Purpose

This is to clarify the definition of “sleeping area” as used in the 2016 edition of the National Fire Protection Association (NFPA) 72, Section (§) 18.4.5.3, and the required location of low-frequency sounders in sleeping areas. 

Background

In new construction, the Minnesota State Fire Code (MSFC) and the Minnesota Building Code (MBC) require fire alarm systems to provide low-frequency alarm signals in all sleeping areas in accordance with the 2016 edition of NFPA 72 (see §18.4.5.3). However, NFPA 72 does not provide a specific definition for “sleeping area.” As a result, there is confusion and inconsistent application of the code among code officials based on the NFPA Annex A commentary (see § A18.4.5.3), which states the intent of this section is to require low-frequency signals in areas intended for sleeping “and in areas that might reasonably be used for sleeping,” such as living rooms.

1. Defining sleeping areas 
2. Both the MSFC and MBC define sleeping and dwelling units (in part) as having “permanent provisions for sleeping” but do not provide a specific definition for a “sleeping area.” When terms are not defined in code, MSFC § 201.4 states that Merriam-Webster Collegiate Dictionary shall be considered as providing ordinarily accepted meanings. Although Merriam-Webster does not have a definition for a “sleeping area” or a “sleeping room,” it does define a “bedroom” as “a room furnished with a bed and intended primarily for sleeping.”

Interpretation

It is the interpretation of the State Fire Marshal Division (SFMD) that living rooms and similar areas, such as family rooms, dens, rec rooms, etc., do not require low-frequency alarm signals unless such areas are provided with permanent provisions for sleeping. This interpretation is based on the following:

• Such areas are not typically designed or intended primarily for sleeping, nor are they typically provided with permanent sleeping provisions (e.g., a bed).  
• Such areas are incongruent with the ordinary accepted meaning of a sleeping area.
• The Annex A Explanatory Material is for informational purposes only, is not part of the NFPA 72 requirements, and has not been adopted under Minnesota Rules.