Sprinkler heads: equipment or building materials? And what's the difference anyway?

Last month the Virginia Supreme Court resolved the question of whether sprinkler heads were equipment or building materials in Royal Indemnity Co. v. Tyco Fire Products, 281 Va. ___ 091993, ___ S.E.2d ___ (2011). Why does it matter you might ask? The short answer is it affects whether defect claims are barred under Virginia's "statute of repose," which limits construction / construction material defect claims to 5 years from cause of action accrual. The court reached that conclusion because it held that sprinklers were not an essential structural component and serve a purpose unrelated to the construction of the building itself. Further, the court held that characteristics of the product lend themselves to close quality control when manufactured, and thus are more akin to manufactured equipment exempt from the statute of repose then construction materials, which are covered by the statute of repose. Whether you agree with the court's conclusion or not, it shows the legal significance of the characterization of construction related products on legal liability.