# ICC's perspective on 'work area' and its effect on IEBC compliance.



## Mr Softy (May 16, 2012)

in our never-ending quest to get a clear, working definition of the 'work area' and it's relationship to Levels 1,2 & 3 work, we recently had an interesting chat with ICC on said subject.

we recently had a 3-family (traditional 3 decker) under renovation on all 3 floors.  architect submitted plans dilineating the Level 2 'work area' at 42% of the building.  OK.   a field inspection revealed work in excess of what was indicated on the plans.

some of the work was exempt as being 'not initially intended'.  OK.  IEBC includes that exemption as part of the definition.

However, considering everything else being done, including all new systems, it was our interpretation that the work area now was over 50%.  so the fire protecton upgrades of 704.2.2 would apply.

as part of our review of the architect's recalculation of work area (under 50%), we contacted ICC to hear their take on 'work area'.

ICC felt that the reconfigured space could/should be calculated as one figure for Level 2 work,  and everything else could be calculated at a different figure as Level 1 work.  basically allowing Levels 1 & 2 to coexist on the same project, and parsing off the 'reconfigured space' when determining if the project escalates to the upgrades of Level 2 or Level 3.  by this method, and with careful math, no project should ever get to a work area of >50%.

both our department, and the state's Fire Services are having a difficult time with this interpretation.  IEBC was adopted because it had provisions for updating fire protection, which we have always had in cases of buildings undergoing extensive renovation.

the main difficulty comes with residential multi-family buildings undergoing substantial, building-wide renovation.   there is state law governing FP upgrades in commercial buildings.  upgrades in residential have always been required through the building code.  it has been part of our state's building code intent for many years.

as i see it, IEBC, creatively applied, would/should never require FP upgrades, even though those triggers are part of the code.

the RDP could -

1. pull a permit for limited work, and once underway, call everything else 'not initially intended'.  or.

2. calculate work area sq footage to the barest minimum (thickness of wall or door), and never exceed 50% of the floor or total area of the building.

curiouser and curiouser.


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## TheCommish (May 16, 2012)

Stick to your guns, it sound like a gut remodel carefully presented to be below the threshold of requiring all the upgrades. I would make them comply with the upgrades by letter citing chapter and verse and had them the appeal paper work at the same time.

The ICC jus has opinions  and is not the enforcing AHJ


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## mtlogcabin (May 16, 2012)

It is not just 50% of the work area. There are 4 conditions that have to be met 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. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction;

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.

Are there corridors shared by different tenants?

Does the building have sufficient water available at the floor?


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## Mr Softy (May 16, 2012)

mtlogcabin said:
			
		

> Are there corridors shared by different tenants?
> 
> Does the building have sufficient water available at the floor?


yes, triple decker, shared front stair and back stair.

yes, we're in the city


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## brudgers (May 16, 2012)

Well, it's deja vu all over again, with an ICC interpretation on top.

  You got the code you wanted, now enforce it the way it was written.

  Until you can change it to something more danceable.


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## Mr Softy (May 16, 2012)

brudgers, i have you on perma-ignore.

i do not know what you posted, nor do i care.

thank you for playing.  good bye.


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## brudgers (May 16, 2012)

I'm in good company.

  You ignore the building code too.


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## mtlogcabin (May 16, 2012)

I agree the the ICC on this one

Chapter 7 Alterations—Level 2. Like Chapter 6, the purpose of this chapter is to provide detailed requirements and provisions to identify the required improvements in the existing building elements, building spaces and building structural system. This chapter is distinguished from Chapters 6 and 8 by involving space reconfiguration that could be up to and including 50 percent of the area of the building. In contrast, Level 1 alterations (Chapter 6) do not involve space reconfiguration and Level 3 alterations (Chapter 8) involve extensive space reconfiguration that exceeds 50 percent of the building area. Depending on the nature of alteration work, its location within the building and whether it encompasses one or more tenants, improvements and upgrades could be required for the open floor penetrations, sprinkler system or the installation of additional means of egress such as stairs or fire escapes.

Only the reconfigured space/areas count towards level 2 or 3 and without knowing the specific details of the project it is hard say if it exceeds 50% or not. The designer does have the option of using  101.5.3 Performance compliance method and it could be 100% reconfiguration and not require sprinklers.

[h=2]re·con·fig·ure[/h]   /ˌrikənˈfɪgyər/ Show Spelled[ree-kuhn-fig-yer] Show IPA

verb (used with object), re·con·fig·ured, re·con·fig·ur·ing. to change the shape or formation of; remodel; restructure.


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## Papio Bldg Dept (May 16, 2012)

Softy...if the project scope does not match the permit scope, then re-review the project for the actual scope in accordance with your adopted codes.  If the codes do not meet the expectations of the AHJ, whether it is due to loop holes or vague language, then you may go down the amendment and policy change road for future projects, I recommend not changing the rules mid-game if your expectations are not being met now, even if the owner/RDP are trying to pull a fast-one over on you.

It might be time to put on your waffle cone pants.  Good luck.


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## Papio Bldg Dept (May 16, 2012)

brudgers said:
			
		

> Well, it's  deja vu all over again, with an ICC interpretation on top. You got the code you wanted, now enforce it the way it was written.
> 
> Until you can change it to something more danceable.





			
				brudgers said:
			
		

> I'm in good company.   You ignore the building code too.


With a Milton's rule sig, that is very small of you brudgers.

The least you could do is put on your plans examiner hat one more time and give us a step by step account of how the brudger's would have approved this set of plans.

Softy...maybe a few more details in line with mt's posts would be helpful too.


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## brudgers (May 17, 2012)

Papio Bldg Dept said:
			
		

> With a Milton's rule sig, that is very small of you brudgers.  The least you could do is put on your plans examiner hat one more time and give us a step by step account of how the brudger's would have approved this set of plans.    Softy...maybe a few more details in line with mt's posts would be helpful too.


  I think you misunderstand Milton's Rule.     It doesn't mean that every set of plans get approved.

    Or that one ignores the code.

    What Milton's Rule means is that one approaches plan review with the hope of approving the plans and feels disappointment rather than satisfaction when one cannot.

    What Milton's Rule means is that if placing a simple notation on the plans is the difference between approving and rejecting the plans, you place the notation.

    What Milton's Rule means is that if a phone call to the design professional can get you what you need to approve the plans in a day or two, then you make the call.

    But above all, what Milton's Rule means is that you don't go searching for reasons to reject the plans, you don't go stretching your interpretation in order to reject the plans, and you don't bring a chip on your shoulder, a righteous agenda, or any other prejudice to your review...

  In practice that requires interpreting the code in light of common practices.

  In practice that requires interpreting the code to let people go about their business in a reasonably safe manner.

  Most importantly, in practice it requires allowing things that you don't really like.

    ...or at least that's what you try to do.

    That's not the case here.    Unsurprisingly.


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## Mr Softy (May 17, 2012)

mtlogcabin said:
			
		

> Only the reconfigured space/areas count towards level 2 or 3 and without knowing the specific details of the project it is hard say if it exceeds 50% or not. The designer does have the option of using  101.5.3 Performance compliance method and it could be 100% reconfiguration and not require sprinklers.


yes, he does, if the existing building meets the criteria set forth in 101.5.1.  agreed.

and here we are with that nebulous phrase 're-configured space' again.  one might see a moved wall and see an entire room as having been reconfigured.  another might look and see only a wall.



			
				Papio Bldg Dept said:
			
		

> Softy...if the project scope does not match the permit scope, then re-review the project for the actual scope in accordance with your adopted codes.


which is what happened, and this is when it usually comes up.  submitted drawings show one thing, field conditions reveal something completely different.  after consideration, it was agreed that the scope was still under 50%, applying ICCs interpretation on Level 1 and Level 2 co-existing.



			
				Papio Bldg Dept said:
			
		

> If the codes do not meet the expectations of the AHJ, whether it is due to loop holes or vague language, then you may go down the amendment and policy change road for future projects ...


this is the path being followed with the state code board.



			
				Papio Bldg Dept said:
			
		

> I recommend not changing the rules mid-game if your expectations are not being met now, even if the owner/RDP are trying to pull a fast-one over on you.


agreed.

here's the crux of the biscuit, so to speak.

why does the IEBC have any language at all regarding FP upgrades as triggered by scope of work, when, by their own definitions and interpretations, one can use creative accounting and *NEVER* get there?

in the examination of the IEBC before adoption, the work area method of requiring FP upgrades looked pretty good.  we have always had a trigger for these upgrades in our homegrown code - as i stated it's been a core philosphy of our building code for many years.  the upgrades were based on cost of work compared to cost of sprinklers.  but it was pretty easy to game that system and avoid sprinkling buildings undergoing 'substantial renovation' (our code term).

as we're now into a year+ of the IEBC, the flaws in the system, and the difficulty of consistent enforcement are coming to light.

and as stated above, this is a residential renovation issue.

so.

can someone give me an example, hypothetical or real, of Level 2 or Level 3 residential work in which the 50% rule would kick in?


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## brudgers (May 17, 2012)

Mr Softy said:
			
		

> as we're now into a year+ of the IEBC, the flaws in the system, and the difficulty of consistent enforcement are coming to light.


  Well, the way to be consistent is to enforce the code as written.


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## Papio Bldg Dept (May 17, 2012)

brudgers said:
			
		

> Well, the way to be consistent is to enforce the code as written.


Which it appears softy is trying to do that, however we are dealing with near Falstaff-ian greatness here.  In brudger terms, it is the code equivalent of asking a guard to stand outside a tower door and make sure nobody leaves.


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## mtlogcabin (May 17, 2012)

> can someone give me an example, hypothetical or real, of Level 2 or Level 3 residential work in which the 50% rule would kick in?


See Section 403

Gutting a kitchen and relocating the plumbing fixtures and cabints or counters. Expanding a laundry room or bathroom. Removing or adding walls.

Replacing a door or windows would not include the entire floor space in the affected room. These items are under level 2 because when replaced they are required to meet todays code. Doors for egress size, swing and hardware, Windows for EERO, safety glazing, energy code to name a few.

The IEBC is similar to Pelosie's comment on Obama care.

"We have to adopt it to find out what's in it"

Until we start using a code regularly and consistantly we really do not have an understanding of what's in it.

I have a bigger problem with this part than figuring work areas

. 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.

Does that mean a riser already has to be inplace or just that the municiple water supply will be able to provide water to the height needed without a fire pump. The latter seems logical but the actual wording indicates the water supply needs to exist within the building.

From a literal interpretation I do not see where a spinkler can be required in a building that does not have a riser stand pipe already installed

What are your thoughts?


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## Mr Softy (May 17, 2012)

mtlogcabin said:
			
		

> See Section 403Gutting a kitchen and relocating the plumbing fixtures and cabints or counters. Expanding a laundry room or bathroom. Removing or adding walls.


is this the 50% example? or just examples of Level 2? the first sentence is Level 1 - no reconfiguration - unless the cabinet layout is different, then maybe... 



> Replacing a door or windows would not include the entire floor space in the affected room. These items are under level 2 because when replaced they are required to meet todays code. Doors for egress size, swing and hardware, Windows for EERO, safety glazing, energy code to name a few.


no, they are not Level 2, unless they are relocated windows or doors.  if they are straight replacements in the existing opening, that is level 1.  and yes, they need to meet code for new const.



> Until we start using a code regularly and consistantly we really do not have an understanding of what's in it.


yup.



> I have a bigger problem with this part than figuring work areas
> 
> . 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.
> 
> ...


this.


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## brudgers (May 17, 2012)

mtlogcabin said:
			
		

> for design


  I think the code is clear and says what it says.


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## brudgers (May 17, 2012)

Papio Bldg Dept said:
			
		

> Which it appears softy is trying to do that, however we are dealing with near Falstaff-ian greatness here.  In brudger terms, it is the code equivalent of asking a guard to stand outside a tower door and make sure nobody leaves.


  I'm reminded more of the progress of Lancelot running toward the guards at the gate.


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## Papio Bldg Dept (May 17, 2012)

Mr Softy said:
			
		

> why does the IEBC have any language at all regarding FP upgrades as triggered by scope of work, when, by their own definitions and interpretations, one can use creative accounting and NEVER get there?


Sometimes, I just say I don't know the answer...this one of those sometimes.



			
				Mr Softy said:
			
		

> can someone give me an example, hypothetical or real, of Level 2 or Level 3 residential work in which the 50% rule would kick in?


Yes, the one in which the RDP designs it that way.


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## Mr Softy (May 18, 2012)

Papio Bldg Dept said:
			
		

> Yes, the one in which the RDP designs it that way.


excellent.  that RDP needs to hire me as a code consultant.


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## brudgers (May 18, 2012)

Mr Softy said:
			
		

> excellent.  that RDP needs to hire me as a code consultant.


  I wonder what the tuition is at Softy's Dance Studio


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## Mr Softy (May 21, 2012)

Mr Softy said:
			
		

> can someone give me an example, hypothetical or real, of Level 2 or Level 3 residential work in which the 50% rule would kick in?


no takers?


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## Builder Bob (May 22, 2012)

Hypothetically - conversion of large condos w/ lofts into smaller condos to fit into the more "current" economic times.......


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## Mr Softy (May 23, 2012)

Good example.

It's a change of occupancy as defined in Section 2.  But the occupancy classification doesn't change (so 912 doesn't apply)

But Chap 4 kicks in.  And here we go with 'work area' again.

In your example, are you going to consider the total square footage of the newly created units as the 'reconfigured space'?

Because I'm going to use ICC interp and only count the area of the moved walls and new doors as level 2 work and stay well under the 50% triggers.

But wait.  The reconfiguration of the heating system counts as Level 2 work.  But I'll only count the new mechanical closet as reconfigured.  And I'll still be under 50% triggers.


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## Builder Bob (May 24, 2012)

Work area is not defined by the actual wall that is depicted. The work area is the area needed to perform the work .......for example a plan depicts a wall of 16 feet in height..... the wall will have gypsum placed on both sides for full height.

The workers don't stay in the four inch width of the wall to perform work. Are they using scissor lifts, ladders, scaffolding, what?

New HVAC system - How is the duct work going to be installed? Does it magically appear in the open web trusses overhead? Does it float up their and attach itself as required by the codes for support?

Folks,

Common sense should apply........ And be realistic.  As the interpretations rendered by ICC always state - this is their interpretation and it may differ than the AHJ at the local level.

As a plan reviewer in the past, I would often call the contractor and ask him/her to realistically tell me how much room or area they needed to perform the work. That defined the work area...... If the contractors work area was smaller than what the designer stated, I always took the most restrictive approach to maximize the SAFETY of the public that we are suppose to serve and protect.


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## Mr Softy (May 24, 2012)

Bob, you're making my point for me.



			
				Builder Bob said:
			
		

> Work area is not defined by the actual wall that is depicted.


ahhh, but this argument has been made in previous discussions of work area.



			
				Builder Bob said:
			
		

> The workers don't stay in the four inch width of the wall to perform work. Are they using scissor lifts, ladders, scaffolding, what?


yup.  i would agree with that assessment.



			
				Builder Bob said:
			
		

> Folks,Common sense should apply........ And be realistic.  As the interpretations rendered by ICC always state - this is their interpretation and it may differ than the AHJ at the local level.


you will incur the wrath of the design community with crazy talk like that.  your motives could be called into question.



			
				Builder Bob said:
			
		

> As a plan reviewer in the past, I would often call the contractor and ask him/her to realistically tell me how much room or area they needed to perform the work. That defined the work area...... If the contractors work area was smaller than what the designer stated, I always took the most restrictive approach to maximize the SAFETY of the public that we are suppose to serve and protect.


agreed.  that's what we do in our office.

and that's why this is such a valid discussion.  IEBC talks about 'work area' and 'reconfigured space' but does a really crappy job defining what those terms mean.  we have recently adopted IEBC and are attempting to formulate a workable, consistent, and enforceable interpretation.

ICCs interp is a load of rubbish, IMHO.  sets up the FP triggers as false idols- looks like they care about FP upgrades, but then interp in a way that they never can be reached.


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## Papio Bldg Dept (May 24, 2012)

Mr Softy said:
			
		

> ICCs interp is a load of rubbish, IMHO.  sets up the FP triggers as false idols- looks like they care about FP upgrades, but then interp in a way that they never can be reached.


I would say that interp is the way it is because of the poor code language and definitions.  The Inconsistent Code Council is just as subceptible to writing unenforceable code as your department is.  Good luck, and be careful.


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## mtlogcabin (May 24, 2012)

> IEBC talks about 'work area' and 'reconfigured space' but does a really crappy job defining what those terms mean. we have recently adopted IEBC and are attempting to formulate a workable, consistent, and enforceable interpretation.


That is good and exactly what the building department should do with regards to the application of "work areas" definition in your jurisdiction. What ever is decided for your jurisdiction just be consistant in the application of it.

104.1 General.

The code official is hereby authorized and directed to enforce the provisions of this code. The code official shall have the authority to render interpretations of this code and to adopt policies and procedures in order to clarify the application of its provisions. Such interpretations, policies, and procedures shall be in compliance with the intent and purpose of this code. Such policies and procedures shall not have the effect of waiving requirements specifically provided for in this code.


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## Mr Softy (May 24, 2012)

Papio Bldg Dept said:
			
		

> I would say that interp is the way it is because of the poor code language and definitions.  The Inconsistent Code Council is just as subceptible to writing unenforceable code as your department is.  Good luck, and be careful.


that's certainly true.

our department doesn't 'write' code language.  we're trying to enforce the ICCs language in a way that reflects real construction.  and keeps the state philosophy and history of FP upgrades when applicable.


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## skipharper (May 24, 2012)

When we can, lets rule out yes before we answer no!!itty


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## Mr Softy (May 24, 2012)

skipharper said:
			
		

> When we can, lets rule out yes before we answer no!!itty


that's helpful.


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## Mr Softy (May 24, 2012)

mtlogcabin said:
			
		

> That is good and exactly what the building department should do with regards to the application of "work areas" definition in your jurisdiction. What ever is decided for your jurisdiction just be consistant in the application of it.104.1 General.
> 
> The code official is hereby authorized and directed to enforce the provisions of this code. The code official shall have the authority to render interpretations of this code and to adopt policies and procedures in order to clarify the application of its provisions. Such interpretations, policies, and procedures shall be in compliance with the intent and purpose of this code. Such policies and procedures shall not have the effect of waiving requirements specifically provided for in this code.


this is good.  except.

this section has been struck through amendment.  promulgation and interpretation is the jurisdiction of the state.


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## mtlogcabin (May 24, 2012)

Mr Softy said:
			
		

> this is good. except.this section has been struck through amendment. promulgation and interpretation is the jurisdiction of the state.


What the state doesn't know may keep you from :banghd

Seriously if the state will not give you direction/clarification in this area then adopt your own policy. Your chances of being challenged are low and if you are it will force the state to address your concerns of how to consistantly apply the numbers to a work area description.   Either way you have something to work with now and in the future


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## brudgers (May 24, 2012)

Mr Softy said:
			
		

> this is good.  except.  this section has been struck through amendment.  promulgation and interpretation is the jurisdiction of the state.


  And this thread and the suggestion of hiring a person charged with interpreting the code as a consultant is why.


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## Mr Softy (May 25, 2012)

mtlogcabin said:
			
		

> Seriously if the state will not give you direction/clarification in this area ...


that's what we're working on.


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## brudgers (May 25, 2012)

Yes you've already established that you are doing things you don't want the state to know about.


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## mtlogcabin (Jul 18, 2012)

Found this interpretation with regards to sprinkler requirements in an existing building Level 2 alterationhttp://www2.iccsafe.org/cs/committeeArea/pdf_file/EB_03_12_04.pdf''>http://www2.iccsafe.org/cs/committeeArea/pdf_file/EB_03_12_04.pdf' rel="external nofollow">

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


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