Extent of sprinker installtion under level 3 alteration and partial change of occupancy

[Tim Mailloux]

My firm current has a project in design right now, and the Building official and I have a disagreement on the scope of the new sprinkler system we are adding under the projevt. The project consists of a renovation / partial change of use to an existing assembly building on a college campus, the existing building is one story type 2A construction, no sprinklers, applicable code is the 2015 IEBC, 2015 IBC and CT state amendments.

Half of the existing building (Area A) is an existing A1 Auditorium and the other half of the building (Area B) is an existing A3 gymnasium. Area B is not in in the project scope, while Area A is completely being gutted and changed into an A2 Dining hall. The renovation is a level 3 alteration and partial change of occupancy classification (IEBC 1001.3.1) under the Existing Building Code. Due to the level 3 alteration & partial change of occupancy classification We are required to install a sprinkler system in the portion of the building that is being renovated, but the BO is of the opinion that we also have to install a sprinkler system in the existing gym because of IBC 903.2.1 which states:

903.2.1 Group A. - An automatic sprinkler system shall be provided throughout buildings and portions thereof used as Group A occupancies as provided in this section. For Group A-1, A-2, A-3 and A-4 occupancies, the automatic sprinkler system shall be provided throughout the story where the fire area containing the Group A-1, A-2, A-3 or A-4 occupancy is located, and throughout all stories from the Group A occupancy to, and including, the levels of exit discharge serving the Group A occupancy. For Group A-5 occupancies, the automatic sprinkler system shall be provided in the spaces indicated in Section 903.2.1.5.


I am of the opinion that the BO if trying to push a requirement for a sprinkler system in a new A occupancy building on this project when the IEBC is clear that the sprinkler system only has to be installed in the work area undergoing the change in occupancy classification.


IEBC 904.1 Automatic Sprinkler Systems - An automatic sprinkler system shall be provided in a work area where required by Section 804.2 or this section

IEBC 804.2 Automatic sprinkler systems. Automatic sprinkler systems shall be provided in accordance with the requirements of Sections 804.2.1 through 804.2.5. Installation requirements shall be in accordance with the International Building Code.

804.2.2 Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1and S-2. - In buildings with occupancies in Groups A, B, E, F-1, H, I, M, R-1, R-2, R-4, S-1 and S-2, work areas that have exits or corridors shared by more than one tenant or that have exits or corridors serving an occupant load greater than 30 shall be provided with automatic sprinkler protection where all of the following conditions occur:

1. The work area is required to be provided with automatic sprinkler protection in accordance with the International Building Code as applicable to new construction; and

2. The work area exceeds 50 percent of the floor area.

Exception: If the building does not have sufficient municipal water supply for design of a fire sprinkler system available to the floor without installation of a new fire pump, work areas shall be protected by an automatic smoke detection system throughout all occupiable spaces other than sleeping units or individual dwelling units that activates the occupant notification system in accordance with Sections 907.4, 907.5 and 907.6 of the International Building Code.

IEBC 1001.3.1 Partial change of occupancy classification - Where a portion of an existing building is changed to a new occupancy classification, Section 1012 shall apply.

IEBC 1012.1.1.2 Change of occupancy classification with separation - Where a portion of an existing building that is changed to a new occupancy classification and that portion is separated from the remainder of the building with fire barriers having a fire-resistance rating as required in the international Building Code for the separate occupancy, that portion shall comply with all of the requirements of Chapter 9 for the new occupancy classification and with the requirements of this chapter.

Commentary: When the change of occupancy classification is wholly contained in a portion of the building that is completely separated from the other uses occupying the building by fire barriers as required by Table 508.4 of the IBC, compliance with the requirements of Chapter 9 and Sections 1002 through 1012 is only required for that portion of the building occupied by the new occupancy classification. The remaining portion(s) of the building that are legally occupied are permitted to continue occupancy without change, until activities specifically covered in the code occur.

• Table 508.4 does not require any separation between A2 & A3, so no fire barrier is required.

1012.2.1 Fire sprinkler system -Where a change in occupancy classification occurs that requires an automatic fire sprinkler system to be provided based on the new occupancy in accordance with Chapter 9 of the International Building Code, such system shall be provided throughout the area where the change of occupancy occurs.

 

[RLGA]

There is no separation between the two areas, so Section 1012.1.1.1 will apply even though Table 508.4 says no separation is required--Section 1012.1.1.2 relies on a physical fire-rated barrier. Therefore, you have to either sprinkler the other area or convert the wall separating the two into a 2-hour wall. If it is masonry, then you are most of the way there; all you have to do is change out any unprotected openings for fire-rated ones, protect penetrations, and install dampers in ductwork, if applicable.

 

[steveray]

Tim,
I agree with you on how the actual code section reads, but the commentary for the unseparated section reads as Ron says:

Requirements of this subsection and Section
1011.1.1.2 provide alternatives for the evaluation process
where the change of occupancy occurs in only a
portion of an existing building. These two sections
incorporate two of the philosophies for mixed-use
occupancies found in Section 508 of the IBC.
If the portion of the building that is undergoing the
change of occupancy classification is not separated
from the remainder of the building by fire barriers, this
allows the two or more uses to remain unseparated
from each other; however, the entire building must
then comply with the requirements of Chapter 9 and
those of this chapter for the most restrictive occupancy
group. This also applies to exceeding threshold
requirements in Chapter 9 of the IBC. This
philosophy is consistent with the approach made for
mixed uses, nonseparated, as given in Section 508.3
of the IBC. Note that this could require construction
activity in existing occupied spaces or portions of the
building not otherwise impacted by the change of
occupancy classification.

 

[Tim Mailloux]

There is no separation between the two areas, so Section 1012.1.1.1 will apply even though Table 508.4 says no separation is required--Section 1012.1.1.2 relies on a physical fire-rated barrier. Therefore, you have to either sprinkler the other area or convert the wall separating the two into a 2-hour wall. If it is masonry, then you are most of the way there; all you have to do is change out any unprotected openings for fire-rated ones, protect penetrations, and install dampers in ductwork, if applicable.

Thanks Ron!
The existing wall seperating the Gym from the new A2 dinning hall is masonry construcion, so I got that going for me. We will need to replace the exiting doors as there are no visalbe fire rating tags on them, and then protect penetration and install dampers in the ductwork as you state above. I am not sure the BO is going to change his mind on the sprinklers as he is certain IBC 903.2.1 requires the entire floor be sprinklered.

 

[steveray]

I am sure it is not the first time that BO has been wrong....

 

[Tim Mailloux]

I am sure it is not the first time that BO has been wrong....

the BO is this case is OSBI.
I have been told they will consider a code mod but as far as I can tell our approach is code compliant and have no idea what code setion or sections we are asking relief from.

 

[steveray]

Does their mind change going the 1012.1.1.2 route? I guess I know why that section doesn't really say "work area" because it is not really applicable to COO...But it clearly says "that portion" not "throughout the building" or even "throughout the or all A fire areas"

 

[Tim Mailloux]

Does their mind change going the 1012.1.1.2 route? I guess I know why that section doesn't really say "work area" because it is not really applicable to COO...But it clearly says "that portion" not "throughout the building" or even "throughout the or all A fire areas"

1012.1.1.2 is the way we are going, I was told with a fire barrier between the work area and existing they would consider a code mod to not make the project provide sprinklers in the existing gym. I need to call Darren on Monday and have him walk me thru what he is expecting.

The newest wrinkle is that OFSM (state fire marshall) now wants to enforce the 2/3rds assembly entrance requirements (state statute) on the existing gym under this project. The gym has no bleacher, is only used for pick up games of basketball but they want us to use the 1 per 7 occupant load which works out to about 1300 people. The existing entrance to the gym isnt even close to being able to accommodate 2/3rds of that load.

 

[steveray]

Tell them they should have written the amendment differently...

CHAPTER 10 – CHANGE OF OCCUPANCY
(Add) 1005.2 Main Entrance – Group A. In Group A occupancies created by change of
occupancy that have a single main entrance, such main entrance shall also be the main exit. The
main entrance/exit shall be of sufficient width to accommodate not less than two-thirds of the
occupant load, but such width shall not be less than the total required width of all means of egress
leading to the exit. The remaining exits shall be capable of providing at least one-half of the total
required exit capacity.
Exception: In assembly occupancies where there is no well-defined main entrance and main
exit or where multiple main entrances and main exits are provided, exits shall be permitted to

The "new" A absolutely, but not if the gym is existing to remain....

 

[Tim Mailloux]

Tell them they should have written the amendment differently...

CHAPTER 10 – CHANGE OF OCCUPANCY
(Add) 1005.2 Main Entrance – Group A. In Group A occupancies created by change of
occupancy that have a single main entrance, such main entrance shall also be the main exit. The
main entrance/exit shall be of sufficient width to accommodate not less than two-thirds of the
occupant load, but such width shall not be less than the total required width of all means of egress
leading to the exit. The remaining exits shall be capable of providing at least one-half of the total
required exit capacity.
Exception: In assembly occupancies where there is no well-defined main entrance and main
exit or where multiple main entrances and main exits are provided, exits shall be permitted to

The "new" A absolutely, but not if the gym is existing to remain....

I agree with you, and this was my approach during the initial code review. But OSFM is telling me that Part 4 - Existing Occupancies, of the State fire code also has an amendment requiring the assembly main entrance exit. Thats what I'm looking into this morning.

 

[cda]

I agree with you, and this was my approach during the initial code review. But OSFM is telling me that Part 4 - Existing Occupancies, of the State fire code also has an amendment requiring the assembly main entrance exit. Thats what I'm looking into this morning.

what is the exit width of the main entrance now?

 

[Tim Mailloux]

what is the exit width of the main entrance now?

The existing gyms main entrance / exit consists of two pairs of 6'-0" doors (136" clear width) with a egress capacity of 680 people. Based on the size of the gym and the 1 person per 7 sqft we are being asked to use for the occupant load calculation, the gym has an Occ load of 1,482 people (just crazy!). We are being told that under state law The main entrance needs accommodate 2/3rd of that load, or 988 people. As I mentioned before this gym has no bleachers and is used entirely for pickup games of basketball, and sometimes volley ball on a collage campus. The campus has an actual athletic facility where sporting activities with spectators are held.

 

[steveray]

Sounds like OSFM does not really want to fight or enforce the higher OL uses later which I do understand....We usually have that discussion with the FM and the tenant/ owner to figure out what the true "worst case" might be...

 

[mtlogcabin]

At a 1-per 7 sq ft net occupant load just what does the FM think all these people will be doing in the gym? standing around waiting for a train.
What was the original OL for the gym as designed? That is what I would find out and use that figure in lieu of what the FM wants to use based on a new code edition. I will bet it was 15

 

[Tim Mailloux]

At a 1-per 7 sq ft net occupant load just what does the FM think all these people will be doing in the gym? standing around waiting for a train.
What was the original OL for the gym as designed? That is what I would find out and use that figure in lieu of what the FM wants to use based on a new code edition. I will bet it was 15

The gym was built in the 50's or 60's, the only documentation we have are some very basic floor plans and elevations. The FM understands that day to day this space will have a very small load, but "in the off chance the preseident comes to campus whos to say they don't pack this room for a political rally"......his words.

 

[steveray]

Well then they should be using 5sf....

 

[mtlogcabin]

The gym is not going through a change of occupancy therefore your quoted amended code section of section 10 should not be applicable but this should be since it would be consistent with the code it was constructed under

805.3.3 Main entrance—Group A.
Buildings of Group A with an occupant load of 300 or more shall be provided with a main entrance capable of serving as the main exit with an egress capacity of not less than one-half of the total occupant load. The remaining exits shall be capable of providing one-half of the total required exit capacity.

 

[Tim Mailloux]

The gym is not going through a change of occupancy therefore your quoted amended code section of section 10 should not be applicable but this should be since it would be consistent with the code it was constructed under

805.3.3 Main entrance—Group A.
Buildings of Group A with an occupant load of 300 or more shall be provided with a main entrance capable of serving as the main exit with an egress capacity of not less than one-half of the total occupant load. The remaining exits shall be capable of providing one-half of the total required exit capacity.

Apparently there is something in the CT fire code that applies. For existing occupancy permitted prior to 2005, the fire code is based on a heavily modified version of the 2015 NFPA 101. There is also a CT State Statute that comes into play, but as far as I can tell that Statute gives the BO & FM a lot of leeway on enforcement in an existing occupancy.

 

[mtlogcabin]

Then try this section and post the Occupant Load that the main door will handle plus 1/3
680 Plus 33% = about 900 not to far off of the 988 that might be in there for that one time special event.

1004.5 Areas without fixed seating.
The number of occupants shall be computed at the rate of one occupant per unit of area as prescribed in Table 1004.5. For areas without fixed seating, the occupant load shall be not less than that number determined by dividing the floor area under consideration by the occupant load factor assigned to the function of the space as set forth in Table 1004.5. Where an intended function is not listed in Table 1004.5, the building official shall establish a function based on a listed function that most nearly resembles the intended function.

Exception: Where approved by the building official, the actual number of occupants for whom each occupied space, floor or building is designed, although less than those determined by calculation, shall be permitted to be used in the determination of the design occupant load.

 

[Tim Mailloux]

Then try this section and post the Occupant Load that the main door will handle plus 1/3
680 Plus 33% = about 900 not to far off of the 988 that might be in there for that one time special event.

1004.5 Areas without fixed seating.
The number of occupants shall be computed at the rate of one occupant per unit of area as prescribed in Table 1004.5. For areas without fixed seating, the occupant load shall be not less than that number determined by dividing the floor area under consideration by the occupant load factor assigned to the function of the space as set forth in Table 1004.5. Where an intended function is not listed in Table 1004.5, the building official shall establish a function based on a listed function that most nearly resembles the intended function.

Exception: Where approved by the building official, the actual number of occupants for whom each occupied space, floor or building is designed, although less than those determined by calculation, shall be permitted to be used in the determination of the design occupant load.

I wish.....that exception has been deleted from the current CT code.

 

[steveray]

Like they tell you when we "fail" you.....They have to give you a code section....

 

[mtlogcabin]

I am beginning to feel your pain or should I say PIA amendments you are stuck working with

 

[steveray]

Maybe this:

(Amd) 13.2.3.6.1 Every assembly occupancy shall be provided with a main entrance/exit. With respect to the capacity of such main entrance/exit, the requirements of section 29-381a of the 84 Connecticut General Statutes shall supersede the requirements of Sections 13.2.3.6.2 to 13.2.3.6.4, inclusive.

I don't have a copy of 101 here, but this does seem to indicate that it is a violation if there is not a "main exit" ....That is a lot of violations.....

 

[Tim Mailloux]

I am beginning to feel your pain or should I say PIA amendments you are stuck working with

You have no idea!
The worst ammendment IMO we have to deal with here in CT from the design side of things is the deletion of the increased door and stair capacity with a sprinkler system. Sprinklers or no sprinklers we are stuck with .2 for doors and .3 for stairs. I once called the state fire Marshall to ask about this amendment which is driven the the FM community in state and this is actually what we told me "we here at the office of the State Fire Marshal do not feel that wet people can egress any faster in an emergency than dry people"........