• Welcome to the new and improved Building Code Forum. We appreciate you being here and hope that you are getting the information that you need concerning all codes of the building trades. This is a free forum to the public due to the generosity of the Sawhorses, Corporate Supporters and Supporters who have upgraded their accounts. If you would like to have improved access to the forum please upgrade to Sawhorse by first logging in then clicking here: Upgrades

Does the building code still apply in this scenario?

NeuBee

Registered User
Joined
Jan 24, 2024
Messages
5
Location
SF
Working on an unusual project. Its a training structure for the fire department made from storage containers, no electrical, plumbing, or insulation. Its essentially a metal box stacked together with doors and windows so they can set mock fire scenarios for training. My question is, does the building code still apply even if its not designed for life/safety of the occupant? For example, if the intent is exiting the 2nd floor through a window instead of a door, can I ignore the number of doors required by code?
 
I'd call it a Group U and build it "to comply with the requirements of this code commensurate with the fire and life hazard incidental to their occupancy" per 312.1 of the IBC

I would say the code still applies generally, but many components of the code can be waived depending on the comfort level of your jurisdiction. I'd let you pretty much do what you want to do as long as you aren't building in traps like in some hidden ancient treasure temple :)
 
Welcome to the forum! You did not say the location of the project, or the Authority Having Jurisdiction. Please provide, so that we know which building code you are referring to.

If it is the California Building Code, then CBC 101.2 says that the scope applies to "buildings", and CBC 202 says the definition of "building" is that it is "intended for human occupancy". It sounds to me like what you have is not a building, but a training device that pretends to be a building.
CBC 104.11 also allows for alternate means of compliance other than the prescriptive parts of the code. What you are proposing inherently has a "fire watch" by trained fire professionals (as well as those in training) as a performance based alternative.

Is the fire department telling you the plan and features that they want? are they willing to accept their own plan as a performance based alternative to the code?
 
Here in Oregon the scope of our IBC (called the Oregon Structural Specialty Code) is quite a bit different than the model code's scope. I recently was approached regarding the proposed construction of a stand-alone training structure that had no additional uses and determined that it was not contemplated by the Oregon code and was outside of the scope of our code.
 
Welcome to the forum! You did not say the location of the project, or the Authority Having Jurisdiction. Please provide, so that we know which building code you are referring to.

If it is the California Building Code, then CBC 101.2 says that the scope applies to "buildings", and CBC 202 says the definition of "building" is that it is "intended for human occupancy". It sounds to me like what you have is not a building, but a training device that pretends to be a building.
CBC 104.11 also allows for alternate means of compliance other than the prescriptive parts of the code. What you are proposing inherently has a "fire watch" by trained fire professionals (as well as those in training) as a performance based alternative.

Is the fire department telling you the plan and features that they want? are they willing to accept their own plan as a performance based alternative to the code?
You got it right, its going to be under the CBC, and yes its the fire department giving the input on how the design/layout should be. Highlighting the definition of a building just clarified so much for me. Thank you for that. My thinking now is that CBC no longer applies, but would there be another set of codes that guides the construction of a training structure such as this? (Structural will be done properly to assure the safety of trainees, etc) Something from NFPA perhaps, but it'll have to be adopted by the AHJ? (Thank you to everyone as well for your input, it helped a lot)
 
You got it right, its going to be under the CBC, and yes its the fire department giving the input on how the design/layout should be. Highlighting the definition of a building just clarified so much for me. Thank you for that. My thinking now is that CBC no longer applies, but would there be another set of codes that guides the construction of a training structure such as this? (Structural will be done properly to assure the safety of trainees, etc) Something from NFPA perhaps, but it'll have to be adopted by the AHJ? (Thank you to everyone as well for your input, it helped a lot)
May not be a building, but the CBC definitely applies to structures as well.

2022 CBC - 1.1.3 Scope

The provisions of this code shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures throughout the State of California.

[A] STRUCTURE. That which is built or constructed.
 
May not be a building, but the CBC definitely applies to structures as well.

2022 CBC - 1.1.3 Scope

The provisions of this code shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures throughout the State of California.

[A] STRUCTURE. That which is built or constructed.
That's true too.. Thank you. Such a fine line that I am unsure where to stand..
 
As a caveat, this type of a set up would be regulated by NFPA standards for firefighting and live burn scenarios. We have set up the same thing in our community without the live burn because of all the regulations involved. I do not remember exact NFPA standard, but I am think 1492????
 
This sounds familiar. There may be a previous discussion of the topic.

Someone should be paying attention to the structural and exiting concerns of the facility while it is on fire.
 
As a caveat, this type of a set up would be regulated by NFPA standards for firefighting and live burn scenarios. We have set up the same thing in our community without the live burn because of all the regulations involved. I do not remember exact NFPA standard, but I am think 1492????

Was the proposed NFPA standard legally adopted or is the building official exceeding his authority?
 
This sounds familiar. There may be a previous discussion of the topic.
 
Yes, I think you're referring to NFPA 1402: Standard on Facilities for Fire Training and Associated Props

Trying to look for a section regarding scope to see if it applies. From my understanding, it has to be adopted by the AHJ first?
 
May not be a building, but the CBC definitely applies to structures as well.

2022 CBC - 1.1.3 Scope

The provisions of this code shall apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures throughout the State of California.

[A] STRUCTURE. That which is built or constructed.
According to that definition of "structure" , an automobile and my smartphone are also subject to the Building Code, because they are built and constructed.
Not trying to be a smarta$$, just pointing out the limitations of the language in providing a useful distinction.
 
Was the proposed NFPA standard legally adopted or is the building official exceeding his authority?
Since this structure would be hard to make code compliant, I believe the 2 sections below give the BO the authority to reference the use of NFPA 1402: Standard on Facilities for Fire Training and Associated Props for this structure without it being adopted locally. After all, isn't that the purpose of a standard is to tell you how to install a system or conduct a specific operation safely?

Ask you legal counsel if they agree.

1706128710418.png

1706128753191.png
 
Understanding that an NFPA standard has to be legally adopted, however if someone gets injured or worst, where will the finger pointing start. Just threw that out there for consideration. As the former safety officer on our department, I would allow as much search and rescue drills as they wanted, but no live fire.
 
For the love of Pete, think this through. This is not a normally occupied building - it's a freaking training facility. The enterprise would have to meet zoning regulations for institutional use, sure, but what lives - exactly - are you protecting by trying to assert code? The occupants? *There are no occupants*.

Fire safety? The folks going into it are going to be firefighters, geared, garbed and the like.

Our (Canuck) Codes allow for buildings that can't be classified to be constructed according to "good engineering practice."

If you absolutely want to have some involvement, get engineering on the structural elements. Anything further and you're one step away from writing up the shacks in a paintball facility for not meeting Code.... or telling Timmy's dad that he can't have a treefort in the sticks.
 
Just wanted to say thank you to all who commented so far. I appreciate the different points of view and have learned from it. For now, without a standard to stick to; I'm proceeding with the premise that I'd use the building code as a guide for best practice, but the final word on safety/build quality is deferred to the BO/FM based on their needs. Will update on my side if anything changes.
 
This sounds like a setup for an armageddon battle between the plan reviewer and the fire marshall. All that’s missing is the zoning office.
 
Our fire department had smoke machines that did not use open flame so we would smoke the h*ll out them. We have had them for 15 years and installed infrared cameras inside to monitor the teams doing the drill. The community helped out and a local welding shop constructed a metal platform on one side to do elevated rescues. Hardest issue was where two containers join and getting them waterproof. Enough thread drift, sorry.
 
Top