# Separate Buildings Created by Firewall, and Accessible Route



## Glennman CBO (Sep 29, 2010)

'09 IBC, B occupancy.

A 2 hr fire wall is separating a building into 2 buildings in lieu of sprinklers. The building is type V-B. This was done under the '03 IBC (I think). The building has a 2nd story at 2900 sq ft, not requiring an accessible route due to the exception in section 1104.4.

Now the owner of the "aggregate" building wants to add a 2nd floor in the other half of the building (on the other side of the firewall). This area will be approx 2500 sq ft.

Is he required to provide an accessible route now that he is adding the other 2nd floor space, or is it considered a separate building with regards to accessibility as well as with regards to omitting sprinklers. In other words, is this considered an aggregate building with regards to fire protection only, and not accessibility?

I don't know alot about the building, except what our plans examiner is telling me about what is being proposed. I have no idea how the building entrances are layed out, or how this wall is constructed. I hope the question is not too general.

Thanks all.


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## TJacobs (Sep 29, 2010)

Are these separate addresses and businesses?


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## brudgers (Sep 29, 2010)

As I recall, the only stipulation on using a firewall to create two buildings is that it cannot be used to get around area limitations.

Keep in mind that the 3000 s.f. in aggregate is an IBC only requirement and not the currently enforceable ADAAG 1994.

In that document multiple floors less than 3000 sf are allowed.


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## Glennman CBO (Sep 29, 2010)

All one address, but separate suites.


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## Glennman CBO (Sep 29, 2010)

Brudgers, can you clarify? I thought that firewalls can be used to reduce building areas (i.e. separate buildings) per section 503. I know this is off subject. Please forgive.


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## brudgers (Sep 29, 2010)

That's what I get for going off of memory.

I was recalling FBC 706.

It requires a 4 hour wall to overcome area limitations.

Unlike the IBC.

You never forget your first girl.


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## Glennman CBO (Sep 29, 2010)

Thanks Brudgers. I don't know about the ADAAG, but chapter 11 of the building code states that "aggregate" areas above and below the accessible level that exceed 3000 sq ft must be accessible. In this situation, if one sees it as aggregate (adding the 2 spaces together), then they need an accessible route to the 2nd floor. However, the building owner is claiming that since they have this firewall, then the "aggregate" term doesn't apply.

I kind of see his point, but I'm not sure if the term "two buildings" can be taken to that extent.


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## brudgers (Sep 30, 2010)

Glennman CBO said:
			
		

> I kind of see his point, but I'm not sure if the term "two buildings" can be taken to that extent.


If you kinda' see the point approve the plan...see my signature.

The code says they're two buildings anyway.  If you're going to reset allowable area at the firewall, it's hard to see why the 3000 sf wouldn't reset.  Where would you stop, 3000 sf per block? Would it be any different if each building was under separate ownership?


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## mtlogcabin (Sep 30, 2010)

If the 2 hour fire barrier has an opening connecting the 2 areas then you have to consider the aggregate number. If the two areas are totally seperate (exits, restrooms etc) then you could probably consider them as seperate buildings provided the tenants are not health care providers.


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## TJacobs (Sep 30, 2010)

*Fire* walls may be used to create separate buildings to permit compliance with height and area restrictions.

*Fire* walls may be used to create separate *fire* areas to avoid sprinkler requirements.

I am not sure that a *fire* wall or any other *fire* separation assembly should be used in the avoidance of accessibility requirements.


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## brudgers (Sep 30, 2010)

TJacobs said:
			
		

> *Fire* walls may be used to create separate *fire* areas to avoid sprinkler requirements.


Firewalls create buildings. [705.1] Note that "shall" makes consideration as separate buildings mandatory not optional.

Fire Barriers create fire areas. [508.3.3.1 & 706.3.8 & 706.3.9]


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## TJacobs (Sep 30, 2010)

brudgers said:
			
		

> Firewalls create buildings. [705.1] Note that "shall" makes consideration as separate buildings mandatory not optional.Fire Barriers create fire areas. [508.3.3.1 & 706.3.8 & 706.3.9]


2006 IBC:

503.1 General.

The height and area for buildings of different construction types shall be governed by the intended use of the building and shall not exceed the limits in Table 503 except as modified hereafter. Each part of a building included within the exterior walls or the exterior walls and fire walls where provided *shall be permitted to be a separate building*.

FIRE AREA. The aggregate floor area enclosed and bounded by *fire walls*, fire barriers, exterior walls or fire-resistance-rated horizontal assemblies of a building.

I stand by my previous response as written.  I agree that fire walls create separate buildings, but I believe I would let a designer design a fire wall and not create a separate building if the designer did not want or need to.  Not sure that a fire wall gets you out of accessibility.

That said, I can see where mtlogcabin's reponse is coming from.


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## brudgers (Sep 30, 2010)

705.1 allows no latitude.

_Each portion of a building separated by one or more fire walls that comply with the provisions of this section _*shall*_ be considered a separate building._

If the designer designates it as a fire wall and it complies with the section, then _they_ are considered two buildings.

Maybe the language is bad, but the more restrictive applies.


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## mark handler (Sep 30, 2010)

*ADAAG*

*4.1.1(5) (a) In new construction, a person or entity is not required to meet fully the requirements of these guidelines where that person or entity can demonstrate that it is structurally impracticable to do so. Full compliance will be considered structurally impracticable only in those rare circumstances when the unique characteristics of terrain prevent the incorporation of accessibility features. If full compliance with the requirements of these guidelines is structurally impracticable, a person or entity shall comply with the requirements to the extent it is not structurally impracticable. Any portion of the building or facility which can be made accessible shall comply to the extent that it is not structurally impracticable.*

Can you make it accessible, do so. "no latitude" for fire walls.


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## brudgers (Oct 1, 2010)

ADAAG generally allows stories under 3000 sf to be exempt from vertical accessibility.

So a pair of buildings each with 2900 sf on the second floor would comply.

The IBC's aggregate provision is in question.

However, if you're going to aggregate the second floors of multiple buildings where do you stop, the lot, the block, the zoning district?

BTW openings in fire walls tend to defeat the purpose.


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## mtlogcabin (Oct 1, 2010)

brudgers said:
			
		

> 705.1 allows no latitude. _Each portion of a building separated by one or more fire walls that comply with the provisions of this section _*shall*_ be considered a separate building._
> 
> If the designer designates it as a fire wall and it complies with the section, then _they_ are considered two buildings.
> 
> Maybe the language is bad, but the more restrictive applies.


 Go back to the charging lanquage of 705

701.1 Scope.

The provisions of this chapter shall govern the materials and assemblies used for structural fire resistance and fire-resistance-rated construction separation of adjacent spaces to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings.

Chapter 7 provides a way to exceed the maximum area and height limits of Chapter 5 and are consider seperate buildings for that purpose only it can still be one "facility" which was the point I was trying to make in my first post. If the buildings will be acting as one "facility" with shared egress componants and restrooms ect then I do not see how the aggregate portion would not be applicable


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## mark handler (Oct 1, 2010)

brudgers said:
			
		

> ADAAG generally allows stories under 3000 sf to be exempt from vertical accessibility.So a pair of buildings each with 2900 sf on the second floor would comply.
> 
> The IBC's aggregate provision is in question.
> 
> ...


All floors must still be accessible. The only thing that provision excepts is an elevator.  All other elements must be accessible. Stairs, Corridors, doors, restrooms, spaces, on the second floor must still comply fully.

There is more to access than an elevator.

There are more disabilities than those in wheelchairs.

A firewall does not mean the spaces on the second floor need not comply.


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## TJacobs (Oct 1, 2010)

mtlogcabin said:
			
		

> Go back to the charging lanquage of 705701.1 Scope.
> 
> The provisions of this chapter shall govern the materials and assemblies used for structural fire resistance and fire-resistance-rated construction separation of adjacent spaces to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings.
> 
> Chapter 7 provides a way to exceed the maximum area and height limits of Chapter 5 and are consider seperate buildings for that purpose only it can still be one "facility" which was the point I was trying to make in my first post. If the buildings will be acting as one "facility" with shared egress componants and restrooms ect then I do not see how the aggregate portion would not be applicable


Exactly.  Fire separations are for fire...


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## Builder Bob (Oct 1, 2010)

http://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_03_15_04.pdf

I beleive that you may find a partial answer in this.... Just FYI (Yes I did go back and visit the dark side ------)


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## Builder Bob (Oct 1, 2010)

I think to clear up some of the confusion - Are the structures truly independent of each other without any common use areas?

Defined: Common Use.

Refers to those interior and exterior rooms, spaces, or elements that are made available for the use of a restricted group of people (for example, occupants of a homeless shelter, the occupants of an office building, or the guests of such occupants).

i.e. Restrooms located in one building so that the occupants of another building have to travel thru the other space to use the facilities?

The best way to look at a fire wall is that it may be used to create a separate building ---- It may also be used to create allowable building area for the type of construction (Area Separation Wall = UBC's ASW)

If a firewall is used and each space has it's own separate plumbing facilities, it own common use areas, etc. Then I believe it would be safe to assume that the two second floors would not be considered an aggregate area -(Based upon the interpretation of ICC posted previously)

I hope this helps... Good luck and let us know how it pans outs.

Builder bob


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## mark handler (Oct 1, 2010)

Builder Bob said:
			
		

> http://http://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_03_15_04.pdfI beleive that you may find a partial answer in this.... Just FYI (Yes I did go back and visit the dark side ------)


Link Broken....


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## Builder Bob (Oct 1, 2010)

Link Fixed --- Try it now...

http://www2.iccsafe.org/cs/committeeArea/pdf_file/BU_03_15_04.pdf


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## brudgers (Oct 1, 2010)

mtlogcabin said:
			
		

> Go back to the charging lanquage of 705701.1 Scope.
> 
> The provisions of this chapter shall govern the materials and assemblies used for structural fire resistance and fire-resistance-rated construction separation of adjacent spaces to safeguard against the spread of fire and smoke within a building and the spread of fire to or from buildings.
> 
> Chapter 7 provides a way to exceed the maximum area and height limits of Chapter 5 and are consider seperate buildings for that purpose only it can still be one "facility" which was the point I was trying to make in my first post. If the buildings will be acting as one "facility" with shared egress componants and restrooms ect then I do not see how the aggregate portion would not be applicable


ADAAG doesn't have the aggregate requirement.

The aggregate  only needs to be considered in terms of IBC compliance.

In other words, ADAAG allows two separate 3000 sf areas within a building which do not have vertical accessibility.

IBC does not allow that.

However, the division into buildings is based on the IBC, and under the IBC each building is allowed to have 3000 sf without vertical accessibility.

Now, without going to court, there isn't any way to say that the situation meets ADAAG, but on the face of things it appears to because ADAAG doesn't currently look at aggregate areas.

There is no basis for saying that despite resetting the allowable area a fire wall  does not reset the aggregate area without vertical accessibility and ADAAG is irrelevant to aggregate area requirements.


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## brudgers (Oct 1, 2010)

TJacobs said:
			
		

> Exactly.  Fire separations are for fire...


And firewalls create separate buildings.


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## Glennman CBO (Oct 1, 2010)

Very interesting Builder Bob. I thought this topic was over! I'll print that interp and pass it around.

From what I hear about the building, the firewall was built due to area limitations. Apperently, there are fire doors that connect the "facilities" within the (2) "halves" (if you will). Also, It may not be a "firewall", it could be a "fire barrier", since (as I've discovered since working in this jurisdiction) everyone here seems to use the term "firewall" in a sort of generic fashion. Everything is a "firewall", because people don't seem to understand that there is actually a defined difference in the walls that make up areas, or buildings, or what have you. A sad example is one of the inspectors required a 4 ft continuation of a "firewall" out over the side walk out side a strip mall because he didn't know the difference (it was actually a "fire barrier" wall. So, who knows what they actually have!

I'll be looking more into it on Monday. Have a good weekend!


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## mtlogcabin (Oct 2, 2010)

From what you described in the OP the fire wall may ahve been required because it was a stepped building See 705.6.1


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