Interpretation #9158

I am requesting formal technical assistance regarding the application of the Florida Building Code (FBC) to a facility which is licensed under FS 409.175 as a Residential Child-Caring Agency.

Project Overview:
Existing single-family home built in 1959, approximately 1,300 sq. ft.
Licensed to serve five or fewer non-custodial children.
Residents are capable of self-preservation (non-custodial care).
Facility falls under the scope of FAC Chapter 69A-41, Fire Safety Standards for Residential Child-Caring Facilities.
Specific Question:
Under the FBC, Group R-3 occupancies (single-family dwellings / small residential facilities) are generally described in Section 903.2.8.1:
“An automatic sprinkler system installed in accordance with Section 903.3.1.3 shall be permitted in Group R-3 occupancies.”

Given that the facility is:
Licensed under FS 409.175, not FS 419.001 (Community Residential Homes);
Serving non-custodial children, all capable of self-preservation;
An existing building constructed in 1959;
Occupancy limited to six residents in a single-family dwelling,
I respectfully request clarification on the following:
Whether the FBC requires the installation of an automatic fire sprinkler system in this facility, or whether compliance with existing fire safety requirements under FAC 69A-41 (smoke detection, alarms, egress, fire extinguishers, drills) is sufficient.
Whether the facility can be classified as R-3, and if so, whether Section 903.2.8.1 permits the AHJ to accept alternative life safety measures in lieu of sprinklers.
Any guidance on how the FBC’s Existing Building provisions may apply to a change of occupancy from a private dwelling to a licensed small residential child-caring facility.
I am seeking a written technical assistance response that I can provide to the local Authority Having Jurisdiction (AHJ) and maintain in my licensing file.
Thank you very much for your time and guidance. Please let me know if additional documentation, drawings, or licensing records are required.