building is made to comply with the requirements of this code for such division or group of occupancy. Subject to the approval of the building official, the use or occupancy of existing buildings shall be permitted to be changed and the building is allowed to be occupied for purposes in other groups without conforming to all the requirements of this code for those groups, provided the new or proposed use is less hazardous, based on life and fire risk, than the existing use.

6.  Portland Fire Code (PFC) 102.1.4 “Construction and design provision. The construction and design provisions of this code shall apply to: …. Existing structures, facilities and conditions which, in the opinion of the fire code official, constitute a distinct hazard to life or property.”


A.  2009 International Building Code (IBC)

B.  2010 Oregon Structural Specialty Code (OSSC)

C.  2007 Portland Fire Code (PFC)

D.  Definitions:

1.  Nightclub: means an A-2 occupancy use under the 2009 International Building Code Code which (a) has areas for dancing or viewing performers; and (b) serves food or drink. “Nightclub” does not include houses of worship, theaters with fixed seating, banquet halls, or lodge halls.


When an existing unsprinklered A2 occupancy with an occupant load of 100 or more is undergoing an addition or alteration, fire sprinklers are required under the following conditions:

A.  The Fire Marshal finds that when occupant loads are increased in eating and drinking establishments the additional risk constitutes a distinct hazard to life above what existed prior to the re-development.

B.  Automatic fire sprinklers will be required as specified in FMO Policy FIR 8.09 where the occupant load of a nightclub is greater than 100.

C.  Fire sprinklers will be required throughout the fire area for A2 occupancies where the renovation results in an increase in occupant load of 25 or more or an increase of 15% above the current calculated occupant load which ever is smaller.


Revised policy adopted by Chief of Portland Fire & Rescue March 18, 2014.
Adopted by Chief of Portland Fire & Rescue February 2, 2009.
Filed for inclusion in PPD February 2, 2009.
Openings in Lieu of Automatic Sprinklers administrative rule deleted from PPD by Chief of Portland Fire & Rescue June 12, 2007.