# Building vs. Enclosure Distinction?



## Paul Bixel (Feb 15, 2018)

Hi Folks,

I am an electrical engineer, no so familiar with building codes.  The subject of building code comes up in my world when designing outdoor electrical equipment as to what constitutes a "building" subject to codes.  For example at every intersection with a stoplight I can see a stainless steel enclosure that encloses the electrical controls for that intersection.  Is that enclosure subject to building codes?  Is it a building and if not why not?

Thanks,
Paul


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## cda (Feb 15, 2018)

Welcome


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## cda (Feb 15, 2018)

Paul Bixel said:


> Hi Folks,
> 
> I am an electrical engineer, no so familiar with building codes.  The subject of building code comes up in my world when designing outdoor electrical equipment as to what constitutes a "building" subject to codes.  For example at every intersection with a stoplight I can see a stainless steel enclosure that encloses the electrical controls for that intersection.  Is that enclosure subject to building codes?  Is it a building and if not why not?
> 
> ...




Normally not a Building

Size for one/ piece of equipment


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## cda (Feb 15, 2018)

[A]BUILDING. Any structure utilized or intended for supporting or sheltering any occupancy.

Not meant for sheltering or occupancy


From international building code

https://codes.iccsafe.org/public/document/IBC2018/chapter-2-definitions


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## Paul Bixel (Feb 15, 2018)

Thanks for these responses.  But in 312.1 of this code I see Group U covering structures not meant to be occupancies but still having code requirements.  For example a 'tank' or a 'fence' is a structure that is covered by this code and it is not meant to be shelter or occupancy.

I need some text to point and AHJ to that says "Only 'buildings' are in the scope of this code".  Instead I have the Group U classification seeming to say exactly the opposite that all structures must be classified into an Occupancy class.


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## cda (Feb 15, 2018)

*You look at the examples given for a “U”*

*I am thinking yours does not fall under them.*



*If you were doing something the size of a cell tower site Building, than I would call it a Building.*


*312.1General.*
Buildings and structures of an accessory character and miscellaneous structures not classified in any specific occupancy shall be constructed, equipped and maintained to conform to the requirements of this code commensurate with the fire and life hazard incidental to their occupancy. Group U shall include, but not be limited to, the following:


Agricultural buildings


Aircraft hangars, accessory to a one- or two-family residence (see Section 412.4)


Barns


Carports


Communication equipment structures with a gross floor area of less than 1,500 square feet (139 m2)


Fences more than 6 feet (1829 mm) in height


Grain silos, accessory to a residential occupancy




Livestock shelters


Private garages


Retaining walls


Sheds


Stables


Tanks


Towers


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## tmurray (Feb 15, 2018)

Paul, A similar thing would be a deck. Not a building, but a structure. When we say "supports an occupancy" this generally means that someone is in the building or using the structure to do something (living, working, etc.). If you are designing an enclosure and someone will need to enter it to service equipment, it would likely be subject to the building code (telephone switchers, electrical vaults). If someone is just reaching into the cabinet to maintain it (like those controlling traffic lights), then they are not regulated by the building code.


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## cda (Feb 15, 2018)

*105.2Work exempt from permit.*
Exemptions from permit requirements of this code shall not be deemed to grant authorization for any work to be done in any manner in violation of the provisions of this code or any other laws or ordinances of this jurisdiction. Permits shall not be required for the following:


Building:

1.One-story detached accessory structures used as tool and storage sheds, playhouses and similar uses, provided that the floor area is not greater than 120 square feet (11 m2).


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## Paul Sweet (Feb 15, 2018)

If the enclosure is for a single piece of equipment it probably wouldn't be considered a building.  If it is large enough for more than one piece of equipment and has space for somebody to enter it and work on the equipment it's likely to be considered a building. IBC 105 exempts buildings under 120 SF from needing a permit.


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## Paul Bixel (Feb 15, 2018)

I am thinking of an equipment enclosure that is not intended to be entered.  It is intended that you remove the covers and reach in to service it and then replace the cover or close the door when done.

But people here do not like risk of any kind that they will run afoul of an AHJ.  So wording like "shall include, but not be limited to, the following:" does not help me at all.  It just throws doubt in the minds of people like myself who are not experts and at the mercy of arbitrary interpretations.

105.2 does help if the enclosure is small enough but for larger pieces then what?  We have large pieces of equipment.  They are larger than 120 sq ft. but the enclosure does not permit an adult to get inside.  You are intended to reach in to service and then replace the covers or close the access doors.

I do appreciate the comments.


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## tmurray (Feb 15, 2018)

I would not want to consider the equipment as a building because I would have no idea what to enforce. Building codes are designed primarily to ensure occupants can get out of building/structures in an emergency. Yes, they do other things too, but on a fundamental level, this is the function. If a person physically cannot get in there to begin with, I want no part of that liability.


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## cda (Feb 15, 2018)

Paul Bixel said:


> I am thinking of an equipment enclosure that is not intended to be entered.  It is intended that you remove the covers and reach in to service it and then replace the cover or close the door when done.
> 
> But people here do not like risk of any kind that they will run afoul of an AHJ.  So wording like "shall include, but not be limited to, the following:" does not help me at all.  It just throws doubt in the minds of people like myself who are not experts and at the mercy of arbitrary interpretations.
> 
> ...




It is a piece of equipment

Like an above ground transformer box or:::

The picture above


Normally does not fall under the building code.


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## Paul Bixel (Feb 15, 2018)

What is pictured is an excellent example of a structure in my world.  You could also imagine a row of 10 of these all lined up.  Maybe even taller or deeper boxes.

"Normally does not fall under the building code" is perfectly understandable and reasonable to me.   But the lawyers involved would want chapter and verse of why such a structure does not fall under the building code when other structures such as fences do.

When there is money involved nobody wants a surprise.  That's the only explanation I can give for such a question as this.  I hope you can forgive me for posing it.


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## Rick18071 (Feb 15, 2018)

I would only require an electrical permit for something like this.


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## cda (Feb 15, 2018)

Paul Bixel said:


> What is pictured is an excellent example of a structure in my world.  You could also imagine a row of 10 of these all lined up.  Maybe even taller or deeper boxes.
> 
> "Normally does not fall under the building code" is perfectly understandable and reasonable to me.   But the lawyers involved would want chapter and verse of why such a structure does not fall under the building code when other structures such as fences do.
> 
> When there is money involved nobody wants a surprise.  That's the only explanation I can give for such a question as this.  I hope you can forgive me for posing it.





No problem the strange questions are fun, and I ask them also


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## mtlogcabin (Feb 15, 2018)

[A] 101.3 Intent.
The purpose of this code is to establish the minimum requirements to safeguard the public health, safety and general welfare through structural strength, means of egress facilities, stability, sanitation, adequate light and ventilation, energy conservation, and safety to life and property from fire and other hazards attributed to the built environment and to provide safety to fire fighters and emergency responders during emergency operations.

Unless your equipment supports a Risk Category III or IV occupancy there would be no building permits because you are not building or constructing onsite. A building permit may be required for the foundation/pad to ensure it will with stand seismic and wind loads for the Risk Category III or IV so they remain operational after a natural disaster. Think cell tower equipment, emergency generators, electrical equipment supporting police and fire communications at towers, etc


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## my250r11 (Feb 15, 2018)

Think mtlogcabin hit the nail on the head!


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## Paul Bixel (Feb 16, 2018)

mtlogcabin,

Unfortunately for me our equipment is sometimes used for Category III purposes such "Power-generating stations, water treatment facilities for potable water, waste water treatment facilities and other public utility facilities not included in Risk Category IV." as discussed here
https://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_12_113_12.pdf

Also the photo shared above is of a traffic light controller.  That would seem to meet the definition of a Risk Cat III structure according to this link since failure would cause a substantial hazard to human life.

So are we saying then that the risk category is what requires compliance with the building code?


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## cda (Feb 16, 2018)

F


Paul Bixel said:


> mtlogcabin,
> 
> Unfortunately for me our equipment is sometimes used for Category III purposes such "Power-generating stations, water treatment facilities for potable water, waste water treatment facilities and other public utility facilities not included in Risk Category IV." as discussed here
> https://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_12_113_12.pdf
> ...




NO

If what is being looked at does not fall under the “ scope” of IBC.

Than none of IBC applies


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## mtlogcabin (Feb 16, 2018)

Paul Bixel said:


> Also the photo shared above is of a traffic light controller. That would seem to meet the definition of a Risk Cat III structure according to this link since failure would cause a substantial hazard to human life.


ASCE 7-10 Section 13.6.4 thru 13.6.6 is probably where you will find your answer for how to design your equipment enclosures that will meet code. The foundation/pad, anchorage and fastener design requirements are also within Chapter 13 of ASCE 7-10.
The traffic light controller is not be a Risk Cat III structure failure is not a substantial hazard to human life.


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## tmurray (Feb 16, 2018)

Paul Bixel said:


> What is pictured is an excellent example of a structure in my world.  You could also imagine a row of 10 of these all lined up.  Maybe even taller or deeper boxes.
> 
> "Normally does not fall under the building code" is perfectly understandable and reasonable to me.   But the lawyers involved would want chapter and verse of why such a structure does not fall under the building code when other structures such as fences do.
> 
> When there is money involved nobody wants a surprise.  That's the only explanation I can give for such a question as this.  I hope you can forgive me for posing it.


There is probably not a more receptive group to ask this to.


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## DuaneW (Feb 16, 2018)

I would see the only thing it would need to meet is set backs but with being said utility don't have the same requirements as a building. As the AHJ where i am I would never even see plans for this, it would be the highway or street department that would handle things like that with no over site of the building department or fire inspections.


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## Francis Vineyard (Feb 16, 2018)

Virginia exempt from permits (on private property, the code is not applicable to federal and state ownership and control of the equipment and property);

1)    “Detached prefabricated buildings housing the equipment of a publicly regulated utility service, provided the floor area does not exceed 150 sf.

2)    Fences of any height unless required for pedestrian safety as provided for by Section 3306, or used for the barrier for a swimming pool.

So if the “enclosure” is without a roof it would be exempt from a permit.

*IBC
Definition.*

*[A] BUILDING. *Any structure used or intended for supporting or sheltering any use or occupancy.

*[A] STRUCTURE. *That which is built or constructed.

*Group U. *commentary;

“This definition is intentionally broad so as to include within its scope, and therefore the scope of the code (see Section 101.2), everything that is built as an improvement to real property. See also the definitions for “Building” and “Area, building” for the difference between a building and structure.

Structures classified as Group U, such as fences, equipment, foundations and retaining walls, are somewhat outside the primary scope of the code (i.e., means of egress, fire resistance). They are not usually considered to be habitable or occupiable. Nevertheless, many code provisions do apply and need to be enforced (e.g., structural design and material performance). Structures housing accessory equipment that is part of a utility or communications system are often classified as Group U occupancies when there is no intent that these structures be occupied except for servicing and maintaining the equipment within the structure. A pumphouse for a water or sewage system or an equipment building at the base of a telecommunications tower are examples of such buildings.”

*2018 Group U*
Communication equipment structures with a gross floor area of less than 1,500 sf.


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## mark handler (Feb 16, 2018)

It's all about size
A electrical box enclosure my not be covered by the building code
But  Large switch gear room/bldg will be

Some cities regulate through their municipal codes the location of traffic boxes.


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## Mark K (Feb 17, 2018)

I suggest that the question is which entity has jurisdiction?  See what the state legislature has determined.  In California public utilities are regulated by the state PUC and thus the utilities are bound by PUC rules and not the Building Code.  The connection point determines the extent of the building departments jurisdiction.  Roads and the infrastructure supporting them may be governed by the Department of Transportation.  Local public works are under control of the City but not the Building Department.

The language of a model code, even if adopted by a jurisdiction, is not relevant if it is in conflict with state statute or some agency that has been given jurisdiction.  The world does not begin and end with the building code.  Building officials need to have a broader perspective.

I have become aware of the National Electrical Safety Code which is published by IEEE.  This is a model code that is intended to address issues of concern to electrical utilities and has been adopted by some states and governmental authorities..


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## RuralFD (Aug 18, 2020)

Hi, I have a follow up question. Would the enclosure for an diesel emergency generator be subject to egress requirements? The enclosure has doors and can be entered for the purpose of operating and servicing the genset. Pictured below is an example, not the actual unit. However, a day tank was installed on the radiator end and it has to be climbed over to access the fuel filters. So if tehre's an emergency and you're between the day tank and radiators, you either have to be skinny to squeeze past the radiator, or clumb over the day tank (not shown below, 24 inches tall).









Thanks,
Mark


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## steveray (Aug 18, 2020)

[A] 105.2.3 Public service agencies. A permit shall not be
required for the installation, alteration or repair of generation,
transmission, distribution or metering or other related
equipment that is under the ownership and control of public
service agencies by established right.


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## cda (Aug 18, 2020)

RuralFD said:


> Hi, I have a follow up question. Would the enclosure for an diesel emergency generator be subject to egress requirements? The enclosure has doors and can be entered for the purpose of operating and servicing the genset. Pictured below is an example, not the actual unit. However, a day tank was installed on the radiator end and it has to be climbed over to access the fuel filters. So if tehre's an emergency and you're between the day tank and radiators, you either have to be skinny to squeeze past the radiator, or clumb over the day tank (not shown below, 24 inches tall).
> 
> 
> 
> ...



I vote No

Most of those size come with two doors


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## steveray (Aug 18, 2020)

RuralFD said:


> Hi, I have a follow up question. Would the enclosure for an diesel emergency generator be subject to egress requirements? The enclosure has doors and can be entered for the purpose of operating and servicing the genset. Pictured below is an example, not the actual unit. However, a day tank was installed on the radiator end and it has to be climbed over to access the fuel filters. So if tehre's an emergency and you're between the day tank and radiators, you either have to be skinny to squeeze past the radiator, or clumb over the day tank (not shown below, 24 inches tall).
> 
> 
> 
> ...


If it is only entered for servicing the unit, then it is typically exempt from proper Ch 10 MOE, but there are always exceptions....


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## RuralFD (Aug 18, 2020)

Ours actually has 5 doors, two per side and one on the end. Trouble is that at that end door there's a day tank that spans the width of the enclosure. The fuel filters were installed on the interior side of the day tank. To get to those filters, you have to climb/step over the day tank. The space between the edge of the radiator and wall is too narrow to squeeze through (or so I am told, might depend on the operator). So that is an egress issue the owner is concerned about and their saftey person is quoting _CalOsha Requirement required proper egress and exit. In an area where diesel is present proper egress is required in case of an emergency. Climbing over the platform to enter/exit does not meet Title 8 §3215 

Title 8-3215_

So then the question is does Title 8 apply to this enclosure? It can be walked around in to access the generator. The contractor wants a Code call-out to force them to make a correction, but there might be one....

Thanks,
Mark


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## cda (Aug 18, 2020)

RuralFD said:


> Ours actually has 5 doors, two per side and one on the end. Trouble is that at that end door there's a day tank that spans the width of the enclosure. The fuel filters were installed on the interior side of the day tank. To get to those filters, you have to climb/step over the day tank. The space between the edge of the radiator and wall is too narrow to squeeze through (or so I am told, might depend on the operator). So that is an egress issue the owner is concerned about and their saftey person is quoting _CalOsha Requirement required proper egress and exit. In an area where diesel is present proper egress is required in case of an emergency. Climbing over the platform to enter/exit does not meet Title 8 §3215
> 
> Title 8-3215_
> 
> ...



Don’t over think it

It is a piece of equipment

They should not be doing major work with it running.

To noisy to begin with


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## ADAguy (Aug 19, 2020)

RuralFD said:


> Hi, I have a follow up question. Would the enclosure for an diesel emergency generator be subject to egress requirements? The enclosure has doors and can be entered for the purpose of operating and servicing the genset. Pictured below is an example, not the actual unit. However, a day tank was installed on the radiator end and it has to be climbed over to access the fuel filters. So if tehre's an emergency and you're between the day tank and radiators, you either have to be skinny to squeeze past the radiator, or clumb over the day tank (not shown below, 24 inches tall).
> 
> 
> 
> ...



Think "OSHA"


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## ADAguy (Aug 19, 2020)

steveray said:


> [A] 105.2.3 Public service agencies. A permit shall not be
> required for the installation, alteration or repair of generation,
> transmission, distribution or metering or other related
> equipment that is under the ownership and control of public
> service agencies by established right.



Yes, and it should also comply with seismic, wind load and fire.


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## ADAguy (Aug 19, 2020)

cda said:


> Don’t over think it
> 
> It is a piece of equipment
> 
> ...



Owner continue to be concerned, worker protection required.


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## RuralFD (Aug 19, 2020)

ADAguy said:


> Yes, and it should also comply with seismic, wind load and fire.


It does comply with seismic and wind.


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## RuralFD (Aug 19, 2020)

steveray said:


> [A] 105.2.3 Public service agencies. A permit shall not be
> required for the installation, alteration or repair of generation,
> transmission, distribution or metering or other related
> equipment that is under the ownership and control of public
> service agencies by established right.


So this seems to imply it does not need to meet egress code.


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## Rick18071 (Aug 19, 2020)

It's a machine. Requiring egress on this is like requiring egress for a Red Box video rental vending machine.


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## RuralFD (Aug 19, 2020)

Rick18071 said:


> It's a machine. Requiring egress on this is like requiring egress for a Red Box video rental vending machine.


I understand that the only reason someone should be there is to perform maintence service, but its not quite the same as a Red Box machine for which you cannot walk into and close a door. 

Ultimately the Owner may want changes to eliminate the need to climb over the day tank. The issue is of course money. If its Code Required, the contractor must correct this deficiency on their own dime. If its not code required, then the Owner must pay.


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## ADAguy (Aug 20, 2020)

Have you reviewed OSHA worker safety requirements for clear work space, trip hazards, moving parts protection, elec. hazards, etc.? Regs vs code.


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