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Occupancy Load Factor - Cold Storage - 2019 CBC

@Tinker2

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May 19, 2021
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1
Location
San Luis Obispo
We are doing a project that includes 200 320SF refrigerated storage containers for palettes of frozen cannabis. They are maintained at minus 28 degrees.

The Building Department is claiming that a person could get stuck inside one of these freezers. (last I heard, hanging out in a -28 degree storage container isn't something you do), and that they need to be unlockable from the inside.

No one could go inside and accidentally get locked in, because it is a difficult, noisy, and timely process to lock the the doors. The Building Department also claims the freezer square footage should be included in the occupant load calculation for egress.

We are claiming that they are not "occupiable space" according to the 2019 CBC Definitions, and not subject to egress requirements for door hardware, or be used in the calculation to determine the safe dispersal area.

Has anyone out there encountered this scenario before? Can freezers be considered occupiable space? Any thoughts? Are their requirements legitimate?

Thank you for your help -
 
I take it they are inside a building???

Yes occupiable

So what door hardware is on the inside??

Normally push plunger and or crank if that fails??

Yes have done a few deep freezes including a Hagen daz deep freeze about the same size,,,, and it had fire sprinklers!!!!
 
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I don’t know about occupiable area and such, but I can’t believe you would even consider not having an emergency exit device on the inside.
 
How could it not be occupiable? It's a room that a person can walk in to. Seems like the Bldg Dept has this one right based on the info you provided.

No different than a grocery warehouse, packing plant, etc. Even the walk-in beer cooler at the liquor store. All occupiable.
 
How could it not be occupiable? It's a room that a person can walk in to. Seems like the Bldg Dept has this one right based on the info you provided.

No different than a grocery warehouse, packing plant, etc. Even the walk-in beer cooler at the liquor store. All occupiable.

Just wondering what the BD is actually wanting???

The thing should come with a door??
 
We have a gas station convenience store with a walk in beer cooler, that's occupiable! You'll have an employee or two going in and retrieving some weed, that would be occupiable? The building itself most likely will need to be fire sprinklered protected with a sprinkler head in each storage container same as a large milk cooler.
(last I heard, hanging out in a -28 degree storage container isn't something you do)
People do some pretty stupid stuff, and the codes try to protect stupid.
 
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