2023 Florida Existing Building Code - Alteration Level?

[tbz]

So, I am reviewing a project at an existing Hotel Lobby, nothing is really being altered, just updated.

The existing open lobby grand stairway and balcony currently has aprx 36-inch high guards, which also serve as the handrails on the stair flights, without handrail extensions.

The designer has designed the new guards/handrails to be the same as the old guards and handrails, 36-inches high, no handrail extensions.

The existing guard/handrails are perfectly fine and do not need to be replaced.

Per 2023 Florida Building Code, Existing Building, 8th Edition, for a level 2 alteration, which I am deeming the replacement of the guards and handrails to be, correct me if I am wrong and the project is just a level 1, Chapter 6 points me to Chapter 8.

Then under section 803.5 Guards. It says,

803.5.1 Minimum requirement.

Every portion of a floor, such as a balcony or a loading dock, that is more than 30-inches (762 mm) above the floor or grade below and is not provided with guards, or those in which the existing guards are judged to be a danger of collapsing, shall be provided with guards.

803.5.2 Design.

Where there are no guards or where existing guards must be replaced, the guards shall be designed and installed in accordance with the Florida Building Code, Building.

So, they are neither collapsing, nor must they be replaced, it does not say IF REPLACED ANYWHERE, which I find odd, but here is the big question, how do you justify that if replacing with new guards, they must be 42-inches high minimum and then add in handrails between 34-38 on each side with compliant extensions.

I was always under the impression you could leave what there as is, but if you replaced it, it must be done to the current code.

But the code seems to leave a loop hole or am I over thinking this.

Regards Tom

 

[NCRooster]

If you replace the guards, they would need to comply with the current code due to 801.3 - "All new construction elements, components, systems, and spaces shall comply with the requirements of the Florida Building Code, Building."

 

[Yankee Chronicler]

Per 2023 Florida Building Code, Existing Building, 8th Edition, for a level 2 alteration, which I am deeming the replacement of the guards and handrails to be, correct me if I am wrong and the project is just a level 1, Chapter 6 points me to Chapter 8.

The Florida version of the IEBC describes Level 2 Alterations thusly:

603.1 Scope​

Level 2 alterations include the addition or elimination of any door or window, the reconfiguration or extension of any system, or the installation of any additional equipment; and shall apply where the work area is equal to or less than 50 percent of the building area.

How are you getting from that to classify a handrail/guardrail as a Level 2 alteration?

 

[tbz]

Yankee,

I have always had the circle conflict with plan reviewers and inspectors that altering a specific item, the main frame stayed, is a level 1, completely removing an entire structural product, guards & handrails need to meet loads, from a location and replacing with an entirely new product kicked you to level 2.

So if completely replacing a structural item, like a guard system with handrails it is not a level 2 and is a level 1, please explain.