# File Room



## Examiner (Jan 25, 2010)

Is a room with the name "File Room" considered to be a storage room as listed in Table 508.2?  Items in the room could be in metal file cabinets or cardboard boxes and yes the room is over 100-sf.


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## Plans Approver (Jan 25, 2010)

Re: File Room

Maybe, Yes under 508.2, Not necessarily under footnote b in Table 508.3 and not necessarily if your building is mixed occupancy B & S-1. Designer's choice. (2006 IBC)


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## jpranch (Jan 25, 2010)

Re: File Room

Storage is storage. It's all about fuel load. Non-sprinklered business use >100 sq. ft. gets a 1 hour enclosure.


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## hlfireinspector (Jan 25, 2010)

Re: File Room

It seems we are all assuming that the file room is INCIDENTAL USE AREA to the occupancy. The poster did not say that. INCIDENTAL USE AREAS are not limited in the code by any size restrictions as accessory use is, however if it is larger that the occupancy of the building I do not see how it can be incidental. If mixed use is chosen we are back to the post M/S1/M that I had posted. We all found that the 2009 IBC changed wording to make this seperation issue better understood. 508.3 says no seperation is required if less than 10% of the floor area or unsprinklered up to 1000 sq. feet or sprinklered up to 3000 sq. feet so, they must mean that seperation is required at values greater that this. If seperation is required this section says:

508.3.3.4 Separation. Individual occupancies shall be separated from adjacent occupancies in accordance with Table 508.3.3

508.3.3.4.1 Construction. Required separations shall be fire barriers constructed in accordance with

Section 706 or horizontal assemblies constructed in accordance with Section 711, or both, so as to completely separate adjacent occupancies.

What code is the building being built under???????????????


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## Plans Approver (Jan 25, 2010)

Re: File Room

I think the OP is asking if a file room over 100 sf automatically becomes incidental use. It doesn't by 2006 IBC 508.2.1:

"Occupancy classification. An incidental use area shall be classified in accordance with the occupancy of that portion of the building in which it is located *or* the building shall be classified as a mixed occupancy and shall comply with Section 508.3."

As a side note 2009 IBC removes strorage rooms from the incidental use table and deletes footnote b from the mixed use table. All storage is is either accessory (10%) or mixed use (as I read it).


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## Examiner (Jan 26, 2010)

Re: File Room

Building Code IBC 2006 (Existing building was constructed under the SBC)

One story building.  Occupancy Use Group: Business (major)

The building has an automatic fire suppression system throughout.

Construction Type II-B (existing building).

Exterior walls are 6”-CMU with brick veneer and above the 6”-CMU and brick the drawings show 8”-CMU to the roof.  The 8”-CMU is bearing on the 6”-CMU and brick.

Roof framing:  Steel beams supporting the roof above the exterior Side walls have fireproofing but not any other beams.  Bar joist are above the End walls instead of beams for roof framing.  Interior columns appear to plaster as a fireproofing.  Exterior columns are masonry.  There is not any other fireproofing on the roof system.  The exterior CMU walls do have plaster on the interior side of the CMU.

Tenant space most interior walls are being demolished and much of the HVAC ducts.  Existing Restrooms are being remodeled for ADA compliance.

One Tenant space area is 26,610-sf.

The Tenant space has; three File Rooms, one Storage room and one Supply room.  The three File Rooms total area is 2,933-sf.  The total area of all the listed rooms is 3,586-sf.  Not one of the listed rooms is under 100-sf.

The entire building is 48,471-sf.  The other Tenant takes up the remaining area.

The issue is the HVAC system is using plenum return (non-ducted return) above the ceilings and through the walls.

Are the File Rooms considered to be Incidental Use?  What about the Storage and Supply room.

Do you feel that a non-separated Mixed Occupancy use would allow the HVAC plenum return through these rooms without fire or smoke dampers?


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## vegas paul (Jan 26, 2010)

Re: File Room

The entire building sounds like it works under non-separated occupancies (508.3.2), so no separation is required.  Keep in mind that IF the building "works" by using non-separated occupancies, then you do NOT have to consider incidental use areas.   This is an OR, not an AND (as Plans Approver pointed out earlier).


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## Plans Approver (Jan 26, 2010)

Re: File Room

Ah! The real question is "Are the walls surrounding the storage areas required to extend to the roof above?" Correct?

It is all dependent on occupancy.

Accessory occupancy does not apply as total of file and other storage rooms exceed 10% of the area.

The occupancy is noted as B, Business (major); this seems to indicate other occupancies are involved. If the *DP* has indicated mixed occupancies as B & S-1 then the incidental use table does not apply. Separated or nonseparated mixed occupancies do. No rated separation required, no fire dampers - at least, it is sprinklered.

If it is a straight B occupancy then incidental use is applicable w/ smoke partitions to roof deck, smoke seals on doors, smoke dampers on ducts supplying or returning air, transfer grilles. Of course, to be sprinklered throughout, the rooms require sprinklers.


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## barlovian (Jan 26, 2010)

Re: File Room

IBC 2006 508.2.2 Separation:   Incidental use areas shall be separated or protected, or both, in accordance with Table 508.2.

The way that I read this section, separation is required.  Even if you use non separated uses for height and area calculations.

Does the building code explain the difference between a Use and an Occupancy?


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## vegas paul (Jan 26, 2010)

Re: File Room



			
				barlovian said:
			
		

> The way that I read this section, separation is required. Even if you use non separated uses for height and area calculations


barlovian - I respectfully disagree.  508 has FOUR different methods of addressing mixed use and occupancy - you can choose any one of them.  Incidental uses (508.2) is one of them.  Mixed occupancies is another, which is further sub-divided into Accessory, Non-separated, and Separated.  The charging statement (508.1) says "... shall comply with the applicable provisions of this section" (meaning 508).  So, if you comply with 508.3.2, you have complied WITHOUT addressing incidental uses, and 508.3.2.3 says no separation required.

Clear as mud?  This is my interpretation, your mileage may vary.


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## barlovian (Jan 26, 2010)

Re: File Room

Paul—

I used to use it that way, too, and I could be easily convinced to change my mind.  I used to run into conflicts where Table 508.2 requires protection from a “lesser” hazard.

How would you look at this example in a Type IIb building?

A large room is used to store trash and soiled linen collected from the rest of a building.  The designer calls the trash/linen collection room a Moderate-Hazard Storage Use.  S-1.  Base tabular area per Table 503 is 17,500.

The trash/linen collection room is located in a nursing home.  Use I-2.  Base tabular area per Table 503 is 11,000 SF making I-2 the more stringent of the two uses.

Applying Section 508.3.2, Non-Separated occupancies, no separation is required between the trash room and the nursing home.


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## Plans Approver (Jan 26, 2010)

Re: File Room

There are many plusses to I-2 occupancies such as smoke compartments, smoke barrier corridor walls, smoke and fire alarms as well as sprinklers. The life safety code may also be applicable by your local or state health department which will limit the amount of soiled linens or require rated enclosures. It may not be part of your enforcement duties, but, 2006 LSC Table 18.3.2.1 requires 1 hour for soiled linen and storage rooms greater than 100 sf. (2009 LSC code changes from room area to gallons of linens and trash, over 64 gallons requires rating. Try enforcing that at plan review.)

Every time I get involved with separation issues, I have to keep reminding myself that rated construction is a passive system of delaying the spread of fire whereas sprinklers are an active system that not only delays, but, sometimes, many times, extinguishes the fire.


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## kilitact (Jan 26, 2010)

Re: File Room

barlovian wrote:



> Applying Section 508.3.2, Non-Separated occupancies, no separation is required between the trash room and the nursing home.


Section 508.2, states that incidental use shall comply with the provisions of this section or be classified as mixed use in accordance with Section 508.3


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## Examiner (Jan 26, 2010)

Re: File Room

I will have to review the answers in a few days.  However, I will add that Code Congress on another occasion has told me that Incidental Use areas when selected to use “constructed to resist the passage of smoke” as mentioned in 508.2.2.1 means that you are not required to provide smoke seals on doors.  The doors have to comply with gap requirements as if they are a fire rated door but do not have to have seals.  I think they referenced NFPA 80 regarding the doors.  The NFPA 80 is also mentioned in the last sentence of Section 508.2.2.1.  Louvers in the doors for air transfer would require smoke dampers.  Again mentioned in Section 508.2.2.1.

As for the return air opening in the walls above the ceilings; if the room is to be considered as an Incidental Use area then the openings in the walls would require smoke dampers.  Code Congress has already informed me on that issue.  The Code Commentary reads; ‘The wall construction described here is required to be neither a smoke barrier conforming to Section 709 nor a smoke partition conforming to Section 710.”

My dilemma is; can I avoid the smoke dampers for the rooms addressed in my earlier post using non-separated occupancies?


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## barlovian (Jan 26, 2010)

Re: File Room

Kilitact--I don't see where that occurs in 508.2

508.2 Incidental uses. Incidental use areas shall comply with the provisions of this section.

Exception: Incidental use areas within and serving a dwelling unit are not required to comply with this section.

508.2.1 Occupancy classification. An incidental use area shall be classified in accordance with the occupancy of that portion of the building in which it is located or the building shall be classified as a mixed occupancy and shall comply with Section 508.3.

508.2.2 Separation. Incidental use areas shall be separated or protected, or both, in accordance with Table 508.2.

508.2.2.1 Construction. Where Table 508.2 requires a fire-resistance-rated separation, the incidental use area shall be separated from the remainder of the building by a fire barrier constructed in accordance with Section 706 or a horizontal assembly constructed in accordance with Section 711, or both. Where Table 508.2 permits an automatic fire-extinguishing system without a fire barrier, the incidental use area shall be separated from the remainder of the building by construction capable of resisting the passage of smoke. The partitions shall extend from the floor to the underside of the fire-resistance-rated floor/ceiling assembly or fire-resistance-rated roof/ceiling ceiling assembly above or to the underside of the floor or roof sheathing, or sub deck above. Doors shall be self- or automatic closing upon detection of smoke in accordance with Section 715.4.7.3. Doors shall not have air/ transfer openings and shall not be undercut in excess of the clearance permitted in accordance with NFPA 80.


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## Plans Approver (Jan 26, 2010)

Re: File Room



			
				barlovian said:
			
		

> Kilitact--I don't see where that occurs in 508.2508.2 Incidental uses. Incidental use areas shall comply with the provisions of this section.
> 
> Exception: Incidental use areas within and serving a dwelling unit are not required to comply with this section.
> 
> ...


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## Plans Approver (Jan 26, 2010)

Re: File Room



			
				kilitact said:
			
		

> My dilemma is; can I avoid the smoke dampers for the rooms addressed in my earlier post using non-separated occupancies?


Yes.  If you are going to use nonseparated mixed occupancy, then 508.2.2, 508.2.2.1, and 508.2.3 do not apply. You wrote that you were sprinklered throughout. Go directly to 508.3.2.

Extra to your post: With incidental use, section 508.2.2.1 tells you how to build the partition that resists the passage of smoke. It's just common construction. The doors can be common doors also. The advice you received to follow "some" of the requirements of NFPA 80 can present a problem.  If the builder installs a listed door and frame you can be reasonably assured that it will meet the requirements, even without gaskets.  However, if the builder picks up a door, prehung or knocked-down at a big box store, you have no assurance that anything complies. Rather measuring an 1/8" (or 1/8" +/- 1/16" for metal doors) and ending up in an argument in the field and possibly having a do-over, we require seals on jambs and head as simple as self adhering weatherstripping found a few aisles over in that big box store w/ undercuts per NFPA 88.


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## Examiner (Jan 27, 2010)

Re: File Room

I thought that I just about had this figured out with all the responses to my post.

Since the below is under _Section 508.3.3 Separated Occupancies _I am now confused.  I thought that I read the other options _508.3.1, 508.3.2_ & _508.3.3_ were to be used if you did not use the _Incidental Use _in _508.2_.

Part of the _Code Commentary _from _Example 1_ for _Table 508.3.3_

_…The fire area containing the Group B occupancy does not require sprinklers because neither the provisions in Section 903 nor the high-rise building requirements (Section 403) apply; therefore, no sprinklers are required in any of the fire areas based on occupancy classification. Nevertheless, the requirements for __*incidental use areas would still be applicable *__within each fire area (see commentary, Section 508.2)._

Part of the _Code Commentary _from _508.2 Incidental Uses_;

_….Table 508.2 is applicable where an incidental use is not classified separately as to its occupancy (i.e., a mixed occupancy condition)….._

AND

_….Even though incidental use areas are not considered to be mixed-use conditions, such locations may be classified separately from their occupancy and the building designed in accordance with Section 508.3 (i.e., mixed occupancies).  In such cases, the presence of the higher relative fire hazard is accounted for by protection features that result from considering such areas as one of the building’s group classifications.  The application of Section 508.3 will result in certain building features being governed by code requirements that are commensurate with the higher relative fire hazard of these areas._

Am I misreading something?


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## Plans Approver (Jan 27, 2010)

Re: File Room



			
				Examiner said:
			
		

> I thought that I just about had this figured out with all the responses to my post.Since the below is under _Section 508.3.3 Separated Occupancies _I am now confused.  I thought that I read the other options _508.3.1, 508.3.2_ & _508.3.3_ were to be used if you did not use the _Incidental Use _in _508.2_.
> 
> Part of the _Code Commentary _from _Example 1_ for _Table 508.3.3_
> 
> _…The fire area containing the Group B occupancy does not require sprinklers because neither the provisions in Section 903 nor the high-rise building requirements (Section 403) apply; therefore, no sprinklers are required in any of the fire areas based on occupancy classification. Nevertheless, the requirements for __*incidental use areas would still be applicable *__within each fire area (see commentary, Section 508.2)._


The example you are reading from is for *separated* mixed occupancy. The B occupancy is a straight B, not mixed.  The building is mixed occupancy, but, each occupancy is evaluated separately per 508.3.3.1.



			
				Examiner said:
			
		

> Part of the _Code Commentary _from _508.2 Incidental Uses_;   _….Table 508.2 is applicable where an incidental use is not classified separately as to its occupancy (i.e., a mixed occupancy condition)….._
> 
> AND
> 
> ...


"Table 508.2 is applicable where an incidental use is *not** classified separately as to its occupancy* (i.e., a mixed occupancy condition)" That's kind of a double negative, Table 508.2 is for incidental use, not mixed.

"Even though incidental use areas are not considered to be mixed-use conditions, such locations *may* be classified separately from their occupancy and the building designed in accordance with Section 508.3 (i.e., mixed occupancies)." "May" is the operative word. The design professional decides how it is to be designed.


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