Exit access door separation

[Sifu]

IBC 2012, non-suppressed commercial office building.

I have an existing building where the proposed B tenant space has an occupant load >49. The existing plan shows the two exit access doors without the required separation.

If we had the IEBC adopted (we do not), as a level 2 alteration, would the exit separation be an issue? Section 805.4 requires two exit access doorways but makes no mention of separation. So am I to take it that the separation requirements of IBC 1015.2.1 do not apply?

I know its a hypothetical but I am trying to learn it and when I run up against a sticky proposal I try to see if the IEBC would help.


805.4 Egress doorways. Egress doorways in any work area
shall comply with Sections 805.4.1 through 805.4.5.
805.4.1 Two egress doorways required. Work areas shall be provided with two egress doorways in
accordance with the requirements of Sections 805.4.1.1 and 805.4.1.2.
805.4.1.1 Occupant load and travel distance. In any work area, all rooms and spaces having an
occupant load greater than 50 or in which the travel distance to an exit exceeds 75 feet (22 860
mm) shall have a minimum of two egress doorways.

 

[Francis Vineyard]

Is this applicable to your question?

801.3 Compliance. All new construction elements, components, systems, and spaces shall comply with the requirements of the International Building Code.

Code Commentary ""New elements, components and spaces created as a result of Level 2 alteration work must comply with the IBC or other applicable code, as Section 101.4 of the IBC makes reference to other I-Codes, . . .

 

[cda]

I am thinking the separation is required.

Otherwise why the requirement for two doors.

 

[RLGA]

You say "proposed B tenant space." This sounds like space is being reconfigured, and as FV and cda indicate, if the space is reconfigured, then the new space is required to comply with the IBC and separation would be required

 

[Sifu]

Without getting too far into the weeds.....the space is existing, two tenant spaces were combined on a previous permit but the occupant load was less than 49 so two exit access doors were not required, therefore I did not enforce the separation. Now, the interior space is being reconfigured by the existing tenant and conference rooms are being added which pushes the occ load over 50. The adjacent spaces are all occupied so moving the exit access doors is not feasible for the tenant. As I looked for a compliant path I figured I would check the IEBC since we will be adopting it in the future and I found that the only MOE requirement for a level 2 alteration is that the doors be provided, without mention of separation. Understanding that the IEBC is not adopted this is not a path they can take unless they appeal to the CBO with a request for modification, which I would do if I were them based on the IEBC, if it would work.

I am not quite sure how to apply the concepts of "work area" here to begin with. They are changing a few offices into conference rooms, but not changing the MOE, which is not in their "work area", but I do understand that the MOE is an extension of the work area, and would be required to be updated if the occ load is altered. It seems unlikely that the IEBC would make the blanket statement that no separation will ever be needed in a level 2 alteration, yet since it only mentions that the doors must be there I wondered.

I know what their next proposal will be on this. They will try to divide the spaces with a demising wall to create two spaces, each with occ loads <49, and install a door between them for circulation. I don't think that meets the intent of the code but I also am not sure how to disapprove it since the code uses the term space and doesn't use tenancy as a defining factor.

1015.1 Exits or exit access doorways from spaces. Two
exits or exit access doorways from any space shall be provided
where one of the following conditions exists:

 

[cda]

Can you post a floor plan

 

[Sifu]

 

[Sifu]

I love that I finally figured out how to do that!

 

[RLGA]

So, in the floor plan, what is being altered? The entire white area or just portions of the white area? Where was the existing wall that separated the two tenant spaces?

 

[Mr. Inspector]

Maybe section 303.6 works better for you if you use the Prescriptive Compliance Method. But I have noticed the Performance Compliance Method Chapter 13 is always the easiest way to go, but you need an architect to do it for you.

 

[cda]

One person an office

Equals less than fifty??

 

[mtlogcabin]

Understanding that the IEBC is not adopted this is not a path they can take unless they appeal to the CBO

Not True

2012 IBC

3401.6 Alternative compliance.
Work performed in accordance with the International Existing Building Code shall be deemed to comply with the provisions of this chapter.

 

[RLGA]

Not True

2012 IBC

3401.6 Alternative compliance.
Work performed in accordance with the International Existing Building Code shall be deemed to comply with the provisions of this chapter.

...unless that was modified by amendment via the adopting ordinance.

 

[Sifu]

The conference room was created out of office space, the clouded office was a conference room on the first go-round but they changed back to office when this issue came up, some of the other office walls were moved but nothing else significant.

I think the former demising wall was beside the center-most door. The grey shading was a request to dis-count the halls out of the gross area calculation in order to get the area/occ load down but I told them no on that.

Can 3401.6 be used if the IEBC was not adopted. If so, why even adopt it?

I have considered sending them down the chapter 34 compliance alternative path but that is such a PITA I was hoping to find a more definitive yes or no.

As far occ load, this is the proposal (disregard the omission of the hallways, if you add them back in they exceed 50).

 

[RLGA]

If they did not amend that paragraph, then you could make an argument that, by reference, the IEBC can be used.

Disregarding the IEBC reference for now, IBC Section 3404.1 states, "Alterations shall be such that the existing building or structure is no less complying with the provisions of this code than the existing building or structure was prior to the alteration."

Prior to the alteration, it was complying--with the alteration, it is not. Therefore, it must be made to comply.

 

[RLGA]

Here are a couple of alternative approaches that may fly:

1. Assuming the conference room is to be occupied by the other occupants of the tenant space, the total occupant load can be based on the gross floor area of the tenant space, but the conference room must be designed for the 14 occupants (MOE, etc.).
2. Per the Exception to Section 1004.1.2, request approval to use the actual occupant load of the conference room based on number of seats at the table (10). This will drop your occupant load down by 4, which will lower it to below 50.

 

[cda]

The conference room was created out of office space, the clouded office was a conference room on the first go-round but they changed back to office when this issue came up, some of the other office walls were moved but nothing else significant.

I think the former demising wall was beside the center-most door. The grey shading was a request to dis-count the halls out of the gross area calculation in order to get the area/occ load down but I told them no on that.

Can 3401.6 be used if the IEBC was not adopted. If so, why even adopt it?

I have considered sending them down the chapter 34 compliance alternative path but that is such a PITA I was hoping to find a more definitive yes or no.

As far occ load, this is the proposal (disregard the omission of the hallways, if you add them back in they exceed 50).
View attachment 3006

Only 1 1/2 people can be in some offices


Oh boy back to:

Round up
Or
Round down

Or

 

[RLGA]

Only 1 1/2 people can be in some offices


Oh boy back to:

Round up
Or
Round down

Or

If you based the occupant load of the tenant suite on individual occupant loads of each space, the total occupant load will be heavily skewed in one direction or another, depending on how one does rounding. For office areas, I never look at each individual office space--I look at the aggregate office area and apply the 100 sf/occupant load factor to the gross floor area of the office area, excluding storage spaces and conference rooms; for those I use 300 sf/occupant and 15 sf/occupant, respectively.

This tenant space as approximately 4,007 sq. ft. of gross floor area according to the table. If you subtract out all of the storage areas and the conference room, the gross floor area is 3,864 sq. ft. This provides an occupant load of 38. I never round up, except when the aggregate gross floor area for a function provides less than 1 occupant, then I use 1 occupant, such as the storage spaces in this case, which have an aggregate area of 143 sq. ft. Now we're at 39 occupants. The conference room is based on net floor area, so assuming the area provided in the table is the net area, then the occupant load for the conference room is 14. Now the occupant load is 53.

If we calculated the total occupant load based on the individual occupant loads of each space using standard rounding methods, then the occupant load would be 46. If we rounded anything less than 1 to 1, and rounded down for all others, the occupant load would be 45. If we rounded up everything, then the occupant load would be 62.

 

[Sifu]

The best I can come up with is 53 as well. The CBO will not allow a stated occupant load. The problem I have here is that I have hundreds of buildings that are questionable, and anything we approve is shared by the building community. So I am setting a precedent when I approve or disapprove something outside of the prescriptive code. This architect in particular has done it to me before. As a matter of fact he tried it on this project by saying I approved the joining of the suites 2 years ago, fortunately I was able to point out that he increased his occupant load. RLGA makes the point I have had stuck in my mind but was hoping to be out-though on is valid "Prior to the alteration, it was complying--with the alteration, it is not. Therefore, it must be made to comply."

I will send them down the path of compliance alternative score method.

 

[Francis Vineyard]

In the case where the AHJ can issue a blanket code modification based on the event that the 2018 new updated formula using 150 instead of 100 gross will easily bring it under 50.

 

[Francis Vineyard]

Here's the explanation to the increase O.L. for Group B

"To our knowledge there is no formal record indicating the basis of the occupant load factors included in the 1934 Buildings Exits Code. However, it seems likely that the results from a National Bureau of Standards (NBS) [now referred to as National Institute of Standards and Technology (NIST)] study published in 1935 were the most likely basis of the occupant load factors adopted into the 1934 Code. However, since the initial NBS study in 1935, several other studies have been conducted to determine the occupant load factors for various occupancies. One common similarity of each of the studies was that all of the subsequent studies have concluded that the 100 ft2 /occupant (gross) occupant load factor for business occupancies is conservative. Studies conducted between 1966 and 1992 have indicated that occupant load factors in business occupancies ranged from 150 ft2 /occupant (gross) to 278 ft2 /occupant (gross). In addition, a 1995 study of 23 Federal sector and private sector office buildings also indicated a mean occupant load factor of 248 ft2 /occupant for all office buildings.Lastly, a recent project to study the appropriateness of the 100 ft2 /occupant load factor for business occupancies has been undertaken by the NFPA Fire Protection Research Foundation. The study was conducted by WPI undergrad students. The recommendations of this study have indicated that it is reasonable to increase the occupant load factor to 150 ft2 /occupant in business occupancies and to create a new occupant load sub-category for concentrated use areas in business occupancies"

E 9-15 Table 1004.1.2, 1004.6 (New); (IFC[BE] Table 1004.1.2, 1004.6 (New)) Proponent: Dave Frable, representing US General Services Administration
https://www.iccsafe.org/wp-content/uploads/IBC-Egress.pdf

 

[Sifu]

I had made a note about that change but completely forgot about it. I think that is a good approach and I will run it up the flagpole. Thanks.

 

[Sifu]

That flag didn't fly. Too much concern that it sets the precedent and opens a can of worms we don't want opened. We don't want to make a blanket exception either since we don't know when we will adopt (it has already been delayed a year).

Can't say I didn't try.

 

[Builder Bob]

If the space is being reconfigured, why not move the conference room from the corner and move it up the corridor where two exits could be provided, add a door to ensure proper means of egress for the egress, then ensure rest of corridor is less than 49 occupants with less than 75 feet of travel to CPT ?