Existing Building Code | Stairs

[rosegamble]

Hello all,

Reading Section 804 of the Existing Building Code. Does Section 804 apply to any Level 2 alteration, or just to Level 2 alterations there are multiple tenants? 804.1 (Scope) is worded in a very confusing way and the commentary doesn't clear it up.

Thanks!

 

[Sifu]

Any work area (defined) in the listed occupancies AND where the conditions listed in IFC 915.1.2 through 915.1.6 exist. I read this to mean any area where work is scoped must comply, but areas not included in the original scope of the work are not required to comply.

 

[rosegamble]

Any work area (defined) in the listed occupancies AND where the conditions listed in IFC 915.1.2 through 915.1.6 exist. I read this to mean any area where work is scoped must comply, but areas not included in the original scope of the work are not required to comply.

Hello! Thank you. What do you mean by IFC? I am asking about the Existing Building Code, Section 804 (Level 2 Alteration, under the work area compliance method).

 

[Yankee Chronicler]

IFC is International Fire Code. In an existing building, the IFC applies if and when the IEBC sends you to it.

The provisions of IEBC Section 804 apply where it says they apply:

The requirements of this section shall be
limited to work areas that include exits or corridors shared
by more than one tenant within the work area in which Level
2 alterations are being performed, and where specified they
shall apply throughout the floor on which the work areas are
located or otherwise beyond the work area.

I don't find it confusing at all. What is your project? Does the work area include multiple tenants?

 

[rosegamble]

IFC is International Fire Code. In an existing building, the IFC applies if and when the IEBC sends you to it.

The provisions of IEBC Section 804 apply where it says they apply:



I don't find it confusing at all. What is your project? Does the work area include multiple tenants?

Right. So "The requirements of this section shall be
limited to work areas that include exits or corridors shared
by more than one tenant within the work area in which Level
2 alterations are being performed..."

So let's say an old restaurant space is being renovated into another restaurant as a Level 2 alteration. Does 804 not apply then? Does 804 only apply when there is "more than one tenant"?

 

[Yankee Chronicler]

Right. So "The requirements of this section shall be
limited to work areas that include exits or corridors shared
by more than one tenant within the work area in which Level
2 alterations are being performed..."

So let's say an old restaurant space is being renovated into another restaurant as a Level 2 alteration. Does 804 not apply then? Does 804 only apply when there is "more than one tenant"?

No, it applies where it says it applies: where there are exits or corridors that are shared by more than one tenant within the work area. It's written in English. Just read what it says.

 

[rosegamble]

No, it applies where it says it applies: where there are exits or corridors that are shared by more than one tenant within the work area. It's written in English. Just read what it says.

Yes, I can see it is written is English - thanks for that. It is just strange because there is very little egress information written in for Level 1 alterations so it begs the question what to do with egressing in a Level 2 alteration where there is only one tenant.

 

[Yankee Chronicler]

A level 1 alteration is limited to finishes, so it would not affect egress.

You still have not answered the basic questions pertaining to your project:

• What's the total floor area of the building, and what's the area of the work area involved?
• Do the alterations involve relocating, adding or removing any walls, doors, or windows?
• Is the building a single tenant building, or a multi-tenant building?
• If it is a multi-tenant building, are there any exits or corridors within the work area that are shared by more than one tenant?

The answer to your question is in the answers to these questions.

 

[rosegamble]

A level 1 alteration is limited to finishes, so it would not affect egress.

You still have not answered the basic questions pertaining to your project:

• What's the total floor area of the building, and what's the area of the work area involved?
• Do the alterations involve relocating, adding or removing any walls, doors, or windows?
• Is the building a single tenant building, or a multi-tenant building?
• If it is a multi-tenant building, are there any exits or corridors within the work area that are shared by more than one tenant?

The answer to your question is in the answers to these questions.

Thanks for your message. Those questions are not 100% pertinent to my question, as my question is more general in nature. I will provide a scenario below to better explain.

Additionally, when you have a Level 2 alteration all parts of Chapter 7 (Level 1) apply in addition to all parts of Chapter 8 (Level 2). The Existing Building Code is cumulative in that way.

The hypothetical scenario I posed earlier was a restaurant space being renovated into another restaurant space as a Level 2 alteration based on the changes being made. No change of occupancy, so Chapter 10 does not apply. There would just be one tenant. Let's say the front exterior stair and entry of the restaurant was not up to current codes, as an example. Let's say there is a desire to use the Prescriptive Compliance Method. For egressing in a Level 2 alteration, one looks to 804. If 804 does not apply because it pertains only to spaces with multiple tenants, then one would look to Chapter 7's egressing requirements, which as I mentioned earlier are quite light. The original question was: if the space only has one tenant (like my hypothetical restaurant scenario), does 804 not apply? If so, this leaves me a bit in the dark. I guess the most straightforward conclusion is that the Existing Building Code would not require me to upgrade the entry sequence as part of this restaurant renovation.

 

[Yankee Chronicler]

You still have not provided the total area of the building and the area of the alteration work area. BUT ...

If you are using the prescriptive method, Level 2 does not apply. "Level 2" applies only if you are using the Work Area Method. If you are using the prescriptive method, chapters 3 and 5 apply.

You may not need to make improvements for egress, but alterations in existing buildings also require improvements in accessibility unless the altered space is already 100% accessible. Section 306 applies whether using the Prescriptive Method or the Work Area Method. See section 306, and particularly 306.7.1.

 

[rosegamble]

You still have not provided the total area of the building and the area of the alteration work area. BUT ...

If you are using the prescriptive method, Level 2 does not apply. "Level 2" applies only if you are using the Work Area Method. If you are using the prescriptive method, chapters 3 and 5 apply.

You may not need to make improvements for egress, but alterations in existing buildings also require improvements in accessibility unless the altered space is already 100% accessible. Section 306 applies whether using the Prescriptive Method or the Work Area Method. See section 306, and particularly 306.7.1.

Ah, sorry. That was a typo. I meant work area method not prescriptive. My bad. So in the exact scenario previously described in the last post, with that typo fixed, why would area matter? In my hypothetical scenario we have already established it’s Level 02 based on scope (work area method). Does area further come into play somehow? Obviously it would be for the IBC, but just asking for the existing building code.

Good point about accessibility!

 

[Yankee Chronicler]

The area matters because it might be a Level 3 alteration, not a Level 2. On the other hand, if you won't be moving, removing, or adding any walls, doors, or windows, it may be a Level 1 alteration even if the work includes the entire building.

 

[Sifu]

Hello! Thank you. What do you mean by IFC? I am asking about the Existing Building Code, Section 804 (Level 2 Alteration, under the work area compliance method).

I see now that you did not include the code year, and that the ref. to 804 must be taken from the 2021 IEBC. Disregard my previous post as I was using/assuming the 2018 IEBC, which is where the IFC was brought in.

804.1 Scope. The requirements of this section shall be
limited to work areas that include exits or corridors shared
by more than one tenant within the work area in which Level
2 alterations are being performed, and where specified they
shall apply throughout the floor on which the work areas are
located or otherwise beyond the work area.

Now assuming 2021 IEBC, level 2 alteration using the work area compliance method.

So for my 2 cents on the actual question: IMO, the upgrades to the MOE are scoped first by the shared exit or corridor condition limitation. If that condition does not exist, you are done. (If the MOE meets either exception to 804.1, I believe you can stop right here as well) Doesn't sound like the shared condition applies, so you stop at this point. If it did apply, and you don't meet either exception then everything that applies to the work area in 804 applies, and you then need to determine which, if any specific element in 804 will cause in increase in your scope. For example, 804.10 would require the handrails of the steps to meet that section even if you didn't intend to do any work on them because they serve the floor that contains your work area. (There are a few sections in 804 that cause an increase in scope)

JMHO.

 

[rosegamble]

I see now that you did not include the code year, and that the ref. to 804 must be taken from the 2021 IEBC. Disregard my previous post as I was using/assuming the 2018 IEBC, which is where the IFC was brought in.

804.1 Scope. The requirements of this section shall be
limited to work areas that include exits or corridors shared
by more than one tenant within the work area in which Level
2 alterations are being performed, and where specified they
shall apply throughout the floor on which the work areas are
located or otherwise beyond the work area.

Now assuming 2021 IEBC, level 2 alteration using the work area compliance method.

So for my 2 cents on the actual question: IMO, the upgrades to the MOE are scoped first by the shared exit or corridor condition limitation. If that condition does not exist, you are done. (If the MOE meets either exception to 804.1, I believe you can stop right here as well) Doesn't sound like the shared condition applies, so you stop at this point. If it did apply, and you don't meet either exception then everything that applies to the work area in 804 applies, and you then need to determine which, if any specific element in 804 will cause in increase in your scope. For example, 804.10 would require the handrails of the steps to meet that section even if you didn't intend to do any work on them because they serve the floor that contains your work area. (There are a few sections in 804 that cause an increase in scope)

JMHO.

Thank you. I agree. So it seems like with my hypothetical renovated restaurant space that is Level 2 for various reasons under the work area compliance method (based on area, etc.) that an existing non compliant front door/front stair, used only by the restaurant, would not have to be brought up to compliance for egress. (Because there is only one tenant, which I find to be a weird and very specific condition)

But I would have 306 to contend with. 306.7 seems to be saying that any facility that is "altered" must be made accessible unless technically not feasible. Let's say there is no ramp and only this entrance in question. I guess I'd have to argue the "not feasible" part to avoid a ramp and other accessibility measures.

 

[Yankee Chronicler]

"technically infeasible" basically means it can't be done without altering the building structure. It's a tough hurdle to meet.

Under the IEBC, the need for accessibility improvements is subject to the provision limiting the cost to 20% of the overall project cost. Why would you want to do a restaurant and NOT make it accessible?

 

[rosegamble]

"technically infeasible" basically means it can't be done without altering the building structure. It's a tough hurdle to meet.

Under the IEBC, the need for accessibility improvements is subject to the provision limiting the cost to 20% of the overall project cost. Why would you want to do a restaurant and NOT make it accessible?

I wouldn't! Just trying to understand the rules. Thank you for your help! You certainly see a lot of non-compliant entrances in old buildings though, despite all the renovations...

 

[Sifu]

But I would have 306 to contend with. 306.7 seems to be saying that any facility that is "altered" must be made accessible unless technically not feasible. Let's say there is no ramp and only this entrance in question. I guess I'd have to argue the "not feasible" part to avoid a ramp and other accessibility measures.

I think so, and the non-feasible part isn't an easy argument. If it won't fly, I believe you would need to demonstrate that 20% of your budget would go to the accessible route, but exactly which part of the accessible route would be specified by the designer.

 

[Yankee Chronicler]

I wouldn't! Just trying to understand the rules. Thank you for your help! You certainly see a lot of non-compliant entrances in old buildings though, despite all the renovations...

But those old buildings may have satisfied the 20% rule by spending the money on other things, such as perhaps making toilet rooms accessible. The rule only says that the cost of providing accessibility upgrades doesn't have to exceed 20% of the project cost -- it doesn't stipulate where the owner has to spend that 20%.

 

[Sifu]

Like YC says, that cost can be eaten by any number of things, including maybe the door you mention.