# defining the 'work area'



## Mr Softy (Jul 10, 2011)

good morning all.

here's a question we're currently wrestling with in our office -

how extensively can the 'work area' be defined?  where does it end?

the issue at hand is the sprinkler requirements for residential multi-family buildings undergoing Level 2 Alterations as defined by IEBC 2009.

the specific case is this - a three family structure (typical triple-decker, three residential units stacked one on top of each other).  these are prime targets of developers looking to do a quick condo conversion.

the owner/contractor applies for a permit for gut rehabs of the kitchen and bathroom on all floors, with one wall being taken down (tripping Level 2).  by measuring square footage of these two rooms, they stay below the 50% of the floor area threshold for sprinkles.

but part of the project is installing replacement windows, and doing a sheetrock layover over all the existing walls and ceilings.

is it reasonable to interpret that the the work area has now extended throughout the unit? and the sprinkler requirement is met?

specific code section for sprinker requirements is 2009 IEBC 704.2.2

btw, first post - howdy everyone!


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## brudgers (Jul 10, 2011)

Would you require sprinklers for a straight out window replacement?

Would you require sprinklers for a layer of sheet rock?

If you would in both those cases then you are being consistent.

Otherwise, you're just abusing your power.


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## Mr Softy (Jul 10, 2011)

brudgers said:
			
		

> Would you require sprinklers for a straight out window replacement?Level 1
> 
> Would you require sprinklers for a layer of sheet rock?
> 
> ...


Level 1 work does not bring in the sprinkler requirement.

Level 2 with work on more than 50% of the floor area does.  removing a wall is Level 2 (any reconfiguration of space)

the question is - if there is work that is Level 2 , can one parse off the Level 1 work into a different work area and thus avoid the sprinkler requirement?


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## TimNY (Jul 10, 2011)

No, the level 2 work encompasses the entire area in which work is being performed.


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## mark handler (Jul 10, 2011)

IMHO the the work area is everywhere the work is, if it is the entire unit, it is the entire unit.

And they should not be able to "split" the permits over time to skip the requirements.


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## brudgers (Jul 11, 2011)

mark handler said:
			
		

> And they should not be able to "split" the permits over time to skip the requirements.


And why is that?

And have you ever tried to administer such a system across multiple owners?

And multiple editions of the code?


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## brudgers (Jul 11, 2011)

Mr Softy said:
			
		

> Level 1 work does not bring in the sprinkler requirement.Level 2 with work on more than 50% of the floor area does.  removing a wall is Level 2 (any reconfiguration of space)
> 
> the question is - if there is work that is Level 2 , can one parse off the Level 1 work into a different work area and thus avoid the sprinkler requirement?


Of course you can.

And why wouldn't you?


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## mtlogcabin (Jul 11, 2011)

You have to meet all 5 requirements before sprinklers are required

704.2.2 Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2.

In buildings with occupancies in Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where all of the following conditions occur:

1 It is an R-2. Yes then Sprinkler

2 Are the exits or corridors shared or have an Occupant load of over 30. No. Sprinklers not required

1. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction; Yes

2. The work area exceeds 50 percent of the floor area; and



3. The building has sufficient municipal water supply for design of a fire sprinkler system available to the floor without installation of a new fire pump. Is there water available at the floor (existing riser) if not sprinklers not required.


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## RJJ (Jul 11, 2011)

Agree with MT.


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## mark handler (Jul 11, 2011)

brudgers said:
			
		

> And why is that?


If you split the permits to circumvent the code, you might as well remove the all the scoping requirements of the code.


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## brudgers (Jul 11, 2011)

mark handler said:
			
		

> If you split the permits to circumvent the code, you might as well remove the all the scoping requirements of the code.


I can tell you love that theory.

Which explains why you didn't answer the tough questions.


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## mark handler (Jul 11, 2011)

_And have you ever tried to administer such a system across multiple owners?_

_ And multiple editions of the code? _

I am not, nor have I ever been, a member of a building department.

I have "administer(ed)" Many multi-year’d and multi-editions of the code for clients.

The state of California actually has a three year "cost" analysis for the 20 percent accessibility expenses.

This takes into account the past three years of permits on the property, not based on owners.


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## Mr Softy (Jul 11, 2011)

mark handler said:
			
		

> IMHO the the work area is everywhere the work is, if it is the entire unit, it is the entire unit.And they should not be able to "split" the permits over time to skip the requirements.


yup



			
				brudgers said:
			
		

> Of course you can.And why wouldn't you?


yup



			
				mark handler said:
			
		

> If you split the permits to circumvent the code, you might as well remove the all the scoping requirements of the code.


and yup.

it does seem that the loophole is there, big as day.  one guy gets the permit for the Level 2 kitchens and bath.  another gets a permit for Level 1 windows.  neither trips a sprinkler requirement.

anyone know of any official interps or appeal cases that address this?

we're inclined to call it all Level 2, and let them appeal.


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## ewenme (Jul 11, 2011)

I've been dealing with this issue in recent days: Level 2 in three units of a twelve-unit buildings, new roof, new windows, new siding, new interiors, new kitchen remodels, but 'it's really only a Level 1 in the overall weighting of things.' Their quote. If one takes the method of the architect, it's obvious that they aren't required to put in sprinklers. The question from the fire marshal was "if they do this same thing next year in 25% of the units, and the same thing the year after, we'll never get them to be sprinklered. Is that allowable?" Sounds like it's common to piece-meal stuff to be just outside the code requirements. It's the economy; the cost; the time; whatever other excuse, it's the camel putting his nose in the tent and then his shoulder, then... pretty soon the camel owns the tent.

OK. Getting off the soapbox. It is encouraging to see that others are having to deal with the same, and coming to the same conclusions. Thank you! And welcome to the Board, Mr. Softy. I used to love to go the Caravelle {sp} in New Jersey... greatest soft ice cream in the world!


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## mtlogcabin (Jul 11, 2011)

> The question from the fire marshal was "if they do this same thing next year in 25% of the units, and the same thing the year after, we'll never get them to be sprinklered. Is that allowable?"


Yes. The IEBC is not a retro code for sprinklers and no where is the amount of work cumulative over a period of time. If the fire marshal wants to get them sprinklered he needs to have a local ordinance that requires it.


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## mark handler (Jul 11, 2011)

Breaking down the project into smaller parts to circumvent the code is like breaking down the project into smaller parts so that a contractor's license is not required. The project should not be split in phases to circumvent the law.


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## Mr Softy (Jul 11, 2011)

well, here's something interesting -

IEBC Commentary.  Classification of Work.  404.2 Application for Level 2 Work.

it talks about Lev2 work including the provisions for Lev1 work, then...

"This requirement effectively compounds the requirements for someone planning to alter an existing structure.  For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"


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## brudgers (Jul 11, 2011)

mark handler said:
			
		

> _And have you ever tried to administer such a system across multiple owners?__ And multiple editions of the code? _
> 
> I am not, nor have I ever been, a member of a building department.
> 
> ...


Gee, you mean to tell me that multiple permits to avoid scoping requirements is actually codified in California?

I never would have guessed.

I would have guessed that you had never tried to enforce scope requirements across multiple projects however - you're comments pretty much gave it away.


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## brudgers (Jul 11, 2011)

ewenme said:
			
		

> "if they do this same thing next year in 25% of the units, and the same thing the year after, we'll never get them to be sprinklered. Is that allowable?"


In the absence of a law dictating otherwise yes.

And if the fire marshal doesn't like it, he should use the democratic process upon which our freedom relies to change the law.


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## brudgers (Jul 11, 2011)

mark handler said:
			
		

> Breaking down the project into smaller parts to circumvent the code is like breaking down the project into smaller parts so that a contractor's license is not required. The project should not be split in phases to circumvent the law.


There is no law which requires sprinklers.

There is a building code which requires sprinklers when certain thresholds are exceeded.

Structuring a project to avoid crossing those thresholds is perfectly legal and sound design.

Your argument is like saying because the speed limit on the street in front of your house is 25mph, the cop should ticket you as you pull into your driveway at the end of a 200 mile trip because your average speed was 50 mph during the four hours you were gone.

Apply the code as it is written.

Apply the law as it is written.

And live with it.


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## brudgers (Jul 11, 2011)

Mr Softy said:
			
		

> well, here's something interesting -IEBC Commentary.  Classification of Work.  404.2 Application for Level 2 Work.
> 
> it talks about Lev2 work including the provisions for Lev1 work, then...
> 
> "This requirement effectively compounds the requirements for someone planning to alter an existing structure.  For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"


The commentary is not the code.


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## Mr Softy (Jul 11, 2011)

brudgers said:
			
		

> The commentary is not the code.


this is right.

but it can give guidance to intent and enforcement.


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## mtlogcabin (Jul 11, 2011)

> "This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"


It is still one project and covering a window versus eliminating are not the same.


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## Mr Softy (Jul 11, 2011)

mtlogcabin said:
			
		

> It is still one project and covering a window versus eliminating are not the same.


they are exactly the same, in that the elimination or creation of one window classifies as Level 2 Alteration.

and going by the commentary, kicks the entire project into Level 2.


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## mark handler (Jul 11, 2011)

brudgers said:
			
		

> Apply the code as it is written. Apply the law as it is written. And live with it.


Live with it, are you saying that with a straight face

*When codes and or laws are wrong you change them; you don’t, Live with it.*

Live with it, is that what you said durring the civil right movement?

"Our country, right or wrong."  When right to be kept right; when wrong to be put right.  ~Carl Schurz


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## Yankee (Jul 11, 2011)

Set a time window for grouping projects as building department policy. It isn't only what is in the code book, it is also polices set by the building department in order to administrate the code. Aggrieved parties can go to the Building Code Board of Appeals as a method of keeping the building department from getting too big of a head. That's the way it works, , ,


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## mtlogcabin (Jul 11, 2011)

mark handler said:
			
		

> Live with it, are you saying that with a straight face*When codes and or laws are wrong you change them; you don’t, Live with it.*


Agree we can always work to change them but as a designer, builder or code official what is adopted is what we have to "live with" at the time a project is being designed and built.


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## Mr Softy (Jul 11, 2011)

Yankee said:
			
		

> Set a time window for grouping projects as building department policy.


that's creating code through policy.  definitely not allowed.  i wouldn't want to pitch that to an appeals board.

i'm not happy about brudgers' loophole, but i can see that it exists, and i don't see a way around it if one is going by the book.


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## Yankee (Jul 11, 2011)

Mr Softy said:
			
		

> that's creating code through policy.  definitely not allowed.  i wouldn't want to pitch that to an appeals board.i'm not happy about brudgers' loophole, but i can see that it exists, and i don't see a way around it if one is going by the book.


I believe it to be defensible. It is not creating code.


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## brudgers (Jul 11, 2011)

Mr Softy said:
			
		

> they are exactly the same, in that the elimination or creation of one window classifies as Level 2 Alteration.and going by the commentary, kicks the entire project into Level 2.


But in your project they are replacing windows - not making new ones or deleting existing ones.

I'll put it another way, plenty of jurisdictions don't even require a permit for size for size replacement and here you are talking about requiring an NFPA13r system, along with the flow and tamper hardwired to continuous monitoring.

Seriously, that's not the intent of the code.


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## brudgers (Jul 11, 2011)

mark handler said:
			
		

> Live with it, are you saying that with a straight face*When codes and or laws are wrong you change them; you don’t, Live with it.*
> 
> Live with it, is that what you said durring the civil right movement?
> 
> "Our country, right or wrong."  When right to be kept right; when wrong to be put right.  ~Carl Schurz


I'm inspired.


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## brudgers (Jul 11, 2011)

Yankee said:
			
		

> Set a time window for grouping projects as building department policy. It isn't only what is in the code book, it is also polices set by the building department in order to administrate the code. Aggrieved parties can go to the Building Code Board of Appeals as a method of keeping the building department from getting too big of a head. That's the way it works, , ,


 If I walked into a building department and they told me this was policy, my next stop would be the jurisdiction's legal department to ask if they had reviewed this policy.


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## TimNY (Jul 11, 2011)

They are replacing the windows, but the trigger for level 2 is the removal of a wall. If they replace all the windows, the work area is the entire building.

If they are sheetrocking all of the walls, the work area is the entire building.

Use discretion, BUT, the level 2 trigger doesn't seem so far fetched when they are replacing all windows, sheetrocking all walls, rehabbing all kitchens and baths..  Yes, it seems counter-intuitive that removing a single wall someplace would trigger a level 2 throughout.. but I believe that is where the code leads us.


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## Mr Softy (Jul 12, 2011)

brudgers said:
			
		

> But in your project they are replacing windows - not making new ones or deleting existing ones.I'll put it another way, plenty of jurisdictions don't even require a permit for size for size replacement and here you are talking about requiring an NFPA13r system, along with the flow and tamper hardwired to continuous monitoring.
> 
> Seriously, that's not the intent of the code.


if you are referring to my OP, window replacement is part of a larger renovation project involving the removal of walls.

the example given in the commentary would not trigger sprinklers.  the 'work area' has to be 50% of the floor area.

replacing windows alone, even if over the entire building, is still only Level 1 work.  no sprinkles.

i think the commentary's example is showing that any Level 2 work in a project escalates the entire project to Level 2.  i can work with that.

and...Massachusetts has required a building permit of replacement windows for over 10 years. their effeciency has been regulated by our energy conservation codes for that long.


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## Mr Softy (Jul 12, 2011)

brudgers said:
			
		

> If I walked into a building department and they told me this was policy, my next stop would be the jurisdiction's legal department to ask if they had reviewed this policy.


i agree with you on this.


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## brudgers (Jul 12, 2011)

TimNY said:
			
		

> They are replacing the windows, but the trigger for level 2 is the removal of a wall. If they replace all the windows, the work area is the entire building.If they are sheetrocking all of the walls, the work area is the entire building.
> 
> Use discretion, BUT, the level 2 trigger doesn't seem so far fetched when they are replacing all windows, sheetrocking all walls, rehabbing all kitchens and baths..  Yes, it seems counter-intuitive that removing a single wall someplace would trigger a level 2 throughout.. but I believe that is where the code leads us.


You can interpret it that way - or you can interpret it in a way which meets the intent of the code which is major changes to the configuration or use of a space trigger significant life-safety upgrade requirements and minor renovations do not.

The basic question is, because it is perfectly legal and eminently reasonable for the person to  phase the work across multiple permits so as to avoid a huge increase  in project scope, why are you trying to screw them with a questionable  code interpretation?

Or to put it another way, why are you inclined to interpret the code as if the public is your enemy?


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## Mr Softy (Jul 12, 2011)

it's not so much that the regulated community is the enemy.  the public is not my enemy, but i'm not their friend, either.  yes, my interp may be contrary to your interests, but *i *am the one who will have to answer for *my* decisions.

on borderline cases, no-one is going to be interested in my 'friendly' interpretation of the codes intent.

i agree with your statement about _major changes _triggering life safety upgrades.

my overall intent with this thread is to findout how others are interpreting 'work area' when it's getting real close to the 50% threshold.

.


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## brudgers (Jul 12, 2011)

Mr Softy said:
			
		

> it's not so much that the regulated community is the enemy.  the public is not my enemy, but i'm not their friend, either.  yes, my interp may be contrary to your interests, but *i *am the one who will have to answer for *my* decisions.


We used to call this "Inspector's Remorse."

At one time in the distant past the inspector convinced themselves that they missed something.

Now they decide to make up for it by over interpreting the code in what is often the most absurd way possible.

The main reason for this is that it is far easier than studying the code deeply and rendering tough decisions.

And by "tough decisions" I mean decisions which the inspector doesn't like but are correct and reasonable.

To put it another way, if it's close to the 50% work area but under it - the tough decision is to forgo finding excuses for judging it to be over 50%.

Rationalizing a different interpretation is really easy - which is why so many people do it.


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## Mr Softy (Jul 12, 2011)

i know from personal experience that i do not 'over-interpret the code in what is often the most absurd way possible'.

that's insulting to me, and most of the inspectors i know.

'The main reason for this is that it is far easier than studying the code deeply and rendering tough decisions.'

and this is even more insulting.

i'm all for debating this issue, and i don't disagree with a lot of what you're saying, but please stop with the condescension.

i will admit to being conservative in my interpretations, especially as regards fire safety.  as are most inspectors, i think.  we're the ones who have to defend our actions.



> To put it another way, if it's close to the 50% work area but under it - the tough decision is to forgo finding excuses for judging it to be over 50%.


yup, if it's under, it's under.  but when it's close, is there a defined way to determine where the line is?

ICC - in the commentary - has taken the position that any work performed in conjunction with Level 2 work, is also classified as Level 2.

and when the thresholds are met, the thresholds are met.

i have not seen any part of IEBC 704.2.2 which states 'at the inspectors discretion'.

the sharp contractor/owner/architect should recognize the loophole that's already been called out.

but if there is simultaneous Level 1 and Level 2 work, as a way of skirting fire protection requirements, i would be comfortable presenting a reasonable case that the work is conjoined as Level 2.


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## Mr Softy (Jul 12, 2011)

so the debate stays focused, here's the example i am making -

R-2 multi family, in this case, a triple decker.  like this -







egress stairs shared by more than one tenant.

developer is gut renovating kitchens and baths throughout (with removal of non-bearing partitions), approximately 35% of the floor area, per floor.  so far so good.  704.2.2 has not been met.

but the scope of work is going to include ceiling cans throughout the units, layover of sheetrock walls and ceilings, siding, insulation,  and let's throw in replacement windows throughout.

work is Level 2

R-2 requires sprinkles at 0 sq ft.

work is over 50% of floor

there is water available.


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## mtlogcabin (Jul 12, 2011)

It is not the code officials job to determine the method used. From what you described Chapter 3 would be the wise choice and no one is circumventing anything in the code. If windows are replaced they meet todays code, if a wall is removed it can't create a negative impact in the structure or egress. 

It is the designers/applicants choice as to what path they choose to be compliant. An inspectors job is to assure compliance with that method.

The hard part with the IEBC is a DP should be involved and they need to read and understand the code, most won't.  

101.5 Compliance methods.

The repair, alteration, change of occupancy, addition or relocation of all existing buildings shall comply with *one of the methods* listed in Sections 101.5.1 through 101.5.3 as selected by the applicant. Application of a method shall be the sole basis for assessing the compliance of work performed under a single permit unless otherwise approved by the code official. Sections 101.5.1 through 101.5.3 shall not be applied in combination with each other. Where this code requires consideration of the seismic-force-resisting system of an existing building subject to repair, alteration, change of occupancy, addition or relocation of existing buildings, the seismic evaluation and design shall be based on Section 101.5.4 regardless of which compliance method is used.

Exception: Subject to the approval of the code official, alterations complying with the laws in existence at the time the building or the affected portion of the building was built shall be considered in compliance with the provisions of this code unless the building is undergoing more than a limited structural alteration as defined in Section 807.4.3. New structural members added as part of the alteration shall comply with the International Building Code. Alterations of existing buildings in flood hazard areas shall comply with Section 601.3.

101.5.1 Prescriptive compliance method. 

Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

101.5.2 Work area compliance method.

Repairs , alterations , additions , changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 4 through 12 of this code shall be considered in compliance with the provisions of this code.

101.5.3 Performance compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 13 of this code shall be considered in compliance with the provisions of this code.


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## Mr Softy (Jul 12, 2011)

mtlogcabin said:
			
		

> 101.5.1 Prescriptive compliance method.
> 
> Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.


The Fire Code makes a number of presumptions about the required level of fire protection in existing buildings.

In my example, the Fire Code requires the building have standpipes. (IFC Table 4603.1, which requires standpipes in all occupancies except R3)

There are sprinkler requirements for Use Groups A & M.

So now the prescriptive method cannot be used.


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## mtlogcabin (Jul 12, 2011)

Chapter 3

I doubt the 3rd floor is over 50 feet above the level of fire department access so no standpipes are required

4603.5 Standpipes.

Existing structures with occupied floors located more than 50 feet (15 240 mm) above or below the lowest level of fire department vehicle access shall be equipped with standpipes installed in accordance with Section 905.


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## TimNY (Jul 12, 2011)

brudgers said:
			
		

> You can interpret it that way - or you can interpret it in a way which meets the intent of the code which is major changes to the configuration or use of a space trigger significant life-safety upgrade requirements and minor renovations do not.The basic question is, because it is perfectly legal and eminently reasonable for the person to  phase the work across multiple permits so as to avoid a huge increase  in project scope, why are you trying to screw them with a questionable  code interpretation?
> 
> Or to put it another way, why are you inclined to interpret the code as if the public is your enemy?


I'm sorry, I missed the part where I had a problem with phasing permits.

You submit a permit wanting to do a level 2, it's reviewed as level 2.  You want to complete part now, get a C.O and remove a wall later, go for it.

I said it before, I can't predict what an applicant will do in the future, and I don't inspect today based on what I think might happen tomorrow.

Not to say there is anything unlawful about a municipality creating a lookback period.  I don't think you could do it via policy, but via local law... NFIP encourages this.


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## brudgers (Jul 12, 2011)

Mr Softy said:
			
		

> i know from personal experience that i do not 'over-interpret the code in what is often the most absurd way possible'.that's insulting to me, and most of the inspectors i know.
> 
> 'The main reason for this is that it is far easier than studying the code deeply and rendering tough decisions.'
> 
> ...


They're meeting the code, not skirting requirements.

You read the code and didn't like what it said.

Hence, you're still digging for a way to make it over.

Which is why however insulted you feel, my analysis is still accurate.


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## mtlogcabin (Jul 12, 2011)

Mr Softy

Going back to our original post

"the owner/contractor applies for a permit for gut rehabs of the kitchen and bathroom on all floors, with one wall being taken down (tripping Level 2). by measuring square footage of these two rooms, they stay below the 50% of the floor area threshold for sprinkles".

Did the owner state on his application which level of compliance he choose or did the building department?

My question is who determined it was a Level I to begin with? If it is the building department then they are wrong. You can remodel 100% of the floor area under Option 1 and sprinklers are not required.

This code provides three main options for a designer in dealing with rehabilitation of existing buildings. These are laid out in Section 101.5 of this code:

OPTION 1: Work for alteration, repair, change of occupancy, addition or relocation of all existing buildings shall be done in accordance with the Prescriptive Compliance Method given in Chapter 3. It should be noted that this same method is provided in Chapter 34 of the International Building Code .

OPTION 2: Work for alteration, repair, change of occupancy, addition or relocation of all existing buildings shall be done in accordance with the Work Area Compliance Method given in Chapters 4 through 12.

OPTION 3: Work for alteration, repair, change of occupancy, addition or relocation of all existing buildings shall be done in accordance with the Performance Compliance Method given in Chapter 13. It should be noted that this option is also provided in Chapter 34 of the International Building Code .


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## TimNY (Jul 12, 2011)

*101.5.1 Prescriptive compliance method. *_Repairs, alterations, additions _and changes of occupancy complying with Chapter 3 of this code in buildings complying with the _International Fire Code_ shall be considered in compliance with the provisions of this code.

Option 1 isn't an option for all buildings.

However, point taken about who chose the route for compliance.  I am guilty doing the same thing.  I have never had a designer state what route they are using, I just get a set of plans.  I automatically review them based on the work classification method.

I should mark them "Designer to specify compliance route" and see what happens.


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## Mr Softy (Jul 12, 2011)

brudgers said:
			
		

> They're meeting the code, not skirting requirements._i never said they were skirting requirements__._
> 
> You read the code and didn't like what it said.
> 
> ...


you don't agree with my interpretation.  that's fine.

but sheesh, stop making ridiculous assumptions.


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## Mr Softy (Jul 12, 2011)

mtlogcabin said:
			
		

> Did the owner state on his application which level of compliance he choose or did the building department?


i have received 1 application since Feb where the DP chose Chap 3.

we adopted IEBC (with MA amendments)  in Feb, and nearly 6 months later most of the contractors still don't know that.

we've given out instructional material explaining the compliance paths and work levels with every application.

i had one contractor tell me he was doing Level 1, 2, and 3 work.  because he was working on all three floors.

so to answer your question, we've been assigning the Level of Work based on the application.

we've only just recently had two of these triple decker applications come in.


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## Mr Softy (Jul 12, 2011)

mtlogcabin said:
			
		

> Chapter 3I doubt the 3rd floor is over 50 feet above the level of fire department access so no standpipes are required
> 
> 4603.5 Standpipes.
> 
> Existing structures with occupied floors located more than 50 feet (15 240 mm) above or below the lowest level of fire department vehicle access shall be equipped with standpipes installed in accordance with Section 905.


oh well caught - thanks!


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## ICE (Jul 12, 2011)

Tall dogs and ice cream cones.  Who didn't see it coming?


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## brudgers (Jul 13, 2011)

Mr Softy said:
			
		

> approximately 35% of the floor area, per floor.  so far so good.  704.2.2 has not been met.but the scope of work is going to include ceiling cans throughout the units, layover of sheetrock walls and ceilings, siding, insulation,  and let's throw in replacement windows throughout.
> 
> work is Level 2
> 
> ...


6" cans have a projected floor area of 0.2 square feet each.

5/8" sheet rock has a floor area of 0.052 square feet per linear foot.

A 36" window with an 8" stool has a projected floor area of 2 square feet.

400 lineal feet of drywall + 10 windows + 50 cans = 50 square feet of floor area.

If the floors are larger than 334 square feet, that's less than 15% of the floor area.

Since the floors look more like 2000 sf, to get an additional 15% of floor area from those components you are talking about something like 2400 lf of drywall + 60 windows + 300 cans *per floor*.

For those scoring at home, that's 7200 lf drywall (57,000 square feet assuming 8' ceilings) + 180 windows + 900 cans (an electrical service upgrade should be considered) *for the building*.*

Just to get the additional 15%.

Of course, it's not likely you're interested in actually approving the plans given that your argument hinges on the absurdity that 35% is close to 50%.

[Edit] *A structural system upgrade might also be necessary as the 480 sheets of drywall will add an additional 33kips of load to the foundation.


----------



## Mr Softy (Jul 13, 2011)

brudgers said:
			
		

> 6" cans have a projected floor area of 0.2 square feet each.5/8" sheet rock has a floor area of 0.052 square feet per linear foot.
> 
> A 36" window with an 8" stool has a projected floor area of 2 square feet.
> 
> ...


see, that's better.

rather than just over-interpreting these posts to an absurd level because it's easier than actually reading the posts, you took time to make a reasonable point.

i don't disagree with your measurements.

what i'm curious about has there ben any interps or appeals based upon measuring in such a way?

however a 6" can has an actual area of 4 sq ft after one is done making the hole it will sit in, and treating that opening, both for fire separation and sound tranmittal.  and i suppose one could say that the area required for an electrician to set up and install that can gets even larger.  the spread for a 6' step ladder probably adds another 8' to the equation.

let's keep playing


----------



## rooster (Jul 13, 2011)

Mr Softy said:
			
		

> ICC - in the commentary - has taken the position that any work performed in conjunction with Level 2 work, is also classified as Level 2.
> 
> and when the thresholds are met, the thresholds are met.
> 
> ...


----------



## rooster (Jul 13, 2011)

by the way.  why is this project still level 2?  If you've determined the the work area to be over 50%, then it's a level 3.


----------



## Mr Softy (Jul 13, 2011)

rooster said:
			
		

> But if you can direct me to the section where it says Level 2 swallows up Level 1 and now it's all in the _work area_ I will reconsider.


IEBC Commentary. Ch 4 Classification of Work. 404.2 Application for Level 2 Work.

it talks about Lev2 work including the provisions for Lev1 work, then...

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"


----------



## Mr Softy (Jul 13, 2011)

rooster said:
			
		

> by the way.  why is this project still level 2?  If you've determined the the work area to be over 50%, then it's a level 3.


yes, and that kicks back to 704.2.2 for the FP thresholds


----------



## rooster (Jul 13, 2011)

Mr Softy said:
			
		

> IEBC Commentary. Ch 4 Classification of Work. 404.2 Application for Level 2 Work.it talks about Lev2 work including the provisions for Lev1 work, then...
> 
> "This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"


But I do not see anything about "work area."  from 704.2.2 - 2. _*The work area exceeds 50 percent of the floor area;*_

And according to the definition of "work area" (given abv), this would be where the spaces are reconfigured.  Not every place you are doing work.


----------



## rooster (Jul 13, 2011)

Mr Softy said:
			
		

> yes, and that kicks back to 704.2.2 for the FP thresholds


So a project that replaces drywall and demo's one partition is considered a level 3?  I'm not saying this is exactly your situation, but it could happen.  And it just doesn't seem like the intent of the code.


----------



## brudgers (Jul 13, 2011)

rooster said:
			
		

> So a project that replaces drywall and demo's one partition is considered a level 3?  I'm not saying this is exactly your situation, but it could happen.  And it just doesn't seem like the intent of the code.


You don't even need to demo drywall, just paint the existing and someone will claim the work area is 100% - see reference to ladders below.


----------



## Mr Softy (Jul 13, 2011)

rooster said:
			
		

> But I do not see anything about "work area."  from 704.2.2 - 2. _*The work area exceeds 50 percent of the floor area;*_  And according to the definition of "work area" (given abv), this would be where the spaces are reconfigured.  Not every place you are doing work.


well, that's the problem.  what is "work area"?

by the commentary, it appears that work area is compounded and it becomes everywhere you are doing work.  some Level 2 work kicks an entire project into Level 2.



			
				rooster said:
			
		

> So a project that replaces drywall and demo's one partition is considered a level 3?  I'm not saying this is exactly your situation, but it could happen.  And it just doesn't seem like the intent of the code.


it would be Level 3 if it is over 50% of building area.  again, usingh the commentary's position that work area compounds.

as brudgers as pointed out earlier (when not being absurd), work major in scope should be what triggers FP requirements, not an arbitrary 50% work area number.  as demonstrated, it is nearly impossible to determine where that figure lies - it depends who is measuring.   so the 'intent' is becomes very difficult to discern.

however even a term like 'major in scope ' becomes a moving target.  we had a substantial renovation definition that hinged on cost of project vs. cost of sprinkler system.  but the state folks really wanted to go with the ICC family of codes.  so here we are trying to determine the intent of 'work area'.



			
				brudgers said:
			
		

> You don't even need to demo drywall, just paint the existing and someone will claim the work area is 100% - see reference to ladders below.


you're funny.


----------



## rooster (Jul 13, 2011)

Earlier you posted this commentary.

_"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"_

My question is this: How do you explain the defnition of Work Area in chapter 2?  I'm genuinely interested in this because this situation is on my table now.

Below is another part of the code and commentary which tells you to look at the definition of work area in chapter 2.  And further more, I can't base my decision on an interpretation of the commentary.  I need a number.

SECTION 405

ALTERATION—LEVEL 3

405.1 Scope. Level 3 alterations apply where the work area

exceeds 50 percent of the aggregate area of the building.

commentary

_Anytime the project area, as defined in Section 202,_

_exceeds one-half of the aggregate building area, it is_

_considered to be a Level 3 alteration and, therefore,_

_has to meet the requirements of Chapter 8. In the_

_code, a work area encompasses all portions of the existing_

_building that are proposed to be reconfigured._

Where does it say that if the Level 2 work exceeds 50%, then it's a level 3?


----------



## rooster (Jul 14, 2011)

OK, I was thinking about this a little last night and thought of a situation:

With Mr. Softy's interpretation of the code, you could potentially have a project with a total reconfiguration of space in 49% of the building, but it would not require sprinklers.  We're talking a total blow out of walls with no spaces even close to what they were before the alteration...in almost half of the building...no sprinklers.

Now to the other extreme...

You could have a project that merely replaces ceiling tiles thoughout and closes up one window in a remote room, and now you will need sprinklers.  Not only that, but this project is now a level 3 alteration, so it would have to comply with all three chapters.

It just doesn't make sense.  How could the second situation be a higher level alteration?

But when I read the definition of work area, then it seems clearer that this is not the intention.  I still haven't found where "level 2 work" = "work area."  If I find this equation, then I'll reconsider.  One can make the assumption that wherever you are doing work, it is the work area...but the definition of work area does not say this.


----------



## TimNY (Jul 14, 2011)

That's why the performance-based option exists.

The work area option exists as a simple way to classify the scope of the work and mandate required improvements in association with that work.  It is a good choice for a simple project, such as making changes to a single room.  The work area option is not well suited to all projects.

When the project gets more complicated, you could choose the work area option, but as you noted, it will not make sense in some scenarios.  Construction will be significantly easier if the performance-based method is used.


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> OK, I was thinking about this a little last night and thought of a situation:With Mr. Softy's interpretation of the code, you could potentially have a project with a total reconfiguration of space in 49% of the building, but it would not require sprinklers.  We're talking a total blow out of walls with no spaces even close to what they were before the alteration...in almost half of the building...no sprinklers.
> 
> Now to the other extreme...
> 
> ...


by the definition of the levels of work, it is conceivable that an owner could do a gut renivation of an R-2, but with no reconfiguration of space, and not trigger any sprinkler requirements.

the bit of text i quoted from the commentary gives a bit of insight into the intent of the written code.  ICC has stated that any level 2 work as part of a larger project, puts the entire project into the level 2 category.  now i can see where this language can be interpretted to one's advantage and disandvantage (and that woud be for both sides of the counter).

your example is a great example of this.  yes, once you close up the wall, by the IEBC, the project becomes Level 2 work.

we used to have language (through case law) that required the feasablity of sprinkler installation as part of the project.  f'rinstance, an expensive renovation that could have reached a monetary threshold, but didn't include deomlition of walls and ceilings, would not facilitate the installation of a system.  so a system would not be required.

this new work area thing is not easy because the ICC has not clearly defined what work area is.

is it the strictest limitation of the area undergoing change, as brudgers has argued, or is it the net area where work is happening?


----------



## TimNY (Jul 14, 2011)

One of us could get off our butt and just ask the ICC..

Single building divided into two spaces, lets say a 4000sf space and a 6000sf space.  The 4000sf space wants to move the single dividing wall so they now have 4500sf.  Is this level 2 or level 3?

Same scenario, the 6000sf space wants to move the wall to reduce their space to 5500sf.  Level 2 or Level 3?

We can "what if" this all day long.  In the end a little discretion is warranted for simple projects..  For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.


----------



## Mr Softy (Jul 14, 2011)

TimNY said:
			
		

> One of us could get off our butt and just ask the ICC..Single building divided into two spaces, lets say a 4000sf space and a 6000sf space.  The 4000sf space wants to move the single dividing wall so they now have 4500sf.  Is this level 2 or level 3?
> 
> Same scenario, the 6000sf space wants to move the wall to reduce their space to 5500sf.  Level 2 or Level 3?
> 
> We can "what if" this all day long.  In the end a little discretion is warranted for simple projects..  For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.


my take -

both scenarios are Level 2 work.  reconfiguration of space.

it's the extent of associated work that makes it difficult.

if only the wall is being moved and then finishes around the wall completed, i don't see where the 50% threshold is met.

but if the wall is moved and a complete renovation of half the building, then maybe the 50% has been met.


----------



## TimNY (Jul 14, 2011)

My take: Level 3.

*WORK AREA.* That portion or portions of a building consisting of all reconfigured spaces...

Is space 1 reconfigured? Yes.  Is space 2 reconfigured? Yes.  Work area is 100%.

Would the requirements imposed by a Level 3 throughout be unreasonable? Yes.

Could you use the performace-based method and make life much easier? Absolutely!

(edit: we do have to stipulate these are the only 2 spaces in the building for this to work [i know somebody would nitpick this   ])


----------



## brudgers (Jul 14, 2011)

Mr Softy said:
			
		

> the bit of text i quoted from the commentary gives a bit of insight into the intent of the written code.


It doesn't give insight into the intent of the code.

It gives one interpretation of the section.

As this board has shown, these interpretations are often flat out wrong.

Indeed the definition of work area shows that the interpretation which you cite is inconsistent with other sections of the code - and with that other section being more specific, it is quite clear that the interpretation is incorrect and not based on a deep understanding of the code.

Keep in mind that the commentary is something which the ICC does to check off their bucket list - as suggested by the fact that it is longer than the code itself, it is obviously not built upon broad consensus, i.e. compare it to the brevity of the Annex to NFPA 101.


----------



## rooster (Jul 14, 2011)

TimNY said:
			
		

> We can "what if" this all day long.  In the end a little discretion is warranted for simple projects..  For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.


You are right.  I haven't spent enough time with the performance based method, but it seems a bit excessive for the example of replacing ceiling tiles and closing up a window.  Furthermore it seems that given the example of of the ceiling tiles / closing a window, the work area option works just fine.  You simply call your alteration a level 2 and then mark the reconfigured space (the room with the closed window) on the plan and call it a day.  As long as that work area doesn't exceed 50%, then what's the problem?  It seems to me that the intent of the code is to make sure that space is still safe once the window is removed...not to trigger your whole project into a level 3 situation.  I don't know, unless I'm missing something.

And you are also right that we could what if all day long.  And I would have to agree with you that by definition of work area, your example would be a level 3.


----------



## mtlogcabin (Jul 14, 2011)

Here is a link based on the 2003 edition stating if water is not available at the floor then sprinklers are not required. They did not include R occupancies in the question because there was an exception in the section for R occupancies 3 stories or less.

http://www2.iccsafe.org/cs/committeeArea/pdf_file/EB_03_12_04.pdf


----------



## Mr Softy (Jul 14, 2011)

brudgers said:
			
		

> It doesn't give insight into the intent of the code.It gives one interpretation of the section.
> 
> As this board has shown, these interpretations are often flat out wrong.


that's rich.

so you're saying the ICC interp of the ICC code is flat out wrong?


----------



## rooster (Jul 14, 2011)

Mr Softy said:
			
		

> well, that's the problem.  what is "work area"?


You keep saying the ICC does not clearly define "work area".  But it does, and I've referred to it now multiple times.  Here it is again:

WORKAREA. That portion or portions of a building consisting

of all reconfigured spaces as indicated on the construction

documents. Work area excludes other portions of the building

where incidental work entailed by the intended work must be

performed and portions of the building wherework not initially

intended by the owner is specifically required by this code.

Now if you take this definition and apply it to the project in question, I believe you'll find your answer, and from the sounds of it, the work area will be 35% (from previous post).  Yes, work is going on in all parts of the building...and yes all that work is now Level 2, but this definition of "work area" given by the ICC does not tell you to take them into account.  If you decide to include all that work as the work area, I don't believe you are following the code.  And a commentary won't cut it...which by the way doesn't even mention the word "work area."


----------



## texasbo (Jul 14, 2011)

Mr Softy said:
			
		

> brudgers...but sheesh, stop making ridiculous assumptions.


You're new 'round these parts, huh? Your request would constitute a Level 10 Alteration...


----------



## texasbo (Jul 14, 2011)

Mr Softy said:
			
		

> that's rich.so you're saying the ICC interp of the ICC code is flat out wrong?


Actually, I disagree with you on this one; who writes the code? We do. ICC just publishes it. Then they hire some people to interpret it. There is nothing magical about these people, and there is nothing magical about ICC's sanction of their interpretation. I don't care about ICC's interpretation; I care about mine. And I also care about the interpretation of some of the very smart code people I know, including many on this forum. You never know what you're getting on the other end of an ICC interp. It may be very good, and it may not...


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> Now if you take this definition and apply it to the project in question, I believe you'll find your answer, and from the sounds of it, the work area will be 35% (from previous post).  Yes, work is going on in all parts of the building...and yes all that work is now Level 2, but this definition of "work area" given by the ICC does not tell you to take them into account.


it may not tell you to include it, but it also does not say to not include it.

the only thing specifically not included is incedental work areas and areas where the code may require upgrades.


----------



## brudgers (Jul 14, 2011)

Mr Softy said:
			
		

> that's rich.so you're saying the ICC interp of the ICC code is flat out wrong?


I am saying that the ICC interpretation is an interpretation and subject to error - it is not the committee's interpretation but that of some author who was hired to interpret the entire fricken code.

And yes, it is often incorrect (as in this case if the citations by other posters are correct) where it ignores the definition of work area.

I'll point out, that if the ICC interpreted the code in ways in which those people who require interpretations did not like, the ICC would generate less revenue.


----------



## brudgers (Jul 14, 2011)

Mr Softy said:
			
		

> it may not tell you to include it, but it also does not say to not include it.the only thing specifically not included is incedental work areas and areas where the code may require upgrades.


Getting interpretations you don't like, are you?

Hmmm....


----------



## Mr Softy (Jul 14, 2011)

for the record.

what we are requiring of contractors is a drawing in the plan set that clearly defines the work area.  and square foot calculations indicationg the ratio of work area to total area.

(as i stated earlier, i have only had one application where the contractor opted for Chap 3.)

we've had two similar R-2 projects come in in which the scope is demo and rehab of kitchens and baths.  works out to be about 25% of the floor area.  we notify the contractors about expansion of work area.

we have had one R-2 project where the scope was minimal at first, but mushroomed into major renovations including extensive layout changes throughout (Level 2 into Level 3).  on this one we required compliance with the sprinkler requirements of 704.2.2.


----------



## Mr Softy (Jul 14, 2011)

brudgers said:
			
		

> Getting interpretations you don't like, are you?Hmmm....


i would ask you the same question.


----------



## rooster (Jul 14, 2011)

Mr Softy said:
			
		

> i would ask you the same question.


Once owners find out their modest rehab project sky-rockets into major renovations, don't be surprised when they phase projects to skirt _your _requirements.

I'm not concerned with what the code doesn't say...only with what it says.  You can't add things in.  If it said "where ANY work is being done"  then I would consider all work being done.  But it specifically says reconfigured spaces.

And for the record, I don't believe the commentary you referred to is inaccurate, I just don't think it has to do with work area.


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> Once owners find out their modest rehab project sky-rockets into major renovations, don't be surprised when they phase projects to skirt _your _requirements.


they're not _my_ requirements.  they're the requirements of major renovations.

i'm talking about expanded scope that sure looks like major renovations (and i think we can all say that we know that when we see it).

IEBC leaves a big grey area in the middle between where you obviously don't need FP upgrades and where you do.  all they reference is a sq ft number and it doesn't address scope.  nor does it talk about parsing off Lev 1 from Lev 2.  on the contary it seems they go the other way.

we're searching for something enforcable and consistent.


----------



## rooster (Jul 14, 2011)

Mr Softy said:
			
		

> they're not _my_ requirements.  they're the requirements of major renovations.i'm talking about expanded scope that sure looks like major renovations (and i think we can all say that we know that when we see it).
> 
> IEBC leaves a big grey area in the middle between where you obviously don't need FP upgrades and where you do.  all they reference is a sq ft number and it doesn't address scope.  nor does it talk about parsing off Lev 1 from Lev 2.  on the contary it seems they go the other way.
> 
> we're searching for something enforcable and consistent.


I see no reference in the code to "major renovation."  Therefore I cannot comment on what one looks like nor the IEBC requirements for "major renovations."


----------



## rooster (Jul 14, 2011)

Ok, I reread the commentary you refer to, and I don't know whether it is consistent with the code.

404.2 Application. Level 2 alterations shall comply with the

provisions of Chapter 6 for Level 1 alterations as well as the

provisions of Chapter 7.

I'm still looking to see where the code says once you're in level 2, everything is a level 2.


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> I see no reference in the code to "major renovation."  Therefore I cannot comment on what one looks like nor the IEBC requirements for "major renovations."


i didn't refer to any code reference for 'major renovation'.  real world scope of work, independent of any concept of 'work area'.

but anyway, let me get this straight -

when you walk onto a jobsite, you have no clue whether you're looking at major work or minor work?


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> Ok, I reread the commentary you refer to, and I don't know whether it is consistent with the code.404.2 Application. Level 2 alterations shall comply with the
> 
> provisions of Chapter 6 for Level 1 alterations as well as the
> 
> ...


Here's the commentary language -

"*This requirement effectively compounds the requirements* for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"

that's how i read the first (bolded) phrase.

here i've changed the example, but the code effect would stay the same.

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing horsehair plaster with blueboard, the building owner decides to remove one wall within a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"

redoing the wall covering would be Level 1 work - changing a system.  The removal of a wall would be Level 2.  ICC compounds the work into Level 2.


----------



## brudgers (Jul 14, 2011)

Mr Softy said:
			
		

> we're searching for something enforcable and consistent.


Tellingly, correct doesn't enter into the equation.

Neither does reasonable.

Or cost-effective for that matter.

The beauty of the building department is that so long as you are consistent you are covered.

Even when you are wrong.

On the other hand, being personally responsible, I have to get it right.


----------



## mtlogcabin (Jul 14, 2011)

Mr Softy said:
			
		

> i have received 1 application since Feb where the DP chose Chap 3.we adopted IEBC (with MA amendments) in Feb, and nearly 6 months later most of the contractors still don't know that.
> 
> we've given out instructional material explaining the compliance paths and work levels with every application.
> 
> ...


Then the building department is wrong and acting as the DP on the project. You may be requiring them to spend more money then required to be code compliant. The DP's and builders will never learn a new code unless they are made to. The project can sit in the plan review stage untill the cows come home if it isn't right. I am sure you would not issue a permit for new construction under the building code without the design information on them. IEBC 101.5 requires the design/compliance method being used to be identified and shown. Once the Prescriptive or Work Area or Performance compliance method is choosen that is the one that is used. You do not mixed the requirments to require compliance. What was described in your OP can easily be achieved through Chapter 3


----------



## Mr Softy (Jul 14, 2011)

mtlogcabin said:
			
		

> Then the building department is wrong and acting as the DP on the project.


not really.  the work is what it is.

and the design team can certainly choose Chap 3.  now, if they don't know Chap 3...


----------



## Mr Softy (Jul 14, 2011)

brudgers said:
			
		

> Tellingly, correct doesn't enter into the equation.Neither does reasonable.
> 
> Or cost-effective for that matter.
> 
> ...


well, as correct as can be. 

and reasonable only to a degree.  I prefer to err on the side of too conservative or too literal, and let a discussion with the appeals board sort everything out.  'reasonable' often has the potential to get me in BIG trouble.

we try not to be 'wrong', but on your side of the counter it may not be seen as right.  but we try, and we remain open to alternate interpretations.


----------



## brudgers (Jul 14, 2011)

Mr Softy said:
			
		

> I prefer to err on the side of too conservative or too literal, and let a discussion with the appeals board sort everything out.  'reasonable' often has the potential to get me in BIG trouble.


I can tell that you prefer to err.

It comes with having someone else to ultimately take responsibility for getting it right.

The "You can always appeal" my decision approach, is what I call "holding the permit hostage."

Like Inspector's remorse, it is another common practice with code officials.


----------



## Mr Softy (Jul 14, 2011)

i wish i could be as perfect as you.

i have no remorse.

and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.

but don't ask me to be liberal with the egress regs or the FP regs.  you don't like my conservative approach - appeal it.  i will have code on my side, and will make an cogent argument to back my position.

what will your pitch be?  'waaaa, it's too hard, it's not fair'?


----------



## rooster (Jul 14, 2011)

Mr Softy said:
			
		

> i wish i could be as perfect as you.i have no remorse.
> 
> and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.
> 
> ...


I'm still waiting to see what part of the code you're hanging your hat on.


----------



## rooster (Jul 14, 2011)

Mr Softy said:
			
		

> i didn't refer to any code reference for 'major renovation'.  real world scope of work, independent of any concept of 'work area'.but anyway, let me get this straight -
> 
> when you walk onto a jobsite, you have no clue whether you're looking at major work or minor work?


I don't care if the entire bulding is enveloped in a cloud of plaster dust while the interior is nothing but the air between the studs.  As long as no spaces are getting reconfigured, it's a level 1.  It looks pretty major, but the code says it's level 1.


----------



## Mr Softy (Jul 14, 2011)

rooster said:
			
		

> I don't care if the entire bulding is enveloped in a cloud of plaster dust while the interior is nothing but the air between the studs.  As long as no spaces are getting reconfigured, it's a level 1.  It looks pretty major, but the code says it's level 1.


absolutely.  no disagreement.  and i couldn't and wouldn't call it anything else.

(as an aside, when we were talking about adoption of IEBC, this scenario came up.  but none of us had ever seen such a project.  in our experiences, there is always reconfiguration of space. )

for me, it's a disconnect in the code that such a project which is certainly major in scope, and offering the ideal conditions for installation of a sprinkler system, could not require a FP upgrade, yet a marginal Level 2 project could.


----------



## brudgers (Jul 15, 2011)

Mr Softy said:
			
		

> i wish i could be as perfect as you.i have no remorse.
> 
> and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.
> 
> ...


Whine, hardly.

My preferred approach starts with burying unreasonable bureaucrats in paper and dragging them to endless meetings to work things out - which of course I follow up with...you guessed it, more paper.

When the correspondence gets to be about 1/2" thick and there are a dozen or so written communications to which the bureaucrat has not responded - I stick it in envelope with a cover letter to the city attorney.

It's the counter punch to your "hold the permit hostage" strategy - create an unexpected amount of friction from unexpected sources by creating an unexpected paper trail.

Getting inside a decision loop like yours is trivial.

OODA [http://en.wikipedia.org/wiki/OODA_loop]


----------



## brudgers (Jul 15, 2011)

Mr Softy said:
			
		

> for me, it's a disconnect in the code that such a project which is certainly major in scope, and offering the ideal conditions for installation of a sprinkler system, could not require a FP upgrade, yet a marginal Level 2 project could.


You're pushing an agenda which goes beyond code requirements.

And treating the building code like mere suggestions in the process.

As it has become apparent, making something up and holding the permit hostage when the code doesn't say what you want it to say appears to be your M.O.


----------



## rooster (Jul 15, 2011)

Mr Softy said:
			
		

> Here's the commentary language - "*This requirement effectively compounds the requirements* for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"
> 
> that's how i read the first (bolded) phrase.
> 
> ...


I'm going to go at this from one other direction.  I've hung in here to see if maybe there was a flaw in my logic, but so far I'm satisfied.

Below is the scope of a level 3 alteration.  If you interpret the code the way are doing, then level 2 doesn't even have to come into play whatsoever.  An owner could simply be replacing ceiling tiles 100% and this would kick it into a level 3 because you are considering ALL the work to be the work area, where as the definition of work area does not consider ALL the work.  If you want to be consistent, then you'll have to require sprinkler for this job that is replacing ceiling tile only...not just the job that is tearing down plaster and replacing drywall.

SECTION 405

 ALTERATION—LEVEL 3

 405.1 Scope. Level 3 alterations apply where the work area

 exceeds 50 percent of the aggregate area of the building.

commentary

 Anytime the project area, as defined in Section 202,

 exceeds one-half of the aggregate building area, it is

 considered to be a Level 3 alteration and, therefore,

 has to meet the requirements of Chapter 8. In the

 code, a work area encompasses all portions of the existing

 building that are proposed to be reconfigured.


----------



## rooster (Jul 15, 2011)

On the flip side, if you look at the work area as it is defined, I believe you'll find there is a greater opportunity to be consistent, as level 1 alterations will never be triggered into a level 3, and you won't have one window elimination triggering a level 3.

To put it another way, if you require sprinklers in this project (assuming we're stinking with the work area option), then you'll have to require them for every level 1 project that exceeds 50% of the building...reconfiguration or not.


----------



## Mr Softy (Jul 15, 2011)

rooster, i follow you argument to a point.

i might argue that to get to Level 3, Level 2 work must be part of the equation.  Level 1 cannot go direct to Level 3 otherwise.

the ceiling tile example, while building wide, would still be only Level 1.



> Below is the scope of a level 3 alteration. If you interpret the code the way are doing, then level 2 doesn't even have to come into play whatsoever. An owner could simply be replacing ceiling tiles 100% and this would kick it into a level 3 because you are considering ALL the work to be the work area, where as the definition of work area does not consider ALL the work. If you want to be consistent, then you'll have to require sprinkler for this job that is replacing ceiling tile only...not just the job that is tearing down plaster and replacing drywall.SECTION 405
> 
> ALTERATION—LEVEL 3
> 
> ...


last phrase - proposed to be *reconfigured* - there's your Level 2 work escalating to Level 3.

and the first phrase - project area - introduces a term that isn't defined.


----------



## Mr Softy (Jul 15, 2011)

brudgers said:
			
		

> Whine, hardly.My preferred approach starts with burying unreasonable bureaucrats in paper and dragging them to endless meetings to work things out - which of course I follow up with...you guessed it, more paper.
> 
> When the correspondence gets to be about 1/2" thick and there are a dozen or so written communications to which the bureaucrat has not responded - I stick it in envelope with a cover letter to the city attorney.
> 
> ...


i'm not surprised your projects take forever. :banghd



			
				brudgers said:
			
		

> As it has become apparent, making something up and holding the permit hostage when the code doesn't say what you want it to say appears to be your M.O.


wow.

how do you klnow my M.O.?  what projects have we worked on together? please tell me i'm anxious to know.



			
				brudgers said:
			
		

> You're pushing an agenda which goes beyond code requirements.


you dealt with the local Fire Department lately?

I work under the aegis of the Dept of Public Safety, not the Dept of Making it Easy for Architects.

this is my last correspondence with you.

thank you for playing, we have some lovely parting gifts.


----------



## rooster (Jul 15, 2011)

Mr Softy said:
			
		

> rooster, i follow you argument to a point.i might argue that to get to Level 3, Level 2 work must be part of the equation.  Level 1 cannot go direct to Level 3 otherwise.


Where does the code say this?


----------



## rooster (Jul 15, 2011)

Mr Softy said:
			
		

> the ceiling tile example, while building wide, would still be only Level 1.
> 
> last phrase - proposed to be *reconfigured* - there's your Level 2 work escalating to Level 3.
> 
> and the first phrase - project area - introduces a term that isn't defined.


Yes!  reconfigured spaces.  No where in the code does it say what level this work is or has to be.  Only that it is reconfigured.

If I look only at the scope of level 3 alteration below I will find nothing that gives me the idea that Level 2 must be reached first...I find only that I need to figure out what the work area is, which fortunately is defined in Chapter 2... where there is a definition that makes no reference to reaching certain levels of alteration.

SECTION 405

 ALTERATION—LEVEL 3

 405.1 Scope. Level 3 alterations apply where the work area

 exceeds 50 percent of the aggregate area of the building.


----------



## Mr Softy (Jul 15, 2011)

801.2  Compliance - In addition to the provisions of this chapter, work shall comply with all the requirements of Chaps 6 and 7.

my read is that if you hit Level 3, compliance with 2 and 1 are required as well. but to be in Level 2 requires reconfiguration.  no reconfiguration, no Level 2 and then no Level 3.

or.

as it requires compliance with Chap 7, as long as there is no reconfiguration, one can say no compliance with Chap 7 required.  and as the FP requirements live in Chap 7, level 3 work that involves no reconfiguration dooes not trigger FP requirements.


----------



## TimNY (Jul 15, 2011)

A quick scan of the Level 1 Alteration chapter does not use the word "WORK AREA".

Yet another angle.. You have Level 1 work going in a space; pick your favorite 1000sf commercial space.  It could be a ballroom in hotel, or a retail store.

The designer decides to make a Level 2 alteration;  remove a window, remove a door, add a wall, whatever.

What is the work area for the Level 2 alteration?  Does it include the space (part of it, all of it) that is a Level 1 alteration?

If the work area now includes the space (part, all) that was a Level 1 alteration, what rules do you apply?

The work area has to be limited in some fashion.  Is it a wall?  Is it an imaginary line?  Is it the projected line of a window sill?


----------



## Mr Softy (Jul 15, 2011)

Tim, this is exactly the question.


----------



## rooster (Jul 15, 2011)

Mr Softy said:
			
		

> Tim, this is exactly the question.


Are you serious?  You want to go back to the beginning?  Your question was to define "work area" and that definition is supplied by the code.  Now if you want to argue about what consitutes a reconfigured space, then that's a whole other issue altogether.

cock-a-doodle-do...over & out.


----------



## Mr Softy (Jul 15, 2011)

rooster said:
			
		

> Are you serious?  You want to go back to the beginning?  Your question was to define "work area" and that definition is supplied by the code.  Now if you want to argue about what consitutes a reconfigured space, then that's a whole other issue altogether.  cock-a-doodle-do...over & out.


alright alright  that was the question 

but it is still the thing we are wrestling with -

where is the line between reconfigured space and the work area?  is there a line?  can there be a lilne?  should there be line?

after 6 pages Tim still doesn't see an answer, and neither do i.

there seems to be nothing in the code that sets it out either.


----------



## rooster (Jul 15, 2011)

Mr Softy said:
			
		

> alright alright  that was the question but it is still the thing we are wrestling with -
> 
> *where is the line between reconfigured space and the work area?  is there a line?  can there be a lilne?  should there be line?*
> 
> ...


OK, I can't resist.  According to the definition of work area there is no line...WORK AREA = RECONFIGURED SPACE...simple as that.  There can't be a line between them, because they are one in the same.  If the code wants to include more than the reconfigured spaces into the work area, it needs to tell me that.


----------



## brudgers (Jul 15, 2011)

Mr Softy said:
			
		

> i'm not surprised your projects take forever. :banghd


As if further evidence that you rely on holding the permit hostage to your made up requirements was needed.



			
				Mr Softy said:
			
		

> you dealt with the local Fire Department lately?


Of course.

And unsurprisingly, they don't have carte blanche to make stuff up.

Even when they think they do.

As any city attorney will tell you.


----------



## mtlogcabin (Jul 15, 2011)

106.2.1 Construction documents.

Construction documents shall be dimensioned and drawn upon suitable material. Electronic media documents are permitted to be submitted when approved by the code official. Construction documents shall be of sufficient clarity to indicate the location, nature and extent of the work proposed and show in detail that it will conform to the provisions of this code and relevant laws, ordinances, rules and regulations, as determined by the code official. The work areas shall be shown.

It should be defined on the drawings


----------



## brudgers (Jul 15, 2011)

Mr Softy said:
			
		

> alright alright  that was the question but it is still the thing we are wrestling with -


By "we" you must mean, you and the mouse in your pocket.


----------



## TimNY (Jul 15, 2011)

Yes, I do want to go back to the beginning.  Because it seems the beginning is where all the disagreement is.  And spare me your theatrics.  Nobody on this forum is above reproach; the time will come where you will be wrong on a subject and I will be happy to debate the issue in a professional manner.

Let me reword such that the question can't be avoided by scrutinizing the wording and overlooking the obvious intent of the question.

Where is the "reconfigured space"?  Where does the "space" end?  Is the space the room?  In my scenario is the entire 1000sf "space"?

If so, assume there is a shaft 20 feet away from the wall/door/window to be reconfigured.  Do you follow level 1 or level 2?


----------



## mtlogcabin (Jul 15, 2011)

In the beggining of the IECC code is the administrative section where the DP is required to choose one of 3 methods for his/her project.

101.5.1 Prescriptive compliance method.

Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

101.5.2 Work area compliance method.

Repairs , alterations , additions , changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 4 through 12 of this code shall be considered in compliance with the provisions of this code.

101.5.3 Performance compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 13 of this code shall be considered in compliance with the provisions of this code

If a DP/contractor does not choose or is not smart enough to figure a method and provide proper documentations as to how they are going to comply with that method then as a building department I believe you should default to the presriptive method and follow that.


----------



## brudgers (Jul 15, 2011)

TimNY said:
			
		

> Where does the "space" end?


Obviously, at 51%.


----------



## rooster (Jul 15, 2011)

TimNY said:
			
		

> Yes, I do want to go back to the beginning.  Because it seems the beginning is where all the disagreement is.  And spare me your theatrics.  Nobody on this forum is above reproach; the time will come where you will be wrong on a subject and I will be happy to debate the issue in a professional manner.Let me reword such that the question can't be avoided by scrutinizing the wording and overlooking the obvious intent of the question.
> 
> Where is the "reconfigured space"?  Where does the "space" end?  Is the space the room?  In my scenario is the entire 1000sf "space"?
> 
> If so, assume there is a shaft 20 feet away from the wall/door/window to be reconfigured.  Do you follow level 1 or level 2?


I hope you didn't take my remarks as condescending because they were not meant to be.  I was only voicing my frustration that we don't seem to be getting anywhere.  I don't claim to be right.  I am only looking at what the code says and everytime I bring something from the code to the table, it seems to be countered with inferences pulled from the code.  For instance...why can't we accept that the work area doesn't include level 1 alterations?  No reconfiguration of space = not a part of work area (as defined by code).

Now the situation you have brought to the table brings a whole new element to the discussion, and one I'm not clear on myself.  What is considered the reconfigured space?  Is it the area of the window being closed or the space the window serves?  I don't know.  According to the code it sounds like the "space" would be considered the work area.

But, this doesn't seem to be the OP's problem.  In fact, in a previous post he states the reconfigured space to be 35% of the project.  He doesn't have a question about that.  I believe he said that it was nowhere near 50%.  He has a question about whether or not the replacing windows and drywall turns the "work area" into 100%.  And I have yet to see the section where the code states this.  All the while a very explicit definition of work area exists, and it has nothing to do with thresholds of levels or compounding of chapters that must be complied with.


----------



## rooster (Jul 15, 2011)

mtlogcabin said:
			
		

> In the beggining of the IECC code is the administrative section where the DP is required to choose one of 3 methods for his/her project. 101.5.1 Prescriptive compliance method.
> 
> Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.
> 
> ...


Thanks.  Quite honestly I just don't have a lot of experience with this method, so I'll have check it out to see how it works in comparison to the work area option.


----------



## rooster (Jul 15, 2011)

rooster said:
			
		

> Thanks.  Quite honestly I just don't have a lot of experience with this method, so I'll have check it out to see how it works in comparison to the work area option.


OK, took a quick look at the IFC (2003) while looking at the prescriptive method, and it requires sprinklers in an R occupancy.  So the example of the OP would not be in compliance, so sprinklers would be required...right?


----------



## Mr Softy (Jul 15, 2011)

rooster said:
			
		

> OK, took a quick look at the IFC (2003) while looking at the prescriptive method, and it requires sprinklers in an R occupancy.  So the example of the OP would not be in compliance, so sprinklers would be required...right?


As I read it, you cannot use Chap 3 if the building does not comply with IFC.

one either makes the building comply, or one goes to the work area method.


----------



## Mr Softy (Jul 15, 2011)

rooster said:
			
		

> But, this doesn't seem to be the OP's problem.  In fact, in a previous post he states the reconfigured space to be 35% of the project.  He doesn't have a question about that.  I believe he said that it was nowhere near 50%.  He has a question about whether or not the replacing windows and drywall turns the "work area" into 100%.  And I have yet to see the section where the code states this.  All the while a very explicit definition of work area exists, and it has nothing to do with thresholds of levels or compounding of chapters that must be complied with.


35% counting gross square footage of rooms where work is being performed.

one method of calculation put forth  is net square footage of reconfigured space only.  so if a wall is being removed, does reconfigured space = 5.5" X length of wall?  and that's it.


----------



## Mr Softy (Jul 15, 2011)

OK here's a further example -

permit issued for kit and bath renovation, with ext. siding removal and replacement.

upon inspection find -

wall between kitchen and dining room removed

wall between dining room and living room removed

wall between 2 bedroom removed and reframed with closets.

2 bathrooms reframed

new closet framed for HVAC unit

LVLs installed in center bearing wall

25 ceiling cans installed throughout unit (minimum hole size 12x18)

new heating system installed with new ductwork run

what's the call?


----------



## mtlogcabin (Jul 15, 2011)

> So the example of the OP would not be in compliance, so sprinklers would be required...right?


Not so fast. Chapter 3 is the same as Chapter 34 in the IBC so you probably have more experiance with it than you think.

If the building complies with the fire code then no sprinklers are required

IFC 2009

102.1 Construction and design provisions.

The construction and design provisions of this code shall apply to:

1. Structures, facilities and conditions arising after the adoption of this code.

2. Existing structures, facilities and conditions not legally in existence at the time of adoption of this code. For the sake of discussion it was legal at the time the I-Codes where adopted

3. Existing structures, facilities and conditions when required in Chapter 46. Does chapter 46 requires sprinklers in an existing building? Only for 2 cases

4603.4 Sprinkler systems.

An automatic sprinkler system shall be provided in existing buildings in accordance with Sections 4603.4.1 and 4603.4.2

4603.4.1 Pyroxylin plastics.

4603.4.2 Group I-2.

4. Existing structures, facilities and conditions which, in the opinion of the fire code official , constitute a distinct hazard to life or property. The FCO better be able to document the distinct hazard. Not meeting todays code requirements is not a distinct hazard by itself. 

2009 IFC

903.2 Where required.

Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in Sections 903.2.1 through 903.2.12.

So 903.2 does not apply to an alteration under IEBC Chapter 3. Even under the work area method a sprinkler system is not required by all level 2 alterations. You have to meet all the conditions of Section  704.2.2 and most small buildings don't. The building described in the OP does not meet the conditions to require sprinklers.

Chapter 46 Construction Requirements for Existing Buildings. Chapter 46 is also a new chapter in the 2009 International Fire Code . This chapter applies to existing buildings constructed prior to the adoption of this code and intends to provide a minimum degree of fire and life safety to persons occupying existing buildings by providing for alterations to such buildings that do not comply with the minimum requirements of the International Building Code . While this chapter is new, its content existed previously in the IFC but in a random manner that was neither efficient nor user-friendly. In the 2007/2008 code development cycle, code change F294-07/08 was approved that consolidated the retroactive elements of IFC/2006 Sections 607, 701, 704, 903, 905, 907 and 2506 and all of Section 1027 into a single chapter for easier and more efficient reference and application to existing buildings. As with other chapters of the International Fire Code , Section 4602 contains definitions applicable to the chapter contents.


----------



## Mr Softy (Jul 15, 2011)

we're new to the IFC, so here's an observation -

4603  requires existing buildings to comply with not less than the minumum provisions specified in Table 4603.1...

Table 4603.1 requires sprinklers in A, F, H-2, H-3, I-2, and M use groups.

which is significantly more than the sprinkler requiremnt put forth in the text of the code (4603.4).


----------



## rooster (Jul 15, 2011)

Ok, I'm listening.

I didn't catch the "new building" part.  Unfortunately I only have access to IFC 2003, so I can't weigh in on chapter 46.

Thank you.  This will give me something chew on for awhile.


----------



## brudgers (Jul 15, 2011)

Mr Softy said:
			
		

> 35% counting gross square footage of rooms where work is being performed.one method of calculation put forth  is net square footage of reconfigured space only.  so if a wall is being removed, does reconfigured space = 5.5" X length of wall?  and that's it.


The only reason that you have an issue with that approach is because you are pushing an agenda rather than enforcing the building code. Holding the permit hostage is how you forward your agenda and your rationale is that the public is your enemy.


----------



## mtlogcabin (Jul 15, 2011)

4603 requires existing buildings to comply with not less than the minumum provisions specified in Table 4603.1... Correct

Table 4603.1 requires sprinklers in A, F, H-2, H-3, I-2, and M use groups. Incorrect The Table sends you to 4603.4 period and nowhere else.

which is significantly more than the sprinkler requiremnt put forth in the text of the code (4603.4). How?

4603.4 Sprinkler systems.

An automatic sprinkler system shall be provided in existing buildings in accordance with Sections 4603.4.1 and 4603.4.2.

4603.4.1 Pyroxylin plastics.

An automatic sprinkler system shall be provided throughout existing buildings where cellulose nitrate film or pyroxylin plastics are manufactured, stored or handled in quantities exceeding 100 pounds (45 kg). Vaults located within buildings for the storage of raw pyroxylin shall be protected with an approved automatic sprinkler system capable of discharging 1.66 gallons per minute per square foot (68 L/min/m2) over the area of the vault. This could be your A or M occupancies if they have more than 100 pounds within the theater (A) or store (M) Table 4603.1 does not automatically require sprinklers in all A or M occupancies. 

4603.4.2 Group I-2.

An automatic sprinkler system shall be provided throughout existing Group I-2 fire areas . The sprinkler system shall be provided throughout the floor where the Group I-2 occupancy is located, and in all floors between the Group I-2 occupancy and the level of exit discharge .


----------



## Mr Softy (Jul 15, 2011)

OK i'm following where you're going.


----------



## RickAstoria (Jul 15, 2011)

I'm not sure what the issue here is. Getting a report on our lovely dog, Brudgers. Yes, I know the dog has a brashness about himself. Brudgers, be a good boy and not be so brash. I know you have a certain personality that rubs off as harsh and somewhat brash and difficult to get along with. Lets just behave and get along guys.

Otherwise, if it derails to personal attacks, I'll or one of the mods may lock the thread if necessary. So far, I don't see it has reached that state at the moment. Lets keep it at that.

MODERATOR mode off.

Lets have fun.


----------



## alora (Jul 15, 2011)

rooster said:
			
		

> ...  An owner could simply be replacing ceiling tiles 100% and this would kick it into a level 3 because you are considering ALL the work to be the work area, ...


Ceiling tile is a finish.

No permit required.

105.2, 2006 IEBC.


----------



## TimNY (Jul 15, 2011)

rooster said:
			
		

> I hope you didn't take my remarks as condescending because they were not meant to be.  I was only voicing my frustration


Welcome to the ICC  

The topic was dragged all around (IO contributed to the dragging and I got off on a tangent.

Yes, the work area is the reconfigured space.

Yes, the work area shall meet the requirements for level 2 (or level 3 if the area is >50%)

I think part of the point trying to be made is if you have level 1 work going on in the level 2 work area, the level 1 alteration no longer exists, it is level 2 within the work area.

The next great debate will be defining the reconfigured space, but I think that is another thread.


----------



## rooster (Jul 16, 2011)

alora said:
			
		

> Ceiling tile is a finish.No permit required.
> 
> 105.2, 2006 IEBC.


Yeah, I saw that section after I posted that.  Substitute a level 1 alteration of your choosing.


----------



## rooster (Jul 16, 2011)

TimNY said:
			
		

> Welcome to the ICC   The topic was dragged all around (IO contributed to the dragging and I got off on a tangent.
> 
> Yes, the work area is the reconfigured space.
> 
> ...


Yeah, maybe we'll give the topic a rest for a week or two...

Somehow this all seems to be more complicated than it should be...I like the prescriptive method pointed out by MT.  I was just under the impression that the building needed to be in compliance as if it were a new building...forgive me, I just went through a process concerning uncertified building built 100 years ago that by state law had to comply with today's code...so I was in that frame of mind.

One thing is for certain...one can't spend too much time with the code book...or books...sigh.


----------



## ICE (Jul 17, 2011)

You guys aren't done are you?


----------



## jar546 (Jul 17, 2011)

I have been reading through this thread tonight and I absolutely love the discussion.  The opinions vary and this is a very important discussion.  I would ask that everything be kept in perspective and we must all realize that some posters are more direct and brash than others and that some people have thinner skin that others.  Nothing that I have read so far is completely out of control, nor am I reading anything as being personal.  There are observations that may or may not be correct, there may be some opinions that may be interpreted as being personal but I am not seeing it and we all may have to agree to disagree.

This is one of the best threads to ever be started because it really hits home for many of us that struggle with existing buildings and when certain "expensive" items are triggered to be installed.  Luckily for me, there is an appeals board to overrule me if the applicant feels strongly enough to take it there.

We all have opinions based on our interpretation of issues like this and we are all coming from different angles based on our job title.  I think we all want to do the right thing when it comes right down to it.

Please, please continue this discussion with less speculation, opinions on the past that are not relevant to the written code as we know it.

I have learned to sit back and not take everything personally and that some just don't know how to play nice or at least nice enough for the person they are playing with.

This is a great example of why I don't allow editing after a specific amount of time.  We don't throw out the whole bushel when we find one bad apple.


----------



## ICE (Jul 18, 2011)

*"This is one of the best threads to ever be started"*

An ice cream cone named Mr. Softy belts one out of the park on his first at bat.  If you see an Oscar Mayer, expect big things.


----------



## JBI (Jul 18, 2011)

Sure beats 'attic stairs'! (@ Mr. S, inside joke about another thread that took on a life of it's own) I skipped over pages 5 through the end, so forgive me for going back to the OP...

*WORK AREA.* That portion or portions of a building consisting of all _reconfigured spaces (that would be where the actual spaces are reconfigured)_ as indicated on the construction documents (this is the one I think everyone is missing. This should be noted by the DP on the plans). Work area excludes other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by this code.

The window replacements, etc are not 'reconfigured spaces', IMHO.

The DPR is required to indicate the work area on the construction documents. (*401.2 Work area.* The work area, as defined in Chapter 2, shall be identified on the construction documents.)

I also believe you've got the commentary a bit off. It was saying that level two work must meet the requirements of both chapters, not that it should make the whole project the work area.

Despite his gruff manner, brudgers makes a valid point (or two). That the Code doesn't specifically provide for nor prohibit 'combining' all work into the scope of level two is awkward, but your local or state law may contain some language that could prove useful. Lacking that, have the DP do HIS job and indicate the work area on the documents. Then the Code Official can do HIS job and review it for compliance.

By the way Mr. S... Welcome to the board!


----------



## rooster (Jul 19, 2011)

JBI said:
			
		

> Sure beats 'attic stairs'! (@ Mr. S, inside joke about another thread that took on a life of it's own) I skipped over pages 5 through the end, so forgive me for going back to the OP... *WORK AREA.* That portion or portions of a building consisting of all _reconfigured spaces (that would be where the actual spaces are reconfigured)_ as indicated on the construction documents (this is the one I think everyone is missing. This should be noted by the DP on the plans). Work area excludes other portions of the building where incidental work entailed by the intended work must be performed and portions of the building where work not initially intended by the owner is specifically required by this code.
> 
> The window replacements, etc are not 'reconfigured spaces', IMHO.
> 
> ...


This is a good summary of what I was trying to get across in 7 pages...where were you last week?

After looking at the definition of Work Area, I began to think of the project as having two parallel lines...two lines that never have to criss-cross.

One line is the *levels of alteration*.  In this line you can have level 1 throughout and a level 2 happening in one space.  Yes, the level 2 has to comply with chapter 6&7, but I don't believe the level 1 necessarily has to become a level 2.  Nowhere does it say this, except for that one commentary.

And the second line is that of the *work area* that is marked on the drawings.  This line has no need to identify the level of the alteration...only the area.  Now, of course these spaces will be a level 2 just because by definition a level 2 is the reconfig of space.  But, this doesn't really matter.  This line has to do with area of reconfig. space and area alone.  Not the level of the alteration.

Now I never have one little level 2 tripping a predominately level 1 alteration into a level 3 or into sprinklers.  Not that I'm trying to skirt anything...I'm just trying to avoid exploding project scopes that make the client not do anything, therefore making the building even less safe.

This seems reasonable to me and it's the way I deal with my CDs now.  I'll just note that there are level 1 alterations throughout...then I'll note level 2 alterations

(reconfig. spaces) marked on Work Area Plan.  This makes it clear that there is work happening throughout the building, but it also makes clear that space reconfiguration is only happening where I note it.  If my marked work area hits 50%...then it's off to level 3...but only for the reconfig. spaces as the level 3 scope says.

Now if the reviewer questions what I've marked as the limits of the reconfiguration of space, then we can have that discussion.  But the alteration level can be left out of it.

I'll be submitting these drawings soon...I'll let you know how it goes.

I'm glad this discussion happened.  Every time this would come up in a project questions would come up exactly like Mr. Softy's origianl post.  I feel much more comfortable dealing with it in this way.  It seems less muddy.  Whether it's right or wrong, I guess we'll find out.

And I'm now also more aware of Chapter 3 which mt pointed out.  But even then, it seems that the work area option shouldn't be that mysterious.


----------



## Mr Softy (Jul 19, 2011)

JBI, thanks for chiming in - the more viewpoints, the better.

we absolutely insist the work area be specifically identified on the construction drawings.

rooster - i follow you logic about work area and levels not intersecting.

but.

with a limited interpretation and measurement of work area, a project may never hit any square footage triggers.  despite however much work is being performed.  so why are those triggers there?

here's another question to kick around re: reconfigured space -

where would one draw the line when measuring reconfigured space?  the strict area of the walls being changed?  or the area of the rooms where the reconfiguration is taking place?

on small stuff like moving a window or a door, i can see the work area being very limited.  but where would you consider the work area if a wall is coming down between rooms?  or if numerous walls are to be moved?

i am curious as to other views on this.

here's the definition (again) - That *portion* or portions of a building *consisting of **all reconfigured spaces *.

if there is a 1000 sq ft portion of a building that is reconfigured, is the work area that 1000 sq ft? sure looks like it.


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## rooster (Jul 19, 2011)

Mr Softy said:
			
		

> JBI, thanks for chiming in - the more viewpoints, the better.we absolutely insist the work area be specifically identified on the construction drawings.
> 
> rooster - i follow you logic about work area and levels not intersecting.
> 
> ...


We've talked a lot about the intent of the IEBC...here it is:

_101.3 Intent. The intent of this code is to provide flexibility to_

_permit the use of alternative approaches to achieve compliance_

_with minimum requirements to safeguard the public health,_

_safety and welfare insofar as they are affected by the repair,_

_alteration, change of occupancy, addition and relocation of_

_existing buildings._

Like it or not, we are talking about "minimum requirements."


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## rooster (Jul 19, 2011)

Mr Softy said:
			
		

> JBI, thanks for chiming in - the more viewpoints, the better.we absolutely insist the work area be specifically identified on the construction drawings.
> 
> rooster - i follow you logic about work area and levels not intersecting.
> 
> ...


When I hear the phrase "reconfiguration of space" I think of the space...not the object, therefore I would think the affected space would be the work area.  I hate to say it, but it almost seems like some flexibility is in order.

Let's use your window example, but let's make it simpler.  Let's say it's just getting eliminated...not moved.

Now let's say you have 2 cases: a sleeping room & a one room warehouse.

If we look at the sleeping room, the elimination of a window is a very big deal, and it affects the life-safety of the entire space of the sleeping room (no matter where the occupant is)...therefore I would have to say that the entire sleeping room would be the work area.

Now on the other hand, if we look at the elimination of a window in a one room warehouse, do we consider the whole warehouse the work area?  To me, that doesn't seem reasonable, mainly because it most likely doesn't affect the life-safety of the entire space like it does the sleeping room.  Actually, I've done projects where we put a small office in a large warehouse (which by defualt eliminates a wndw to the warehouse), and we only call out the addition of the office as the work area.  To call out the rest of the warehouse as the work area, would have looked kind of silly...unless it affected the life-safety of the warehouse space.

So there it...what can I say....I don't have an answer except that we all might have to just take it all of this with a grain of salt.

On the note of flexibility...here is an exception to using the compliance methods. This is the exception to 105.1:

_Exception: Subject to the approval of the code official, alterations_

_complying with the laws in existence at the time the_

_building or the affected portion of the buildingwas built shall_

_be considered in compliance with the provisions of this code_

_unless the building is undergoing more than a limited structural_

_alteration as defined in Section 807.4.3. New structural_

_members added as part of the alteration shall complywith the_

_International Building Code. Alterations of existing buildings_

_in flood hazard areas shall complywith Section 601.3._

To me, it's all coming down to "are we any worse off?"


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## mtlogcabin (Jul 19, 2011)

> To me, it's all coming down to "are we any worse off?"


Exactly. Same as removing a non-structural wall between the kitchen and living room in an apartment. Did it really re-configure the uses within the space. No, the kitchen and living room have the same square footage it just became an open floor plan. Did it negatively affect anything? No, so it meets 101.3


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## brudgers (Jul 19, 2011)

Mr Softy said:
			
		

> but.
> 
> with a limited interpretation and measurement of work area, a project may never hit any square footage triggers.  despite however much work is being performed.  so why are those triggers there?


Just to break your heart.

Seriously, every one of your posts falls into the same pattern.

"I know what the code says - but..."

We can only hope that one day fairness and justice replace your personal agenda and willingness to break the law.


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## brudgers (Jul 19, 2011)

rooster said:
			
		

> To me, it's all coming down to "are we any worse off?"


Those whose personal agenda requires making the public dance to their whims, feel they are.


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## Mr Softy (Jul 19, 2011)

here are two questions -

Project - there are two adjacent 10x10 rooms.  the wall between the two is being moved 2 feet, to create an 8x10 room and a 12x10 room.

does the project qualify as Level 2?  Yes or No

Is the work area -

a 200 Sq ft, the combined area of the two reconfigured spaces.

b. 20 sq ft.  the area the wall was moved

c. 5 sq ft  the area of the wall (6"x 10')


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## texas transplant (Jul 19, 2011)

brudgers,

You have made your point, get a little more civil please or drop it.   The two of you are not in the same mind set, Mr. Softy is working to understand this.  Be constructive or just set back and watch.  You could say the same things in a better way.

Why try and drive off people that want to learn, you know the old more flies with honey than vinegar.


----------



## texasbo (Jul 19, 2011)

Mr. Softy, allow me to congratulate you on remaining professional throughout the incessant and boorish attacks by brudgers. Kind of like an irritating little yap dog snapping at your heels, no?



			
				Mr Softy said:
			
		

> here are two questions -Project - there are two adjacent 10x10 rooms.  the wall between the two is being moved 2 feet, to create an 8x10 room and a 12x10 room.
> 
> does the project qualify as Level 2?  Yes or No
> 
> ...


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## texasbo (Jul 19, 2011)

texas transplant said:
			
		

> brudgers,  Be constructive or just set back and watch.


Again, that would be a level of alteration that is simply not attainable. Clearly built into his psyche; clearly "little man syndrome".


----------



## brudgers (Jul 19, 2011)

Mr Softy said:
			
		

> here are two questions -Project - there are two adjacent 10x10 rooms.  the wall between the two is being moved 2 feet, to create an 8x10 room and a 12x10 room.
> 
> does the project qualify as Level 2?  Yes or No
> 
> ...


The work area is as shown by the design professional.

By definition.

And despite your wishing the world was full of rainbows and unicorns.


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## jar546 (Jul 19, 2011)

Adding a receptacle triggers level 2.  Smoke that.


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## Mr Softy (Jul 19, 2011)

jar546 said:
			
		

> Adding a receptacle triggers level 2.  Smoke that.


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## rooster (Jul 19, 2011)

Yeah, my brain's about fried...

I'm starting to like Chapter 3.  As far as I can tell you make sure the new work complies with IBC and as long as the existing isn't _less_ conforming then you're good to go.  And then check IFC for fire protection, etc...am I wrong dude?

_* SECTION 303*_

_*ALTERATIONS*_

_*303.1 General. Except as provided by Section 301.2 or this*_

_*section, alterations to any building or structure shall comply*_

_*with the requirements of the International Building Code for*_

_*new construction. Alterations shall be such that the existing*_

_*building or structure is no less conforming to the provisions of*_

_*the International Building Code than the existing building or*_

_*structure was prior to the alteration.*_


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## mtlogcabin (Jul 19, 2011)

here are two questions -

Project - there are two adjacent 10x10 rooms. the wall between the two is being moved 2 feet, to create an 8x10 room and a 12x10 room.

does the project qualify as Level 2? Yes or No

 Yes if the designer chooses to use the Work Area Compliance method. No if he chooses to use one of the other 2 methods. 

Is the work area -

a 200 Sq ft, the combined area of the two reconfigured spaces.

b. 20 sq ft. the area the wall was moved

I 

would agree only 20 sq ft of the space has been reconfigured

c. 5 sq ft the area of the wall (6"x 10')

The Alteration method does not automatically require compliance with all the requirements of Chapter 7

Use Jars coment for example "Adding a receptacle triggers level 2" It only triggers the requirements found in Section 708 and nothing else.


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## RickAstoria (Jul 19, 2011)

Brudgers,

Behave. Don't make inciteful accusations of others like claims of being a criminal. If it continues and degrades, the thread may have to be locked.


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## peach (Jul 19, 2011)

A building official can make an interpretation of the code which can become BD policy without every codifying it; that's exactly the the Board of appeals is for: the code official misinterpretated the code... not to get a waiver of the code.


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## JBI (Jul 19, 2011)

The entire room(s) where walls are either moved or removed would constitute the 'work area'. The rooms are the 'altered spaces' - be it by getting bigger or smaller.

As far as the mystical thresholds? Ask yourself this... Is/will the building be less safe after the project than before?

How was the space used/occupied prior to the renovation versus after? Is the level of activity increasing? The hazard?

Codes are, necessarily, written for broad generalizations. Whatever is written one can always devise a 'spoiler' - a scenario that seems to defy logic or impose an unreasonable burden. That's not a bad Code issue, it's an extreme example issue. There are many things in the Codes that I don't fully agree with, but as Dwaynne 'The Rock' Johnson would say... "IT DOESN"T MATTER WHAT YOU THINK!!!". Some days all you can do is suck it up and live with it. Well, that and write a Code Change Proposal for ICC and your State Code writers...


----------



## rooster (Jul 21, 2011)

I personally attack every ice cream cone I come across.


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## jar546 (Jul 21, 2011)

At this point, there is another thread that can be used to debate the complaint about the posts.  I am going to clean this thread up by moving some of the posts to that new thread in an attempt to keep this thread on topic.

This has been a great thread for Existing Buildings and I think that we can all learn from it and see the difference of opinions..

Back on topic!!!

topic


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## jar546 (Jul 21, 2011)

Let's look at percentages another way.

If a room is 10' x 10' with 10' high ceilings, the actual square footage of the room when you combine the walls, ceiling & floor is 600 square feet.

When you move one of the 10' walls, you are moving 100 square feet or 1/6 or 17%

Work area says nothing about floor area.


----------



## rooster (Jul 21, 2011)

rooster said:
			
		

> I personally attack every ice cream cone I come across.


kinda outta context now...or maybe not...it's always a true statement.


----------



## mtlogcabin (Jul 21, 2011)

This has been a very interesting and educational thread and I to would like to see it keep going



> Work area says nothing about floor area.


The work area refers to spaces and a space is within something so I would not agree with your example of applying percentages

Here is my take on the work area definition

WORK AREA. That portion or portions of a building consisting of all reconfigured spaces as indicated on the construction documents. A wall defines a space and is not part of the space. The area of a space must change.

Work area excludes other portions of the building where incidental work entailed by the intended work must be performed A ballroom is being reconfigured and new chandelier light fixtures are installed The chandeliers in the lobby will be changed to match the ballroom. The lobby work would be incidental and not part of the work area. 

and portions of the building where work not initially intended by the owner is specifically required by this code. A meeting room was reconfigured and the occupant load went from 40 to 55. Panic hardware is now required on all doors along the egress path. This work is not included in the work area.


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## Mr Softy (Jul 21, 2011)

rooster said:
			
		

> I personally attack every ice cream cone I come across.


----------



## rooster (Jul 21, 2011)

I like your examples, but why did you answer "b" to softy's question?  Do you consider the rest of the two spaces incidental?


----------



## ewenme (Jul 21, 2011)

deleted by the poster...


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## Min&Max (Jul 21, 2011)

The building code, in fact all codes, are minimum standards. If a contractor or owner finds a "loophole" to avoid doing something then more power to them. At least they are aware of what is in the code. And just because you may consider it a "loophole" doesn't make it so. It may be a well thought out course of action for the contractor/designer/owner to avoid unnecessary bureaucratic red tape. Regardless, the code is a minimum and I will do my best to help whoever down that minimum path.

In all the previous back and forth banter I see nothing that would resemble a personal attack. Just lively interaction that makes this board unique and special. Anyone who does not like it should probably find a more "politically correct" arena.


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## Papio Bldg Dept (Jul 21, 2011)

mtlogcabin said:
			
		

> This has been a very interesting and educational thread and I to would like to see it keep going


Thank you...that is a very good description/take on work area, and something I might use in the future.  Not sure where I stand on work area versus floor area versus percentage.  It is something I need to give some more thought on my vacation to Big Thompson Canyon, where I plan to have no work areas.


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## jar546 (Jul 21, 2011)

mtlogcabin said:
			
		

> This has been a very interesting and educational thread and I to would like to see it keep goingThe work area refers to spaces and a space is within something so I would not agree with your example of applying percentages
> 
> Here is my take on the work area definition
> 
> ...


Agree with your post and opinion.


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## RickAstoria (Jul 21, 2011)

In response to Ewenme's post

I will simply state a quote from Chapter 6 (602.5) of the unmodified IBC 2006 (I think the 2009 is still the same in this regard).

(that includes Type V-A and V-B. A means sprinklered or something to that extent and B means non-sprinklered)

602.5 Type V. Type V construction is that type of construction in which the structural elements, exterior walls and interior walls are of any materials permitted by this code.

Wood light frame construction would be under this section. Such as a typical light wood frame Ranch style house.

Type IV is for Heavy Timber

Type III is for buildings that are made of non-combustable exterior walls but the interior maybe of light wood frame construction. Such as a building with concrete of brick exterior but made of light wood or aluminum/steel interior walls and floors. Some cases of heavier steel frame or Timber Frame. This typically includes alot of school buildings in the 1920s that had wood floors and interior walls and roof but the exterior is concrete or masonry or similarly non-combustable construction (typically of fire rating of 3 hours or greater).

Type I & II are for buildings that are made of non-combustable construction entirely throughout. CMU and concrete interior walls, Concrete/CMU exterior walls and pre-stressed concrete roof and such would be a good example.

States may modify this to however they decide.

Light wood frame construction can almost never be really a Type I or II or a type IV. It maybe a Type III if the exterior walls are like brick or concrete (not brick veneer skin over wood stud frame). That is what the code says. I am not quoting it all. Just read Chapter 6.


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## ewenme (Jul 21, 2011)

Excuse the post above... it was meant for another thread in the commercial building codes section.


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## Mr Softy (Jul 21, 2011)

jar546 said:
			
		

> Let's look at percentages another way.If a room is 10' x 10' with 10' high ceilings, the actual square footage of the room when you combine the walls, ceiling & floor is 600 square feet.
> 
> When you move one of the 10' walls, you are moving 100 square feet or 1/6 or 17%
> 
> Work area says nothing about floor area.


do you mean the *cubic volume *is 1000 ft 3 ?


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## Mr Softy (Jul 21, 2011)

mtlogcabin said:
			
		

> This has been a very interesting and educational thread and I to would like to see it keep goingThe work area refers to spaces and a space is within something so I would not agree with your example of applying percentages
> 
> Here is my take on the work area definition
> 
> ...


i agree with your examples of incedental work.

and you definition of work area


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## brudgers (Jul 21, 2011)

Mr Softy said:
			
		

> i agree with your examples of incedental work.and you definition of work area


Keep in mind that spaces are as defined on the construction documents not in the building department.


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## Papio Bldg Dept (Jul 21, 2011)

brudgers said:
			
		

> Keep in mind that spaces are as defined on the construction documents not in the building department.


That is an interesting, albeit a bit off topic, point.  I recently had an application for a trampoline dodge-ball facility.  The application and construction documents noted it was to be a 'B' occupancy.  I don't believe I was wrong in not accepting it as a 'B' occupancy by also keeping in mind that spaces may be defined incorrectly, by both the construction documents or the building department.


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## brudgers (Jul 21, 2011)

It's part of the definition of Work Area in the code.

"That portion or portions of a building consisting of all *reconfigured spaces* *as indicated on the construction documents.*"


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## peach (Jul 21, 2011)

one work area can affect many other work areas... saw an example today which is  going to be almost un-inspectable.  Project creep, maybe..


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## texasbo (Jul 21, 2011)

brudgers said:
			
		

> It's part of the definition of Work Area in the code."That portion or portions of a building consisting of all *reconfigured spaces* *as indicated on the construction documents.*"


And as Papio said, when they are indicated incorrectly (which unfortunately is not uncommon), those construction documents are "DENIED".


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## peach (Jul 21, 2011)

Deny it at plan review - don't dump it on the inspector in the field.


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## Mr Softy (Jul 21, 2011)

peach said:
			
		

> Deny it at plan review - don't dump it on the inspector in the field.


hi peach.

in both instances i am citing, the 'work area' had expanded wildly during construction.  after review,and after the permit had been issued.

both expansions of scope were uncovered during a field inspection for something else.

we look for a minimum of three essential documents -  an existing condition plan, a proposed plan, and a scoping plan.


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## peach (Jul 21, 2011)

welcome back, you softy you!

The work area frequently expands after construction starts.. sometimes existing conditions are uncovered... yadayada...

that's what stop work orders are for.

Sounds like your jurisdiction has a pretty good plan, but the scope can change in a hurry (PARTICULARLY in existing buildings).. one of those OH CRAP moments!

We recently had one.. a Tenant fitout in an existing building... NOT ONLY was the old temporary wiring from the base building still in place, it was individual conductors (what the NEC calls "festoon wiring"), but it was HOT.. needless to say, my inspector said pull it out on the entire floor (out of scope).


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## Mr Softy (Jul 21, 2011)

peach said:
			
		

> ... sometimes existing conditions are uncovered... yadayada... that's what stop work orders are for.


uncovering existing conditions is one thing...

our MO (so to speak) is to use Stop Work Orders only when absolutely necessary.  the preferred method is to work out a solution, and give the GC/DP a the opportunity to make things right.  Stop Work Orders just put lots of people out of work.  our way generally works out well.


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## peach (Jul 21, 2011)

working out solutions doesn't always work.. need to get their attention... particularly after construction starts; catch it at plan review if you can (which means the plan reviewer needs to ask some thougthful questions.. which they rarely do.. or visit the site (which they never do)...  a SWO gets the attention (and the word travels faster than a fire in a matchbook.. don't over use it, of course, or the contractor will start writing the cost into their bid)..

Once a project is out of control, you need to rein it in at any cost (to them, of course).. sooner rather than later..


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## Mr Softy (Jul 21, 2011)

peach said:
			
		

> working out solutions doesn't always work.. need to get their attention...


no, it doesn't unfortunately.  and trust me, we do know how to get their attention when we need to.


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## peach (Jul 21, 2011)

then use it!!!!


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## brudgers (Jul 21, 2011)

texasbo said:
			
		

> And as Papio said, when they are indicated incorrectly (which unfortunately is not uncommon), those construction documents are "DENIED".


 The code may be poorly written, but the work area determination is found on the construction documents.

Short of having an alternative set of construction documents, there is no authority in the IEBC for a code official to determine the work area.

Unless of course, said code official takes it upon themselves to create those construction documents.


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## texasbo (Jul 22, 2011)

brudgers said:
			
		

> The code may be poorly written, but the work area determination is found on the construction documents.Short of having an alternative set of construction documents, there is no authority in the IEBC for a code official to determine the work area.
> 
> Unless of course, said code official takes it upon themselves to create those construction documents.


You are wrong. The work area is NOT determined on the CD's. Read your code. It is INDICATED on the CD's. The DETERMINATION is made by the Building Department, hence the point of this thread. If the DP was in charge of DETERMINING things, submittal would not be required to the Building Department. You can INDICATE a 15 story building as type V construction, but it will be DETERMINED as something else.

What the work area is or isn't in this PARTICULAR case is certainly up for debate, but DETERMINATION certainly is not.


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## fatboy (Jul 22, 2011)

Yup, have to agree with TXBO, the DP can submit whatever they desire, but yes, the building department's Plans Examiners job is to determine if the DP's plans are in compliance with the code. Call it whatever you want, holding the permit hostage, making applicants do the dance, jump through hoops, but that is the Plans Examiners job, to review the submitted plan for compliance. And yes, it is their interpretation, cold hard fact, if it doesn't work out for the DP, then there are appeals processes to address that.


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## jar546 (Jul 22, 2011)

fatboy said:
			
		

> Yup, have to agree with TXBO, the DP can submit whatever they desire, but yes, the building department's Plans Examiners job is to determine if the DP's plans are in compliance with the code. Call it whatever you want, holding the permit hostage, making applicants do the dance, jump through hoops, but that is the Plans Examiners job, to review the submitted plan for compliance. And yes, it is their interpretation, cold hard fact, if it doesn't work out for the DP, then there are appeals processes to address that.


Yeah, what he said.

DPs consistently submit plans that are not compliant and the plans examiner is there to verify compliance.  Case in point:  DP submits plans for a chinese restaurant with a total of 2,000 sq'.  1,000 for the kitchen and then shows a net area in the dining room of 750 sq' with mixed tables & chairs.  What occupant load do they show us?  14 in order to eliminate a bathroom.  They showed tables and 9 chairs on the plans.  Nice try.

Am I suppose to be forced to accept that because it was submitted by a DP?  Absolutely not. Could they have asked for the exception by the BCO under Ch 10 of the IBC and explained why but no, they just provide what they think it should be.


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## Mr Softy (Jul 22, 2011)

yup.

the contractor indicated work in the kitchen and bath.  only.  fine.

i determined, upon inspection, that the work was over the whole building.  my call.

if the GC doesn't want the BI making field determinations, don't venture off the CDs.


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## Papio Bldg Dept (Jul 22, 2011)

brudgers said:
			
		

> there is no authority in the IEBC for a code official to determine the work area.


*106.3 of the 2006 IEBC: Examination of documents*

The code official shall examine or cause to be examined the construction documents and shall ascertain (determine) by such examinations whether the construction or occupancy indicated (not determined) and described is in accordance with the requirements of this code and other pertinent law or ordinances.

I believe that is called authority brudgers, whether you want to admit it or not.  And like all authority, it too can be abused.  :beatdhrs

I find it is best to take each project on a case by case basis, and although I do not like take projects hostage, however, that is a tool the codes give us in order to ascertain compliance, and I am more than happy to use it, especially when the last six RDP submitted Tenant Finishes didn't provide even a door schedule (granted in two cases the GC had submitted prelims without authorization by the RDP).


----------



## jar546 (Jul 22, 2011)

Papio Bldg Dept said:
			
		

> *106.3 of the 2006 IEBC: Examination of documents* The code official shall examine or cause to be examined the construction documents and shall ascertain (determine) by such examinations whether the construction or occupancy indicated (not determined) and described is in accordance with the requirements of this code and other pertinent law or ordinances.
> 
> I believe that is called authority brudgers, whether you want to admit it or not.  And like all authority, it too can be abused.  :beatdhrs
> 
> I find it is best to take each project on a case by case basis, and although I do not like take projects hostage, however, that is a tool the codes give us in order to ascertain compliance, and I am more than happy to use it, especially when the last six RDP submitted Tenant Finishes didn't provide even a door schedule (granted in two cases the GC had submitted prelims without authorization by the RDP).


OK, this is going to be an interesting post/reply coming up from our resident PITA.opcorn


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## brudgers (Jul 22, 2011)

Papio Bldg Dept said:
			
		

> the construction or occupancy indicated  and described is in accordance with the requirements of this code


The code is quite clear. The work area is *by definition* what is indicated on the plans.

I will also point out, that the work area appears to be neither an occupancy nor construction and therefore does not fall within the purview of the code official under 106.3.

I'm not saying that the code is well written.

But that's what it says, and the reason one goes and talks to the city attorney rather than dealing with the products of a DQ.


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## brudgers (Jul 22, 2011)

jar546 said:
			
		

> Yeah, what he said.DPs consistently submit plans that are not compliant and the plans examiner is there to verify compliance.  Case in point:  DP submits plans for a chinese restaurant with a total of 2,000 sq'.  1,000 for the kitchen and then shows a net area in the dining room of 750 sq' with mixed tables & chairs.  What occupant load do they show us?  14 in order to eliminate a bathroom.  They showed tables and 9 chairs on the plans.  Nice try.
> 
> Am I suppose to be forced to accept that because it was submitted by a DP?  Absolutely not. Could they have asked for the exception by the BCO under Ch 10 of the IBC and explained why but no, they just provide what they think it should be.


I think you are missing the difference.

Work area is defined solely by what is indicated on the construction documents.

The code provides no other way of determining it.

And, therefore, using any other method to determine the work area besides looking at the construction documents to see what is indicated is not in compliance with the code, and therefore absent a modification to the model code by local ordinance, making a determination of the work area which is different from what is indicated on the plans is not within the building official's purview.


----------



## TimNY (Jul 22, 2011)

If you are going to babble about attorneys, you better become familiar with the reasonable person doctrine.  I find that the people who threaten legal action are the ones that know the least about it.  Good for you if you were able to successfully threaten a green city attorney in a city fearful of all litigation, no matter how baseless.

An appeal of the inspector's interpretation is not handled through the city attorney, and I expect any competent attorney to tell you that.  And who do you think they're going to call to figure out the truth (hint, it's not you).

If you should have the conviction to actually file a suit, most cities are insured for such incidents.  Council is provided by the insurer.  At which time the Judge will dismiss because you failed to follow the established procedure for appealing a decision.

And to be clear "design professional" does not appear anywhere in the definition of "work area".  It _does_ say "reconfigured spaces as indicated on the plans".  I see a wall moved, it indicates the spaces have been reconfigured and defines the work area.  I don't see where the code gives the designer exclusive rights to determining the work area.


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## TimNY (Jul 22, 2011)

brudgers said:
			
		

> I think you are missing the difference.Work area is defined solely by what is indicated on the construction documents.
> 
> The code provides no other way of determining it.
> 
> And, therefore, using any other method to determine the work area besides looking at the construction documents to see what is indicated is not in compliance with the code, and therefore absent a modification to the model code by local ordinance, making a determination of the work area which is different from what is indicated on the plans is not within the building official's purview.


"reconfigured spaces as indicated on the plans"

Work area is not indicated on the plans.  Reconfigured spaces are.  It does not say who determines what the reconfigured spaces are.


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## brudgers (Jul 22, 2011)

TimNY said:
			
		

> "reconfigured spaces as indicated on the plans"Work area is not indicated on the plans.  Reconfigured spaces are.  It does not say who determines what the reconfigured spaces are.


It's not a person, it is the construction documents.

By definition.

If the code official authors the construction documents then they get to determine the work area.

Otherwise they do not.


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## mtlogcabin (Jul 22, 2011)

> Work area is defined solely by what is indicated on the construction documents.


I agree with the statement. Remember a work area is a reconfiguration of a space and just that word alone will lead to different applications



> making a determination of the work area which is different from what is indicated on the plans is not within the building official's purview.


 It is within the building officials purview to review the _indicated work area_ and work in other areas of a project that may not have been included in the _indicated work area_ to see if that work is incidental or required by code for the _indicated work area_ If the building official believes the work is not incidental work or work required by code he can ask the DP for more info or clarification.


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## brudgers (Jul 22, 2011)

TimNY said:
			
		

> If you are going to babble about attorneys, you better become familiar with the reasonable person doctrine.  I find that the people who threaten legal action are the ones that know the least about it.  Good for you if you were able to successfully threaten a green city attorney in a city fearful of all litigation, no matter how baseless.An appeal of the inspector's interpretation is not handled through the city attorney, and I expect any competent attorney to tell you that.  And who do you think they're going to call to figure out the truth (hint, it's not you).
> 
> If you should have the conviction to actually file a suit, most cities are insured for such incidents.  Council is provided by the insurer.  At which time the Judge will dismiss because you failed to follow the established procedure for appealing a decision.
> 
> And to be clear "design professional" does not appear anywhere in the definition of "work area".  It _does_ say "reconfigured spaces as indicated on the plans".  I see a wall moved, it indicates the spaces have been reconfigured and defines the work area.  I don't see where the code gives the designer exclusive rights to determining the work area.


Where did I threaten legal action?

I merely suggested communicating with the city attorney.

You can read my full description and rationales earlier in this thread.

The TL;DR is that the way to combat the code officials raising the stakes by holding the permit hostage is to leverage the weight of bureaucracy of under which they operate in a way that brings effective pressure to bear upon them and thereby bring them to the light.

It is only a green attorney whose cost benefit analysis or lack thereof will conclude that the code official's position is worth fighting for.

Just the administrative overhead for an quasi-judicial appeal can easily run a couple of grand...and for what?

Lest you assume that the press of bureaucracy would be brought after the permit was denied, nay, the process starts right at the friendly prelim meeting to allow the sense of dread to build over time in an atmosphere of uncertainty and constant barrage of paperwork.

And it is all the better when the code official uses terms like "loophole" or claims that the commentary is part of the code, or uses some method other than what is indicated on the construction documents to determine the work area.


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## brudgers (Jul 22, 2011)

mtlogcabin said:
			
		

> I agree with the statement. Remember a work area is a reconfiguration of a space and just that word alone will lead to different applications It is within the building officials purview to review the _indicated work area_ and work in other areas of a project that may not have been included in the _indicated work area_ to see if that work is incidental or required by code for the _indicated work area_ If the building official believes the work is not incidental work or work required by code he can ask the DP work more info or clarification.


On the other hand, if the construction documents delineate an area which encompasses all the altered spaces, the building official has no leeway to say "the work area must be too the far side of the room" because looking at what is indicated on the construction documents is the sole  code compliant method of determining the work area.


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## Papio Bldg Dept (Jul 22, 2011)

brudgers said:
			
		

> The code is quite clear. The work area is *by definition* what is indicated on the plans. I will also point out, that the work area appears to be neither an occupancy nor construction and therefore does not fall within the purview of the code official under 106.3.
> 
> I'm not saying that the code is well written.


I can actually see the logic behind that.  Something I need to think more about.  Thanks Brudgers.  I apologize if I assumed a broader scope than the OP discussion.


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## brudgers (Jul 22, 2011)

Papio Bldg Dept said:
			
		

> I can actually see the logic behind that.  Something I need to think more about.  Thanks Brudgers.  I apologize if I assumed a broader scope than the OP discussion.


There's no need to apologize.

The code is a complex document and unpacking it is difficult, and made only more so by the pressure underwhich code officials operate.

As I've said before, an inspector can't say, "I'm not sure. Give me a week to think about it. Then I'll tell you if you have to tear it out."

Throw in everyone's natural confirmation bias, the poor organization of the icodes, and the ICC's love affair with   with adding prescriptive provisions in every code cycle, and there is a reason to call on attorneys for interpretation.

But why does it make sense to have the construction documents indicate the work area?

Consider two cases where the alteration is to open up a of the kitchen to create a bar and pass-through to the adjacent space.

In one case the adjacent room is a traditional 10x14 dining room.

In the other the adjacent room is an open 28x14 open living/dining area.

Experience would tell us that the reconfiguration is no more extensive in one case than the other.

But if you allow the code official to determine the work area, there are plenty of people here in this very thread who have advocated a non-compliant means of determining the work area which would make one work area more than twice as large as the other.

Not only does that make no sense, it does little to facilitate a perception of code officials as professionals.


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## Papio Bldg Dept (Jul 22, 2011)

brudgers said:
			
		

> Consider two cases where the alteration is to open up a of the kitchen to create a bar and pass-through to the adjacent space.In one case the adjacent room is a traditional 10x14 dining room.
> 
> In the other the adjacent room is an open 28x14 open living/dining area.
> 
> Experience would tell us that the reconfiguration is no more extensive in one case than the other.


I apologized because I made an assumption of your comment out of context with the discussion and I should be more careful to keep in mind what is actually being said (and not spoken for all you Heidegger fans).

True, I am in agreement that they should not be considered differently, and perhaps I need to re-read the OP conversation again now that it is trimmed down.

The issue I was discussing is when the plan shows the scope of the work area as you described in the two reconfiguration cases, however the inspector discovers the scope is much larger or the plan examiner determines the reconfiguration will require modifications that will increase the work area and scope of the reconfiguration for code compliance (i.e. means of egress system).

To use your example again for a 400sf conference room:

In one case the adjacent room is a traditional 10x25 conference room.

In the other the adjacent room is an open concept 25x15 conference room moveable partitions to split the conference room.

In the second case, doors outside the work area would now need to open in the direction of egress.  I was suggesting the plans may not accurately indicate the entire work area and may need to be adjusted by the RDP.


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## mtlogcabin (Jul 22, 2011)

> In the second case, doors outside the work area would now need to open in the direction of egress


They change of the swing of the doors would be work required by the code and should not be included in the work area

Just MHO

and portions of the building where work not initially intended by the owner is specifically required by this code. A meeting room was reconfigured and the occupant load went from 40 to 55. Panic hardware is now required on all doors along the egress path. This work is not included in the work area.


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## Mr Softy (Jul 22, 2011)

mtlogcabin said:
			
		

> They change of the swing of the doors would be work required by the code and should not be included in the work area Just MHO
> 
> and portions of the building where work not initially intended by the owner is specifically required by this code. A meeting room was reconfigured and the occupant load went from 40 to 55. Panic hardware is now required on all doors along the egress path. This work is not included in the work area.


Ok - i agree with that

how about this -

A meeting room was reconfigured and the occupant load went from 40 to 55. Panic hardware is now required on all doors along the egress path. This work is not included in the work area. An adjacent kitchen and two bathrooms were added after permitting.  Those spaces have become part of the work area.  They are not incidental to the original work and are not required by code due to the original work.


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## brudgers (Jul 22, 2011)

Papio Bldg Dept said:
			
		

> The issue I was discussing is when the plan shows the scope of the work area as you described in the two reconfiguration cases, however the inspector discovers the scope is much larger or the plan examiner determines the reconfiguration will require modifications that will increase the work area and scope of the reconfiguration for code compliance (i.e. means of egress system).


By definition, incidental work and work required by code are not part of the work area.


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## mtlogcabin (Jul 22, 2011)

Mr Softy said:
			
		

> Ok - i agree with thathow about this -
> 
> A meeting room was reconfigured and the occupant load went from 40 to 55. Panic hardware is now required on all doors along the egress path. This work is not included in the work area. An adjacent kitchen and two bathrooms were added after permitting. Those spaces have become part of the work area. They are not incidental to the original work and are not required by code due to the original work.


No they do not automatically become part of the work area

106.4 Amended construction documents.

Work shall be installed in accordance with the reviewed construction documents, and any changes made during construction that are not in compliance with the approved construction documents shall be resubmitted for approval as an amended set of construction documents.

Adding bathrooms could be done completely under the IBC or Chapter 3 of the IEBC or it could be another work area,  it would be the designers choice. As a jurisdiction you could ammend the permit or require a new one.


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## RickAstoria (Jul 22, 2011)

fatboy said:
			
		

> Yup, have to agree with TXBO, the DP can submit whatever they desire, but yes, the building department's Plans Examiners job is to determine if the DP's plans are in compliance with the code. Call it whatever you want, holding the permit hostage, making applicants do the dance, jump through hoops, but that is the Plans Examiners job, to review the submitted plan for compliance. And yes, it is their interpretation, cold hard fact, if it doesn't work out for the DP, then there are appeals processes to address that.


In addition, determine is a function of interpretation. Ultimately, the interpretation of code is that of the B.O. as outlined in Section 104 (104.1 in particular). The Designer (Architector or anyone else) can draw and write whatever they want. The determination of compliance is that of the B.O. and up to the B.O.'s interpretation of the code. It is ultimately his call not the Designer.

The Designer should strive to be correct with the interpretation and prepare plans accordingly for expediency of Plan Review. That is a different issue.


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## RickAstoria (Jul 22, 2011)

brudgers said:
			
		

> It's not a person, it is the construction documents.By definition.
> 
> If the code official authors the construction documents then they get to determine the work area.
> 
> Otherwise they do not.


As an Architect or Building Designer, you can define the intended use of the space reconfigured as you develop that from the project program between you and the client. When you prepare the plans, you define this room is a Bedroom and this room is the kitchen and this room is the bathroom. From there the B.O. or designated plan reviewer will interpret your plans according to how they are prepared and ascertain what code requirements applies to that space (or work area) When there is a change in space, we are then talking about a change of use and requirements in those areas. It is a Designer/B.O. hand in hand operation.

The B.O. determines what the applicable code requirements to be met are from interpretation of the plans and the interpretation of the adopted building codes.

The effected area is determined from the information you provide of before & after changes and the code requirements that are to be applied and then ascertain whether it is compliant. As is said, the B.O. doesn't design the work. They determine code compliance from the work that is designed and then whether to issue permit or not.


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## Daddy-0- (Jul 23, 2011)

I agree with Mtlogcabin. If the work does not match the plans they should resubmit an amended version to plan review. Plans written and work installed must match or resubmit. IMO.


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## brudgers (Jul 23, 2011)

RickAstoria said:
			
		

> The B.O. determines what the applicable code requirements to be met are from interpretation of the plans and the interpretation of the adopted building codes.


In the case of a lay person without a license, that may be the case.

Licensed design professionals are expected to be capable of determining the code requirements on their own - such as those found in Chapter 5 of the IBC.

This is done by reading the code - and reading the code for each and every project is a good practice - and far better than just going from memory.


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## fatboy (Jul 23, 2011)

"In the case of a lay person without a license, that may be the case.

Licensed design professionals are expected to be capable of determining the code requirements on their own - such as those found in Chapter 5 of the IBC.

This is done by reading the code - and reading the code for each and every project is a good practice - and far better than just going from memory."

That may be the expectation, but it is certainly not what happens in real life. Not saying all the time, or all DP's, just saying that there is a reason there are plan reviewers. I've had DP's admit to me they tried to slip something by. There are plenty that have no clue, or could care less, what the code says. To the ones that do care, and read/research the code, my hat is off to you.


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## brudgers (Jul 23, 2011)

Just so you are aware, the reference to chapter 5 of the IBC is related to an ongoing discussion on another internet.

In that discussion, an unlicensed person offered an interpretation of table 506 which indicated a fundamental misunderstanding of the information contained in the table.

It was suggested to that person that they actually read chapter 5 and figure out why their answer was off base.

However, that suggestion was not followed through, and an opportunity was taken here to suggest that the ability to do basic code research would be helpful in fulfilling their career plans.


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## mark handler (Jul 23, 2011)

brudgers said:
			
		

> ... related to an ongoing discussion on another internet....


Is there another internet?

Is that the one Al Gore created?


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## RickAstoria (Jul 23, 2011)

brudgers said:
			
		

> In the case of a lay person without a license, that may be the case.Licensed design professionals are expected to be capable of determining the code requirements on their own - such as those found in Chapter 5 of the IBC.
> 
> This is done by reading the code - and reading the code for each and every project is a good practice - and far better than just going from memory.


Not true. Not really. Ok, it is presumed that any building designer or licensed architect or engineer would be able to understand the code. However, it would also be expected that every person is intelligent enough to understand the code. However, it is not expected of an RDP to be an expert of the code and is not expected to properly interpret the code otherwise ALL architects would A) Have to pass the Plan Reviewer exams as part of the architectural licensing exam in addition to the ARE and then have the ability to submit without plan review. If it was really and truly expected by law, then why would you have to have your plans reviewed. It is customarily expected by clients that you have a better grasp of the code then the client. Otherwise, why did they hire you? If you want to be qualified then you need to not only pass plan reviewer exams for BOTH residential and commercial level plan review, you need to also maintain continuing education like a certified plan reviewer in addition to the exams and continuing education required for architectural. If you want that status than maybe the state law should require all architects to pass the Plan Reviewer exams for both Residential and Commercial level (whatever they want to call it), but also ARE & state exam(s) and also maintain continuing education in code updates as well as normal continuing education (no double dipping).

Are you up for that?


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## RickAstoria (Jul 23, 2011)

brudgers said:
			
		

> In the case of a lay person without a license, that may be the case.Licensed design professionals are expected to be capable of determining the code requirements on their own - such as those found in Chapter 5 of the IBC.
> 
> This is done by reading the code - and reading the code for each and every project is a good practice - and far better than just going from memory.


Not if any projects recently have been mostly IRC related stuff which didn't involve Chapter 5 of IBC.


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## RickAstoria (Jul 23, 2011)

mark handler said:
			
		

> Is there another internet?Is that the one Al Gore created?


He meant another internet site not another internet. Note the->   ....


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## RickAstoria (Jul 23, 2011)

brudgers said:
			
		

> It was suggested to that person that they actually read chapter 5 and figure out why their answer was off base.However, that suggestion was not followed through, and an opportunity was taken here to suggest that the ability to do basic code research would be helpful in fulfilling their career plans.


I think the unlicensed person already agreed and didn't want to pursue an ongoing debate and accepted it. Why an ongoing discussion. BTW: It was Table 503 not Table 506.

http://www.korel.com/construction-type.asp - Obviously This is partly wrong. I would not argue "protected" or "not protected" but it has some point to it and gives a sense of what kind of building fits the categories. It is not really matter of protected or not protected. I say that it is a matter of levels of fire-protection. Essentially, there is 5 types of construction and 2 levels of fire protection rating standard.

I would argue that in each Construction Type Category I, II, III, IV or V - there is two levels of construction ratings. Level A and Level B. In essence, Type I or II is always fire-rated construction. But it is the level of rating as I study it.


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## KZQuixote (Jul 23, 2011)

brudgers said:
			
		

> Just so you are aware, the reference to chapter 5 of the IBC is related to an ongoing discussion on another internet.In that discussion, an unlicensed person offered an interpretation of table 506 which indicated a fundamental misunderstanding of the information contained in the table.
> 
> It was suggested to that person that they actually read chapter 5 and figure out why their answer was off base.
> 
> However, that suggestion was not followed through, and an opportunity was taken here to suggest that the ability to do basic code research would be helpful in fulfilling their career plans.


Hey Ben,

Did they use a three corner rule on your fingers in school?

What possible connection could this thread have to another internet?

If the poster on this alternate internet missed some fundamental point, why wasn't it pointed out to him/her? Oh I get it! In this alternate Internet as may be the case in alternate Universes, the same rules don't apply to each.

That being the case, I'm glad to be part of this one!

Bill

Given that you mistyped and were referring to another site on this internet. What possible relevance could that have here? This discussion is totally and thoroughly contained in this thread. How else could the membership keep up?


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## RickAstoria (Jul 23, 2011)

Ben is just razzing me. That is all. I know who and what Ben is talking about. It has little to any relevance to this forum and this thread.

Ben, I already had looked at Chapter 5 and looked it over. I didn't bother to discuss that end of the topic because I agreed with the person who gave the correction. You do realize that I have original IBC 2006 from ICC prior to the publishing of the commentary version. That was not available for purchase at the time.

It was part of a set of books purchased. Also, it never really defined A & B of each type.

It should have been and indicated in footnotes to the Tables with some sort of brief commentary.


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## rooster (Jul 23, 2011)

RickAstoria said:
			
		

> Not true. Not really. Ok, it is presumed that any building designer or licensed architect or engineer would be able to understand the code. However, it would also be expected that every person is intelligent enough to understand the code. However, it is not expected of an RDP to be an expert of the code and is not expected to properly interpret the code otherwise ALL architects would A) Have to pass the Plan Reviewer exams as part of the architectural licensing exam in addition to the ARE and then have the ability to submit without plan review. If it was really and truly expected by law, then why would you have to have your plans reviewed. It is customarily expected by clients that you have a better grasp of the code then the client. Otherwise, why did they hire you? If you want to be qualified then you need to not only pass plan reviewer exams for BOTH residential and commercial level plan review, you need to also maintain continuing education like a certified plan reviewer in addition to the exams and continuing education required for architectural. If you want that status than maybe the state law should require all architects to pass the Plan Reviewer exams for both Residential and Commercial level (whatever they want to call it), but also ARE & state exam(s) and also maintain continuing education in code updates as well as normal continuing education (no double dipping).Are you up for that?


But in the end...after the reviewer has made his review and ALL is said and done...who is responsible...no matter what the BO approves or does not approve?  If the DP misses a handrail extension and the BO misses that the DP missed the handrail extension...who's responsible for that omission when it is built incorrectly in the field?


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## KZQuixote (Jul 23, 2011)

"Ben is just razzing me. That is all. I know who and what Ben is talking about. It has little to any relevance to this forum and this thread."

My Point perzactly!

Private jokes and joans should be limited to private messages and not posted in such a manner that regular members are left wondering what they missed!

Bill


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## brudgers (Jul 23, 2011)

mark handler said:
			
		

> Is there another internet?Is that the one Al Gore created?


It was the one used to accomplish the mission.


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## RickAstoria (Jul 23, 2011)

rooster said:
			
		

> But in the end...after the reviewer has made his review and ALL is said and done...who is responsible...no matter what the BO approves or does not approve?  If the DP misses a handrail extension and the BO misses that the DP missed the handrail extension...who's responsible for that omission when it is built incorrectly in the field?


Sure. Due diligence and E&O. The DP (whether licensed or not) would be the target of lawsuits because the states surely has indemnification by statutes while the DP's weewee is flapping in the wind to get shot off. So, unlucky you, the DP. Life isn't always fair.


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## peach (Jul 24, 2011)

we're far afield from the OP... and the thread is no longer relevant.


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## jar546 (Jul 24, 2011)

I will unlock this if someone PMs me and wants to get this back on topic.  This is too important of an issue to massacre this thread.


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