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ABA Therapy Clinic Occupancy Group classfication

abatherapy

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Joined
Apr 29, 2025
Messages
6
Location
Houston
Hey everyone, I’m new to navigating occupancy groups and building codes, so bear with me.

I’m in Texas and currently leasing a space that’s about 2,450 sqft. I’m in the process of getting our occupancy permit, but I’ve run into a bit of a challenge. The fire marshal has the space classified as Group B, which I understand. But based on that classification, it’s only rated for 16 occupants using a load factor of 150. That’s a problem for us since we’re expecting to have 30+ people in the building at times.

We’ll be using four of the rooms as “classrooms” for our clients, each ideally holding around 6 to 8 people. Altogether, those classroom spaces make up about 662 sqft. From what I understand, using the 20 sqft load factor for educational spaces, that would allow for 33 people just in those rooms before factoring in the rest of the space.

Does anyone have experience with getting different rooms in the same suite classified under different occupancy types? If so, what does that process look like?
 
The occupancy factor of one person per 150 square feet is for determining the minimum occupant load, not the maximum. That ratio comes from IBC section 1004.5 and Table 1004.5. Then there's section 1004.5.1:

1004.5.1 Increased Occupant Load
The occupant load permitted in any building, or portion thereof, is permitted to be increased from that number established for the occupancies in Table 1004.5, provided that all other requirements of the code are met based on such modified number and the occupant load does not exceed one occupant per 7 square feet (0.65 m2) of occupiable floor space. Where required by the building official, an approved aisle, seating or fixed equipment diagram substantiating any increase in occupant load shall be submitted. Where required by the building official, such diagram shall be posted.

If you have egress capacity for 30+ people, there's no reason you can't have 30+ people in the space.

As to Educational, that applies only to organized educational institutions serving grade 12 and younger. Any other educational occupancy is classified under whatever is being taught. If you are running a therapy clinic, I would classify that as Business (B occupancy). Your "classrooms" are business conference rooms and are classified as B occupancies.
 
The occupancy factor of one person per 150 square feet is for determining the minimum occupant load, not the maximum. That ratio comes from IBC section 1004.5 and Table 1004.5. Then there's section 1004.5.1:



If you have egress capacity for 30+ people, there's no reason you can't have 30+ people in the space.

As to Educational, that applies only to organized educational institutions serving grade 12 and younger. Any other educational occupancy is classified under whatever is being taught. If you are running a therapy clinic, I would classify that as Business (B occupancy). Your "classrooms" are business conference rooms and are classified as B occupancies.
How do I go about finding out what my egress capacity is?
 
How do I go about finding out what my egress capacity is?

You look at the number and size of the egress paths, and multiply them by the capacity factors in the code.

If you are on the ground floor, let's say you have two exit doors, and that they are standard 3-foot doors. A 3-foot door typically leaves 33 inches of clear exit width. Section 1005.3.1 says for doors in other than group H and I-2 you use a factor of 0.15 if protected by a sprinkler system or an emergency voice alert system. Otherwise the factor is 0.2.

33 divided by 0.15 gives each door a capacity of 220 people. 33 divided by .2 gives each door a capacity of 165 people.

Stairs use a different factor. If you are on an upper story, you take the width of each stair and divide by a factor of of 0.2 if protected by a sprinkler system or an emergency voice alert system. Otherwise the factor is 0.3.

For a minimum 44-inch wide stair, the factor of 0.2 provides a capacity of 220 people per stair. If the factor is 0.3, the capacity will be 146 people.
 
You look at the number and size of the egress paths, and multiply them by the capacity factors in the code.

If you are on the ground floor, let's say you have two exit doors, and that they are standard 3-foot doors. A 3-foot door typically leaves 33 inches of clear exit width. Section 1005.3.1 says for doors in other than group H and I-2 you use a factor of 0.15 if protected by a sprinkler system or an emergency voice alert system. Otherwise the factor is 0.2.

33 divided by 0.15 gives each door a capacity of 220 people. 33 divided by .2 gives each door a capacity of 165 people.

Stairs use a different factor. If you are on an upper story, you take the width of each stair and divide by a factor of of 0.2 if protected by a sprinkler system or an emergency voice alert system. Otherwise the factor is 0.3.

For a minimum 44-inch wide stair, the factor of 0.2 provides a capacity of 220 people per stair. If the factor is 0.3, the capacity will be 146 people.
I'm on the first floor and there is no sprinkler system. And yes my doors are standard 3 feet wide. so technically my max capacity should be 165?
 
The Ch. 3 Use and occupancy is not directly tied to the occupant load from Ch.10....You are likely fine....
On the permit given to me by the county, it says "Occupant Load Calculated: 16 occupants". When would I find out my max occupant limit? Maybe when they come inspect and give me the Certificate of Occupancy?
 
On the permit given to me by the county, it says "Occupant Load Calculated: 16 occupants". When would I find out my max occupant limit? Maybe when they come inspect and give me the Certificate of Occupancy?

If you stated previously that you already have a permit, I missed it. What kind of permit is the one that states the calculated occupant load is 16? If a permit says that, then I would expect the AHJs (Authorities Having Jurisdiction) to regard that as the maximum occupant load you are allowed to have in the space. This issue is normally addressed during the permit application (plan review) process, and if the applicant and the plan reviewer have different ideas of what the occupant load will be, that gets negotiated before any permit is issued.
 
I'm on the first floor and there is no sprinkler system. And yes my doors are standard 3 feet wide. so technically my max capacity should be 165?

How many exit doors do you have? Each 3-foot door provides egress for 165 people.

However, there are other considerations pertaining to egress, such as exit access travel distance and common path of exit access travel distance.
 
If you stated previously that you already have a permit, I missed it. What kind of permit is the one that states the calculated occupant load is 16? If a permit says that, then I would expect the AHJs (Authorities Having Jurisdiction) to regard that as the maximum occupant load you are allowed to have in the space. This issue is normally addressed during the permit application (plan review) process, and if the applicant and the plan reviewer have different ideas of what the occupant load will be, that gets negotiated before any permit is issued.
I shouldve expained it better, thats my bad. I got a permit from the county to do some demo/remodel work on the space. As part of that permit, it included in there the "Occupant Load Calculated" which says 16 occupants. There really wasnt a plan review process. I sent in plans of what work im going to do and they approved it and sent the permit. I wasnt aware of the occupancy issue until the permit was already sent!
 
How many exit doors do you have? Each 3-foot door provides egress for 165 people.

However, there are other considerations pertaining to egress, such as exit access travel distance and common path of exit access travel distance.
I have 2 exits both 3 feet. From the exit all the way to the back wall of the building is about 45 feet.
 
If you have two exits, each a 3-foot door, you have egress capacity for 330 people.

Exit access travel distance is not measured in a straight line, it is measured from the point most remote from the exit(s) to the exit door, along the natural path of exit travel (and around obstacles such as furniture). That said, if the building is only 45 feet deep, at 2,450 s.f. the other dimension should be around 54 feet. You probably meet the travel distance requirements with no problem.

I shouldve expained it better, thats my bad. I got a permit from the county to do some demo/remodel work on the space. As part of that permit, it included in there the "Occupant Load Calculated" which says 16 occupants. There really wasnt a plan review process. I sent in plans of what work im going to do and they approved it and sent the permit. I wasnt aware of the occupancy issue until the permit was already sent!

Yes, there was a plan review process. You submitted a plan with an application for the building permit, the department reviewed your plan, approved it, and issued the permit.

At this point, my suggestion would be for you to submit a revised plan as an amended construction document. This would be the same plan, but showing a greater occupant load and clearly showing that you have capacity to egress 330 people, as well as identifying the point most remote from the two exit doors and showing the travel distance to each exit door. This is referred to as an egress diagram, and is commonly provided with most plans for commercial construction -- for this very reason.

The code citation for submitting amended construction documents is:

[A] 107.4 Amended Construction Documents


Work shall be installed in accordance with the approved construction documents, and any changes made during construction that are not in compliance with the approved construction documents shall be resubmitted for approval as an amended set of construction documents.
 
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