defining the 'work area'

[brudgers]

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.

You're pushing an agenda which goes beyond code requirements.

And treating the building code like mere suggestions in the process.

As it has become apparent, making something up and holding the permit hostage when the code doesn't say what you want it to say appears to be your M.O.

 

[rooster]

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.

I'm going to go at this from one other direction. I've hung in here to see if maybe there was a flaw in my logic, but so far I'm satisfied.

Below is the scope of a level 3 alteration. If you interpret the code the way are doing, then level 2 doesn't even have to come into play whatsoever. An owner could simply be replacing ceiling tiles 100% and this would kick it into a level 3 because you are considering ALL the work to be the work area, where as the definition of work area does not consider ALL the work. If you want to be consistent, then you'll have to require sprinkler for this job that is replacing ceiling tile only...not just the job that is tearing down plaster and replacing drywall.

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.

 

[rooster]

On the flip side, if you look at the work area as it is defined, I believe you'll find there is a greater opportunity to be consistent, as level 1 alterations will never be triggered into a level 3, and you won't have one window elimination triggering a level 3.

To put it another way, if you require sprinklers in this project (assuming we're stinking with the work area option), then you'll have to require them for every level 1 project that exceeds 50% of the building...reconfiguration or not.

 

[Mr Softy]

rooster, i follow you argument to a point.

i might argue that to get to Level 3, Level 2 work must be part of the equation. Level 1 cannot go direct to Level 3 otherwise.

the ceiling tile example, while building wide, would still be only Level 1.

Below is the scope of a level 3 alteration. If you interpret the code the way are doing, then level 2 doesn't even have to come into play whatsoever. An owner could simply be replacing ceiling tiles 100% and this would kick it into a level 3 because you are considering ALL the work to be the work area, where as the definition of work area does not consider ALL the work. If you want to be consistent, then you'll have to require sprinkler for this job that is replacing ceiling tile only...not just the job that is tearing down plaster and replacing drywall.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.

last phrase - proposed to be reconfigured - there's your Level 2 work escalating to Level 3.

and the first phrase - project area - introduces a term that isn't defined.

 

[Mr Softy]

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]

i'm not surprised your projects take forever. :banghd

As it has become apparent, making something up and holding the permit hostage when the code doesn't say what you want it to say appears to be your M.O.

wow.

how do you klnow my M.O.? what projects have we worked on together? please tell me i'm anxious to know.

You're pushing an agenda which goes beyond code requirements.

you dealt with the local Fire Department lately?

I work under the aegis of the Dept of Public Safety, not the Dept of Making it Easy for Architects.

this is my last correspondence with you.

thank you for playing, we have some lovely parting gifts.

 

[rooster]

rooster, i follow you argument to a point.i might argue that to get to Level 3, Level 2 work must be part of the equation. Level 1 cannot go direct to Level 3 otherwise.

Where does the code say this?

 

[rooster]

the ceiling tile example, while building wide, would still be only Level 1.

last phrase - proposed to be reconfigured - there's your Level 2 work escalating to Level 3.

and the first phrase - project area - introduces a term that isn't defined.

Yes! reconfigured spaces. No where in the code does it say what level this work is or has to be. Only that it is reconfigured.

If I look only at the scope of level 3 alteration below I will find nothing that gives me the idea that Level 2 must be reached first...I find only that I need to figure out what the work area is, which fortunately is defined in Chapter 2... where there is a definition that makes no reference to reaching certain levels of alteration.

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.

 

[Mr Softy]

801.2 Compliance - In addition to the provisions of this chapter, work shall comply with all the requirements of Chaps 6 and 7.

my read is that if you hit Level 3, compliance with 2 and 1 are required as well. but to be in Level 2 requires reconfiguration. no reconfiguration, no Level 2 and then no Level 3.

or.

as it requires compliance with Chap 7, as long as there is no reconfiguration, one can say no compliance with Chap 7 required. and as the FP requirements live in Chap 7, level 3 work that involves no reconfiguration dooes not trigger FP requirements.

 

[TimNY]

A quick scan of the Level 1 Alteration chapter does not use the word "WORK AREA".

Yet another angle.. You have Level 1 work going in a space; pick your favorite 1000sf commercial space. It could be a ballroom in hotel, or a retail store.

The designer decides to make a Level 2 alteration; remove a window, remove a door, add a wall, whatever.

What is the work area for the Level 2 alteration? Does it include the space (part of it, all of it) that is a Level 1 alteration?

If the work area now includes the space (part, all) that was a Level 1 alteration, what rules do you apply?

The work area has to be limited in some fashion. Is it a wall? Is it an imaginary line? Is it the projected line of a window sill?

 

[Mr Softy]

Tim, this is exactly the question.

 

[rooster]

Tim, this is exactly the question.

Are you serious? You want to go back to the beginning? Your question was to define "work area" and that definition is supplied by the code. Now if you want to argue about what consitutes a reconfigured space, then that's a whole other issue altogether.

cock-a-doodle-do...over & out.

 

[Mr Softy]

Are you serious? You want to go back to the beginning? Your question was to define "work area" and that definition is supplied by the code. Now if you want to argue about what consitutes a reconfigured space, then that's a whole other issue altogether. cock-a-doodle-do...over & out.

alright alright that was the question

but it is still the thing we are wrestling with -

where is the line between reconfigured space and the work area? is there a line? can there be a lilne? should there be line?

after 6 pages Tim still doesn't see an answer, and neither do i.

there seems to be nothing in the code that sets it out either.

 

[rooster]

alright alright that was the question but it is still the thing we are wrestling with -

where is the line between reconfigured space and the work area? is there a line? can there be a lilne? should there be line?

after 6 pages Tim still doesn't see an answer, and neither do i.

there seems to be nothing in the code that sets it out either.

OK, I can't resist. According to the definition of work area there is no line...WORK AREA = RECONFIGURED SPACE...simple as that. There can't be a line between them, because they are one in the same. If the code wants to include more than the reconfigured spaces into the work area, it needs to tell me that.

 

[brudgers]

i'm not surprised your projects take forever. :banghd

As if further evidence that you rely on holding the permit hostage to your made up requirements was needed.

you dealt with the local Fire Department lately?

Of course.

And unsurprisingly, they don't have carte blanche to make stuff up.

Even when they think they do.

As any city attorney will tell you.

 

[mtlogcabin]

106.2.1 Construction documents.

Construction documents shall be dimensioned and drawn upon suitable material. Electronic media documents are permitted to be submitted when approved by the code official. Construction documents shall be of sufficient clarity to indicate the location, nature and extent of the work proposed and show in detail that it will conform to the provisions of this code and relevant laws, ordinances, rules and regulations, as determined by the code official. The work areas shall be shown.

It should be defined on the drawings

 

[brudgers]

alright alright that was the question but it is still the thing we are wrestling with -

By "we" you must mean, you and the mouse in your pocket.

 

[TimNY]

Yes, I do want to go back to the beginning. Because it seems the beginning is where all the disagreement is. And spare me your theatrics. Nobody on this forum is above reproach; the time will come where you will be wrong on a subject and I will be happy to debate the issue in a professional manner.

Let me reword such that the question can't be avoided by scrutinizing the wording and overlooking the obvious intent of the question.

Where is the "reconfigured space"? Where does the "space" end? Is the space the room? In my scenario is the entire 1000sf "space"?

If so, assume there is a shaft 20 feet away from the wall/door/window to be reconfigured. Do you follow level 1 or level 2?

 

[mtlogcabin]

In the beggining of the IECC code is the administrative section where the DP is required to choose one of 3 methods for his/her project.

101.5.1 Prescriptive compliance method.

Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

101.5.2 Work area compliance method.

Repairs , alterations , additions , changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 4 through 12 of this code shall be considered in compliance with the provisions of this code.

101.5.3 Performance compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 13 of this code shall be considered in compliance with the provisions of this code

If a DP/contractor does not choose or is not smart enough to figure a method and provide proper documentations as to how they are going to comply with that method then as a building department I believe you should default to the presriptive method and follow that.

 

[brudgers]

Where does the "space" end?

Obviously, at 51%.

 

[rooster]

Yes, I do want to go back to the beginning. Because it seems the beginning is where all the disagreement is. And spare me your theatrics. Nobody on this forum is above reproach; the time will come where you will be wrong on a subject and I will be happy to debate the issue in a professional manner.Let me reword such that the question can't be avoided by scrutinizing the wording and overlooking the obvious intent of the question.

Where is the "reconfigured space"? Where does the "space" end? Is the space the room? In my scenario is the entire 1000sf "space"?

If so, assume there is a shaft 20 feet away from the wall/door/window to be reconfigured. Do you follow level 1 or level 2?

I hope you didn't take my remarks as condescending because they were not meant to be. I was only voicing my frustration that we don't seem to be getting anywhere. I don't claim to be right. I am only looking at what the code says and everytime I bring something from the code to the table, it seems to be countered with inferences pulled from the code. For instance...why can't we accept that the work area doesn't include level 1 alterations? No reconfiguration of space = not a part of work area (as defined by code).

Now the situation you have brought to the table brings a whole new element to the discussion, and one I'm not clear on myself. What is considered the reconfigured space? Is it the area of the window being closed or the space the window serves? I don't know. According to the code it sounds like the "space" would be considered the work area.

But, this doesn't seem to be the OP's problem. In fact, in a previous post he states the reconfigured space to be 35% of the project. He doesn't have a question about that. I believe he said that it was nowhere near 50%. He has a question about whether or not the replacing windows and drywall turns the "work area" into 100%. And I have yet to see the section where the code states this. All the while a very explicit definition of work area exists, and it has nothing to do with thresholds of levels or compounding of chapters that must be complied with.

 

[rooster]

In the beggining of the IECC code is the administrative section where the DP is required to choose one of 3 methods for his/her project. 101.5.1 Prescriptive compliance method.

Repairs, alterations, additions and changes of occupancy complying with Chapter 3 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.

101.5.2 Work area compliance method.

Repairs , alterations , additions , changes in occupancy and relocated buildings complying with the applicable requirements of Chapters 4 through 12 of this code shall be considered in compliance with the provisions of this code.

101.5.3 Performance compliance method.

Repairs, alterations, additions, changes in occupancy and relocated buildings complying with Chapter 13 of this code shall be considered in compliance with the provisions of this code

If a DP/contractor does not choose or is not smart enough to figure a method and provide proper documentations as to how they are going to comply with that method then as a building department I believe you should default to the presriptive method and follow that.

Thanks. Quite honestly I just don't have a lot of experience with this method, so I'll have check it out to see how it works in comparison to the work area option.

 

[rooster]

Thanks. Quite honestly I just don't have a lot of experience with this method, so I'll have check it out to see how it works in comparison to the work area option.

OK, took a quick look at the IFC (2003) while looking at the prescriptive method, and it requires sprinklers in an R occupancy. So the example of the OP would not be in compliance, so sprinklers would be required...right?

 

[Mr Softy]

OK, took a quick look at the IFC (2003) while looking at the prescriptive method, and it requires sprinklers in an R occupancy. So the example of the OP would not be in compliance, so sprinklers would be required...right?

As I read it, you cannot use Chap 3 if the building does not comply with IFC.

one either makes the building comply, or one goes to the work area method.

 

[Mr Softy]

But, this doesn't seem to be the OP's problem. In fact, in a previous post he states the reconfigured space to be 35% of the project. He doesn't have a question about that. I believe he said that it was nowhere near 50%. He has a question about whether or not the replacing windows and drywall turns the "work area" into 100%. And I have yet to see the section where the code states this. All the while a very explicit definition of work area exists, and it has nothing to do with thresholds of levels or compounding of chapters that must be complied with.

35% counting gross square footage of rooms where work is being performed.

one method of calculation put forth is net square footage of reconfigured space only. so if a wall is being removed, does reconfigured space = 5.5" X length of wall? and that's it.