# Defining Work Area



## jar546 (Jul 10, 2013)

I am going to start this thread all over again.  It was started quite a long time ago and is the 4th most viewed thread in the history of this forum.  It was eventually locked due to how far it got off the OP topic and there were some personality issues.  The person that posted it hit a home run because it was their first post ever.  Here it is to hopefully start a good discussion again.  I would rather start new than try to clean up the mess it became.



> here's a question we're currently wrestling with in our office - how extensively can the 'work area' be defined? where does it end?
> 
> the issue at hand is the sprinkler requirements for residential multi-family buildings undergoing Level 2 Alterations as defined by IEBC 2009.
> 
> ...


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## RLGA (Jul 10, 2013)

(The 2012 IEBC is used for this response)

The use of a 'work area' applies only to the *Work Area Compliance Method*, which is one of three compliance methods provided by the IEBC.  The permit applicant selects the method which is to be used and not the building official.  I usually advise my clients to use the *Prescriptive Compliance Method *whenever possible.  The third compliance method is the *Performance Compliance Method*, but that method is only permitted for buildings built prior to a certain date as determined by the jurisdiction--usually, it's the date when a formal building code was first adopted for use by the jurisdiction.

As for the definition of a 'work area,' the IEBC provides a definition in Chapter 2, which I won't duplicate here.  'Work area' applies to reconfigured space, which is applicable to Level 2 alterations and above.  Level 1 alterations do not reconfigure space, and thus are not part of the 'work area.'

Replacing windows and overlaying gypsum board does not reconfigure space, so it would be considered Level 1 alteration work if it does not qualify as a repair; thus, this work is not part of the 'work area.'  The reconfigured bathrooms and kitchens would definitely be considered Level 2 alterations and each would be considered a 'work area.'

Per Section 804.2.2, if the work area does not exceed 50% of the floor area, then a sprinkler system is not required.  Besides, Exception 1 of that section exempts 3-story Group R structures from the sprinkler requirement.

As I mentioned earlier, I generally advise my clients to use the *Prescriptive Compliance Method*--it is much easier to use and definitely does not trigger the installation of a sprinkler system for the type of work indicated in the OP.  If there was a change in occupancy or additions were being made, then a sprinkler system throughout may be required.


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## mtlogcabin (Jul 10, 2013)

Wow I guess RLGA nailed that one and put and end to the discussion


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## jar546 (Jul 10, 2013)

mtlogcabin said:
			
		

> Wow I guess RLGA nailed that one and put and end to the discussion


For once everyone agrees!!!

Now on to that handrail, stairs to attic discussion


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## RLGA (Jul 11, 2013)

I don't know why I missed the old thread the first time around, but I'm glad I had the opportunity here to respond.

Now I have a 'work area' question for you all:

Assume an existing, very large warehouse (Group S-1) with a total building area of 15,000 sq. ft.  In the corner is a small 200 sq. ft. office.  The owner wants to expand the office to 400 sq. ft.  The office is definitely part of the 'work area'; however, technically, the storage portion is also reconfigured, which means that it, too, is part of the 'work area', thereby making 100% of the building area is reconfigured.  This now requires a sprinkler system , since the 'work area' exceeds 50% of building area and the 2012 IBC Section 903.2.9 requires a Group S-1 fire area exceeding 12,000 sq. ft. to be sprinklered.  Does that seem fair?


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## jar546 (Jul 11, 2013)

I would like to know how using 200' square of the storage area constitutes 100% of the existing 14,800


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## RLGA (Jul 11, 2013)

My question exactly.

Since 200 sq. ft. was taken from the large storage area, the large storage area has technically been reconfigured, too, and is thus part of the 'work area.'

See the definition of a work area--"That portion or portions of a building consisting of *all* reconfigured spaces..."  Therefore, the office and the storage area are both part of the work area, which, in this case, is 100% of the building area.

Now, I agree that this is ridiculus.  But what is there to prevent a building official, who only sees black and white in the code book, from making that kind of determination?  In my opinion, nothing.  I believe an exception needs to be added, such as limiting the 'work area' to 10 feet beyond the extent of the alteration work where the remaining walls of reconfigured space is greater than 10 feet from the location of the altered work...or, something to that effect.


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## jar546 (Jul 11, 2013)

I would only recognize this as a 2.7% work area which is more inline with the intent of the code.  I agree with you that there are those inspectors that only read black and white.


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## Mac (Jul 11, 2013)

Imagine the large warehouse operator wants to build a new 200 SF office in the far corner, and convert the old office to warehouse psace.

Would you handle that the same way?


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## RLGA (Jul 11, 2013)

> Imagine the large warehouse operator wants to build a new 200 SF office in the far corner, and convert the old office to warehouse psace. Would you handle that the same way?


Technically, yes--100% of the building area would be affected as I described it above.  However, with my proposed exception, the 'work area' under that scenario would still not require a sprinkler installation, even though the 'work area' would be slightly larger compared to my example.Below is graphical example of how my proposed exception would work...
	

		
			
		

		
	

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View attachment 756


Any thoughts?
	

		
			
		

		
	

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/monthly_2013_07/572953c98514e_CurrentIEBCworkareaapplication.JPG.a26069ec5991797869a5e7e56e6f40a7.JPG

/monthly_2013_07/572953c986e79_ExistingCondition.JPG.98ac3bb5350b4947dc242f52b316158d.JPG

/monthly_2013_07/572953c98d8e2_ProposedAlterationWork.JPG.db83ae4c494acccb7e623a66a882bc27.JPG

/monthly_2013_07/572953c98fbfe_ProposedExceptionforWorkArea.JPG.fb426a2913d28195354915f9a575e350.JPG


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## jar546 (Jul 11, 2013)

Interesting proposal but do you think it is too specific and may not apply in all instances where the intent is for it to apply?


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## RLGA (Jul 11, 2013)

jar546 said:
			
		

> Interesting proposal but do you think it is too specific and may not apply in all instances where the intent is for it to apply?


I need to flesh it out some more and apply it to several conditions to see how it affects the application of the code.  For example, if the 10-foot exception is applied to a space and the area within that 10-foot limitation exceeds 50% of the space, then the area of the entire space shall be included in the work area.


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## Rick18071 (Jul 12, 2013)

What if they did a level 2 on 50% of the building and after it was finished they did the other 50% on a new permit?


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## peach (Jul 14, 2013)

Rick,  that happens too frequently.. little pieces of work a couple of years apart.. all under 50% of the floor area.  Within 5 years or so, the entire building is renovated and none of it up to current code.


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## RJJ (Jul 14, 2013)

I call that expansion by creep!


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## peach (Jul 14, 2013)

exactly... we know that.. and yet we keep falling for it.  I thought the IEBC had a limitation to the timing of work to avoid it, but I can't find it right now.. may be a local amendment only.


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## chris kennedy (Jul 14, 2013)

RLGA said:
			
		

> overlaying gypsum board does not reconfigure space


How about a stupid question from an electrician? Laminating boards over existing walls and slightly reducing square footage doesn't 'reconfigure space'?


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## peach (Jul 14, 2013)

reconfiguring is a wide open definition....


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## tmurray (Jul 15, 2013)

RLGA said:
			
		

> I need to flesh it out some more and apply it to several conditions to see how it affects the application of the code.  For example, if the 10-foot exception is applied to a space and the area within that 10-foot limitation exceeds 50% of the space, then the area of the entire space shall be included in the work area.


This might seem like a dumb question, but I use a different code. The 10' rule you are muling around would only be applied horizontally (like in a set of plans), or would this also be applied vertically? For instance if I am adding a office that has 8' ceilings, the 10' foot rule would mean that the work area would extend the 8' height of the office, the framing and then 10' up? I guess in that scenario the work area would also extend from 10' under the proposed office as well.


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## RLGA (Jul 15, 2013)

tmurray:  Work area applies only to the horizontal projection (i.e. floor area) of the alteration work.  Therefore, regardless of how high (vertical) the alteration work is, the affected floor area remains the same; thus, the work area is the same.


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## rleibowitz (Jul 15, 2013)

In Massachusetts you can appeal any and all decisions made by a Building Official to an informal "Board of Appeals" where two State Building officials and a Fire Official will hear your request. The filing fee is $50 and appeals are heard in 30 days. In order to be successful you may have to show hardship or an alternative to a Building Officials ruling. When I hear complains about a building official...hey you can appeal!


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## peach (Jul 15, 2013)

as long as the Board of Appeals realizes they can't issue a code modification.....


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## mtlogcabin (Jul 16, 2013)

RLGA said:
			
		

> I need to flesh it out some more and apply it to several conditions to see how it affects the application of the code.  For example, if the 10-foot exception is applied to a space and the area within that 10-foot limitation exceeds 50% of the space, then the area of the entire space shall be included in the work area.


I believe the definition gives the designer the responsibility to determine the work area. If the designer defines the work area as including a 10 ft space located next to the new walls then the remaining warehouse space would not be included and the sprinkler requirements would not be applicable. JMHO

WORK AREA. That portion or portions of a building consisting of all reconfigured spaces as indicated on the construction documents. Work area excludes other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by this code.


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## peach (Jul 17, 2013)

mtlogcabin: I agree with you.. problem always is... one designer says this.. the NEXT designer says that.. that's how they get around the IEBC limits.


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## mtlogcabin (Jul 18, 2013)

peach said:
			
		

> mtlogcabin: I agree with you.. problem always is... one designer says this.. the NEXT designer says that.. that's how they get around the IEBC limits.


So one designer knows how to use the code for the benefit of his/her client and the other doesn't? How is that getting around the IEBC limits/options?


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## peach (Jul 19, 2013)

that's up to the designer's code knowledge.


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## Mr Softy (Sep 10, 2013)

oy.

Code Committee gets back to work in a few weeks, and 'reconfigured space' is item one on the agenda.

the key question is still - why have thresholds to FP upgrades (based on % of work area) if the code is written (or applied) in a way that those thresholds never get met?

RLGA's warehouse example is an extreme, but valid, example.

the front line in the argument has been, and still is, 3-family triple decker apartment buildings being converted to condos with extensive alterations, and reconfiguration of partition walls.


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## jar546 (Sep 10, 2013)

They will have to clarify the intent.

Was it written the way it was on purpose to give leeway?

What is the general consensus of the membership?

Is it a problem at all?


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## Mr Softy (Sep 10, 2013)

jar546 said:
			
		

> They will have to clarify the intent.  Was it written the way it was on purpose to give leeway?
> 
> What is the general consensus of the membership?
> 
> Is it a problem at all?


if one asks the ICC, they feel that Level 1 and Level 2 work can co-exist on the same project. a moved wall could be Level 2, but the sheetrock that butts up to it is Level 1.  with this interpretation, one could parse off all reconfiguration into a tiny percentage of the overall project, and never come close to the thresholds that they themselves put in the code.  IIRC, the original document (HUD) that broke work up into levels did this specifically to capture upgrades as the scope of work increased.

the example i have used (repeatedly) is a three unit building, completely gutted, with partition changes. Level 3 - 50% work area of building.  but if i take out the level 1 work (as ICC feels is  possible) i won't be at 50% anymore.

it is a problem in MA as we have had, for 15+ years, in the code and its intent, FP upgrades based on substantial work.


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