2006 IBC 3410 evaluation on non-separated mixed occupancy

[cballinger]

If you didn’t see my newbie post, this is my first time posting a question here. Go easy on me. I am a Building Code Analyst (aka plan reviewer) in Indianapolis, IN. We currently enforce the 2006 IBC as amended by the State of IN.

I have a 7000sf non-separated, non-sprinklered mixed occupancy F-1/A-2 (brewhouse/pub - not sure why they are using F-1 classification rather than F-2, but we’ll go with it). About 3500sf for each occupancy area. They submitted a 3410 evaluation for change of occupancy in an existing building. (No IN amendments to any of the sections in question.)

Section 3410.6 states, “In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building.”

I have always interpreted that the way this evaluation works for the various sections is you use the requirements of the building to determine the category in each section, then look at each occupancy value under that category to determine the score value for that section. Then the lower of the two score values is used in Table 3410.7.

My issue is with the score they used for Section 3410.6.17 Automatic Sprinklers. I determined that the building is required to be sprinklered throughout because it is non-separated, therefore they have an A-2 “fire area” over 5000sf. (Section 3410.6.17 states “...."Required sprinklers" shall be based on the requirements of this code.” I took this to mean that Section 508.3.1.1 requirement applies to the non-separated mixed occupancy. Section 508.3.1.1 states, “...the most restrictive applicable provisions of Section 403and Chapter 9 shall apply to the entire building or portion thereof.” Section 903.2.1.2 requires sprinklers where the A-2 “fire area” exceeds 5000sf.)

So, after determining that the entire building is required to be sprinklered, I chose category a for Section 3410.6.17.1, then looking at Table 3410.6.17, I chose value of -6 for F occupancy being the most restrictive in this section.

They, on the other hand, have interpreted that when doing the evaluation, you should look at the entire building as an A-2 and then the entire building as an F to determine sprinkler requirements. So, they are saying, if you look at the entire building as an F occupancy, then it wouldn’t require sprinklers and used category c for a value of 0. They then used the A-2 value of -4 as most restrictive for the section.

My concern is that the difference between choosing -6 vs -4 for this section is the difference between pass/fail of the overall evaluation. They’ve already tweaked other sections as much as possible and have an exact passing score for fire safety.

I’ve never had a brewhouse/pub that didn’t either provide fire separation between or sprinklers throughout. Looking forward to all your input!

 

[north star]

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1st, ...Welcome to The Building Codes Forum !

2nd, ...is this Brewhouse \ pub intended to seat occupants, rather than

the F-1 [ Factory <---- ??? ] designation that "they" are wanting ?

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[cballinger]

Seating for over 50 occupants on the pub (A-2) side. They don't want to provide fire separation between the brewing area and the pub area because they want to show off their brewing operations to their pub guests, and will offer tours of the brewing area as well.

 

[north star]

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If they use an F-1 Occupancy classification, according to

Table 1004.1.1, ...the calculated occupancy load would

be 70 occupants. [ i.e. - 7,000 sq ft. \ 100 sq. ft. gross

= 70 occupants ].........Actually, it will be less than 70 when

you take in to account furnishings, actual Kitchen areas,

restrooms, egress paths, etc.

Are they going to be able to make a go of it on a [ max. ]

occ. load of 70 occupants ?



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[north star]

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Tours of the Brewing area as well eh ?.....Sure sounds like

the occupant load is getting higher by the moment.

I would argue for an A-2 Occupancy classification as well,

...show them Section 903.2.1.2 [ `06 IBC ] and let them

counter.......Also, I would ask "them" for a calculated

Occupant Load for the entire space, ...if you haven't

already.



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[cballinger]

Occupant load is calculated based upon the use of the space, not the occupancy classification. ? Either way, occupant load isn't a factor in this situation as the fire area exceeds 7000sf and contains an A-2 occupancy area, so sprinklers are required throughout. Sorry, not understanding what you're getting at...

 

[cballinger]

^ I mean fire area exceeds 5000sf

 

[north star]

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Sorry for the confusion, I was trying to say that I agree with your

interpretation of the facts and variables as you presented them.

Hold your ground, ...provide "them" the various applicable code

sections, and let them counter your position with their code

sections and calculations.

Your application sure sounds like an overall A-2 to me.



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[cballinger]

I don't understand what you mean, you would argue for an A-2 occupancy classification? They aren't arguing the classification. It is a mixed occupancy, non-separated A-2 and F-1. The issue is for Section 3410.6.17, the more restrictive, in my opinion is the F value of -6 under category a vs. A-2 value of -4 under category a. They are wanting to use category c for F value of 0 and category a for A-2 value of -4, thus taking -4 as the most restrictive value. I don't agree that they can use different categories in the evaluation because it is my interpretation that the building requires sprinklers throughout because the "fire area" contains an A-2 occupancy. Thus, I think the score should be -6 for F as most restrictive for this section.

 

[north star]

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What are they basing their selection of Category "c" on,

...just to manipulate the outcome of the overall evaluation ?

Also, you mentioned that each fire area is approx. 3,500

sq. ft, ...how are you now arriving at over 5,000 sq.ft. for

the A-2 area ?

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[cballinger]

They have interpreted that when evaluating non-separated mixed occupancies, you would evaluate the entire building as A-2, then the entire building as F, and then choose the value for each and use most restrictive in the overall scoring. So, they are saying, evaluating the entire building as F, it doesn't require sprinklers because fire area isn't over 12000sf. Then, evaluating the entire building as an A-2, it does require sprinklers. So they have a value of 0 for F under category c and a value of -4 for A-2 under category a, then using the most restrictive of the two (A-2, value -4) for the overall scoring in Table 3140.7.

 

[cballinger]

I am saying, you can't evaluate the entire building as a single occupancy and not take into consideration other occupancies in the building when there is no separation.

 

[north star]

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When you showed them Section 508.3.1.1 and "the most restrictive"

wording, what was their response ?........What, if anything, are they

countering with [ specifically ] from the `06 IBC ?

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[cballinger]

They are saying that section 3410 only looks at chapter 9 requirements and that when evaluating mixed occupancies, you evaluate the entire building as each occupancy separately (so you either have a 7000sf F or you have a 7000sf A-2) then take the more restrictive value of the two. I'm saying, you have a 3500sf A-2 with a 7000sf A-2 fire area and a 3500sf F with a 7000sf A-2 fire area, thus required to be sprinklered throughout regardless of which occupancy area is being evaluated.

 

[north star]

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So, "if" you use their logic and say that they indeed have

an 7,000 sq. ft. A-2 [ i.e. - the more restrictive ],

wouldn't that also require the sprinklers according to

Ch. 9 ?



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[cballinger]

Sorry, had to get some sleep at some point.

Yes if they consider the entire building as A-2, yes it would require sprinklers per Ch. 9, which is why they used category a in 3410.6.17 for sprinklers required, none provided. However, I'm not sure I agree the A-2 is the most restrictive in this section. 3410 requires you to evaluate both occupancies and take the more restrictive score for each section. So, you must still evaluate the F occupancy, which they are saying doesn't require sprinklers and using category c for no sprinklers required, none provided. I think the F occupancy does require sprinklers because it is within an A-2 fire area, so they should use category a for F and take score of -6 being the most restrictive in this section. They are saying, when evaluating the F occupancy, there is only an F fire area. Big difference between "occupancy area" and "fire area"...

 

[north star]

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I had to get some sleep too !

I do not agree with their "less restrictive" choice of column "c" to make a determination.

IMO, ...I would still hold to the "more restrictive" stance and use column "a" in the

assessment.

Is there a Building Official or Fire Code Official involved in this mix \ assessment

process ?

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[cballinger]

I firmly believe the same, but am looking for some written explanation somewhere in the code/commentaries to back up my interpretation. I represent the local "Building Official" in my capacity as a City plan reviewer.

 

[steveray]

3410.6 Evaluation process.

The evaluation process specified herein shall be followed in its entirety to evaluate existing buildings. Table 3410.7 shall be utilized for tabulating the results of the evaluation. References to other sections of this code indicate that compliance with those sections is required in order to gain credit in the evaluation herein outlined. In applying this section to a building with mixed occupancies, where the separation between the mixed occupancies does not qualify for any category indicated in Section 3410.6.16, the score for each occupancy shall be determined and the lower score determined for each section of the evaluation process shall apply to the entire building.

According to this......you take the lowest of each at each evaluation....if you are not properly seperated....

 

[cballinger]

Right, but they aren't arguing that the lowest score should be used. They are arguing that the lowest score for Section 3410.6.17 is -4, but I am saying the lowest score for that section is -6 because they should use category a sprinklers required but not provided in the F occupancy area.

 

[steveray]

NOW I understand.....And a good question....I think they may be correct with the -4 because the F does not require the sprinkler under "new" code (from what I can gather) so you would use the C column or the -4 A column for the A2....I would certainly spend some more time researching, but on quick glancing that is what I see...

Try the 2009 Commentary.....http://publicecodes.cyberregs.com/icod/ibc/2009f2cc/icod_ibc_2009f2cc_34_sec001.htm

 

[north star]

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I am of the opinion that you have the correct assessment and the

code sections to support your position.

Question: If both parties are at an impasse, then what ?



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[cballinger]

NOW I understand.....And a good question....I think they may be correct with the -4 because the F does not require the sprinkler under "new" code (from what I can gather) so you would use the C column or the -4 A column for the A2....I would certainly spend some more time researching, but on quick glancing that is what I see...Try the 2009 Commentary.....http://publicecodes.cyberregs.com/icod/ibc/2009f2cc/icod_ibc_2009f2cc_34_sec001.htm

How does the F occupancy area not require sprinklers under the "new" code if it is not separated from the A-2 "fire area"? I've read and reread code and commentary for all of CH 34, 5 and 9 several times and haven't found anything to suggest that evaluation of occupancy should be done considering the entire "fire area" as a single occupancy. It is my interpretation that the F occupancy area requires sprinklers because it is in the same "fire area" as an A-2.

 

[cballinger]

Typically, I would send them to the State building commission to obtain a variance from Indiana Building Code or interpretation from the State Building Law Compliance Officer. In this particular situation, their code consultant requested an interpretation from the State Building Law Compliance Officer, but he opted not to provide an interpretation.....