Guide to Promoting Automatic Fire Sprinkler Systems: Dealing with a Performance-Based Code Environment

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A performance-based code environment in fire protection refers to a regulatory framework where fire safety measures in buildings and other structures are based on their ability to meet specific fire protection goals and objectives. These could be limiting fire growth, ensuring safe evacuation, or protecting structural integrity, as opposed to the far more common and traditional “prescriptive” codes.

When it comes to fire protection, performance-based design was created to consider the specific characteristics of the building, such as with innovative building designs, historic structures, or complex industrial processes. Prescriptive codes and standards typically take a one-size-fits-all approach that may or may not be appropriate due to a building’s unique characteristics.

The performance-based approach promotes a risk-based approach to fire safety, where the desired outcomes are the focus over total adherence to specific code requirements. However, implementing this approach demands greater technical expertise, in-depth analysis, and close collaboration among architects, engineers, regulators, and other stakeholders.

Prescriptive Codes—with Flexibility

Even codes that are considered highly prescriptive, like the IBC, often allow for performance-based alternatives if designers can demonstrate equal or greater safety through detailed analysis approved by the authority having jurisdiction. In contrast, a true performance-based code does not rely on prescriptive requirements as a baseline.

As an example, the Fire Safety Committee of the Nordic Committee on Building Regulations published a model performance-based code for fire safety in buildings in 1994 that proposed the following general objective:

“Every building and structure shall be constructed in such a way and with such materials, and their fittings and furnishings shall be such that, with regard to their use and situation, they afford satisfactory safety with respect to fire for persons who are present in the building, including secure facilities for the rescue of persons and for firefighting, and with respect to the spread of fire to buildings and structures both on the same and adjoining plots. Every building and every structure shall be constructed in such a way that they provide acceptable safety against damage to property and the environment.”

“Deemed-to-Satisfy” Provisions

Compliance with performance-based codes and regulations like that above is typically demonstrated through analysis and/or calculations demonstrating that a proposed design meets the objectives, as opposed to the specific requirements of prescriptive codes. Because of the cost that can be involved with performing a detailed analysis, most performance-based codes also permit the use of pre-accepted solutions, often referred to as “deemed-to-satisfy” provisions.

Verifying a pre-approved solution is relatively straightforward and closely mirrors the process used for complying with standard prescriptive codes. However, verifying a proposed performance-based solution presents more challenges. In many countries, there is a shortage of fire protection engineers, which often leads to these professionals being asked to assist local authorities with design reviews. This situation can lead to conflicts of interest, particularly when engineers are involved in reviewing each other’s projects, potentially discouraging objective critique to avoid conflict.

Differences by Expectations and Experience

Additionally, what is considered an acceptable performance-based solution often varies depending on cultural expectations and local experience. As it relates to fire sprinkler usage, these differences became especially evident in repeated case studies presented by various national teams during the biannual International Conferences on Performance-Based Codes hosted by the Society of Fire Protection Engineers (SFPE).

To see an example of these differences, enter your email address to the left to download the full “Guide to Promoting Automatic Fire Sprinkler Systems: A Road Map for Advocacy.”

Once you download the guide, see chapter 7, table 7-1, which illustrates the use of fire sprinklers by several national teams participating in the conference in their proposals for protection of five unique structures from 1998 to 2006. The five structures included a 40-story high-rise office building, a 28,000 m² shopping mall, a 22-story high-rise hotel, a large international transportation center, and a 30-story housing structure for the elderly.

Beyond cultural biases, performance-based designs are heavily influenced by a society’s tolerance for risk and the assumptions made about fire growth and size, tenability criteria, the effectiveness of passive fire protection measures, and the reliability of fire sprinkler systems. The global lack of professional recognition and consistent standards in these areas also impacts how widely fire sprinklers are incorporated into performance-based fire protection strategies.

For example, the IFSA provided partial funding for a 2010 study of design alternatives in buildings with fire sprinkler systems conducted by Fredrik Nystedt of the Department of Fire Safety Engineering and Systems Safety at Lund University in Sweden. Intended to form the basis of a Nordic guideline on verification of design alternatives, the report encompassed a review of the effectiveness of fire sprinkler systems and proposed design fires appropriate for use in sprinklered buildings, along with proposed tenability criteria. The study also included guidance on verification methods for sprinkler tradeoffs.

Criticism of Performance-Based Codes

Performance-based codes have faced criticism, particularly in the aftermath of the 2017 Grenfell Tower fire in London, which claimed 72 lives. The tragedy sparked widespread calls to reassess England’s building regulations. Notably, in 1985, 306 pages of detailed building codes had been replaced with just 24 pages of performance-based requirements. Among those urging reform was the Royal Institute of British Architects, which called for clearer, more prescriptive rules—including mandatory fire sprinkler systems in all new and converted residential buildings, as required by Regulations 37A and 337B of the Building Regulations for Wales, or at minimum, in residential buildings over three stories tall.

In many ways, the incentives for fire sprinkler use found in prescriptive codes function similarly to “deemed to satisfy” solutions under performance-based systems. Fire safety advocates should continue to promote favorable consideration of active suppression systems in both regulatory frameworks.

When performance-based codes include suggested or required assumptions—such as sprinkler system reliability, tenability thresholds, or maximum fire size—sprinkler advocates should ensure these values are reasonable. One of the more challenging tenability criteria often relates to visual obscuration. Fire testing has shown that sprinkler activation can sometimes increase visual obscuration, as the suppression process disrupts the combustion cycle and releases unburned particles and steam into the air near the fire. However, both firefighters and researchers have consistently emphasized that not all “smoke” is the same. The aerosol produced during sprinkler-controlled fires tends to be less toxic and less irritating to the respiratory system than smoke from uncontrolled combustion.

The Importance of Automatic Sprinkler Systems

One of the main reasons fire sprinklers perform so effectively within performance-based design frameworks is that these methodologies often rely on deterministic models, where the rate of heat release is a critical factor. Since temperatures, smoke generation, and toxic gas production are all directly tied to the heat release rate, the ability of sprinkler systems to limit and suppress that rate significantly reduces a fire’s harmful effects. In many cases, such as when designing smoke control systems, it is not feasible to develop an adequate solution without first defining a maximum fire size. Automatic sprinkler systems are one of the key tools that make this possible—and one of the keys to promoting a risk-based approach to fire safety through a performance-based code environment.

Watch for the next blog post in this series based on the Guide. It highlights contents of chapter eight, “Sprinkler Mandates or Tax Incentives Through Legislation.”

For more information about strategies to promote the greater use of automatic fire sprinkler systems, enter your email address above to download the full “Guide to Promoting Automatic Fire Sprinkler Systems: A Road Map for Advocacy.”