Sorry, here I go again-IEBC C of O

[Sifu]

Recent discussion on C of O for an existing SFD to B occupancy yielded a lot of opinions. I have two more similar projects presented to me, we will treat them as one for the sake of discussion.

Given that I am of the opinion that IEBC ch. 10 does not apply to a C of O from an SFD to a new IBC regulated occupancy, I am now more confused by the fact that the C of O from the SFD is a historic building.

For the sake of this discussion, assume that it is properly designated as an historic building.

Ch. 3, accessibility applies to everything, including existing buildings, with specifics for historic buildings provided at 305.9.
-Using 305.9 a single fully accessible toilet room is required. This is provided, along with 1 that is not, but which contains a shower. Based on the only requirement being a single compliant toilet room, and that bathing rooms are not mentioned, would this be complaint?
-There is an accessible main entrance, with an accessible route from the site arrival point.
-No other mention of any accessible requirements is made in 305.9, so does everything not mentioned in 305.9 get a pass? (maneuvering clearances and kitchenettes specifically)

Ch. 5, prescriptive-IEBC 507.1 pretty much waives all of the requirements of ch. 5 (which includes 506 on C of O's) unless deemed to be a life-safety hazard, except for structural unless the CBO waives those.

Ch. 6-12 are required to be used when using the work area compliance method. 607.2 directs that "the code" applies unless waived by ch. 12. By "the code" I assume it refers to ch. 6 through 12. IEBC 1204.1 tells us that the applicable provisions of ch. 10 apply (which pick up ch. 7,8,9) unless waived in 1204, but as discussed (without a clear consensus) ch. 10 doesn't apply...what now since 7,8,9 are triggered by ch. 10? If ch. 12 can be used regardless if ch. 10 can be used, then do we still use ch. 7 through 9 and ch. 12?

When I review things like this I start from a full IBC compliance perspective, then back out what doesn't apply in an existing building, then back out what wouldn't apply in an historical building. But, this is the first bona fide historical building I have actually reviewed as a C of O. When I back everything out, it would appear very little applies.

Has anyone else done a similar project?

 

[steveray]

Well yeah....if the IEBC does not apply, then none of it applies....Except it does...

 

[Sifu]

Well yeah....if the IEBC does not apply, then none of it applies....Except it does...

Two days trying to figure out what path to follow. Accessibility is pretty straight forward, from what I can tell only those items in 305.9 apply, so site arrival, entry and at least one accessible toilet room, They meet these requirements. For prescriptive compliance, nothing applies unless a life safety issue is observed, and structural capacity verification of live, snow, wind, and seismic loads unless the CBO wants to allow the existing floor and live loads.

What I find interesting is that if they used the work area methods, which include ch. 7-12, the code might be more restrictive, which is unusual.

Of course, this is based on the premise that any of the C of O provisions apply to an existing SFD. There are a few sections that point to a C of O from an SFD, but in the context of them having been R3. Not going down that path again.

As far as I can tell, very little applies to these, and a lot of what does apply is subjective. I'll meet with the CBO to discuss this. These are AHJ owned buildings, so it can be stickier than normal.

 

[steveray]

You don't get to have it both ways.....Either the IEBC applies to COO in this case (and the other one) or you rebuild the whole building to the IBC (good luck).....

As Ch. 12 lives in work area, that is the only way to get relief other than ignoring stuff...

Ch. 5 might be loose enough for interpretation, but I have found it to be less than forgiving for COO...

No one wants to work hard enough to do performance...

 

[Sifu]

These buildings are 100 years old, R3's didn't exist, but neither did the IRC or IBC, or most any other code, certainly none that were adopted in this area. I would think the code should know that was the case for historic buildings, so the implication that they were previously R3's is disingenuous unless it is understood that any single family home, prior to the codes would be considered an R3, no matter what. That is in opposition to the technical opinion I received last week, but I can't find any other conclusion. I am going to apply 305.9 and 506.6 as best I can tell 507 allows.

 

[steveray]

So we have this, not sure what you have:

A] EXISTING BUILDING. A building or structure, or portion thereof, erected in whole or in part, for which a legal building permit and a certificate of occupancy has been issued. Buildings or structures or portions thereof erected prior to October 1, 1970 shall be deemed existing buildings regardless of the existence of a legal permit or a certificate of occupancy.

Basically...it was something...What was it in the last record that anyone has? If not permit or CO, tax? FM inspection? Somewhere the Town has a record of it being something and that something is going to win in court...