2021 IEBC Section 306 and change of occupancy question

[ggm.arch]

......oh, and forgot to mention another very interesting part of the phone conversation. It is mentioned in their response but not as clear or direct. The ICC agent mentioned something I never knew. I always added all of my alteration cost into my 20% upgrade, not the electrical hvac etc as obviously stated in the code, but everything else. He told me that If the alteration does not affect the "primary function," you don't have to do add to the 20% upgrade. So, when it states " where an existing building undergoes alterations involving or affecting an area of primary function," it literally means only when altering an area of "primary function" does it trigger the 20% rule upgrade.
News to me!
then again, we start getting into semantics and have to ask for an interpretation of primary function. in my case he said an employee office alteration in an M occupancy would not trigger accessible route/restroom upgrades. the sales room is the primary function and the office is not. My guess is an office building, however, you'd be hard pressed to argue that an office upgrade isn't part of the primary function, I'd have to say that it was part and would require the 20% upgrades in that occupancy, strange how people are seen differently under different occupancies. It's funny to read this code and with every incarnation, it gets more convoluted and requires even more interpretation(maybe by design?). I wish they'd dump the whole thing and go back to life safety where we were protecting people's lives and not their feeling! hey, but once again, what do i know, I'm just a stupic architect.

 

[ggm.arch]

steveray,
hard for them to be wrong when they wrote it......and, not sure how you can doubt that?

 

[steveray]

They don't write it...we do....they publish it..... ICC-online staff opinion

But you are correct on the 20%, but that get really tough to explain to my customers....

 

[steveray]

This is the section from COO that sends you back to the other parts for alterations, NOT 306.5 to 306.7....

1001.2.1 Change of use. Any work undertaken in
connection with a change in use that does not involve a
change of occupancy classification or a change to another
group within an occupancy classification shall conform to
the applicable requirements for the work as classified in
Chapter 6 and to the requirements of Sections 1002
through 1010.

 

[ggm.arch]

steveray, yep, the fact that they are a publishing company is what aggravates me the most about the code. Since the "you" (who do write the code) do not exist, there is no authority and hence the power resides in a company that has the power to print and withhold information....or at least until you join their club. The state adopts the code as law and we "the plebs" have no direct access to what it means. It's written in a way that seems to give interpretation rights to those who read it, as i said before, by design. the incarnations attempt to clarify, but it only seems to get thicker. I miss the days of the life safety code 90 pages of easy to follow easy to understand easy to implement, says the fossil!

I went through 1001.2.1 and 1011 for good measure. that's how I determined no work.

 

[steveray]

So they are not putting in a sales counter?

 

[Jean Tessmer-HI]

Under federal ADA code under on going barrier removal and because of the change in occupancy it could be considered an alteration which would trigger ADA compliance for the entire Retail space. Because it is accessible to the public it is required to meet ADA.