defining the 'work area'

[rooster]

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

You keep saying the ICC does not clearly define "work area". But it does, and I've referred to it now multiple times. Here it is again:

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.

Now if you take this definition and apply it to the project in question, I believe you'll find your answer, and from the sounds of it, the work area will be 35% (from previous post). Yes, work is going on in all parts of the building...and yes all that work is now Level 2, but this definition of "work area" given by the ICC does not tell you to take them into account. If you decide to include all that work as the work area, I don't believe you are following the code. And a commentary won't cut it...which by the way doesn't even mention the word "work area."

 

[texasbo]

brudgers...but sheesh, stop making ridiculous assumptions.

You're new 'round these parts, huh? Your request would constitute a Level 10 Alteration...

 

[texasbo]

that's rich.so you're saying the ICC interp of the ICC code is flat out wrong?

Actually, I disagree with you on this one; who writes the code? We do. ICC just publishes it. Then they hire some people to interpret it. There is nothing magical about these people, and there is nothing magical about ICC's sanction of their interpretation. I don't care about ICC's interpretation; I care about mine. And I also care about the interpretation of some of the very smart code people I know, including many on this forum. You never know what you're getting on the other end of an ICC interp. It may be very good, and it may not...

 

[Mr Softy]

Now if you take this definition and apply it to the project in question, I believe you'll find your answer, and from the sounds of it, the work area will be 35% (from previous post). Yes, work is going on in all parts of the building...and yes all that work is now Level 2, but this definition of "work area" given by the ICC does not tell you to take them into account.

it may not tell you to include it, but it also does not say to not include it.

the only thing specifically not included is incedental work areas and areas where the code may require upgrades.

 

[brudgers]

that's rich.so you're saying the ICC interp of the ICC code is flat out wrong?

I am saying that the ICC interpretation is an interpretation and subject to error - it is not the committee's interpretation but that of some author who was hired to interpret the entire fricken code.

And yes, it is often incorrect (as in this case if the citations by other posters are correct) where it ignores the definition of work area.

I'll point out, that if the ICC interpreted the code in ways in which those people who require interpretations did not like, the ICC would generate less revenue.

 

[brudgers]

it may not tell you to include it, but it also does not say to not include it.the only thing specifically not included is incedental work areas and areas where the code may require upgrades.

Getting interpretations you don't like, are you?

Hmmm....

 

[Mr Softy]

for the record.

what we are requiring of contractors is a drawing in the plan set that clearly defines the work area. and square foot calculations indicationg the ratio of work area to total area.

(as i stated earlier, i have only had one application where the contractor opted for Chap 3.)

we've had two similar R-2 projects come in in which the scope is demo and rehab of kitchens and baths. works out to be about 25% of the floor area. we notify the contractors about expansion of work area.

we have had one R-2 project where the scope was minimal at first, but mushroomed into major renovations including extensive layout changes throughout (Level 2 into Level 3). on this one we required compliance with the sprinkler requirements of 704.2.2.

 

[Mr Softy]

Getting interpretations you don't like, are you?Hmmm....

i would ask you the same question.

 

[rooster]

i would ask you the same question.

Once owners find out their modest rehab project sky-rockets into major renovations, don't be surprised when they phase projects to skirt your requirements.

I'm not concerned with what the code doesn't say...only with what it says. You can't add things in. If it said "where ANY work is being done" then I would consider all work being done. But it specifically says reconfigured spaces.

And for the record, I don't believe the commentary you referred to is inaccurate, I just don't think it has to do with work area.

 

[Mr Softy]

Once owners find out their modest rehab project sky-rockets into major renovations, don't be surprised when they phase projects to skirt your requirements.

they're not my requirements. they're the requirements of major renovations.

i'm talking about expanded scope that sure looks like major renovations (and i think we can all say that we know that when we see it).

IEBC leaves a big grey area in the middle between where you obviously don't need FP upgrades and where you do. all they reference is a sq ft number and it doesn't address scope. nor does it talk about parsing off Lev 1 from Lev 2. on the contary it seems they go the other way.

we're searching for something enforcable and consistent.

 

[rooster]

they're not my requirements. they're the requirements of major renovations.i'm talking about expanded scope that sure looks like major renovations (and i think we can all say that we know that when we see it).

IEBC leaves a big grey area in the middle between where you obviously don't need FP upgrades and where you do. all they reference is a sq ft number and it doesn't address scope. nor does it talk about parsing off Lev 1 from Lev 2. on the contary it seems they go the other way.

we're searching for something enforcable and consistent.

I see no reference in the code to "major renovation." Therefore I cannot comment on what one looks like nor the IEBC requirements for "major renovations."

 

[rooster]

Ok, I reread the commentary you refer to, and I don't know whether it is consistent with the code.

404.2 Application. Level 2 alterations shall comply with the

provisions of Chapter 6 for Level 1 alterations as well as the

provisions of Chapter 7.

I'm still looking to see where the code says once you're in level 2, everything is a level 2.

 

[Mr Softy]

I see no reference in the code to "major renovation." Therefore I cannot comment on what one looks like nor the IEBC requirements for "major renovations."

i didn't refer to any code reference for 'major renovation'. real world scope of work, independent of any concept of 'work area'.

but anyway, let me get this straight -

when you walk onto a jobsite, you have no clue whether you're looking at major work or minor work?

 

[Mr Softy]

Ok, I reread the commentary you refer to, and I don't know whether it is consistent with the code.404.2 Application. Level 2 alterations shall comply with the

provisions of Chapter 6 for Level 1 alterations as well as the

provisions of Chapter 7.

I'm still looking to see where the code says once you're in level 2, everything is a level 2.

Here's the commentary language -

"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"

that's how i read the first (bolded) phrase.

here i've changed the example, but the code effect would stay the same.

"This requirement effectively compounds the requirements for someone planning to alter an existing structure. For example, if during the process of replacing horsehair plaster with blueboard, the building owner decides to remove one wall within 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"

redoing the wall covering would be Level 1 work - changing a system. The removal of a wall would be Level 2. ICC compounds the work into Level 2.

 

[brudgers]

we're searching for something enforcable and consistent.

Tellingly, correct doesn't enter into the equation.

Neither does reasonable.

Or cost-effective for that matter.

The beauty of the building department is that so long as you are consistent you are covered.

Even when you are wrong.

On the other hand, being personally responsible, I have to get it right.

 

[mtlogcabin]

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.

Then the building department is wrong and acting as the DP on the project. You may be requiring them to spend more money then required to be code compliant. The DP's and builders will never learn a new code unless they are made to. The project can sit in the plan review stage untill the cows come home if it isn't right. I am sure you would not issue a permit for new construction under the building code without the design information on them. IEBC 101.5 requires the design/compliance method being used to be identified and shown. Once the Prescriptive or Work Area or Performance compliance method is choosen that is the one that is used. You do not mixed the requirments to require compliance. What was described in your OP can easily be achieved through Chapter 3

 

[Mr Softy]

Then the building department is wrong and acting as the DP on the project.

not really. the work is what it is.

and the design team can certainly choose Chap 3. now, if they don't know Chap 3...

 

[Mr Softy]

Tellingly, correct doesn't enter into the equation.Neither does reasonable.

Or cost-effective for that matter.

The beauty of the building department is that so long as you are consistent you are covered.

Even when you are wrong.

On the other hand, being personally responsible, I have to get it right.

well, as correct as can be.

and reasonable only to a degree. I prefer to err on the side of too conservative or too literal, and let a discussion with the appeals board sort everything out. 'reasonable' often has the potential to get me in BIG trouble.

we try not to be 'wrong', but on your side of the counter it may not be seen as right. but we try, and we remain open to alternate interpretations.

 

[brudgers]

I prefer to err on the side of too conservative or too literal, and let a discussion with the appeals board sort everything out. 'reasonable' often has the potential to get me in BIG trouble.

I can tell that you prefer to err.

It comes with having someone else to ultimately take responsibility for getting it right.

The "You can always appeal" my decision approach, is what I call "holding the permit hostage."

Like Inspector's remorse, it is another common practice with code officials.

 

[Mr Softy]

i wish i could be as perfect as you.

i have no remorse.

and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.

but don't ask me to be liberal with the egress regs or the FP regs. you don't like my conservative approach - appeal it. i will have code on my side, and will make an cogent argument to back my position.

what will your pitch be? 'waaaa, it's too hard, it's not fair'?

 

[rooster]

i wish i could be as perfect as you.i have no remorse.

and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.

but don't ask me to be liberal with the egress regs or the FP regs. you don't like my conservative approach - appeal it. i will have code on my side, and will make an cogent argument to back my position.

what will your pitch be? 'waaaa, it's too hard, it's not fair'?

I'm still waiting to see what part of the code you're hanging your hat on.

 

[rooster]

i didn't refer to any code reference for 'major renovation'. real world scope of work, independent of any concept of 'work area'.but anyway, let me get this straight -

when you walk onto a jobsite, you have no clue whether you're looking at major work or minor work?

I don't care if the entire bulding is enveloped in a cloud of plaster dust while the interior is nothing but the air between the studs. As long as no spaces are getting reconfigured, it's a level 1. It looks pretty major, but the code says it's level 1.

 

[Mr Softy]

I don't care if the entire bulding is enveloped in a cloud of plaster dust while the interior is nothing but the air between the studs. As long as no spaces are getting reconfigured, it's a level 1. It looks pretty major, but the code says it's level 1.

absolutely. no disagreement. and i couldn't and wouldn't call it anything else.

(as an aside, when we were talking about adoption of IEBC, this scenario came up. but none of us had ever seen such a project. in our experiences, there is always reconfiguration of space. )

for me, it's a disconnect in the code that such a project which is certainly major in scope, and offering the ideal conditions for installation of a sprinkler system, could not require a FP upgrade, yet a marginal Level 2 project could.

 

[brudgers]

i wish i could be as perfect as you.i have no remorse.

and believe it or not, i try and work with the design side as best as i can to achieve something we both can live with.

but don't ask me to be liberal with the egress regs or the FP regs. you don't like my conservative approach - appeal it. i will have code on my side, and will make an cogent argument to back my position.

what will your pitch be? 'waaaa, it's too hard, it's not fair'?

Whine, hardly.

My preferred approach starts with burying unreasonable bureaucrats in paper and dragging them to endless meetings to work things out - which of course I follow up with...you guessed it, more paper.

When the correspondence gets to be about 1/2" thick and there are a dozen or so written communications to which the bureaucrat has not responded - I stick it in envelope with a cover letter to the city attorney.

It's the counter punch to your "hold the permit hostage" strategy - create an unexpected amount of friction from unexpected sources by creating an unexpected paper trail.

Getting inside a decision loop like yours is trivial.

OODA [http://en.wikipedia.org/wiki/OODA_loop]