# Stairs to storage room in horse Tack storage building



## Jon Victor (Jul 30, 2015)

Question...I have a set of stairs going to a storage room above that has a beam that limits the stair clearance in one area to 6' high.  We sent off an email to ICC for an official code interpretation and was told that if a stair is being constructed it needs to meet the requirements of section R311.7.  My questions is this, if this is an accessory structure and is not a _dwelling_, does section R311.7 truly apply?  This set of stairs is in a residential shop/ storage/ tack room and is not intended to be used as a dwelling.  Any comments would be greatly appreciated!

Jon


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## steveray (Jul 30, 2015)

"Dwelling" is specifically mentioned 3 times in 311.1.....Guessing I could let it fly....Which code edition?


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## Jon Victor (Jul 30, 2015)

We are currently under the 2012 IRC


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## north star (Jul 30, 2015)

*@ ~ @ ~ #*







> "My questions is this, if this is an accessory structure and is not a _dwelling_, does section R311.7 truly apply?"


Section R101.2 says that your Accessory structure falls under the provisions of the whole IRC too !

See this link to Section R101.2:  *http://publicecodes.cyberregs.com/icod/irc/2012/icod_irc_2012_1_sec002.htm*

[ *the last 4 words * ].

The stairway dimensions in your Accessory structure must comply as well.



*# ~ # ~ @*


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## Jon Victor (Jul 30, 2015)

north star,  I do agree that an accessory building falls under the scope of the IRC, but I don't necessarily agree that an accessory building is a dwelling and as such would not be subject to the provisions of R311.1.  It is like saying a pull down stair/ladder is a fully functional stair and is subject to the requirements of R311.7.  If there wasn't a stair installed to this area, there would be no requirement, but as soon as a stair is built, suddenly the stair has to be compliant.  If this reasoning were true, pull down ladders should be regulated, right?  Sounds to me like there are some holes in the code on this one.


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## mtlogcabin (Jul 30, 2015)

6 ft is a real head banger. If it is just storage and accessed a couple times a month maybe changing the "stair" geometry would be better. Ships ladder comes to mind.

Another thought is the beam over sized for the loads that are being carried? If so maybe the beam can be modified to provide a few more inches. I realize you may never get the 6' 8" minimum requirement but 6 ft it pretty low for a stair.


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## north star (Jul 30, 2015)

*% - - - %*



Jon Victor,

I do not believe that Section R101.2 is defining your accessory

structure as a dwelling........In my view, this section is requiring

One and Two Family Dwellings to comply, *AND* their accessory

structures.......Two separately defined types of structures,

and the stairways in each must comply with the minimum

dimensional requirements of a stairway [  *RE:* Section R311.7.2,

`12 IRC  ]

To me at least, ...this seems pretty clear !

Stay tuned,  ...because there are a lot of holes in the codes.



*% - - - %*


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## fatboy (Jul 30, 2015)

You are going to get responses all over the place, search "attic access", "attic stair(s)"........... here is one that is specific to a "barn".

http://www.thebuildingcodeforum.com/forum/residential-building-codes/4574-barn-stairs.html


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## cda (Jul 30, 2015)

Call it a "U"

Not sure if that solves the problem


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## cda (Jul 30, 2015)

Welcome Jon!!!

Are you an owner, designer, inspector, or something else??


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## fatboy (Jul 30, 2015)

Looking at it Jon has been with us since almost our inception, just lurking I guess........ But yes, welcome to the inner sanctum!


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## cda (Jul 30, 2015)

Maybe this is someone's alter ego ????


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## steveray (Jul 31, 2015)

Northstar....311 SPECIFICALLY references dwellings vs. the general CH1 stuff....Whilst I agree it is not a great idea at a stair, I believe I would be covered if I allowed it. I would make sure the property owner was aware that they might have an issue with people getting injured, but I am enforcing the minimum code.


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## north star (Jul 31, 2015)

*% ~ % ~ %*

steveray,

Which is the most restrictive application [  *RE:* Section R102.1,  `12 IRC  ] ?

*% ~ % ~ %*


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## ICE (Jul 31, 2015)

Section R311 of the Residential Code applies to dwellings.  A detached storage structure is not a dwelling.

What does the IBC say?  No help there either as it requires 80" headroom for a U occupancy.


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## Jon Victor (Jul 31, 2015)

fatboy said:
			
		

> Looking at it Jon has been with us since almost our inception, just lurking I guess........ But yes, welcome to the inner sanctum!


fatboy,  yes I have been a lurker for quite some time.  I took a hiatus for a couple years (thanks to an unfortunate layoff), but I'm back in force!  Thanks for the welcome!  I'm the Building plans examiner for Twin Falls, Idaho and I also review commercial and residential mechanical plans.


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## Jon Victor (Jul 31, 2015)

The most restrictive is that this is an accessory building, not a dwelling.  I would classify this as a U most likely.  I know some building classifications have been pretty controversial in the 7 years since I have been a plan reviewer, and most that I talk to say that if there is an 8 foot ceiling in the room and it looks like it could potential be converted to some kind of living space, then we should push the most restrictive requirements of the code and call it a dwelling.  But what if the owner just wants a good storage space where they don't have to stoop inside or hit their head on the ceiling.  Just because a car is capable of exceeding the speed limit doesn't mean that we prohibit it from driving on the road, right?  I believe the better approach would be to have solid documentation on file with the AHJ, and maybe even having a letter from the owner saying this will only be used as storage, and move on.  Seems like in the grand scheme of Building Code enforcement, this is a pretty minor thing to be a stickler about.


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## steveray (Jul 31, 2015)

R102.1 General.

Where there is a conflict between a general requirement and a specific requirement, the specific requirement shall be applicable. WHERE IN ANY SPECIFIC CASE, different sections of this code specify different materials, methods of construction or other requirements, the most restrictive shall govern.

My take is it is not a specific case, it is general vs. specific...But thanks for the debate, I just argue or explain like I think I might have to in front of the judge...."Dwelling" was added specifically in the 2009, maybe some commentary might shed some light...


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## north star (Jul 31, 2015)

*~ ~ v ~ ~*

Jon Victor,

I guess that we will agree to disagree on this one.......I will

concur with the official interpretation by ICC also, in that

IMO,  ...all stairways need to comply with R311.7.........In

having documentation on this design issue,  ...I would

have a hard time having an official interpretation on

file by a recognized code agency, and then deciding to

overrule that interpretation.

In your particular application, will the "stairway to the

storage area above" never be used or considered as a

MOE ?

Also, ...glad to see that you have come out of your lurking

status............Please contribute more often !  



*~ ~ v ~ ~*


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## cda (Jul 31, 2015)

Cal it a "u" ouppancy

Does that help?


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## steveray (Jul 31, 2015)

U does not exist in IRC and would hurt in IBC


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## north star (Jul 31, 2015)

*@ : @ : @*

steveray,

Respectfully asking, ...How would you explain to the judge, Section

R101.2 - Scope: *"...shall apply to, ...**and** their Accessory*

*structures"*,  ...Section R102.1, _*"the most restrictive shall shall*_

_*govern"*_, AND an official, documented interpretation by ICC ?

What written justification would you use ?........"Well judge,

I just do not believe that we have a dwelling in this

application ?     



*@ : @ : @*


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## tmurray (Jul 31, 2015)

north star said:
			
		

> *@ : @ : @*steveray,
> 
> Respectfully asking, ...How would you explain to the judge, Section
> 
> ...


I guess the question becomes, is this an accessory structure? To be an accessory structure, like a shed, it would be unlikely to find a shed on a piece of property without a dwelling. So, sheds, pools, etc. are accessories to the dwelling units. However, if we are talking about a horse barn, it likely isn't an accessory building, even if it is located on the same lot as the dwelling. You have to ask yourself if the building would exist without the dwelling present. In my area, the answer would be yes. While we do have plenty of barns and riding arenas on residential properties, the dwellings are not integral to the operation of the farm and in some cases, there is no dwelling on the lot at all.


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## Rick18071 (Jul 31, 2015)

SECTION R311 MEANS OF EGRESS

R311.1 Means of egress.

All dwellings shall be provided with a means of egress as provided in this section. The means of egress shall provide a continuous and unobstructed path of vertical and horizontal egress travel from all portions of the dwelling to the exterior of the dwelling at the required egress door without requiring travel through a garage.

R311.7 Stairways. That's all it says, "stairways". I doesn't specify where the stairway is or if used for a means of egress, it just says "stairway".

R202 DEFINTIONS. One or more flights of stirs, either interior or exterior, with the necessary landings and platforms connecting them to form a continuous passage from one level to another within or attached to a building, porch or deck.

Nothing in the definition about it only in a dwelling or a means of egress.


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## Jon Victor (Jul 31, 2015)

northstar,

Yep, it looks like we have to agree to disagree on this one.  It was a lively debate though and very thought provoking.  I do trust the opinions of ICC officials that have way more experience than I do, and this is probably the first out of the last 20 or so code interpretations that I have disagreed with them on.  Well, my BO has gone with the code interp from ICC and we asked the builder to either remove the stair or make it compliant by removing the beam.  You win some and you lose some.     It is good to be part of this forum and I look forward to future lively debates!


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## north star (Jul 31, 2015)

*~ ~ X ~ ~*



Jon Victor,

It sounds as though you enjoyed the discussion about your particular

application........If so, ...might I also interest you in becoming a regular,

paid subscription member [  i.e. - *a Sawhorse*  ] on this Forum ?

It would be $60.00 for a 2 year subscription, with benefits.

The benefits are listed somewhere on here...  D`OH !

Anyhoo, ...we encourage active particpation on this Forum........The

codes have a lot of answers and questions as well.......We DO

have some lively discussions, but very informative & insightful.

Like most things that are worthwhile, ...there is a financial cost

involved............Since you have been a long time lurker, ...I am

certain that you know that the costs to operate & maintain this

resource is not cheap.

Thanks for your consideration in becoming a Sawhorse !    



*~ ~ X ~ ~*


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