What happens when furniture becomes an enclosed room with four walls and a ceiling that is intended for occupancy?
Prefabricated modular lactation rooms, privacy phone booths, sleep pods and multi-person meeting pods have become popular features of modern office spaces. The locations where these are now found include airports, convention centers, business and government buildings as well. These are factory-built products, rather than rooms being constructed as a part of the structure in accordance with the local building code. They were widely displayed at the 2026 NeoCon show in Chicago and are marketed in furniture showrooms throughout the country.
But are they furniture?
The 2027 International Fire Code (IFC) will for the first time end the guessing game by adding a new Section (323) for Modular Rooms, which will be defined as a “prefabricated structure intended for indoor use to provide privacy that has walls, a ceiling, with or without an integrated floor, and that can include integral electrical wiring, ventilation, and furniture.” A construction permit will now be required for the installation of modular rooms.
Modular rooms will also need to be listed and labeled in accordance with a new Referenced Standard in the code - UL 962-2022 Household and Commercial Furnishings. Requiring the modular room to be a listed product provides a code official with verification that it meets testing requirements for applicable fire and electrical safety for occupancy. The UL 962 listing standard covers the fabrication and safety of the modular room and includes requirements for sound insulation, finish materials, internal wiring, lighting, ventilation, and other construction features. UL 962 requires that modular rooms be tested for flame spread, with minimum passing results equivalent to a UL 723 Flame Spread Index of 200. UL 962 additionally contains furniture flammability requirements for upholstered seating and mattresses (sleep pods) that may be incorporated into the modular room.
As sleep pods, these modular rooms, including sleep pods, cannot be stacked. In fact, the aggregate area of modular rooms within a building cannot exceed 10 percent of the fire area in which they are located.
Modular rooms are not permitted in Factory, Hazardous, Storage, or Utility occupancy groups. The fire code official is additionally authorized to limit the number of modular rooms installed in a single fire area. In buildings equipped with a fire alarm system, the modular room must be equipped with smoke detectors. In other buildings, where required, the modular room shall be equipped with a smoke alarm compatible with the building’s system and in accordance with NFPA 72 National Fire Alarm and Signaling Code.
Where modular rooms are installed in areas equipped with an occupant notification system, the audible and visual signals must also provide notification to the occupants within the modular room.
In addition, the IFC will reference the 2025 edition of NFPA 13 Standard for the Installation of Sprinkler Systems, aligning with the International Code Council's pattern of adopting the most recent standard editions available during the code development cycle.
The following sections are relevant to modular rooms:
NFPA 13-2025 9.2.9.1
Sprinklers shall not be required to be installed in furniture, cabinets, and similar items not intended for occupancy.
NFPA 13-2025 9.2.10 Small Temporarily Occupied Enclosures.
9.2.10.1*
Sprinklers shall not be required in small isolated temporarily occupied enclosures that do not extend to [beyond 18 inches of] the ceiling.**
9.2.10.2
The maximum area of the small temporarily occupied enclosures shall not exceed 24 ft2, and storage [above] shall not be permitted.
*These isolated spaces are similar to hearing testing booths, lactation rooms, phone booths, or pods and are not used for storage. Miscellaneous furniture, wastebaskets, and other non-storage items are allowed in the space. Isolated is intended to mean that units should not be located adjacent to each other and are physically separated.
NFPA 13-2025 10.2.8.4 Obstructions that Prevent Sprinkler Discharge from Reaching Hazard. **
Obstructions located 18 inches or less below a sprinkler deflector will prevent the sprinkler discharge from reaching potential combustibles located below sprinklers.
NFPA 13-2025 10.2.8.3.1.6
Sprinklers shall be permitted to be spaced on opposite sides of the obstruction not exceeding 4 ft in width, where the distance from the centerline of the obstruction to the sprinklers does not exceed one-half the allowable distance between sprinklers.
Therefore, to avoid adding dedicated fire sprinkler heads inside, the pods must be no greater than 24 square feet in size and isolated from each other. Separation between the pods is based on the spacing of the sprinkler heads from the centerline of the pod to one-half of the allowable sprinkler head spacing.
However, spacing the pods from each other is only half the battle. To completely avoid adding internal sprinklers, the pods must also comply with strict dimensional, ceiling, and obstruction rules.
1. Pod Size and Obstruction Limits (The 4-Foot Rule)
The main building's ceiling sprinklers must be able to spray over and around the furniture.
• The Width Exception: Per NFPA 13 and the IBC, a freestanding structure can omit internal sprinklers if its lesser horizontal dimension (width) is 4 feet or less. This classifies the pod as a standard ceiling obstruction rather than a separate room.
• Single-Person Pods: Standard 4'x4' single phone booths usually pass without a dedicated head.
• Multi-Person Pods: Large meeting pods (e.g., 6'x6' or 8'x8') exceed the 4-foot restriction and almost always require internal sprinklers, regardless of how far apart they are spaced from other pods.
2. Vertical Clearance to the Ceiling
A pod acts as a massive block to the room's overarching sprinkler spray pattern.
• Maintain a minimum of 18 inches of clear vertical space between the topmost deflector of the building's sprinkler heads and the roof of the office pod.
• If a pod's solid roof comes within 18 inches of a sprinkler head, it creates a "shadow zone" that leaves the floor unprotected, triggering a code violation.
3. Alternative Solutions to Avoid Hard-Piping Water
If your layout requires placing pods close together, or if you are using larger pods, you can avoid tapping into the building's main sprinkler line by utilizing specific engineering features:
• The "Drop-Ceiling" / Melting Tile Mechanism: Many premium pod manufacturers design roofs with fire-activated panels. In a fire, the acoustic roof tiles automatically release or melt away at a lower temperature (typically 135°F) than the water sprinklers (typically 155°F). This allows the building's existing ceiling heads to spray directly into the pod.
• Open-Grid Ceilings: If a pod features a mesh or open-grid roof where the openings comprise at least 75% of the total roof area, the space is not considered enclosed, allowing you to omit localized internal sprinkler piping.
• Independent dry chemical or gas-based fire suppression tanks are sometimes used as an alternative to wet-pipe sprinklers, but this needs approval by the Authority Having Jurisdiction (AHJ).
What this means for you
- Pods become a permitted scope item, so they belong in the drawing set and FF&E coordination, not just the dealer’s order.
- The 10% fire area cap affects space planning early.
- Existing installations may be required to comply with the new code retroactively if they were not previously approved by the municipality.
Note that the 2027 IFC won’t apply anywhere until a jurisdiction adopts it, so remember to always submit a dimensioned floor plan to your local fire official—prior to ordering pods, as local code interpretations can vary widely. If you need assistance with determining code adoption or amendments, Burnham is always here to help.
