2018 IEBC - Performance Evaluation of mixed-occupancy building

[GEe]

This pertains to a small, three-story building. The proposal is to convert the upper two stories into separate R-3 units (that is, one dwelling unit per level). To do this we are doing a performance evaluation per chapter 13 of the IEBC.

We can attain the necessary points with no sprinklers. But, if no sprinklers, the question is whether we need two exits per dwelling unit.

For exiting, IEBC 1301.6.11 requires compliance with IBC 1006. That section (for example IBC 1006.3.3) allows a single exit for R-3 occupancies, but this normally assumes that sprinklers are provided. So, for example, IBC Table 1006.2.1, categorically indicates 'NP' for unsprinklered R-3 occupancies.

We would argue that IEBC chapter 13 compensates for the assumption of sprinklers -- in particular, there is a big 12 point reduction where sprinklers are required but not provided in an R occupancy.

So far the AHJ is unconvinced. Any experience with this?

 

[RLGA]

You're looking at the wrong information. Table 1006.2.1 is for spaces, not stories. Section 1006.3.3 on single exits has Condition #4, which allows Group R-3 to have a single exit from any story.

 

[GEe]

You're looking at the wrong information. Table 1006.2.1 is for spaces, not stories. Section 1006.3.3 on single exits has Condition #4, which allows Group R-3 to have a single exit from any story.

Thanks for the quick reply and yes... I've made this same argument to them... that if the 'NP' of 1006.2.1 were applied categorically, every room on a level would also require two exits....

But even for 1006.3.3 ex4, they seem to be leaning on this assumption of sprinklers. It sounds like your take is also that this is superseded by the IEBC performance evaluation?

 

[RLGA]

Refer them to IEBC Section 102.4.1 (assuming your jurisdiction did not dump Chapter 1 in its entirety and write their own as many AHJs do).

The IEBC governs in this situation. Just because the IBC assumes a sprinkler system is installed in Group R occupancies does not mean it is required per the IEBC.

Also, just so I understand correctly, these are the only two dwelling units in the building, correct?

 

[GEe]

Refer them to IEBC Section 102.4.1 (assuming your jurisdiction did not dump Chapter 1 in its entirety and write their own as many AHJs do).

The IEBC governs in this situation. Just because the IBC assumes a sprinkler system is installed in Group R occupancies does not mean it is required per the IEBC.

Also, just so I understand correctly, these are the only two dwelling units in the building, correct?

Good tip -- thank you --
And yes, correct. Two units total.

 

[Penguin87]

My state requires most new residential to have sprinklers, and we don't have the IEBC so this question makes no sense to me.

 

[GEe]

Refer them to IEBC Section 102.4.1 (assuming your jurisdiction did not dump Chapter 1 in its entirety and write their own as many AHJs do).

The IEBC governs in this situation. Just because the IBC assumes a sprinkler system is installed in Group R occupancies does not mean it is required per the IEBC.

Also, just so I understand correctly, these are the only two dwelling units in the building, correct?

I received the following interesting response back from the AHJ.

• "Chapter 13 Performance Compliance is a trade-off based compliance path.... However, means of egress is the only aspect that may not have a deficiency. To use Chapter 13, as a minimum the number of exits must meet the requirements of the IBC. The only exception to that is when a fire escape is used as a second means of egress as noted in category A, which is why this is the only negative score (Fire Escapes are only permitted on existing buildings for this exact reason). Straight egress compliance with the IBC in relation to number of exits and capacity score a net score of 0 as the base score. There is no provision in the IBC that allows for a single exit for an R-3 use in a non-sprinklered Building. As such, PLI would deem a single exit to the upper residential floors as a non-compliant condition and the Chapter 13 scoring could not be used due to the existing single exit configuration. The commentary language backs this up as again the performance scoring is comparing the egress systems to the IBC requirements for new construction."
  
  
• The referenced commentary language (from IEBC 1301.6.11) is that "The means of egress is required to conform to the following IBC sections for new construction before evaluation....Section 1006 of the IBC establishes requirements for minimum number of exits."

This strikes me as a strong response but still begs the question. IBC 1006.3.3 doesn't specifically note sprinklers. (And there is no equivalent here to footnote d in the chapter 5 tables that give an NS value for evaluating existing buildings in the IEBC.) There is also the issue noted above that when it comes to spaces, no one is arguing that every room requires two exits. But I'm not sure how to argue that we can satisfy IBC egress requirements "before evaluation".

(One additional clarification: There's no question that a new building would require sprinklers -- the two residential units are over a first floor business use.)

 

[RLGA]

Their position appears to be based on the opinion that Group R-3 occupancies are permitted a single exit because a sprinkler system is required. However, Group R-3 occupancies have always been permitted single means of egress, and the requirement for Group R-3 occupancies to be sprinklered was added in the 2003 IBC. Thus, the single-exit provision for Group R-3 was never contingent on installing a sprinkler system.

If you are an ICC member, I suggest submitting a staff opinion request regarding this situation.

 

[GEe]

Their position appears to be based on the opinion that Group R-3 occupancies are permitted a single exit because a sprinkler system is required. However, Group R-3 occupancies have always been permitted single means of egress, and the requirement for Group R-3 occupancies to be sprinklered was added in the 2003 IBC. Thus, the single-exit provision for Group R-3 was never contingent on installing a sprinkler system.

If you are an ICC member, I suggest submitting a staff opinion request regarding this situation.

Really appreciate the feedback -- thank you

 

[GEe]

I thought should give an update on this. We took the advice from @RLGA and requested an ICC opinion and they agreed that a single exit is acceptable:

Section 1301.6.11 addresses the means of egress capacity and number of exits available to the building occupants. The section also states that the means of egress are required to conform to several sections of the IBC, including Section 1006. Section 1006.3.3 of the IBC contains the conditions for a single exit to be provided from a story or occupied roof. Item 4 of Section 1006.3.3 specifies that a Group R-3 occupancy is permitted to have one exit or access to a single exit. While the IBC requires building containing Group R fire areas to be sprinklered, the number of exits provided is not based on the installation of a sprinkler system. As such, the use of one exit from the second and third floors would, in my opinion, be permitted.

Based on Table 1301.6.11 of the IEBC, the Group R-3 dwelling units would be considered Category ‘b’ since the capacity of the means of egress complies with Section 1005 of the IBC, and the number of exits complies with the minimum number required by Section 1006 of the IBC. As Category ‘b’, a point value of zero is required.

Unfortunately, in an appeal, the building department decided otherwise and is requiring two exits. They are now focusing on IBC Table 1006.2.1 saying that when "NP" is indicated for an R-3 occupancy without sprinklers it doesn't represent a conflict superseded by the IEBC. Instead, it means -- they say -- that a unit without sprinklers cannot have a single path of travel. We tried to argue that this table pertains to spaces and that every room would then require two doors, but they were unconvinced. We may have to yield unless anyone has a clever idea...

 

[steveray]

I respect Rons opinion, but I think I agree with the Town....When the minimum requirements in the IBC change, it affects the IEBC....I hated when they made all of those Ch. 10 changes around 09-12, and this is one of the reasons why....

 

[GEe]

I respect Rons opinion, but I think I agree with the Town....When the minimum requirements in the IBC change, it affects the IEBC....I hated when they made all of those Ch. 10 changes around 09-12, and this is one of the reasons why....

Thank you @steveray. Is your take on this also based on IBC 1006.2.1 -- that the "NP" for spaces equates to a two-exit requirement? That seemed odd to me for a few reasons (I know partially mentioned above already):

• Wouldn't this interpretation of "NP" mean every room in the dwelling requires two exits?
  
  > 1006.2: "Rooms, areas or spaces, including mezzanines, within a story or basement shall be provided with the number of exits or access to exits in accordance with this section."
  
  The AHJ did not think it mean this, but I didn't understand why not.
  
  
• One exit is allowed for stories without reference to sprinklers. (Sprinklers might be assumed, but isn't the point of IEBC Chapter 13 to balance out these underlying assumptions? There is a huge point deduction for a building without sprinklers.)
  
  
• Emergency escape per 1030 notes that it applies to R-2 occupancies only if they have one exit, but it always applies to R-3 occupancies. Of course, in both cases sprinklers are assumed, but this suggests to me that the building code never foresees an R-3 occupancy with two exits. If that's so, the "NP" doesn't mean two exits for an R-3 occupancy. It's just means sprinklers are required -- unless, in this case, superseded by the IEBC.

 

[Joe.B]

Your location is listed as LA. Is the project in CA or a different state?

 

[GEe]

Your location is listed as LA. Is the project in CA or a different state?

Hi @Joe.B - yes this is actually for PA (so 2018 codes).

 

[steveray]

Thank you @steveray. Is your take on this also based on IBC 1006.2.1 -- that the "NP" for spaces equates to a two-exit requirement? That seemed odd to me for a few reasons (I know partially mentioned above already):

• Wouldn't this interpretation of "NP" mean every room in the dwelling requires two exits?
  
  > 1006.2: "Rooms, areas or spaces, including mezzanines, within a story or basement shall be provided with the number of exits or access to exits in accordance with this section."
  
  The AHJ did not think it mean this, but I didn't understand why not.
  
  
• One exit is allowed for stories without reference to sprinklers. (Sprinklers might be assumed, but isn't the point of IEBC Chapter 13 to balance out these underlying assumptions? There is a huge point deduction for a building without sprinklers.)
  
  
• Emergency escape per 1030 notes that it applies to R-2 occupancies only if they have one exit, but it always applies to R-3 occupancies. Of course, in both cases sprinklers are assumed, but this suggests to me that the building code never foresees an R-3 occupancy with two exits. If that's so, the "NP" doesn't mean two exits for an R-3 occupancy. It's just means sprinklers are required -- unless, in this case, superseded by the IEBC.

When they did the "sprinkler all R's" change in the IBC this was overlooked in the IEBC for all of the requirements that refer back to the IBC, in particular Ch. 10....So you are up to the interpretation of the AHJ or any appeal avenue you might have....