# Fire Apparatus Access Roads.....



## Truck3capt (Jul 18, 2017)

A developer has proposed an assisted living complex in our jurisdiction that includes an additional wing for memory care.  Single story, Type V construction and fully sprinklered. (probably required based on the size 60,000sf +/-) Site is dead flat agricultural currently.  No challenging topography other than the parcel is long and skinny. 

Developer has proposed access on the front and one side of the building.  Building is approximately 600 feet wide across the front including the connected memory care wing .  The structure is approx 300 feet deep and pushed almost against the rear lot line/setback. * My interpretation has always been that all three of the items listed below for the exception to 503.1.1 (2012 IFC) have to apply in order for us as the AHJ to authorize the increase of the 150 foot distance.*   Or is it if any one of the three items applies to the project the AHJ can grant relief?   The developer states that they have built this building in other jurisdictions and were given approval to provide access on two sides as long as the  building is sprinklered.

_Exception: The fire code official is authorized to
increase the dimension of 150 feet (45 720 mm) where:
1. The building is equipped throughout with an
approved automatic sprinkler system installed in
accordance with Section 903.3.1.1, 903.3.1.2 or
903.3.1.3.
2. Fire apparatus access roads cannot be installed
because of location on property, topography,
waterways, nonnegotiable grades or other similar
conditions, and an approved alternative means of
fire protection is provided.
3. There are not more than two Group R-3 or Group
U occupancies._

I'm just curious if this is how it would be interpreted in the jurisdictions of the members on the forum. 

Without even checking the height and area tables in the IBC I'm assuming that sprinklers are required in order to build a building of this construction type and occupancy anyway.  Why would they get relief from a requirement  for access roads for providing  life safety systems  that are  required by other sections of the code in order to increase the size of their building?  We've allowed distance increases for buildings on sites with drainage swales, creeks, etc, but usually require additional standpipes, compartmentalization, etc.   Am I missing something?


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## cda (Jul 18, 2017)

Assisted living has many definitions 

Memory unit may be an "I"occupancy.


So what is the city typing the occupancies????


I am thinking access is needed

Type V construction 

Nature of the residence

Access for ambulance 

Stick to the 150 feet to all points


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## Truck3capt (Jul 18, 2017)

cda said:


> Assisted living has many definitions
> 
> Memory unit may be an "I"occupancy.
> 
> ...


This project really hasn't even gotten to the point of typing the occupancy.  I'm not sure that it really matters as far as the access roads go.  The IFC makes no distinction for the access road requirement in relation to the occupancy classification that I'm aware of.  The path that would be required for suppression crews to stretch hose lines would require stretches in the neighborhood of 400 feet plus.  Our rigs have 250 feet of pre-connected 1 3/4 hose  as their longest pre-connected handline.  We can stretch static loads of 2 1/2" line and connect it to hose packs but all of that takes time.  Not to mention the hundreds of EMS calls we run to similar facilities in the city every year.  I'd be interested to see how the jurisdictions that allowed this type of facility without access justified it.


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## RLGA (Jul 18, 2017)

There are multiple instances where the installation of a sprinkler system relaxes a requirement of the code (i.e., trade-off) without the condition that the sprinkler system was not required by another provision of the code. Unless the exception specifically excludes its application when the sprinkler system is required by another provision, the exception can use the sprinkler system--even if the sprinkler system is installed because of another trade-off permitted by the code.


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## cda (Jul 18, 2017)

If a memory facility good possibly it is an "I" occupancy

Sprinklers automatic

Push for the access, does not sound like a hardship problem.

Why other ahj allowed it could be for various reasons, typography, political, fire dept not asked if access meets their needs.


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## Truck3capt (Jul 18, 2017)

RLGA said:


> There are multiple instances where the installation of a sprinkler system relaxes a requirement of the code (i.e., trade-off) without the condition that the sprinkler system was not required by another provision of the code. Unless the exception specifically excludes its application when the sprinkler system is required by another provision, the exception can use the sprinkler system--even if the sprinkler system is installed because of another trade-off permitted by the code.


So your interpretation is that the presence of the sprinkler system alone could be grounds for relaxing the fire apparatus access road requirement?  Even though there is  no reason not to provide the access road other than they want to build the structure up to the lot lines to maximize occupancy? This site has no unique topography and the R-3 and U language is not applicable in this case.

I'm wondering about the "where" in the first sentence of the exception language.  Does that mean all three items of the exception need to be considered together or can they be considered individually?  Maybe I'm splitting hairs here but the climate in our municipality may likely bring some of the things cda mentioned to bear..... I feel like our office is on pretty sound ground to require it based on the use and size of the proposed structure. I just wanted to hear how others have interpreted it.


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## Truck3capt (Jul 19, 2017)

cda said:


> If a memory facility good possibly it is an "I" occupancy
> 
> Sprinklers automatic
> 
> ...



I suggested the same things when they indicated that another jurisdiction allowed it.  Lots of reasons it didn't happen but it's hard to say for sure without looking at the specific situation.


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## cda (Jul 19, 2017)

I do not normally care what other cities do.

I do think apply the maximum of what minimum the code requires.

Not sure how wide your fire lanes are, another could be require the fire lane, but reduce the width

Or see what the minimum length you think you can live with.

Just remember future inspectors and firefighters have to live with what is built.


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## Truck3capt (Jul 19, 2017)

cda said:


> I do not normally care what other cities do.
> 
> I do think apply the maximum of what minimum the code requires.
> 
> ...


I agree.  We fight what other administrations and staff have done every day.  At times I want to say I don't care what they do in Possum Pass, USA. Have to be a little more diplomatic   I have a similar facility two blocks away that has access all the way around it for all of the reasons we've discussed. They're trying to squeeze a prototype  design onto a parcel that isn't suited for it.  I don't like to be unreasonable, but as you said, we're enforcing the minimum. Thanks again.


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## Francis Vineyard (Jul 19, 2017)

Truck3capt said:


> . . . I'm wondering about the "where" in the first sentence of the exception language.  Does that mean all three items of the exception need to be considered together or can they be considered individually?  . . . I just wanted to hear how others have interpreted it.



The items are to be considered individually.

For reference look at the 2015 code edition to help clarify intent made by code change. Below is a screen shot of the 2015; note it adds "where any of the following conditions occur"

The 2012 commentary provides for item 1 "The code does not give the fire code official guidance on how much of an increase over 150 ft. is reasonable. The fire code official must make the determination based on the response capabilities of his or her emergency response units and the anticipated magnitude of the incident.

The "alternative means" in item 2 of the exception may include standpipes, automatic sprinklers, remote fire department connections or additional fire hydrants.

Hope this will apply satisfactorily towards your decision.


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## cda (Jul 19, 2017)

See if you can read some of this


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## steveray (Jul 19, 2017)

I'm with FV...If it meant all 3 it would say "all of the following are met"...



Truck3capt said:


> The fire code official is authorized to



Authorized to is not shall....If your AHJ is not comfortable with it, then don't...Has your department ever had an issue with stretching hose to a sprinklered building? Or do the sprinklers pretty much handle it?


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## cda (Jul 19, 2017)

Do not rely on the sprinklers, especially in an assisted living place


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## mark handler (Jul 19, 2017)

Also, Do not rely on the sprinklers in earthquake areas.


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## TheCommish (Jul 19, 2017)

If your codes supports it, require a civil engineer and registered designee professional to supply preliminary drawings and  codes summary  supporting  their proposal. code official should not be in the business of  designing, rather we should be reviewing  written documents for  for code compliance. If the  proponent is not willing to commit to paper at a minimal level they get a "maybe" response from me.  In all cases it is the design team responsible to ensure  their proposed  project meet with all  laws, regulations,  and requirements  for the proposed project including but not limited to; zoning, land use, storm water  management, use group, and construction type.


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## JCraver (Jul 19, 2017)

steveray said:


> I'm with FV...If it meant all 3 it would say "all of the following are met"...
> 
> 
> Authorized to is not shall....If your AHJ is not comfortable with it, then don't...Has your department ever had an issue with stretching hose to a sprinklered building? Or do the sprinklers pretty much handle it?




I think I disagree on the interpretations.  My '09 reads the same as the posted '12, and says:

_Exception: The fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where:

1. The building is equipped throughout with an approved automatic sprinkler system installed in accordance with Section 903.3.1.1, 903.3.1.2 or 903.3.1.3. (<<< see that period?)

2. Fire apparatus access roads cannot be installed because of location on property, topography, waterways, nonnegotiable grades or other similar conditions, and an approved alternative means of fire protection is provided. (<< there's another one)

3. There are not more than two Group R-3 or Group U occupancies. (< and another)
_
There is no "or" between 1, 2, or 3, there are periods.  If they wanted this to be an any-of-the-three situation, they would've/should've ended the exceptions with a comma, and an "or".  The commentary doesn't clarify it any better, either.  It could be argued that the '15, which is written much better, could point to increasing the distance, but strictly reading the 9 and 12, IMO, you've got to meet all 3.


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## cda (Jul 19, 2017)

15

Exceptions:


1.The fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where any of the following conditions occur:



Ok
I think I lost my link to the I codes????

Someone have a current link ???


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## RLGA (Jul 19, 2017)

Truck3capt said:


> So your interpretation is that the presence of the sprinkler system alone could be grounds for relaxing the fire apparatus access road requirement?  Even though there is  no reason not to provide the access road other than they want to build the structure up to the lot lines to maximize occupancy? This site has no unique topography and the R-3 and U language is not applicable in this case.
> 
> I'm wondering about the "where" in the first sentence of the exception language.  Does that mean all three items of the exception need to be considered together or can they be considered individually?  Maybe I'm splitting hairs here but the climate in our municipality may likely bring some of the things cda mentioned to bear..... I feel like our office is on pretty sound ground to require it based on the use and size of the proposed structure. I just wanted to hear how others have interpreted it.


Yes, all three are applicable (unless there are no Group R-3 and U occupancies, then only the first two are applicable). The second does state "location on property" as one of the qualifying conditions; however, it does state that "and an approved alternative means of fire protection is provided." Thus, the building must provide some means of _approved _additional protection--above and beyond what the code requires--to compensate for the lack of access. For example, this could be accomplished by increasing the sprinkler design from a lower hazard occupancy to a higher hazard occupancy (e.g., light hazard to ordinary hazard, or ordinary hazard to high hazard), or by compartmentalizing the building with fire-resistance-rated construction.


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## Francis Vineyard (Jul 19, 2017)

JCraver said:


> I think I disagree on the interpretations.  My '09 reads the same as the posted '12, and says:
> 
> _Exception: The fire code official is authorized to increase the dimension of 150 feet (45 720 mm) where:
> 
> ...


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## Truck3capt (Jul 19, 2017)

steveray said:


> I'm with FV...If it meant all 3 it would say "all of the following are met"...
> 
> 
> 
> ...



The AHJ is my boss (the city fire marshal) and historically we've required the access roads based on this type of use and the occupant population.  The rapid expansion of assisted living and memory care facilities in this part of our jurisdiction is relatively recent.  It's expanded exponentially in this part of the city, away from the city core and at the fringe of our fire protection coverage in just 4 or 5 years.  I worked on the only ladder company on this side of town over ten years ago and most of our calls were running back into the city because the other direction was mostly rural.  Not the case today and the same companies are running hundreds of EMS calls to these type of facilities in this same running district every year.

I can't think of an issue with stretching lines to a sprinklered building, however, as i said most of these buildings are structures that have been built in the last 6 years so it's a fairly new situation.  So I guess the answer is no.  Residential sprinklers were "amended" out of the IRC when we adopted the 2012 I-Codes.  The state min fire code for us in IL is the 2000 -Life Safety 101.  It was adopted by the state 15 years ago and we're still trying to get traction on getting the existing high-rise building stock in town sprinklered or evaluated with a life safety system.  It's moving slowly even with relatively small fires that have produced civilian fatalities in recent years.  Residential high-rises with the poor, elderly and disabled mostly.


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## cda (Jul 19, 2017)

I would push for access and not fall back on being able to pull more hose if needed.

Just because they ask,,, NO is nice answer.


Plus you start setting up past practice and other builders will want to cut access

Saves money


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## Truck3capt (Jul 19, 2017)

RLGA said:


> Yes, all three are applicable (unless there are no Group R-3 and U occupancies, then only the first two are applicable). The second does state "location on property" as one of the qualifying conditions; however, it does state that "and an approved alternative means of fire protection is provided." Thus, the building must provide some means of _approved _additional protection--above and beyond what the code requires--to compensate for the lack of access. For example, this could be accomplished by increasing the sprinkler design from a lower hazard occupancy to a higher hazard occupancy (e.g., light hazard to ordinary hazard, or ordinary hazard to high hazard), or by compartmentalizing the building with fire-resistance-rated construction.


Thanks, this was where I was headed with my question initially. One of my concerns with this particular facility and others like it are fires that start on the exterior.  We investigate fires that originate on porches, decks, mulch planter beds, and apartment balconies regularly from the cig butt that gets put out in a planter or dropped in the plant bed. We've been lucky that it hasn't happened at a facility this size.  We've had them in the disabled group homes, where it's still a problem but not nearly as many occupants.

The fire spreads up the siding, enters the soffit and extends through the attic before most people even realize they have a problem.  The assisted living units appear to have patio access on all of them.  A fire at the rear with no access could provide a pretty challenging fire problem if a 13R system (no sprinklers in attic) was an allowed option in lieu of a 13 system and the building was lightweight combustible construction.


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## Truck3capt (Jul 19, 2017)

Francis Vineyard said:


> View attachment 2596



I'm glad it's being addressed because I didn't find it spelled out in the code or commentary specifically.


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## Truck3capt (Jul 19, 2017)

cda said:


> I would push for access and not fall back on being able to pull more hose if needed.
> 
> Just because they ask,,, NO is nice answer.
> 
> ...


It will be the FM's decision, but I don't think he's interested in backtracking on what we've done in the past.  Stretching hose takes time and if the sprinklers don't control it as in the case of an exterior fire like I mentioned above we're losing ground on the fire every minute we don't get water on it.    I'm just trying to cover the bases when the "why" comes up.


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## rogerpa (Jul 19, 2017)

Unfortunately codes are not written by wordsmiths. Often, IMO, the code proposals are not thoroughly thought out before being submitted. Additionally, a lot of code gets written on the fly in the hallway at the hearings as multiple parties try to keep their ox from getting gored. Never a good situation.

Here is an example of either / or:

R308.4.2 Glazing adjacent to doors.
Glazing in an individual fixed or operable panel adjacent to a door shall be considered to be a hazardous location
where the bottom exposed edge of the glazing is less than 60 inches (1524 mm) above the floor or walking surface and
it meets* either *of the following conditions:
1. Where the glazing is within 24 inches (610 mm) of either side of the door in the plane of the door in a closed
position.
2. Where the glazing is on a wall perpendicular to the plane of the door in a closed position and within 24 inches (610
mm) of the hinge side of an in-swinging door.

Here's an example of conditional:

R308.4.3 Glazing in windows.
Glazing in an individual fixed or operable panel that meets *all of the following* conditions shall be considered to be a
hazardous location:
1. The exposed area of an individual pane is larger than 9 square feet (0.836 m2),
2. The bottom edge of the glazing is less than 18 inches (457 mm) above the floor,
3. The top edge of the glazing is more than 36 inches (914 mm) above the floor; and
4. One or more walking surfaces are within 36 inches (914 mm), measured horizontally and in a straight line, of the
glazing.


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## JCraver (Jul 20, 2017)

Francis Vineyard said:


> View attachment 2596



That takes care of it, and is much better code.


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## ADAguy (Jul 21, 2017)

How long has this requirement been in the code, pre 78'?
How long have sprinklers been required?
When was access all 4 sides first required, pre 78"?


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