# Change of use/Occupancy - Printing/publishing to Wood Pallet Manufacturing?



## Truck3capt (Feb 15, 2016)

I'm being questioned about the code sections referenced by former officials in my division. The business in question was previously a commercial printing and publishing facility for at least 40 years prior to 2010. They went out of business in 2010 the buildings sold and the new owner offered to lease the building to a company that manufactured wood pallets. About 30,000 SF under roof. 5B construction. No sprinkler. The owner/tenant requested zoning relief and rec'd a use variance. No permits for remodeling work within the building were ever pulled when the pallet company moved in. They essentially moved into the building and started operating.  (IFC 2006 is our adopted fire code with the State also adopting 2000 Life Safety 101.)

Flash forward to late 2012: Previous officials cited violations for a change of use, high piled combustible storage (idle pallets stacked to the ceiling well in excess of 12') and other violations after a complaint was filed and an inspector entered the building for a routine inspection.  Solution: Sprinkle the building.

Flash forward to today. (this is still dragging on) As requested I site several code sections that I think require sprinklers based on the notes from the previous officials that were dealing with this building.  Section 102 Applicability,  Sections from Chapt. 23 High Piled Combust. storage and table 2306.2 for High hazard Commodities, Section 903 on sprinklers based on an F-1 Occupancy with combined fire areas exceeding 24,000 SF.

Today I'm told that they don't think any of this applies to them because this was an existing building and there was no change of use/occupancy because the F-1 Occupancy definitions include a printing and publishing operation.   I used F-1 as the closest occupancy to the wood pallet operation they have in the building today.  I think Section 102 applies but they are hanging their hat on the F-1 definition and the print/publishing operation being no more hazardous than the pallet operation that has moved into the building.

We've burned one pallet repair operation to the ground during my time on the job and had fires at two others.  The first company to arrive at the one that burned down arrived in two minutes and the fire was already coming out of all of the eaves of the building.

I may not get to offer any more opinions on this, I'm not sure they want to hear it, but I'd sure like to think that I'm not completely out in left field on this one.  It's going to come up again.  I meant to look at the commentary before I left the office but I was kind of ticked after getting browbeaten for something that I was just trying to clean up.  Thanks

Truck


----------



## cda (Feb 15, 2016)

1. Sounds like high pile chapter applies.

Which would kick in fire sprinklers

2. Chapter 19 applies.

Which would kick in sprinklers

903.2.3.1 Woodworking operations.

An automatic sprinkler system shall be provided throughout all Group F-1 occupancy fire areas that contain woodworking operations in excess of 2,500 square feet in area (232 m2) which generate finely divided combustible waste or which use finely divided combustible materials.

Maybe not a change of occupancy, but the new business has brought in a process that does not meet the fire code.

Palleys burn great!! Maybe burn a six foot high stack. Record it. Show it to everyone and ask if they want this times a lot.


----------



## cda (Feb 15, 2016)

You can always require a technical report, paid for by the business, done by some one you approve, to see what an expert says.


----------



## steveray (Feb 16, 2016)

*CHANGE OF OCCUPANCY.* A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code

*901.2 Change in occupancy with no change of occupancy classification.* A change in occupancy, as defined in Section 202, with no _change of occupancy_ classification shall not be made to any structure that will subject the structure to any special provisions of the applicable _International Codes_, including the provisions of Sections 902 through 911, without the approval of the _code official_. A certificate of occupancy shall be issued where it has been determined that the requirements for the change in occupancy have been met.


----------



## Truck3capt (Feb 16, 2016)

> 1. Sounds like high pile chapter applies.Which would kick in fire sprinklers
> 
> 2. Chapter 19 applies.
> 
> ...


I wasn't around when all this started but from what I can see in the file and what I can tell from the codes they referenced in the original citation (and some that they didn't but could have referenced) that this thing should be sprinklered.  The F-1 argument seems ridiculous but my own city legal department is arguing that a judge will see the two uses as the same.  I think they are getting pressure from somewhere else not to pursue it.  That said I want to cover my butt in the documentation I've been asked to provide.


----------



## steveray (Feb 16, 2016)

Do you just have the IFC or do you have IBC/ IEBC? See definition of change of occupancy above...


----------



## Truck3capt (Feb 16, 2016)

> *CHANGE OF OCCUPANCY.* A change in the purpose or level of activity within a building that involves a change in application of the requirements of this code*901.2 Change in occupancy with no change of occupancy classification.* A change in occupancy, as defined in Section 202, with no _change of occupancy_ classification shall not be made to any structure that will subject the structure to any special provisions of the applicable _International Codes_, including the provisions of Sections 902 through 911, without the approval of the _code official_. A certificate of occupancy shall be issued where it has been determined that the requirements for the change in occupancy have been met.


The existing building code reference of 902.1 doesn't show up in the IBC or IFC, does it?


----------



## Truck3capt (Feb 16, 2016)

> Do you just have the IFC or do you have IBC/ IEBC? See definition of change of occupancy above...


Yes I'm looking at the IEBC 2006 right now.  I'm trying to stick with the IFC only because that is where all of the original references were pulled from when this owner was originally cited.


----------



## cda (Feb 16, 2016)

> I wasn't around when all this started but from what I can see in the file and what I can tell from the codes they referenced in the original citation (and some that they didn't but could have referenced) that this thing should be sprinklered.  The F-1 argument seems ridiculous but my own city legal department is arguing that a judge will see the two uses as the same.  I think they are getting pressure from somewhere else not to pursue it.  That said I want to cover my butt in the documentation I've been asked to provide.


The occupancy type might be the same,,,

But what they are doing inside pulls in the IFC

Would the city allow them to make tires, than stack / store them 20 feet in the air?

Ok it is a factory, but now they are doing high piled stock!!!!  Which kicks in additional requirements, such as a fire sprinkler system sometimes!!!


----------



## cda (Feb 16, 2016)

Have the city agree to requiring a technical report, from someone you approve.


----------



## Truck3capt (Feb 16, 2016)

> Have the city agree to requiring a technical report' date=' from someone you approve.[/quote']IFC 2006 104.7.2, correct?  I doubt that city legal will do that.  When the owner balked recently at the sprinkler system (that he previously agreed to install) they asked for other options.  Our direction was to hire a design professional to evaluate the building and operations and submit documents that we could review to see if they had a viable solution.  I think they contacted local politicians instead


----------



## steveray (Feb 16, 2016)

2006 IFC

*102.3 Change of use or occupancy.* 

No change shall be made in the use or occupancy of any structure that would place the structure in a different division of the same group or occupancy or in a different group of occupancies, unless such structure is made to comply with the requirements of this code and the _International Building Code_. Subject to the approval of the fire code official, the use or occupancy of an existing structure shall be allowed to be changed and the structure is allowed to be occupied for purposes in other groups without conforming to all the requirements of this code and the _International Building Code_ for those groups, provided the new or proposed use is less hazardous, based on life and fire risk, than the existing use.

*102.4 Application of building code.* 

The design and construction of new structures shall comply with the _International Building Code,_ and any alterations, additions, changes in use or changes in structures required by this code, which are within the scope of the _International Building Code,_ shall be made in accordance therewith.

And if you want to play "touch the badge"....

*102.8 Matters not provided for.* 

Requirements that are essential for the public safety of an existing or proposed activity, building or structure, or for the safety of the occupants thereof, which are not specifically provided for by this code shall be determined by the fire code official.


----------



## cda (Feb 16, 2016)

Well someone high in the city needs to decide if the building and fire code are going to be enforced.  If not this business will keep doing what they want.  Than another business come to town and hear they don't have to follow codes.  And if the city does not enforce, the fire chief should say without following the codes, the building cannot be properly protected and will not put firefighters in a hazardous condition.  So the fire department will not go in, and will only confine the fire to the property


----------



## Truck3capt (Feb 16, 2016)

> 2006 IFC*102.3 Change of use or occupancy.*
> 
> No change shall be made in the use or occupancy of any structure that would place the structure in a different division of the same group or occupancy or in a different group of occupancies, unless such structure is made to comply with the requirements of this code and the _International Building Code_. Subject to the approval of the fire code official, the use or occupancy of an existing structure shall be allowed to be changed and the structure is allowed to be occupied for purposes in other groups without conforming to all the requirements of this code and the _International Building Code_ for those groups, provided the new or proposed use is less hazardous, based on life and fire risk, than the existing use.
> 
> ...


Thanks.  I have the 102.3 and 102.4 sections included in my references I'm preparing to forward.  I may mention the "touch the badge":lemo:  reference but I think the other references should cover this unless there is just no will to pursue it by those above me.


----------



## Truck3capt (Feb 16, 2016)

> Well someone high in the city needs to decide if the building and fire code are going to be enforced. If not this business will keep doing what they want. Than another business come to town and hear they don't have to follow codes. And if the city does not enforce' date=' the fire chief should say without following the codes, the building cannot be properly protected and will not put firefighters in a hazardous condition. So the fire department will not go in, and will only confine the fire to the property[/quote']I agree. We've had the building on our dangerous buildings list since all of this started but that doesn't exclude entry in certain situations.(life at stake with possibility of rescue) .  They have two dozen employees working two shifts. If our guys roll up and they can't account for all of the workers they will be forced to make a risk assessment on the potential for a rescue.  The whole thing stinks, it puts everyone involved in a bad spot.  Just follow the code.  This is going to be decided above me. All I can do at this point is offer my opinion on what the code says and document everything.


----------



## cda (Feb 16, 2016)

Yep...........


----------



## Truck3capt (Feb 16, 2016)

Thanks again guys....


----------



## mtlogcabin (Feb 16, 2016)

The high piled storage can be addressed through house keeping, The sprinklers are not required if no finely divided combustible waste or use finely divided combustible materials are generated.

No sprinklers are required if they where not required at the time of original construction. Remember the legacy codes did not address "Fire Areas" within the codes

[F] 903.2 Where required.

Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in this section.

You have to find the charging language that directs you to require code. An F-1 is an F-1  and the 2006 IFC is the adopted code.


----------



## Builder Bob (Feb 18, 2016)

high-piled combustible storage also includes certain high-hazard commodities, such as rubber tires, Group A plastics, flammable liquids, *idle pallets* and similar commodities, where the top of storage is greater than* 6 feet (1829 mm) in height.*


----------



## Insurance Engineer (Feb 18, 2016)

> The high piled storage can be addressed through house keeping, The sprinklers are not required if no finely divided combustible waste or use finely divided combustible materials are generated.No sprinklers are required if they where not required at the time of original construction. Remember the legacy codes did not address "Fire Areas"
> 
> [F] 903.2 Where required.
> 
> Approved automatic sprinkler systems in new buildings and structures shall be provided in the locations described in this


Every pallet manufacture I have been to had uncontrolled combustible dust from the cutting of wood, I am sure they have the same problem here.

What kind of water supply do they have in the area? The sprinkler demands for this occupancy will be very high . If the public water supply is not adequate they may need a fire pump, $100K and a tank another $300K PLUS the cost of the sprinkler system itself. Just another reason why they do not want to install the protection.


----------



## Truck3capt (Feb 18, 2016)

> The high piled storage can be addressed through house keeping, The sprinklers are not required if no finely divided combustible waste or use finely divided combustible materials are generated.No sprinklers are required if they where not required at the time of original construction. Remember the legacy codes did not address "Fire Areas" within the codes
> 
> [F] 903.2 Where required.
> 
> ...


The original inspectors were told that the operation wasn't feasible if he had to limit the piles to six feet in height.  There is a cutting operation.  It shoots sawdust out a hole in the side of the building into the back of a tractor trailer  

Also,  am I understanding you correctly that Section 102.1,102.2, 102.3 and 102.4 along with the Change of Occupancy definition in Chapter 2 don't apply as far as the requirement for sprinklers under the F-1 classification?  A pallet mfgring plant with high-piled comb. storage and a cutting area wouldn't  be a considerable change in the level and type of activity as compared with the printing operation?  Did I interpret the application of the code to an existing building incorrectly based on section 102?


----------



## Truck3capt (Feb 18, 2016)

> Every pallet manufacture I have been to had uncontrolled combustible dust from the cutting of wood, I am sure they have the same problem here.
> 
> What kind of water supply do they have in the area? The sprinkler demands for this occupancy will be very high . If the public water supply is not adequate they may need a fire pump, $100K and a tank another $300K PLUS the cost of the sprinkler system itself. Just another reason why they do not want to install the protection.


You hit the nail on the head.  They previously agreed to sprinkler the building. They waited till the last minute to get pricing.  A pump will be required.  Uh oh. Now what are we going to do?  And here we are....


----------



## cda (Feb 18, 2016)

> The original inspectors were told that the operation wasn't feasible if he had to limit the piles to six feet in height. There is a cutting operation. It shoots sawdust out a hole in the side of the building into the back of a tractor trailer
> 
> Also, am I understanding you correctly that Section 102.1,102.2, 102.3 and 102.4 along with the Change of Occupancy definition in Chapter 2 don't apply as far as the requirement for sprinklers under the F-1 classification? A pallet mfgring plant with high-piled comb. storage and a cutting area wouldn't be a considerable change in the level and type of activity as compared with the printing operation? Did I interpret the application of the code to an existing building incorrectly based on section 102?


If you have adopted the IFC, some people do not understand it is also a design code:::!!!!!!

In my opinion they have to sprinkle the building because

Woodwork chapter 19

High piled stock chapter 23

No matter what!!!!    It can stay the same occupancy,  BUT when the process changes, it has to meet current code


----------



## mtlogcabin (Feb 18, 2016)

> The original inspectors were told that the operation wasn't feasible if he had to limit the piles to six feet in height. There is a cutting operation. It shoots sawdust out a hole in the side of the building into the back of a tractor trailer
> 
> Also, am I understanding you correctly that Section 102.1,102.2, 102.3 and 102.4 along with the Change of Occupancy definition in Chapter 2 don't apply as far as the requirement for sprinklers under the F-1 classification? A pallet mfgring plant with high-piled comb. storage and a cutting area wouldn't be a considerable change in the level and type of activity as compared with the printing operation? Did I interpret the application of the code to an existing building incorrectly based on section 102?


The cutting operation can be limited to less than a 2,500 sq ft fire area. The manufacturing area of the pallets is an F-1. The storage area for the pallets is an S-1. The building can be broken up with fire barriers if the operation will permit.

The high piled storage is a separate issue and would need to comply with Table 2306.2. Pallets fall under High Hazard Commodity and are very limited in size when no sprinklers are provide.

This is where you should find the charging language to require sprinklers, not in Chapter 9 IMHO if you are challenged in court or by the powers to be.

Section 102 is general in it tells the fire code may be applicable under certain conditions/situations. You have to find the specific code sections that apply to each condition or situation and apply it accordingly.

The IEBC is pretty specific when requiring a sprinkler system for a change of occupancy and "level of activity" is not included

912.2 Fire protection systems.

Fire protection systems shall be provided in accordance with Sections 912.2.1 and 912.2.2.

912.2.1 Fire sprinkler system.

Where a change in occupancy classification occurs that requires an automatic fire sprinkler system to be provided based on the new occupancy in accordance with Chapter 9 of the International Building Code, such system shall be provided throughout the area where the change of occupancy occurs.


----------



## mtlogcabin (Feb 18, 2016)

Chapter 19 is not applicable.

1901.1 Scope.

The storage, manufacturing and processing of timber, lumber, plywood, veneers and byproducts shall be in accordance with this chapter.

This is a lumber yard under chapter 19







This is a plywood plant


----------



## Truck3capt (Feb 18, 2016)

> Chapter 19 is not applicable.1901.1 Scope.
> 
> The* storage, **manufacturing  and processing of* timber, _*lumber*_, plywood, veneers and byproducts shall be in accordance with this chapter.


Chapter 23 is where this all started and what we've always used to address the citation.  The building is a cobbled up mess of 56000 sq.ft. under roof.  We asked them to develop a plan with a design professional to address the size of the fire areas and the cutting operation.  They haven't done that either.

The chapter 19 reference seemed reasonable even though we never pursued it originally.  We've got  lumber stacked in excess of 12 feet high all around the building in every parking area and only a few feet from the building in many cases. I'm not trying to argue with you if you don't think it applies.  I noticed all of the language on raw products , logs stump etc. and I wasn't sure but it seemed like the Scope language concerning the processing of lumber was reasonable.  The place absolutely looks like a lumberyard from the outside with the amount of material stacked everywhere....not to mention the piles and stacks of new pallets and old ones waiting to be recycled.


----------



## cda (Feb 18, 2016)

> Chapter 19 is not applicable.1901.1 Scope.
> 
> The storage, manufacturing and processing of timber, lumber, plywood, veneers and byproducts shall be in accordance with this chapter.
> 
> ...


Sorry

Must have been thinking about

903.2.4.1 Woodworking operations. An automatic sprinkler system shall be provided throughout all Group F-1 occupancy fire areas that contain woodworking operations in excess of 2,500 square feet in area (232 m2) which generate finely divided combustible waste or which use


----------



## cda (Feb 18, 2016)

> The cutting operation can be limited to less than a 2,500 sq ft fire area. The manufacturing area of the pallets is an F-1. The storage area for the pallets is an S-1. The building can be broken up with fire barriers if the operation will permit.
> 
> The high piled storage is a separate issue and would need to comply with Table 2306.2. Pallets fall under High Hazard Commodity and are very limited in size when no sprinklers are provide.
> 
> ...


Just trying to clarify ,,

So in th OP, would you require sprinklers, if they were doing high piled stock ??


----------



## mtlogcabin (Feb 18, 2016)

> Just trying to clarify ' date=',So in th OP, would you require sprinklers, if they were doing high piled stock ??[/quote']HIGH-PILED COMBUSTIBLE STORAGE. Storage of combustible materials in closely packed piles or combustible materials on pallets, in racks or on shelves where the top of storage is greater than 12 feet (3658 mm) in height. When required by the fire code official, high-piled combustible storage also includes certain high-hazard commodities, such as rubber tires, Group A plastics, flammable liquids, idle pallets and similar commodities, where the top of storage is greater than 6 feet (1829 mm) in height.Over 6 feet High Piled Storage Chapter 23 applies2306.1 General.Fire protection and life safety features for high-piled storage areas shall be in accordance with Sections 2306.2 through 2306.10.Table
> 
> 
> 
> ...


/monthly_2016_02/572953f50c41e_highpiled.JPG.fdbb60ed7c2011a69742a51b0b0d4718.JPG


----------



## FM William Burns (Feb 19, 2016)

The problem one will encounter with an occupancy of this type regardless of the chopping up approaches one may consider is the policing. A pallet manufacturer *will* stack pallets throughout 16-18' high since this is what will fit in a transport trailer. The operations is all about handling costs v. labor and the more they need to transfer and process the lower the profit margins they have. The access throughout the exteriors will always be blocked because the nature of their business is making and movement of product. Ours is 50K+ and designed at .60/2000 + 15 heads. They now call this control mode in the standard and based on my experience and understanding on fire behavior any design work is guess work since one can not model a fire within a occupancy like this, the variables are far to excessive versus the burning rate potential. You may want to show the responsible parties and administrative leaders some of the facility fire videos or articles out there to allow them to reconsider if they want to assume the liability to damages to exposure properties (if applicable).


----------



## Truck3capt (Feb 19, 2016)

> The problem one will encounter with an occupancy of this type regardless of the chopping up approaches one may consider is the policing. A pallet manufacturer *will* stack pallets throughout 16-18' high since this is what will fit in a transport trailer. The operations is all about handling costs v. labor and the more they need to transfer and process the lower the profit margins they have. The access throughout the exteriors will always be blocked because the nature of their business is making and movement of product. Ours is 50K+ and designed at .60/2000 + 15 heads. They now call this control mode in the standard and based on my experience and understanding on fire behavior any design work is guess work since one can not model a fire within a occupancy like this' date=' the variables are far to excessive versus the burning rate potential. You may want to show the responsible parties and administrative leaders some of the facility fire videos or articles out there to allow them to reconsider if they want to assume the liability to damages to exposure properties (if applicable).[/quote']I mentioned the fact that we burned a smaller  facility to the ground a few years ago. It was the  middle of the day with an engine company setting a couple blocks away. The workers saw smoke coming from the break room that backed up to the storage area and called 911. 3 minutes later the first company reported heavy fire showing on three sides of the structure.


----------



## Insurance Engineer (Feb 20, 2016)

The following is from FM Data Sheet 8-24 regarding idle pallet storage, some interesting data on these types of fires.

3.1 Loss History

A review of FM Global losses involving the storage of idle pallets from 2002 to 2012 shows that:

 91% of the losses involved idle wood pallet storage, with the remaining 9% involving plastic pallets.  65% of the losses occurred in storage located outside a building.

 57% of the indoor fires reported indicated sprinkler protection was effective, with the remaining reported as ineffective in reducing the extent of the loss. The average monetary loss of fires involving adequately protected pallet storage was 12% of the fires where no or ineffective protection was provided.


----------

