I have an issue with the IBC in this regard: Why does it single out Group S for accessory uses when no other occupancy group section mentions them?
Also, Section 311.1.1 states, "...for storage purposes that is accessory to another occupancy..." but it does not address it as an "accessory occupancy," which Section 508.2 covers. The IBC does not define "accessory" or "accessory occupancy."
Here is what the 2018
Commentary says about Section 311.1.1:
"This provision allows accessory storage areas to be classified in the same occupancy group as the primary occupancy of a space. There are no longer limits on the size of such spaces, nor how much of the floor area such accessory storage can occupy. These storage spaces could occur in any other occupancy, such as a Group B office building, a Group E classroom or a Group M retail store. If the storage isn’t accessory to a primary use, then the storage would be classified in the Group S categories. If it then is in with a mix of other occupancies, Section 508 will be applicable. Table 509 for incidental uses would require storage rooms in Group I-2 and ambulatory care facilities with an area over 100 square feet (9.3 m2) to be separated by fire barriers or horizontal assemblies with a fire-resistance rating of at least 1 hour."
IMO, if Section 311.1.1 were meant to be regulated by Section 508.2, then it would reference that section or be deleted entirely and let Section 508 cover it. Personally, I prefer that it be handled as an incidental use per Section 509 as it was originally provided in the 2006 IBC (although I thought 100 sq. ft. was a bit too restrictive).