defining the 'work area'

[Mr Softy]

Did the owner state on his application which level of compliance he choose or did the building department?

i have received 1 application since Feb where the DP chose Chap 3.

we adopted IEBC (with MA amendments) in Feb, and nearly 6 months later most of the contractors still don't know that.

we've given out instructional material explaining the compliance paths and work levels with every application.

i had one contractor tell me he was doing Level 1, 2, and 3 work. because he was working on all three floors.

so to answer your question, we've been assigning the Level of Work based on the application.

we've only just recently had two of these triple decker applications come in.

 

[Mr Softy]

Chapter 3I doubt the 3rd floor is over 50 feet above the level of fire department access so no standpipes are required

4603.5 Standpipes.

Existing structures with occupied floors located more than 50 feet (15 240 mm) above or below the lowest level of fire department vehicle access shall be equipped with standpipes installed in accordance with Section 905.

oh well caught - thanks!

 

[ICE]

Tall dogs and ice cream cones. Who didn't see it coming?

 

[brudgers]

approximately 35% of the floor area, per floor. so far so good. 704.2.2 has not been met.but the scope of work is going to include ceiling cans throughout the units, layover of sheetrock walls and ceilings, siding, insulation, and let's throw in replacement windows throughout.

work is Level 2

R-2 requires sprinkles at 0 sq ft.

work is over 50% of floor

there is water available.

6" cans have a projected floor area of 0.2 square feet each.

5/8" sheet rock has a floor area of 0.052 square feet per linear foot.

A 36" window with an 8" stool has a projected floor area of 2 square feet.

400 lineal feet of drywall + 10 windows + 50 cans = 50 square feet of floor area.

If the floors are larger than 334 square feet, that's less than 15% of the floor area.

Since the floors look more like 2000 sf, to get an additional 15% of floor area from those components you are talking about something like 2400 lf of drywall + 60 windows + 300 cans per floor.

For those scoring at home, that's 7200 lf drywall (57,000 square feet assuming 8' ceilings) + 180 windows + 900 cans (an electrical service upgrade should be considered) for the building.*

Just to get the additional 15%.

Of course, it's not likely you're interested in actually approving the plans given that your argument hinges on the absurdity that 35% is close to 50%.

[Edit] *A structural system upgrade might also be necessary as the 480 sheets of drywall will add an additional 33kips of load to the foundation.

 

[Mr Softy]

6" cans have a projected floor area of 0.2 square feet each.5/8" sheet rock has a floor area of 0.052 square feet per linear foot.

A 36" window with an 8" stool has a projected floor area of 2 square feet.

400 lineal feet of drywall + 10 windows + 50 cans = 50 square feet of floor area.

If the floors are larger than 334 square feet, that's less than 15% of the floor area.

Since the floors look more like 2000 sf, to get an additional 15% of floor area from those components you are talking about something like 2400 lf of drywall + 60 windows + 300 cans per floor.

For those scoring at home, that's 7200 lf drywall (57,000 square feet assuming 8' ceilings) + 180 windows + 900 cans (an electrical service upgrade should be considered) for the building.*

Just to get the additional 15%.

see, that's better.

rather than just over-interpreting these posts to an absurd level because it's easier than actually reading the posts, you took time to make a reasonable point.

i don't disagree with your measurements.

what i'm curious about has there ben any interps or appeals based upon measuring in such a way?

however a 6" can has an actual area of 4 sq ft after one is done making the hole it will sit in, and treating that opening, both for fire separation and sound tranmittal. and i suppose one could say that the area required for an electrician to set up and install that can gets even larger. the spread for a 6' step ladder probably adds another 8' to the equation.

let's keep playing

 

[rooster]

ICC - in the commentary - has taken the position that any work performed in conjunction with Level 2 work, is also classified as Level 2.

and when the thresholds are met, the thresholds are met.

Can you show me where the IEBC says this. I had this issue a few days ago. I have a situation very similar to what you describe, but I'm on the other side of the submission. The code consistently refers to the percentage of the work area. And by definition the work area is the "reconfiguration of space." I do not find anywhere in the code where it says the percentage of "level 2 work". Therefore even if the whole thing is a Level 2, you would look at the "work area" as only those spaces that are reconfigured. And even then, you don't have to include incidental work or work the "code made me do."

WORKAREA. That portion or portions of a building consisting

of all reconfigured spaces as indicated on the construction

documents. Work area excludes other portions of the building

where incidental work entailed by the intended work must be

performed and portions of the building wherework not initially

intended by the owner is specifically required by this code.

But if you can direct me to the section where it says Level 2 swallows up Level 1 and now it's all in the work area I will reconsider.

 

[rooster]

by the way. why is this project still level 2? If you've determined the the work area to be over 50%, then it's a level 3.

 

[Mr Softy]

But if you can direct me to the section where it says Level 2 swallows up Level 1 and now it's all in the work area I will reconsider.

IEBC Commentary. Ch 4 Classification of Work. 404.2 Application for Level 2 Work.

it talks about Lev2 work including the provisions for Lev1 work, then...

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"

 

[Mr Softy]

by the way. why is this project still level 2? If you've determined the the work area to be over 50%, then it's a level 3.

yes, and that kicks back to 704.2.2 for the FP thresholds

 

[rooster]

IEBC Commentary. Ch 4 Classification of Work. 404.2 Application for Level 2 Work.it talks about Lev2 work including the provisions for Lev1 work, then...

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"

But I do not see anything about "work area." from 704.2.2 - 2. The work area exceeds 50 percent of the floor area;

And according to the definition of "work area" (given abv), this would be where the spaces are reconfigured. Not every place you are doing work.

 

[rooster]

yes, and that kicks back to 704.2.2 for the FP thresholds

So a project that replaces drywall and demo's one partition is considered a level 3? I'm not saying this is exactly your situation, but it could happen. And it just doesn't seem like the intent of the code.

 

[brudgers]

So a project that replaces drywall and demo's one partition is considered a level 3? I'm not saying this is exactly your situation, but it could happen. And it just doesn't seem like the intent of the code.

You don't even need to demo drywall, just paint the existing and someone will claim the work area is 100% - see reference to ladders below.

 

[Mr Softy]

But I do not see anything about "work area." from 704.2.2 - 2. The work area exceeds 50 percent of the floor area; And according to the definition of "work area" (given abv), this would be where the spaces are reconfigured. Not every place you are doing work.

well, that's the problem. what is "work area"?

by the commentary, it appears that work area is compounded and it becomes everywhere you are doing work. some Level 2 work kicks an entire project into Level 2.

So a project that replaces drywall and demo's one partition is considered a level 3? I'm not saying this is exactly your situation, but it could happen. And it just doesn't seem like the intent of the code.

it would be Level 3 if it is over 50% of building area. again, usingh the commentary's position that work area compounds.

as brudgers as pointed out earlier (when not being absurd), work major in scope should be what triggers FP requirements, not an arbitrary 50% work area number. as demonstrated, it is nearly impossible to determine where that figure lies - it depends who is measuring. so the 'intent' is becomes very difficult to discern.

however even a term like 'major in scope ' becomes a moving target. we had a substantial renovation definition that hinged on cost of project vs. cost of sprinkler system. but the state folks really wanted to go with the ICC family of codes. so here we are trying to determine the intent of 'work area'.

You don't even need to demo drywall, just paint the existing and someone will claim the work area is 100% - see reference to ladders below.

you're funny.

 

[rooster]

Earlier you posted this commentary.

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing the aluminum siding on a building with vinyl siding, the building owner decides to eliminate one of four windows from a room, then this project would be classified as a Level 2 alteration and would, therefore, be required to meet the provisions of Chap 6 and 7"

My question is this: How do you explain the defnition of Work Area in chapter 2? I'm genuinely interested in this because this situation is on my table now.

Below is another part of the code and commentary which tells you to look at the definition of work area in chapter 2. And further more, I can't base my decision on an interpretation of the commentary. I need a number.

SECTION 405

ALTERATION—LEVEL 3

405.1 Scope. Level 3 alterations apply where the work area

exceeds 50 percent of the aggregate area of the building.

commentary

Anytime the project area, as defined in Section 202,

exceeds one-half of the aggregate building area, it is

considered to be a Level 3 alteration and, therefore,

has to meet the requirements of Chapter 8. In the

code, a work area encompasses all portions of the existing

building that are proposed to be reconfigured.

Where does it say that if the Level 2 work exceeds 50%, then it's a level 3?

 

[rooster]

OK, I was thinking about this a little last night and thought of a situation:

With Mr. Softy's interpretation of the code, you could potentially have a project with a total reconfiguration of space in 49% of the building, but it would not require sprinklers. We're talking a total blow out of walls with no spaces even close to what they were before the alteration...in almost half of the building...no sprinklers.

Now to the other extreme...

You could have a project that merely replaces ceiling tiles thoughout and closes up one window in a remote room, and now you will need sprinklers. Not only that, but this project is now a level 3 alteration, so it would have to comply with all three chapters.

It just doesn't make sense. How could the second situation be a higher level alteration?

But when I read the definition of work area, then it seems clearer that this is not the intention. I still haven't found where "level 2 work" = "work area." If I find this equation, then I'll reconsider. One can make the assumption that wherever you are doing work, it is the work area...but the definition of work area does not say this.

 

[TimNY]

That's why the performance-based option exists.

The work area option exists as a simple way to classify the scope of the work and mandate required improvements in association with that work. It is a good choice for a simple project, such as making changes to a single room. The work area option is not well suited to all projects.

When the project gets more complicated, you could choose the work area option, but as you noted, it will not make sense in some scenarios. Construction will be significantly easier if the performance-based method is used.

 

[Mr Softy]

OK, I was thinking about this a little last night and thought of a situation:With Mr. Softy's interpretation of the code, you could potentially have a project with a total reconfiguration of space in 49% of the building, but it would not require sprinklers. We're talking a total blow out of walls with no spaces even close to what they were before the alteration...in almost half of the building...no sprinklers.

Now to the other extreme...

You could have a project that merely replaces ceiling tiles thoughout and closes up one window in a remote room, and now you will need sprinklers. Not only that, but this project is now a level 3 alteration, so it would have to comply with all three chapters.

It just doesn't make sense. How could the second situation be a higher level alteration?

But when I read the definition of work area, then it seems clearer that this is not the intention. I still haven't found where "level 2 work" = "work area." If I find this equation, then I'll reconsider. One can make the assumption that wherever you are doing work, it is the work area...but the definition of work area does not say this.

by the definition of the levels of work, it is conceivable that an owner could do a gut renivation of an R-2, but with no reconfiguration of space, and not trigger any sprinkler requirements.

the bit of text i quoted from the commentary gives a bit of insight into the intent of the written code. ICC has stated that any level 2 work as part of a larger project, puts the entire project into the level 2 category. now i can see where this language can be interpretted to one's advantage and disandvantage (and that woud be for both sides of the counter).

your example is a great example of this. yes, once you close up the wall, by the IEBC, the project becomes Level 2 work.

we used to have language (through case law) that required the feasablity of sprinkler installation as part of the project. f'rinstance, an expensive renovation that could have reached a monetary threshold, but didn't include deomlition of walls and ceilings, would not facilitate the installation of a system. so a system would not be required.

this new work area thing is not easy because the ICC has not clearly defined what work area is.

is it the strictest limitation of the area undergoing change, as brudgers has argued, or is it the net area where work is happening?

 

[TimNY]

One of us could get off our butt and just ask the ICC..

Single building divided into two spaces, lets say a 4000sf space and a 6000sf space. The 4000sf space wants to move the single dividing wall so they now have 4500sf. Is this level 2 or level 3?

Same scenario, the 6000sf space wants to move the wall to reduce their space to 5500sf. Level 2 or Level 3?

We can "what if" this all day long. In the end a little discretion is warranted for simple projects.. For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.

 

[Mr Softy]

One of us could get off our butt and just ask the ICC..Single building divided into two spaces, lets say a 4000sf space and a 6000sf space. The 4000sf space wants to move the single dividing wall so they now have 4500sf. Is this level 2 or level 3?

Same scenario, the 6000sf space wants to move the wall to reduce their space to 5500sf. Level 2 or Level 3?

We can "what if" this all day long. In the end a little discretion is warranted for simple projects.. For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.

my take -

both scenarios are Level 2 work. reconfiguration of space.

it's the extent of associated work that makes it difficult.

if only the wall is being moved and then finishes around the wall completed, i don't see where the 50% threshold is met.

but if the wall is moved and a complete renovation of half the building, then maybe the 50% has been met.

 

[TimNY]

My take: Level 3.

WORK AREA. That portion or portions of a building consisting of all reconfigured spaces...

Is space 1 reconfigured? Yes. Is space 2 reconfigured? Yes. Work area is 100%.

Would the requirements imposed by a Level 3 throughout be unreasonable? Yes.

Could you use the performace-based method and make life much easier? Absolutely!

(edit: we do have to stipulate these are the only 2 spaces in the building for this to work [i know somebody would nitpick this ])

 

[brudgers]

the bit of text i quoted from the commentary gives a bit of insight into the intent of the written code.

It doesn't give insight into the intent of the code.

It gives one interpretation of the section.

As this board has shown, these interpretations are often flat out wrong.

Indeed the definition of work area shows that the interpretation which you cite is inconsistent with other sections of the code - and with that other section being more specific, it is quite clear that the interpretation is incorrect and not based on a deep understanding of the code.

Keep in mind that the commentary is something which the ICC does to check off their bucket list - as suggested by the fact that it is longer than the code itself, it is obviously not built upon broad consensus, i.e. compare it to the brevity of the Annex to NFPA 101.

 

[rooster]

We can "what if" this all day long. In the end a little discretion is warranted for simple projects.. For the bigger ones the designer should be spending some time with the performance-based method rather than arguing the work area option doesn't give them what they want.

You are right. I haven't spent enough time with the performance based method, but it seems a bit excessive for the example of replacing ceiling tiles and closing up a window. Furthermore it seems that given the example of of the ceiling tiles / closing a window, the work area option works just fine. You simply call your alteration a level 2 and then mark the reconfigured space (the room with the closed window) on the plan and call it a day. As long as that work area doesn't exceed 50%, then what's the problem? It seems to me that the intent of the code is to make sure that space is still safe once the window is removed...not to trigger your whole project into a level 3 situation. I don't know, unless I'm missing something.

And you are also right that we could what if all day long. And I would have to agree with you that by definition of work area, your example would be a level 3.

 

[mtlogcabin]

Here is a link based on the 2003 edition stating if water is not available at the floor then sprinklers are not required. They did not include R occupancies in the question because there was an exception in the section for R occupancies 3 stories or less.

http://www2.iccsafe.org/cs/committeeArea/pdf_file/EB_03_12_04.pdf

 

[Mr Softy]

It doesn't give insight into the intent of the code.It gives one interpretation of the section.

As this board has shown, these interpretations are often flat out wrong.

that's rich.

so you're saying the ICC interp of the ICC code is flat out wrong?