Does Change of Occupancy trigger gurney requirements for existing elevator?

[Yikes]

I have an existing 3-story "Project Homekey" (California) hotel built in the 1980s that is being converted into permanent supportive housing (adding kitchens into hotel rooms to make them into studio apartments). The existing elevator is 2500# capacity, too small to meet toady's gurney requirements in CBC 3002.4a.

Does the change of occupancy trigger a requirement to demo the existing elevator, enlarge the shaft, and install a 3500# "gurney" elevator?
Or do I have to use exception #5 below and ask for an exception?

 

[arwat23]

Personally, I don't think that specific section necessarily applies to your project. The scope of Ch30 applies to the "design, construction, installation, alteration and repair of elevators and conveying systems and their components." If you are not altering the elevator in any way, the chapter should not apply.

That said, if you are altering or if you need to alter the existing elevator as required by Ch11A / Ch11B (or other sections), then CBC Ch30 / CFC § 1103.3.3 would likely apply. Best course of action is to ask the local AHJ for their input since they have the final say.

I'm currently working on a project were the local fire department wants all (new) elevators, regardless of use, to have room for a stretcher.

 

[steveray]

If you use IEBC prescriptive....absolutely, unless the BO accepts it......Work area, maybe not....

 

[Yikes]

If you use IEBC prescriptive....absolutely, unless the BO accepts it......Work area, maybe not....

I've been thinking about this more regarding the California version of the IEBC, and I'm not sure I agree that it triggers elevator enlargement:

506.1 Compliance​

A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the California Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the code official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.


Two observations:
1. The phrase "requirements... for the use or occupancy" seems focused on "requirements based on occupancy". 3002.4a is a requirements for features of an (new) elevator and have no relation to the type of occupancy or change of occupancy. An elevator is not required to have a legally occupiable 3-story apartment building.
2. Even if you conclude that 506.1 may apply to based on occupancy, in my particular case, apartments are generally (IMO) not an increase in hazard as it relates to the need for a gurney. There are sleeping rooms, just like at the former hotel, whether the sleeping is less than or greater than 30 days. In fact, one could argue that permanent residents are more familiar with the means of egress than hotel guests. And in any case, the gurney is not for resident means of egress or other fire/life safety issues, it is an aid for medical personnel.

 

[steveray]

I've been thinking about this more regarding the California version of the IEBC, and I'm not sure I agree that it triggers elevator enlargement:

506.1 Compliance​

A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the California Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the code official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.


Two observations:
1. The phrase "requirements... for the use or occupancy" seems focused on "requirements based on occupancy". 3002.4a is a requirements for features of an (new) elevator and have no relation to the type of occupancy or change of occupancy. An elevator is not required to have a legally occupiable 3-story apartment building.
2. Even if you conclude that 506.1 may apply to based on occupancy, in my particular case, apartments are generally (IMO) not an increase in hazard as it relates to the need for a gurney. There are sleeping rooms, just like at the former hotel, whether the sleeping is less than or greater than 30 days. In fact, one could argue that permanent residents are more familiar with the means of egress than hotel guests. And in any case, the gurney is not for resident means of egress or other fire/life safety issues, it is an aid for medical personnel.

I might be able to get on board with that...I may have been getting crossed up with our CT amendment for COO

306.5.1 Complete Change of Occupancy​

Where an entire building undergoes a change of occupancy, it shall comply with Section 306.5 and shall have all of the following accessible features:

1. At least one accessible building entrance.
2. At least one accessible route from an accessible building entrance to primary function areas.

As the elevator is the route, it would have to be correct or at least considered in the 20% upgrades per 306.7.1 IF it were not technically infeasible...

Plus ICC's commentary on accessibility:

❖ The code approaches the application of accessibility provisions to a facility that is altered by broadly requiring full conformance, meaning full accessibility is expected. Exceptions are then provided to indicate the conditions under which less than full accessibility is permitted.

As Ch. 11, 1108. would send you to Ch. 30 which gets you the stretcher...

 

[mark handler]

I've been thinking about this more regarding the California version of the IEBC, and I'm not sure I agree that it triggers elevator enlargement:

506.1 Compliance​

A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the California Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the code official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.


Two observations:
1. The phrase "requirements... for the use or occupancy" seems focused on "requirements based on occupancy". 3002.4a is a requirements for features of an (new) elevator and have no relation to the type of occupancy or change of occupancy. An elevator is not required to have a legally occupiable 3-story apartment building.
2. Even if you conclude that 506.1 may apply to based on occupancy, in my particular case, apartments are generally (IMO) not an increase in hazard as it relates to the need for a gurney. There are sleeping rooms, just like at the former hotel, whether the sleeping is less than or greater than 30 days. In fact, one could argue that permanent residents are more familiar with the means of egress than hotel guests. And in any case, the gurney is not for resident means of egress or other fire/life safety issues, it is an aid for medical personnel.

"Subject to the approval of the code official..."
Talk to the BO AND the fire department, BOTH have jurisdiction.

 

[Yikes]

I might be able to get on board with that...I may have been getting crossed up with our CT amendment for COO

306.5.1 Complete Change of Occupancy​

Where an entire building undergoes a change of occupancy, it shall comply with Section 306.5 and shall have all of the following accessible features:

1. At least one accessible building entrance.
2. At least one accessible route from an accessible building entrance to primary function areas.

As the elevator is the route, it would have to be correct or at least considered in the 20% upgrades per 306.7.1 IF it were not technically infeasible...

Plus ICC's commentary on accessibility:

❖ The code approaches the application of accessibility provisions to a facility that is altered by broadly requiring full conformance, meaning full accessibility is expected. Exceptions are then provided to indicate the conditions under which less than full accessibility is permitted.

As Ch. 11, 1108. would send you to Ch. 30 which gets you the stretcher...

The existing 2500# elevator already provides an accessible route for wheelchair users. It’s too small for a stretcher, but a stretcher is not an accessibility requirement in California, which did not adopt INC chapter 11 but instead utilized 2010 ADAS as the model code developing our own code for public housing.

 

[mark handler]

The existing 2500# elevator already provides an accessible route for wheelchair users. It’s too small for a stretcher, but a stretcher is not an accessibility requirement in California, which did not adopt INC chapter 11 but instead utilized 2010 ADAS as the model code developing our own code for public housing.

CALIFORNIA FIRE CODE1103.3.3 Medical Emergency Elevator
For existing hoistways with elevator alterations, or replacements, where the elevator car dimensions do not comply with Section 3002.4.1a of the California Building Code. The elevator car dimensions and/or the clear entrance opening dimensions may be altered where it can be demonstrated to the local jurisdictional authority's satisfaction that the proposed configuration will accommodate the designated gurney or stretcher with equivalent ease to the existing car and/or clear entrance conditions. Written documentation from the local authority shall be provided to the California Occupational Safety and Health Elevator Unit.

 

[steveray]

The existing 2500# elevator already provides an accessible route for wheelchair users. It’s too small for a stretcher, but a stretcher is not an accessibility requirement in California, which did not adopt INC chapter 11 but instead utilized 2010 ADAS as the model code developing our own code for public housing.

But hear me out....And for argument purposes, lets disregard the Change of Occupancy at this time...If you don't use Ch. 11 then vet your language for similar...

306.7.1 Alterations Affecting an Area Containing a Primary Function​

Where an alteration affects the accessibility to, or contains an area of primary function, the route to the primary function area shall be accessible. The accessible route to the primary function area shall include toilet facilities and drinking fountains serving the area of primary function.

1110.8 Elevators​

Passenger elevators on an accessible route shall be accessible and comply with Chapter 30.

3002.4 Elevator Car to Accommodate Ambulance Stretcher​

Where elevators are provided in buildings four or more stories above, or four or more stories below, grade plane, not fewer than one elevator shall be provided for fire department emergency access to all floors. The elevator car shall be of such a size and arrangement to accommodate an ambulance stretcher 24 inches by 84 inches (610 mm by 2134 mm) with not less than 5-inch (127 mm) radius corners, in the horizontal, open position and shall be identified by the international symbol for emergency medical services (star of life). The symbol shall be not less than 3 inches (76 mm) in height and shall be placed inside on both sides of the hoistway door frame.

Accessible means compliance with Ch. 11 and ANSI, the current versions....1110.8 then sends you to Ch. 30 which gets you to 3002.4......

 

[ICE]

(adding kitchens into hotel rooms to make them into studio apartments)

provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.

Adding kitchens is an increase in the hazard based on life and fire risk.