# 2006 IBC 3410 evaluation on non-separated mixed occupancy



## cballinger (Apr 8, 2014)

If you didn’t see my newbie post, this is my first time posting a question here. Go easy on me.    I am a Building Code Analyst (aka plan reviewer) in Indianapolis, IN.  We currently enforce the 2006 IBC as amended by the State of IN.

I have a 7000sf non-separated, non-sprinklered mixed occupancy F-1/A-2 (brewhouse/pub - not sure why they are using F-1 classification rather than F-2, but we’ll go with it). About 3500sf for each occupancy area. They submitted a 3410 evaluation for change of occupancy in an existing building. (No IN amendments to any of the sections in question.)

Section 3410.6 states, “In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building.”

I have always interpreted that the way this evaluation works for the various sections is you use the requirements of the building to determine the category in each section, then look at each occupancy value under that category to determine the score value for that section.  Then the lower of the two score values is used in Table 3410.7.

My issue is with the score they used for Section 3410.6.17 Automatic Sprinklers. I determined that the building is required to be sprinklered throughout because it is non-separated, therefore they have an A-2 “fire area” over 5000sf.  (Section 3410.6.17 states “...."Required sprinklers" shall be based on the requirements of this code.” I took this to mean that Section 508.3.1.1 requirement applies to the non-separated mixed occupancy.  Section 508.3.1.1 states, “...the most restrictive applicable provisions of Section 403and Chapter 9 shall apply to the entire building or portion thereof.” Section 903.2.1.2 requires sprinklers where the A-2 “fire area” exceeds 5000sf.)

So, after determining that the entire building is required to be sprinklered, I chose category a for Section 3410.6.17.1, then looking at Table 3410.6.17, I chose value of -6 for F occupancy being the most restrictive in this section.

They, on the other hand, have interpreted that when doing the evaluation, you should look at the entire building as an A-2 and then the entire building as an F to determine sprinkler requirements. So, they are saying, if you look at the entire building as an F occupancy, then it wouldn’t require sprinklers and used category c for a value of 0.  They then used the A-2 value of -4 as most restrictive for the section.

My concern is that the difference between choosing -6 vs -4 for this section is the difference between pass/fail of the overall evaluation. They’ve already tweaked other sections as much as possible and have an exact passing score for fire safety.

I’ve never had a brewhouse/pub that didn’t either provide fire separation between or sprinklers throughout.  Looking forward to all your input!


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## north star (Apr 8, 2014)

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*1st,* ...Welcome to The Building Codes Forum !   

*2nd,* ...is this Brewhouse \ pub intended to seat occupants, rather than

the F-1 [  Factory *<**---- ???*  ] designation that "they" are wanting ?

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## cballinger (Apr 8, 2014)

Seating for over 50 occupants on the pub (A-2) side.  They don't want to provide fire separation between the brewing area and the pub area because they want to show off their brewing operations to their pub guests, and will offer tours of the brewing area as well.


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## north star (Apr 8, 2014)

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If they use an F-1 Occupancy classification, according to

Table 1004.1.1,  ...the calculated occupancy load would

be 70 occupants.  [ i.e. - 7,000 sq ft. \ 100 sq. ft. gross

= 70 occupants  ].........Actually, it will be less than 70 when

you take in to account furnishings, actual Kitchen areas,

restrooms, egress paths, etc.

Are they going to be able to make a go of it on a [ max. ]

occ. load of 70 occupants ?    



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## north star (Apr 8, 2014)

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Tours of the Brewing area as well eh ?.....Sure sounds like

the occupant load is getting higher by the moment.

I would argue for an A-2 Occupancy classification as well,

...show them Section 903.2.1.2 [ `06 IBC  ] and let them

counter.......Also, I would ask "them" for a calculated

Occupant Load for the entire space, ...if you haven't

already.



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## cballinger (Apr 8, 2014)

Occupant load is calculated based upon the use of the space, not the occupancy classification. ?  Either way, occupant load isn't a factor in this situation as the fire area exceeds 7000sf and contains an A-2 occupancy area, so sprinklers are required throughout.  Sorry, not understanding what you're getting at...


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## cballinger (Apr 8, 2014)

^ I mean fire area exceeds 5000sf


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## north star (Apr 8, 2014)

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Sorry for the confusion, I was trying to say that I agree with your

interpretation of the facts and variables as you presented them.

Hold your ground, ...provide "them" the various applicable code

sections, and let them counter your position with their code

sections and calculations.

Your application sure sounds like an overall A-2 to me.



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## cballinger (Apr 8, 2014)

I don't understand what you mean, you would argue for an A-2 occupancy classification?  They aren't arguing the classification.  It is a mixed occupancy, non-separated A-2 and F-1.  The issue is for Section 3410.6.17, the more restrictive, in my opinion is the F value of -6 under category a vs. A-2 value of -4 under category a.  They are wanting to use category c for F value of 0 and category a for A-2 value of -4, thus taking -4 as the most restrictive value.  I don't agree that they can use different categories in the evaluation because it is my interpretation that the building requires sprinklers throughout because the "fire area" contains an A-2 occupancy.  Thus, I think the score should be -6 for F as most restrictive for this section.


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## north star (Apr 8, 2014)

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What are they basing their selection of Category "c" on,

...just to manipulate the outcome of the overall evaluation ?

Also, you mentioned that each fire area is approx. 3,500

sq. ft, ...how are you now arriving at over 5,000 sq.ft. for

the A-2 area ?

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## cballinger (Apr 8, 2014)

They have interpreted that when evaluating non-separated mixed occupancies, you would evaluate the entire building as A-2, then the entire building as F, and then choose the value for each and use most restrictive in the overall scoring. So, they are saying, evaluating the entire building as F, it doesn't require sprinklers because fire area isn't over 12000sf. Then, evaluating the entire building as an A-2, it does require sprinklers. So they have a value of 0 for F under category c and a value of -4 for A-2 under category a, then using the most restrictive of the two (A-2, value -4) for the overall scoring in Table 3140.7.


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## cballinger (Apr 8, 2014)

I am saying, you can't evaluate the entire building as a single occupancy and not take into consideration other occupancies in the building when there is no separation.


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## north star (Apr 8, 2014)

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When you showed them Section 508.3.1.1 and "the most restrictive"

wording, what was their response ?........What, if anything,  are they

countering with [ specifically ] from the `06 IBC ?

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## cballinger (Apr 8, 2014)

They are saying that section 3410 only looks at chapter 9 requirements and that when evaluating mixed occupancies, you evaluate the entire building as each occupancy separately (so you either have a 7000sf F or you have a 7000sf A-2) then take the more restrictive value of the two.  I'm saying, you have a 3500sf A-2 with a 7000sf A-2 fire area and a 3500sf F with a 7000sf A-2 fire area, thus required to be sprinklered throughout regardless of which occupancy area is being evaluated.


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## north star (Apr 8, 2014)

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So, "if" you use their logic and say that they indeed have

an 7,000 sq. ft. A-2 [ i.e. - the more restrictive  ],

wouldn't that also require the sprinklers  according to

Ch. 9 ?



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## cballinger (Apr 8, 2014)

Sorry, had to get some sleep at some point.  

Yes if they consider the entire building as A-2, yes it would require sprinklers per Ch. 9, which is why they used category a in 3410.6.17 for sprinklers required, none provided.  However, I'm not sure I agree the A-2 is the most restrictive in this section.  3410 requires you to evaluate both occupancies and take the more restrictive score for each section.  So, you must still evaluate the F occupancy, which they are saying doesn't require sprinklers and using category c for no sprinklers required, none provided.  I think the F occupancy does require sprinklers because it is within an A-2 fire area, so they should use category a for F and take score of -6 being the most restrictive in this section.  They are saying, when evaluating the F occupancy, there is only an F fire area.  Big difference between "occupancy area" and "fire area"...


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## north star (Apr 8, 2014)

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I had to get some sleep too !

I do not agree with their "less restrictive" choice of column "c" to make a determination.

IMO,  ...I would still hold to the "more restrictive" stance and use column "a" in the

assessment.

Is there a Building Official or Fire Code Official involved in this mix \ assessment

process ?

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## cballinger (Apr 8, 2014)

I firmly believe the same, but am looking for some written explanation somewhere in the code/commentaries to back up my interpretation.  I represent the local "Building Official" in my capacity as a City plan reviewer.


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## steveray (Apr 8, 2014)

3410.6 Evaluation process.

The evaluation process specified herein shall be followed in its entirety to evaluate existing buildings. Table 3410.7 shall be utilized for tabulating the results of the evaluation. References to other sections of this code indicate that compliance with those sections is required in order to gain credit in the evaluation herein outlined. In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building.

According to this......you take the lowest of each at each evaluation....if you are not properly seperated....


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## cballinger (Apr 8, 2014)

Right, but they aren't arguing that the lowest score should be used.  They are arguing that the lowest score for Section 3410.6.17 is -4, but I am saying the lowest score for that section is -6 because they should use category a sprinklers required but not provided in the F occupancy area.


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## steveray (Apr 8, 2014)

NOW I understand.....And a good question....I think they may be correct with the -4 because the F does not require the sprinkler under "new" code (from what I can gather) so you would use the C column or the -4 A column for the A2....I would certainly spend some more time researching, but on quick glancing that is what I see...

Try the 2009 Commentary.....http://publicecodes.cyberregs.com/icod/ibc/2009f2cc/icod_ibc_2009f2cc_34_sec001.htm


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## north star (Apr 8, 2014)

** : * : * : * : **

I am of the opinion that you have the correct assessment and the

code sections to support your position.

*Question**:* If both parties are at an impasse, then what ?



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## cballinger (Apr 8, 2014)

steveray said:
			
		

> NOW I understand.....And a good question....I think they may be correct with the -4 because the F does not require the sprinkler under "new" code (from what I can gather) so you would use the C column or the -4 A column for the A2....I would certainly spend some more time researching, but on quick glancing that is what I see...Try the 2009 Commentary.....http://publicecodes.cyberregs.com/icod/ibc/2009f2cc/icod_ibc_2009f2cc_34_sec001.htm


How does the F occupancy area not require sprinklers under the "new" code if it is not separated from the A-2 "fire area"?  I've read and reread code and commentary for all of CH 34, 5 and 9 several times and haven't found anything to suggest that evaluation of occupancy should be done considering the entire "fire area" as a single occupancy.  It is my interpretation that the F occupancy area requires sprinklers because it is in the same "fire area" as an A-2.


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## cballinger (Apr 8, 2014)

Typically, I would send them to the State building commission to obtain a variance from Indiana Building Code or interpretation from the State Building Law Compliance Officer.  In this particular situation, their code consultant requested an interpretation from the State Building Law Compliance Officer, but he opted not to provide an interpretation.....


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## north star (Apr 8, 2014)

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From the link that ***steveray*** provided  [ from the `09 IBC - Commentary  ]:

*`09 IBC - Commentary, TABLE 3412.6.16 - MIXED OCCUPANCY VALUES**a*:


*OCCUPANCY**CATEGORIES**a**b**c* A-1, A-2, R-10010 A-3, A-4, B, E, F, M, S-505


a. For fire-resistance ratings between categories, the value shall be obtained by linear interpolation.




This table addresses the relative risk of a building in or close to  compliance with the provisions for

separated mixed occupancies.............When  mixed occupancies are not separated from each other,

the risk from  hazards is greater in high-density occupancies, such as Groups A-1 and  A-2........This

risk is also greater in residential occupancies, because  occupants may be sleeping and not fully alert.

*For this reason,  inadequate separation is given greater negative values.*........In buildings

with lower occupant loads, and where the occupants are alert, the risks  are relatively lower.



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## cballinger (Apr 8, 2014)

This still doesn't answer the question of the F occupancy area not requiring sprinklers.  If I look at the F occupancy area (3500sf) as part of the total "fire area" of 7000sf that also contains an A-2 occupancy area, then I believe the F requires sprinklers.  They are stating the F occupancy evaluation is on a 7000sf F "fire area" and doesn't require sprinklers.


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## cballinger (Apr 8, 2014)

So they are interpreting Section 3410.6 where it states "In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building." to mean that they first look at the entire building ("fire area") as an A-2 occupancy.  Then they look at the entire building ("fire area") as an F-1 occupancy.  Then they determined the F-1 occupancy doesn't require sprinklers because the building ("fire area") is less than 12000sf.

I interpret that when evaluating "each occupancy" per 3410.6.16, that you look at the actual occupancy area (not the entire building area or "fire area").  So I look at the A-2 "occupancy area" of 3500 sf and determine that because it is within a "fire area" over 5000sf, it requires sprinklers.  Then I look at the F-1 "occupancy area" of 3500sf and determine that it too is within a "fire area" over 5000sf that contains an A-2 and therefore the F-1 "occupancy area" requires sprinklers as well.


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## cballinger (Apr 8, 2014)

In my last paragraph that should read 3410.6 not 3410.6.16.


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## cda (Apr 8, 2014)

cballinger said:
			
		

> This still doesn't answer the question of the F occupancy area not requiring sprinklers.  If I look at the F occupancy area (3500sf) as part of the total "fire area" of 7000sf that also contains an A-2 occupancy area, then I believe the F requires sprinklers.  They are stating the F occupancy evaluation is on a 7000sf F "fire area" and doesn't require sprinklers.


Are the possibly saying base code would not require sprinklers in a 7000 sq ft F???

903.2.4 Group F-1. An automatic sprinkler system shall be provided throughout all buildings containing a Group F-1 occupancy where one of the following conditions exists:

1. A Group F-1 fire area exceeds 12,000 square feet (1115 m2).

2. A Group F-1 fire area is located more than three stories above grade plane.

3. The combined area of all Group F-1 fire areas on all floors, including any mezzanines, exceeds 24,000 square feet (2230 m2).


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## north star (Apr 8, 2014)

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Which code section(s) are you citing \ interpreting to require the

sprinkling of the F designated area ?

cda,

That is what I was thinking also !

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## cballinger (Apr 8, 2014)

I'm saying, the sprinkler requirement isn't based upon the "fire area" being an F-1 "fire area".  The F-1 "occupancy area" is not separated from the A-2 "occupancy area".   The sprinkler requirement for the F "occupancy area" is due to the fact that it is part of a "fire area" containing an A-2 occupancy.  Big difference between an "occupancy area" and a "fire area"....


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## cballinger (Apr 8, 2014)

I cited them on section 3410.6.17, with the explanation that the F-1 "occupancy" requires sprinklers because it is not separated from the A-2 "occupancy", referencing Section 508.3.2.1 and Section 903.2.1.


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## mtlogcabin (Apr 8, 2014)

> They have interpreted that when evaluating non-separated mixed occupancies, you would evaluate the entire building as A-2, then the entire building as F, and then choose the value for each and use most restrictive in the overall scoring.


not correct



> I am saying, you can't evaluate the entire building as a single occupancy and not take into consideration other occupancies in the building when there is no separation


Not correct

3410.6.....In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building



They should be evaluating the entire building as an A-2 through out the entire evaluation process

Where the separation between the mixed occupancies qualifies for any category indicated in Section 3410.6.16, the score for each occupancy shall apply to each portion of the building based on the occupancy of the space.



3410.6.16 Mixed occupancies.

Where a building has two or more occupancies that are not in the same occupancy classification, the separation between the mixed occupancies shall be evaluated in accordance with this section. Where there is no separation between the mixed occupancies or the separation between mixed occupancies does not qualify for any of the categories indicated in Section 3410.6.16.1, the building shall be evaluated as indicated in Section 3410.6 and the value for mixed occupancies shall be zero.


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## cballinger (Apr 8, 2014)

When interpreting 3410.6, where it states "the score for each occupancy shall be determined" you are interpreting that to mean that they should evaluate the "entire building" (7000sf fire area) as an A-2 and the "entire building" (7000sf fire area) as an F.... my question is why?  I interpret it to mean that you evaluate each "occupancy", as in, the 3500sf area of that "occupancy".  Where does it say I should evaluate the "entire building" as the occupancy.  It doesn't.  It says I should evaluate the occupancy, then the lower score for each section shall apply to the entire building.


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## cballinger (Apr 8, 2014)

In other words, you evaluate each "occupancy area", then take the lower score of each section and enter into Table 3410.7 for the overall building scores.


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## cda (Apr 8, 2014)

cballinger said:
			
		

> In other words, you evaluate each "occupancy area", then take the lower score of each section and enter into Table 3410.7 for the overall building scores.


not a chap 34 person, but you all may be saying the same thing just different terms.

hope this is stated correctly::

from an outsider on regular non seperated use, the stricter of the occupancies applies to the entire building. So basicly you have the same thing in what you are looking at. The A occupancy requirements apply to the entire building, which kicks in the fire sprinkler requirement for th entire building. The F is just along for the ride.


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## cballinger (Apr 8, 2014)

There is a big difference between an "occupancy area" and a "fire area".  The fire area is dependent upon fire rated separations.  The occupancy area is just the area in a space designated for a particular use.

But that's my point exactly, the F occupancy is required to be sprinklered because it is not separated from the A-2.


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## cda (Apr 8, 2014)

cballinger said:
			
		

> There is a big difference between an "occupancy area" and a "fire area".  The fire area is dependent upon fire rated separations.  The occupancy area is just the area in a space designated for a particular use.But that's my point exactly, the F occupancy is required to be sprinklered because it is not separated from the A-2.


Ok and?  like I said I think you all are saying the same thing, just in a different way


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## cda (Apr 8, 2014)

"""""""They, on the other hand, have interpreted that when doing the evaluation, you should look at the entire building as an A-2 and then the entire building as an F to determine sprinkler requirements. So, they are saying, if you look at the entire building as an F occupancy, then it wouldn’t require sprinklers and used category c for a value of 0. They then used the A-2 value of -4 as most restrictive for the section."""""""""

so the answer to them is they are wrong.

just have them look at the regular non seperated use and I would say it has the same language.

Once again not a chap 34 person


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## cballinger (Apr 8, 2014)

The people I'm in disagreement with are saying, for the 3410 evaluation process, the F occupancy isn't required to be sprinklered because of how they are interpreting Section 3410.6, which determines how the occupancies are evaluated.  You can't evaluate the whole building as an F and the whole building as an A-2 because there are two non-separated occupancies in the building.  You can evaluate each occupancy area, with consideration that it is not separated from the other occupancy area.


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## cballinger (Apr 8, 2014)

I wish I could find a Chapter 34 expert... not sure that exists.


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## cda (Apr 8, 2014)

cballinger said:
			
		

> I wish I could find a Chapter 34 expert... not sure that exists.


If you pay enough!!!!!!


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## north star (Apr 8, 2014)

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If you desire, you could call the ICC Technical Staff and speak with them

for their interpretation.

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## steveray (Apr 8, 2014)

From the 2009 commentary......The evaluation of sprinklers in an existing building is based on whether an automatic sprinkler system is both required and installed. The criteria used to determine when an automatic sprinkler system is required are tied to the same requirements for new construction in Section 903. The thresholds listed in Sections 903.2 through 903.2.12 must be used to evaluate whether those characteristics and occupancies are present and whether a sprinkler system is needed.

Haven't they already lost points for not having the proper seperation in a previous section of analysis?

Section from 2009...

TABLE 3412.6.16 MIXED OCCUPANCY VALUESa

OCCUPANCY CATEGORIES

a b c

 A-1, A-2, R -10 0 10

 A-3, A-4, B, E, F, M, S -5 0 5


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## steveray (Apr 8, 2014)

These 19 safety parameters are focused on critical factors related to the minimum degree of life safety and property protection needed in an existing building.

When mixed occupancies in an existing building are not separated by fire-resistance-rated assemblies or fire walls meeting the most restrictive fire rating of the different occupancies, the entire evaluation must be based on the occupancy with the most restrictive requirements.


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## mtlogcabin (Apr 8, 2014)

After reading and re-reading the commentary on 3410.6.17 and 3410.6.17.1 Categories I am in agreement with you analyses

Category "A" is the correct one for both occupancies because as you have pointed out the fire area exceeds the requirements of 903 for an A-2 use and a fire sprinkler system is required throughout the entire fire area

No sprinklers through out the entire building puts both occupancies in a category "A" for evaluation


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## cballinger (Apr 8, 2014)

steveray said:
			
		

> From the 2009 commentary......The evaluation of sprinklers in an existing building is based on whether an automatic sprinkler system is both required and installed. The criteria used to determine when an automatic sprinkler system is required are tied to the same requirements for new construction in Section 903. The thresholds listed in Sections 903.2 through 903.2.12 must be used to evaluate whether those characteristics and occupancies are present and whether a sprinkler system is needed.Haven't they already lost points for not having the proper seperation in a previous section of analysis?
> 
> Section from 2009...
> 
> ...


No, they did not lose points in this section because, "where there is no separation between mixed occupancies or the separation between mixed occupancies does not qualify for any of the categories indicated in Section 3410.6.16.1, the building shall be evaluated as indicated in Section 3410.6 and the value for mixed occupancies shall be zero."


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## cballinger (Apr 8, 2014)

north star said:
			
		

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> 
> If you desire, you could call the ICC Technical Staff and speak with them
> 
> ...


I had thought about requesting a Technical Opinion from ICC, but I figure I'll be lucky if I get any better answer from "staff" than I would get here unless I get lucky and someone responds that was familiar with the development of Chapter 34.  I'm probably going to request one though anyway.  I'll post here if I find out any new relative info.


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## north star (Apr 8, 2014)

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I, for one, ...would like to know what "The Cow" had to say on this

issue, if you decide to contact them.

Sooooooooo, ...did we abuse you too much on your first outing ?   :devil

We really DO desire to assist everyone where we can !   



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## cballinger (Apr 8, 2014)

Not too bad so far, thanks.     Thanks for the input.


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## cda (Apr 8, 2014)

north star said:
			
		

> *= = | = = | = =*
> 
> I, for one, ...would like to know what "The Cow" had to say on this
> 
> ...


Hay it only took 49 responses, not 100,,   like ???????


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## steveray (Apr 8, 2014)

What is the actual change of occupancy in this project?


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## cballinger (Apr 9, 2014)

The building used to be office and storage space and is changing to brewery/pub. B/M changing to F-1/A-2.


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## cballinger (Apr 9, 2014)

^B/S not B/M.


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## cballinger (Apr 9, 2014)

Sorry, typing from an iPhone now that I'm not at my desk.  :/


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## steveray (Apr 9, 2014)

"Subject to the approval of the building official, the use or occupancy of existing buildings shall be permitted to be changed and the building is allowed to be occupied for purposes in other groups without conforming to all the requirements of this code for those groups, provided the new or proposed use is less hazardous, based on life and fire risk, than the existing use. "

Ask your BO....If they want sprinklers they get sprinklers, does not sound like a less hazardous use.....


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## north star (Apr 9, 2014)

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***steveray**,*

Code section & IBC edition please for ***cballinger***........IMO,

it will help build his/her case in determining which course of action

to follow, and to assist his/her BO.

Thanks!

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## cballinger (Apr 9, 2014)

steveray said:
			
		

> "Subject to the approval of the building official, the use or occupancy of existing buildings shall be permitted to be changed and the building is allowed to be occupied for purposes in other groups without conforming to all the requirements of this code for those groups, provided the new or proposed use is less hazardous, based on life and fire risk, than the existing use. "Ask your BO....If they want sprinklers they get sprinklers, does not sound like a less hazardous use.....


I AM the local "Building Official".  That language in Section 3406.1 was deleted in our State of Indiana amendments.  For a change of occupancy, they are required to meet current code for new construction or pass a 3410 evaluation.


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## cballinger (Apr 9, 2014)

*By the way, I should note, no work is being held up for this.     That's why this is tough, though. The State's Building Law Compliance Officer doesn't want to give an interpretation (I wonder why?). I know if I send them for a State variance it could be a waste of time if I don't have something to back up my interpretation.  The State's Commission would then likely rule no variance is required and it would be a waste of time (time = $) for the owner.


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## north star (Apr 9, 2014)

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Do you have any additional support from a Fire code Official

[ possibly ], or are you the only one providing a different

opinion than "them \ they" ?

IMO, ...you already have enough written code language to

support your position.

If you get turned down,  with you maintaining your position,

...then what ?.............Do you have an alternative plan for

protecting the occupants of the "proposed" establishment,

or another design approach to offer ?



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## cda (Apr 10, 2014)

Well he is the BO, so to me if he says you shall sprinkle

They either do it or go through the appeals process!!!

Another route could be require a technical report from someone the BO approves and paid by the developer


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## steveray (Apr 10, 2014)

That was IBC 2009 3408.1 I believe...


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## cballinger (Apr 10, 2014)

At the moment the inspector doesn't agree with me. Because of the inner workings of our department, I can't send them for a variance at this time. It would be too much to try to explain here how our dept works and our relationship with the State building commission. And because I can't find some code reference that really explains which of us is interpreting it right, I'm hoping I can get a technical opinion from ICC and maybe if they say I'm interpreting it correctly, maybe I can get the inspector on my side and we can send them for a variance to be heard by the commission. I'll update here if I get a response from ICC. Thanks again all.


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## cballinger (Apr 10, 2014)

They also would already have options besides sprinklers- they could provide fire separation between the F-1 and A-2, but they don't want to do either...


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## cda (Apr 10, 2014)

I hate the word

Variance!!!!!!!!!

Sorry to hear about the working conditions, been there


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