To: Local Fire Marshals
From: Lauri Volkert, State Fire Marshal
Topic: Temporary Warming/Cooling Shelters
This general information notice (GIN) revises the information previously provided in GIN 2018-1 and is to be used as a guide for local fire marshals to permit sleeping in existing, non-sprinklered**, nonresidential occupancies.
It clarifies that all temporary warming and cooling shelters with sleeping within existing, nonresidential, non-sprinklered occupancies are required to be reviewed and approved by the State Fire Marshal through the fire code modification process under Connecticut General Statutes (CGS) 29-296. Such temporary shelters typically consist of a temporary change of use under the Connecticut State Fire Safey Code (CSFSC) and may lack some of the required provisions of the code for the for transient sleeping in existing, nonresidential, non-sprinklered buildings.
OSFM would be inclined to approve the change of use within an existing, nonresidential, non-sprinklered building to a Group R (Residential) occupancy to permit temporary sleeping based on the following criteria and should be noted in the modification application inclusive of a floor plan:
- Buildings in consideration shall be noncombustible construction (Type I or II) OR shall be of any other construction type where the sleeping area(s) are separated from other areas of the building by minimum of a one (1) hour fire barrier(s). (See 2022 CSFSC Part IV, Annex A and NFPA 914, Appendix D for additional guidelines).
- Occupancy is limited to the number of occupants calculated using an occupant load factor of 50 gross for Dormitories.
- Sleeping area(s) shall be located on a level of exit discharge.
- Sleeping area(s) shall have exit(s) directly to the exterior.
- There shall be two (2) awake and aware, on-site staff at all times when the building is occupied.
- The building in consideration shall be protected throughout with an NFPA 72 fire alarm system with automatic fire detection and occupant notification in accordance with the CSFSC.
- Carbon Monoxide detection shall be installed in accordance with CSFSC Part III, Section 915.2. (Need inspection by the local fire marshal prior to use to verify the operation).
- No cooking of food. Food warming only.
**If an existing non-residential occupancy building in consideration has an NFPA 13 automatic sprinkler system and occupant notification throughout the building in accordance with the CSFSC, the local fire marshal shall determine if the building complies with all Group R-1 requirements. If the building meets all Group R-1 requirements then no code modification is needed.
OSFM has decided that the section being modified would be CSFSC Part III Section 903.2.8 since the existing nonresidential, non-sprinklered, occupancy building is changing use to a temporary Group R-1 (Residential – Congregate Living Facility). The criteria listed above would be the alternative safeguards listed on the fire code modification request. A separate building code modification shall be submitted to the local building official with the alternative compliance measures being provided. The local building official will forward the request to the Office of the State Building Inspector to review alternative compliance with the Connecticut State Building Code.
We consider each situation to be unique and will be evaluated on a case-by-case basis. Prior to the local fire marshal’s submittal of a fire code modification request, the minimum criteria listed above shall be used to determine an acceptable location for a temporary warming and cooling shelter. Once a fire code modification is granted for a specific building and no further applications for alterations are made in the future to said building, the fire code modification is applicable for the life of the building where the warming or cooling shelter would be allowed in the future without resubmitting a fire code modification request every time a shelter is needed. To ensure no additional alterations have been made, the local fire marshal should conduct an inspection at the beginning of each heating/cooling season when the space will be used to ensure continued compliance with the provisions of the approved modification. A copy of such inspection report shall be forwarded to the local building official so that a temporary use permit could be issued for a Group R-1 Congregate Living Facility not to exceed 180 days within a 12-month period pursuant to CSBC Section 108.1 of the International Building Code.
If there are any questions, please do not hesitate to contact Joseph Duval in our Field Services Division at joseph.duval@ct.gov or (860) 713-5750.
