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Existing Stair Enclosures in Change of Occupancy... two sections stating different requirements

BillS

Member
Joined
Feb 18, 2015
Messages
44
Location
Pittsburgh
Existing building is changing use from S-2 to B. This is a change to a higher-hazard category in 2018 IEBC T1011.4.

Therefore, Section 1011.4.1 EXC 1 says that existing stairways only have be enclosed as per S903.1, which refers you to S802.2.1. There, EXC 5.1 says that the enclosure isn't required because the building is under 3,000 SF. Yay!

However, Section 1011.7.2 says that, because of the same higher-hazard category change, interior stairways have to be enclosed as per IBC, which would require a 1-HR rating. Boo!

What gives? How can these two sections co-exist? I don't understand how you can ever take advantage of the exceptions offered in the former if they are always superceded by the latter. Why write the first option (only comply with S903.1) if it can't ever be used?

Can anyone clarify this for me?
 
I agree with you that these are conflicting, but that is why the ICC gave us Section 102.1, which is standard in nearly every code they publish, whether in that specific section or another Chapter 1 section. It basically states that the specific governs the general, and can be applied in this case.

Section 1011.7.2 is a general requirement since it is intended to be applied to all occupancy groups and none of the exceptions listed are specific to Group B or your building situation. On the other hand, Section 1011.4.1 and its reference to IEBC Section 903.1 and subsequent reference to IEBC Section 802.2.1 and Exception 5.1 is very specific to Group B occupancies. Thus, the specific provision takes precedence over the general provision.

The code development cycle for the 2024 I-Codes is wrapping up, so there is no chance of getting this corrected in the next edition of the IEBC. However, this conflict can be corrected during the next code development cycle for the 2027 I-Codes, which should begin in 2025.
 
I agree with you that these are conflicting, but that is why the ICC gave us Section 102.1, which is standard in nearly every code they publish, whether in that specific section or another Chapter 1 section. It basically states that the specific governs the general, and can be applied in this case.

Section 1011.7.2 is a general requirement since it is intended to be applied to all occupancy groups and none of the exceptions listed are specific to Group B or your building situation. On the other hand, Section 1011.4.1 and its reference to IEBC Section 903.1 and subsequent reference to IEBC Section 802.2.1 and Exception 5.1 is very specific to Group B occupancies. Thus, the specific provision takes precedence over the general provision.

The code development cycle for the 2024 I-Codes is wrapping up, so there is no chance of getting this corrected in the next edition of the IEBC. However, this conflict can be corrected during the next code development cycle for the 2027 I-Codes, which should begin in 2025.
Thanks for the clarification, RLGA!
 
I agree with you that these are conflicting, but that is why the ICC gave us Section 102.1, which is standard in nearly every code they publish, whether in that specific section or another Chapter 1 section. It basically states that the specific governs the general, and can be applied in this case.

Section 1011.7.2 is a general requirement since it is intended to be applied to all occupancy groups and none of the exceptions listed are specific to Group B or your building situation. On the other hand, Section 1011.4.1 and its reference to IEBC Section 903.1 and subsequent reference to IEBC Section 802.2.1 and Exception 5.1 is very specific to Group B occupancies. Thus, the specific provision takes precedence over the general provision.

The code development cycle for the 2024 I-Codes is wrapping up, so there is no chance of getting this corrected in the next edition of the IEBC. However, this conflict can be corrected during the next code development cycle for the 2027 I-Codes, which should begin in 2025.
RLGA. I follow the logic that you present regarding general and specific. I have had conversation with ICC staff on this topic. Their opinion is that IEBC 2021 s. 1911.5, Exception 1 is the general provision and the IEBC 2021 s. 1011.8 is the specific. Therefore, IEBC 2021 s. 1011.8 would prevail. The Commentary further supports that. "Specific requirements for stairways are found in Section 1011.8.2." Same concept, different result. This conflict has existed since the 2003 edition of the IEBC. I do plan to submit a code change proposal during the 2027 cycle to change IEBC 1011.5, Exception 1 to read: "Stairways shall be enclosed in compliance with the applicable provisions of Section 903.1 1011.8.2." I believe that might end the conflict that has existed for over two decades. Your thoughts?
 
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