# Occupancy Separation or not?



## Examiner (Dec 22, 2009)

Given:

Educational Occupancy Use Group.

Type of Construction: Type II-B

Fully automatic fire suppression system throughout.

Using 508.3.2 Nonseparated occupancies if required

The building is very large and has two fire walls making three buildings.

One fire wall is located to make a building where the Assembly occupancy occurs with a few Art, Choir and ROTC classrooms in the building.  The Choir room would be an Assembly use group due to size and resulting occupant load.  This part of building has three major assembly areas one large Gym for competition games, one Cafeteria/Auditorium and one Gym for PE.

The Code Commentary for 305.1 follows and addresses “_used for School purposes only_”.

_It is common for a school to also have gymnasiums (Group A-3), auditoriums (Group A-1), libraries (Group A-3), offices (Group B) and storage rooms (Group S-1). When this occurs, the building is a mixed occupancy and is subject to the provisions of Section 508.3. In accordance with Section 508.3.1, Exception 2, assembly spaces, such as the gymnasium, auditorium, library and cafeteria, do not have to be considered separate occupancies if used for school purposes only and is limited to school occupants (see commentary, Section 508.3.1)._

The question would be if be the building’s use could be sport competition after school hours; is the building still considered Educational per 305.1?  Assuming the sport competition is public school district related.

_Section 508.3.1 Exception #2_ would not require separate occupancies between the Assembly and Group E occupancy use groups.  The building’s Assembly aggregate areas on this side of the fire wall would exceed 10% of building area.  Would the allowable building area be based on Educational or Assembly?


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## brudgers (Dec 22, 2009)

Re: Occupancy Separation or not?

My opinion, educational occupancy encompasses normally associated functional spaces such as offices and auditoriums (just as they include toilets).

The use of the space will determine occupant load - an office in a B occupancy has the same occupant load as an office in an E occupancy or an I occupancy.

The commentary is in my opinion, misguided.

E occupancy accounts for PTA meetings in the cafeteria, meet the teacher nights througout the school, and varsity basketball games in the gym.


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## mtlogcabin (Dec 22, 2009)

Re: Occupancy Separation or not?

Being in a rural area I have NEVER seen a school gymnasium used exclusively for school related functions. I have attended funerals, wedding receptions, church, craft sales, concerts, voted and enjoyed many fundraising events (dinners & auctions) for non school related causes in a school gymnasium. I call them Assembly and treat them accordingly.


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## JBI (Dec 22, 2009)

Re: Occupancy Separation or not?

Let's call this one our own special Christmas Miracle...

I agree with Brudgers.      (Going to watch a Varsity Game tonight... My daughters' old team at our High School.     )

Yes Virginia, there really IS a Santa Claus...  :mrgreen:


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## kilitact (Dec 22, 2009)

Re: Occupancy Separation or not?

I agree with mtlogcabin. the area in question exceeds 10% which puts it out of the accessory use occupancy cited in sec. 508.3.1. design in accordance with the most restrictive  which would be the A-3.


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## mtlogcabin (Dec 22, 2009)

Re: Occupancy Separation or not?



> The building is very large and has two fire walls making three buildings





> Would the allowable building area be based on Educational or Assembly?


If you already have broken the building up into different fire areas then see if each use group will stand on its own for maximum area.


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## TJacobs (Dec 22, 2009)

Re: Occupancy Separation or not?

What kilitact and mtlogcabin said.


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## mtlogcabin (Dec 22, 2009)

Re: Occupancy Separation or not?

TABLE 508.3.3 does not require A's & E's to be seperated so one does not have to be accessory to the other so the 10% requirement is NA

A-3 & E's can be unlimited under certain conditions. It's a Type II and sprinklered can you meet the rest of the requirements?

Some may disagree with the unlimited building approach. If so why? We are all still wanting to learn and improve what we do.

507.6 Group A-3 buildings.

The area of a one-story, Group A-3 building used as a place of religious worship, community hall, dance hall, exhibition hall, gymnasium, lecture hall, indoor swimming pool or tennis court of Type II construction shall not be limited when all of the following criteria are met:

1.	The building shall not have a stage other than a platform.

2.	The building shall be equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1.

3.	The assembly floor shall be located at or within 21 inches (533 mm) of street or grade level and all exits are provided with ramps complying with Section 1010.1 to the street or grade level.

4.	The building shall be surrounded and adjoined by public ways or yards not less than 60 feet (18 288 mm) in width.

507.9 Group E buildings.

The area of a one-story Group E building of Type II, IIIA or IV construction shall not be limited when the following criteria are met:

1.	Each classroom shall have not less than two means of egress, with one of the means of egress being a direct exit to the outside of the building complying with Section 1018.

2.	The building is equipped throughout with an automatic sprinkler system in accordance with Section 903.3.1.1.

3.	The building is surrounded and adjoined by public ways or yards not less than 60 feet (18 288 mm) in width.


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## Examiner (Dec 23, 2009)

Re: Occupancy Separation or not?

Thanks all for your responses:

I think mtlogcabin had a reverse on his first take.

I also agree that the Assembly does not require separation in Educational Occupancy use groups.  The Code does not require separate occupancies between Educational and Assembly in two sections of the Code as pointed out by mtologcabin.  First in Section 508.3.1 and reiterated in Table 508.3.3.

The fact that the reference to not requiring an occupancy separation is an Exception to the 10% rule in 508.3.1, the Exception therefore supersedes the 10% rule.  The Code Commentary also addresses the omission of requiring separation.  The Code Commentary does not address the last part of the Exception “except when applying the assembly occupancy requirements of Chapter 11”.  I cannot find any reference to occupancy separation in Chapter 11.  I am confused on what that part of the sentence is trying to imply.  Any thoughts regarding references to Chapter 11 are trying to imply?

In most cases the after hours use of the Assembly Occupancy is when the Educational parts of the building are locked off.  Most schools prefer the Assembly part of the structure to be secured from the Educational areas in order to prohibit people from wandering the halls of the Educational areas.  Although the Assembly area is not required an occupancy separation it still has to comply with the requirements of Assembly (i.e., egress, restrooms).  Therefore, after hour use of the space by others than School related functions should not require occupancy separation.

As for unlimited area, the building has a two story part and the firewalls between buildings would negate the perimeter clear area.  [ref: 507.9 #1 & #3]


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## mtlogcabin (Dec 23, 2009)

Re: Occupancy Separation or not?

I was ranting in my first post.

What I meant to say is if a school with a gym comes thru I would require they meet the most restrictive requirements in Chapter 9 for assembly and not educational as stated in 508.3.2.1


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## kilitact (Dec 23, 2009)

Re: Occupancy Separation or not?

mtlogcabin wrote:



> I was ranting in my first post.What I meant to say is if a school with a gym comes thru I would require they meet the most restrictive requirements in Chapter 9 for assembly and not educational as stated in 508.3.2.1


I disagree, if the gym is used for school use only than sec. 508.3.1 ex. 2, is applicable, doesn't need to meet requirements for nonseparated use in sec. 508.3.2.1. If the gym is used for events not school related, than this accessory used needs to meet all the requirements for accessory occupancies 10% etc., or nonseparated use.


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## vegas paul (Dec 23, 2009)

Re: Occupancy Separation or not?

kilitact - need some clarification.  508.3.1, Exc. #2 says: "Assembly areas that are ACCESSORY to Group E..."  does that mean they first need to be accessory to qualify for this exception?  I mean, do they need to be aggregate less than 10% in order to be accessory and also assembly spaces?

If an assembly area is ASSOCIATED with a Group E, but not ACCESSORY (more than 10%), then does this exception apply?

hmm...


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## Examiner (Dec 23, 2009)

Re: Occupancy Separation or not?

508.2.1 addresses incidental use area that is specifically addressed Table 508.2.  The Assembly occupancy is not an incidental use area.  It is an accessory occupancy use group.

Are you implying that the entire school must be the size and construction type limitations of the most restrictive Occupancy Use Group as addressed in 508.3.2 and its following sub sections?  I feel that 508.3.1 has already established occupancy separation is not required between Educational and Assembly and therefore this overrules Section 508.3.2 regarding Construction Type and area.  Assembly occupancies are much smaller than Educational allowable areas per the Tables.  I feel that Section 508.3.2 rules when exceeding the 10% rule applies if you have not already meet non-separated use groups elsewhere in the Code.

To require this part of the building to conform to the area requirements of Assembly would cause another firewall.  All of the Assembly areas are on this side of the firewall as are some Educational spaces.  The Assembly exceeds the 10% rule on this side of the firewall.

The Commentary gives an example of Business area separated from Educational area in Section 508.3.2.  But the Business areas in schools are most always under the 10% rule.  I think the Commentary does not address Educational and Assembly in Section 508.3.2 because they are excluded from requiring rated separation.


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## kilitact (Dec 23, 2009)

Re: Occupancy Separation or not?

vegas paul wrote:



> kilitact - need some clarification. 508.3.1, Exc. #2 says: "Assembly areas that are ACCESSORY to Group E..." does that mean they first need to be accessory to qualify for this exception? I mean, do they need to be aggregate less than 10% in order to be accessory and also assembly spaces?If an assembly area is ASSOCIATED with a Group E, but not ACCESSORY (more than 10%), then does this exception apply?


The 10% rule would not be applicable in the case of a school that has accessory use areas such as,  gym’s, libraries and cafeterias etc, has long has the use is school related. IMO


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## brudgers (Dec 23, 2009)

Re: Occupancy Separation or not?



			
				kilitact said:
			
		

> The 10% rule would not be applicable in the case of a school that has accessory use areas such as,  gym’s, libraries and cafeterias etc, has long has the use is school related. IMO


The code requires separations between occupancies not uses (with a few small exceptions which don't apply here).

Occupancy E covers a range of varied uses normally associated with educational facilities.

Collateral community uses such as polling, public meetings, etc. are part and parcel of schools.


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## mtlogcabin (Dec 23, 2009)

Re: Occupancy Separation or not?



> Are you implying that the entire school must be the size and construction type limitations of the most restrictive Occupancy Use Group as addressed in 508.3.2 and its following sub sections?


No but 508.3.3.2 must be met

508.3.3.2 Allowable area.

In each story, the building area shall be such that the sum of the ratios of the actual floor area of each occupancy divided by the allowable area of each occupancy shall not exceed one.


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## Examiner (Dec 23, 2009)

Re: Occupancy Separation or not?

Well I completely missed 508.3.1.1 and 508.3.1.2.  It seems that if the building is mostly Assembly but has some Educational classrooms then the building's primary occupancy is Assembly.

Therefore, on this side of the firewall the building will have to be classified Assembly with all sizes and area increases etc applicable for Assembly.  If the Assembly was not the major part of the total area of the building then Educational would apply.  Sure is a shame that I could not use the areas on the other side of the firewalls.  Firewalls make separated buildings so I have three buildings.  Now I will have to make another building because the actual area exceeds the allowable for Assembly.

Sections in 508.3.2 and its sub sections do not apply for Educational and Assembly.


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## kilitact (Dec 23, 2009)

Re: Occupancy Separation or not?

mtlogcabin wrote:



> No but 508.3.3.2 must be met508.3.3.2 Allowable area.
> 
> In each story, the building area shall be such that the sum of the ratios of the actual floor area of each occupancy divided by the allowable area of each occupancy shall not exceed one


if used for educational purpose, separate, nonseparate has no bearing, its educational use E. sec. 508.3.3.2 is for separate use.

Brudgers wrote:



> The code requires separations between occupancies not uses (with a few small exceptions which don't apply here).Occupancy E covers a range of varied uses normally associated with educational facilities.
> 
> Collateral community uses such as polling, public meetings, etc. are part and parcel of schools.


I disagree, if not part of the school, than ex.2 doesn't apply


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## RickAstoria (Dec 25, 2009)

Re: Occupancy Separation or not?



			
				kilitact said:
			
		

> mtlogcabin wrote:
> 
> 
> 
> ...


if used for educational purpose, separate, nonseparate has no bearing, its educational use E. sec. 508.3.3.2 is for separate use.

Brudgers wrote:



> The code requires separations between occupancies not uses (with a few small exceptions which don't apply here).Occupancy E covers a range of varied uses normally associated with educational facilities.
> 
> Collateral community uses such as polling, public meetings, etc. are part and parcel of schools.


I disagree, if not part of the school, than ex.2 doesn't apply[/quote:15cm08x9]

Lets ask ourselves  what is a Group E...

My understanding - a Group E is for classrooms and labs and may include hallways.

The big question is what is the Gymnasium going to be classified. If it is solely used for education purposes (ie. P.E. Class) then it might be a Group E but if it is used for After-school tournaments with bench seating for parents and all then it might be a Group A and meet the stricter provisions of Group A. However, it might be BOTH and need to comply with both.

However, the big Basketball court area and similar spaces would be a Group A if there will cutomarily be more then 50 people in those spaces at the same time.

It is a good question.

Colleges would be Group B for any place Group E occurs in general.

School Auditorium / Cafetorium (A hybrid of a Cafeteria/Auditorium), Lecture Halls, Eating / Student Activity Areas (indoor or under a roof) would be a Group A as well as any other area with 50 or more people.

Just some thoughts. Once you know your occupancy classifications, you should know your answer to the separation.


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## Examiner (Dec 28, 2009)

Re: Occupancy Separation or not?

Since I posted the original question I will address what I see are the answers.

First off, in an Educational Occupancy (use group Grades K through 12) Assembly Occupancies used for School purposes do not require Occupancy separation.  This is all covered in Section 508.3.1 and its Exception #2.

Section 508.3.2 does not apply here.  Section 508.3.2 is for nonseparated occupancies that are not already give an Exception.  Its use would be for say, a Business Occupancy; where there are Assembly Occupancies in the same building.  Table 508.3.3 list the separation requirements and related footnotes for the Table also address possible exceptions for omission of rated separation of different occupancy use groups.  However, the Table is used for hourly required separation and if you are trying for nonseparated occupancies then the table is a second check whether or not you need to try for nonseparated occupancies.

For Educational and Assembly Occupancy; Sections 508.3.1.1 through 508.3.1.2 do apply since they are subsections of 508.3.1.  Table 508.3.3 reiterates that separation is not required between these two occupancies.  What the owner uses the building for after school hours may also be for school purposes and is still covered by Section 508.3.1.

Section 503.1.1 addresses the requirement of the most restrictive applicable provisions of Section 403 and Chapter 9 of the two occupancies shall apply to the entire building.  Section 403 and Chapter 9 will not cover the allowable area of the building.  Assembly is most likely the most restrictive and therefore; the Educational will have to follow requirements of Educational and Assembly addressed in Section 403 and Chapter 9.  Allowable area and height will be for Educational as long as the Assembly remains the accessory occupancy.

Only when the Assembly has an aggregate area in excess of 10% of the building’s total and is no longer the minor occupancy will Section 508.3.1.2 apply.  Once the Assembly is the major use based on building area will the Educational become the accessory occupancy.  Both still will not require a rated occupancy separation but the entire building must comply with the height and area of the Assembly occupancy.  The Educational will also have to follow requirements addressed in Section 403 and Chapter 9.

In my case the firewall has created a building and put the Assembly occupancy and some classrooms in this building’s area.  The Assembly occupancy is now the major use group because it occupies more than 10% of the building area on this side of the firewall.  Section 508.3.2 still does not apply but Sections 508.3.1.1. & 508.3.1.2 do.


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## fw. (Dec 29, 2009)

Re: Occupancy Separation or not?



			
				\ said:
			
		

> Only when the Assembly has an aggregate area in excess of 10% of the building’s total and is no longer the minor occupancy will Section 508.3.1.2 apply.  Once the Assembly is the major use based on building area will the Educational become the accessory occupancy.  Both still will not require a rated occupancy separation but the entire building must comply with the height and area of the Assembly occupancy.  The Educational will also have to follow requirements addressed in Section 403 and Chapter 9.quote]I'll throw my $0.02 in.  Exception 2, to 508.3.1, exempts the assembly area in the E occupancy from the requirements of 508.3.1, all of the requirements of 508.3.1.  You do not need to worry about height and area of the assembly occupancy, it's not an A, it's not an accessory area A occupancy, it's an E occupancy, nothing more nothing less.


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## Examiner (Dec 29, 2009)

Re: Occupancy Separation or not?

Sections 508.3.1.1 and 508.3.1.2 are sub sections of 508.3.1 and I do not see how they do not apply.  Just because 508.3.1 Exception #2 allows nonseparated use does not negate the requirements of the subsections.  Exception #2 is only addressing deleting rated separation between Assembly and Educational.

My problem is the firewall in the school has created separate buildings and one of the separate buildings is mostly Assembly spaces.  The Educational classrooms occupy a minor area in this building.  They still are not considered to be rated separate occupancies but this side of the firewall the building will have to follow the Assembly limits for building area not Educational.

_508.3.1.2 Allowable area and height. The allowable area and height of the building shall be based on the allowable area and height for the main occupancy in accordance with Section 503.1.  The height of any accessory occupancy shall not exceed the tabular values in Table 503, without height and area increases in accordance with Sections 504 and 506 for such accessory occupancies._

_Code Commentary: The accessory use option is very similar to the nonseparated use option in all of the provisions. This section gives the most significant difference between the two.  For accessory uses, the height and area of the building containing the accessory use would be based upon the height and area of the main use, because accessory uses are limited to 10 percent of the area of the story in which they are housed and because the area is limited to the tabular area given by Table 503, without any increases for height and area.  In other words, the accessory use must be a minor part of the total area of the building._


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## fw. (Dec 30, 2009)

Re: Occupancy Separation or not?

Without quoting the sections, 508.3.1.1 tells you to individually classify each accessory area with it's occupancy.  That is negated by exception #2 because the exception tells you its all an E occupancy.

508.3.1.2, tells you that the height and area are based on the main occupancy, then talks about the accessory occupancy.  There is no accessory occupancy because exception #2 tells you its all an E occupancy.

Let's pretend this is something else where exception #1 or #3 applied, would we be having the same conversation?

An example of subsections not applying after the exceptions would be Section 704.11, requiring parapets on exterior walls of buildings, then there is a whole list of exceptions.  Section 704.11.1, tells you how the parapets are to be constructed.  Would you tell someone that even though they have met one of the parapet exceptions they still need to put up the parapet?


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## Examiner (Dec 30, 2009)

Re: Occupancy Separation or not?

Ran this issue through Code Congress and here is their take as I understand it.

*During School Hours:*

The Exceptions in 508.3.1 overrules all other Sections and subsections, (508.3.1.1, 508.3.1.2 and 508.3.2), related to taking the Exception as well as the 10% rule and area limits for the accessory occupancy mentioned in 508.3.1.

The building area would be based on Educational as the major occupancy use group as long as the accessory occupancy is for school functions during school hours.  Such things as PE classes, basketball games, school plays all during school hours are considered to be related to school activities.  The Assembly occupancy can exceed the 10% area of the building and still not be required to be separated or comply with the Assembly area limits in Table 503.

*After School Hours:*

However, events after school even those related to activities, such as sports, with other schools would not be considered a school activity because it occurs after hours and will have many visitors to the school who are not familiar with the building.  This type of activity would require the building to comply with 508.3.1 and its sub sections not using the Exceptions.

If you use 508.3.1 you will be limited to the 10% rule and cannot exceed the area limits of the minor occupancy in Table 503.  You also cannot get any area increases for the Assembly occupancy if the Assembly is the minor occupancy.  You will be allowed to have non-separated occupancy separation [ref: 508.3.1.3].

If you exceed the 10% rule or the area in Table 503, then you have to decide if you want separated or non-separated occupancies.

In my case going for non-separated occupancies, Section 508.3.2 and its sub sections will apply and the major occupancy will be Assembly.  Now I can get allowable area increases.

In conclusion you have to know how the Assembly space is to be used in an Educational occupancy.  Some school districts may not allow others to use or lease their Assembly spaces due to insurance and liability reasons especially possibility for grades K through 6.

I hope the above aids someone else.  It has been a learning experience for me.

Thank all of you for your input.


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## mtlogcabin (Dec 30, 2009)

Re: Occupancy Separation or not?

Thank You for posting the additional information.


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## brudgers (Dec 30, 2009)

Re: Occupancy Separation or not?

Every school is going to have functions that occur outside of normal school hours.

Therefore, according to the ICC nothing can really be classified as group E.

Sports events?  Occupancy A.

School Store?  Occupancy M.

Detention Hall?  Occupancy I.

Evening ToEFL classes?  Occupancy B.

It's this sort of hair splitting that makes the ICC useless.


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## brudgers (Dec 30, 2009)

Re: Occupancy Separation or not?



			
				Examiner said:
			
		

> *After School Hours:*However, events after school even those related to activities, such as sports, with other schools would not be considered a school activity because it occurs after hours and will have many visitors to the school who are not familiar with the building.


The only time building familiarity comes into play regarding life safety is for permanent dwelling units.

It never is considered a mitigating factor for life-safety in a public building...never mind the absurity of using it in a building that by definition is friggin' full of children.

It just goes to show that they're backing up a pre determined conclusion, not trying to figure it out.

Try to imagine codifying a change in occupancy based not on use but on normal hours of operation.


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## fw. (Dec 30, 2009)

Re: Occupancy Separation or not?

brudgers, well said, both times!!   

You don't need to make this any harder than it already is.  The code says it's an E, it's an E.

Section 705.1, fire walls, says that they "shall be considered separate buildings", not that they are separate buildings.  It's one building that has been divided up with fire walls, it's still a school, and still an E.


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## kilitact (Dec 31, 2009)

Re: Occupancy Separation or not?

examiner posted:



> However, events after school even those related to activities, such as sports, with other schools would not be considered a school activity because it occurs after hours and will have many visitors to the school who are not familiar with the building. This type of activity would require the building to comply with 508.3.1 and its sub sections not using the Exceptions.


This doesn’t make sense; activities during school hours could also have many visitors who are not familiar with the building. This is an EEEEEEEEEEEE


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## TJacobs (Dec 31, 2009)

Re: Occupancy Separation or not?

I would ask the design professional to declare why the firewall is being provided and review based on the response.

Then get the school district to declare in writing that the assembly occupancy will never be leased out to a non-school-related outside entity.


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## JBI (Jan 1, 2010)

Re: Occupancy Separation or not?

Just put an unrated opening in the 'fire wall' and , no more fire wall.

No more fire wall, no seperate buildings.

No seperate buildings, no use/occupancy questions.

Seriously, the OCCUPANCY of the building is for Use Group E.

The USE of those spaces may include assemblages of persons for a variety of reasons. That it is a Varsity Basketball game with visiting spectators as well as locals, does not mean the Educational OCCUPANCY has been eradicated. A fuller understanding of these types of activities would allow one to realize that they are at least as 'educational' as some (many?    ) of the 'classes' during regular school hours.

Oddly, for my 500th post I find myself agreeing (in principle at least) with Brudgers.

Not at all what I expected. Looks like 2010 will be full of surprises...


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