Help me decipher California's Existing Building Code

[Yankee Chronicler]

Please!

The CA EBC opens up with a chart with a bunch of acronyms strung across the top. Then, throughout the body of the code, certain sections preceded by one or more of these acronyms are in italics. I assume this means that the italicized language applies only in certain jurisdictions, represented by the acronyms.

Is that how it works? What jurisdictions do the acronyms refer to?

 

[Joe.B]

Page v of the preface will tell you what the state agency acronyms are. Italics are CA specific language added to the model code. The matrix adoption tables tell you what part a specific state agency has adopted (or not), and/or amended. Division I of Chapter 1 tells you what agencies have regulatory authority over, and who enforces those sections.

For example, HCD is the Department of Housing and Community Development. The matrix for Ch. 1 shows that they only adopt certain sections of this chapter, such as 1.8. Which (in part) states that HCD has authority over housing construction, housing accessibility, and permanent buildings in mobilehome parks and special occupancy parks. Section 1.8.3 gives the local enforcing agency (my department) authority and responsibility to:

1.8.3.1 Duties and powers. The building department of every city, county, or city and county shall enforce all the provisions of law, this code, and the other rules and regulations promulgated by the Department of Housing and Community Development pertaining to the installation, erection, construction, reconstruction, movement, enlargement, conversion, alteration, repair, removal, demolition or arrangement of apartments, condominiums, hotels, motels, lodging houses and dwellings, including accessory buildings, facilities and uses thereto.
For additional information regarding the use and occupancy of existing buildings and appurtenant structures, see California Code of
Regulations, Title 25, Division 1, Chapter 1, Subchapter 1, commencing with Article 1, Section 1.

Within other chapters of this code, and other code books, certain sections will have a state agency acronym in brackets that will let the user know that that section is only applicable to certain situations. For example, Section 321 of the CEBC has [BSC, DSA-SS & DSA-SS/CC] in the title. You would go to page v to see what those agencies are, then look in Div. 1 of Ch. 1 and see what those provisions apply to, and who enforces those provisions.

But hey, at least the weather's nice over here...

 

[RLGA]

California is an odd animal. I try to avoid projects in CA if I can. Each state department seems to have its own fiefdom where it dictates which parts of the CBC apply to its own little world.

As progressive as California thinks it is, it is still stuck in the ways of the old UBC. For example, in California, you can use a sprinkler system only for an area increase or a height increase, but not both — I learned this the hard way. Ouch!

 

[arwat23]

Every part of Title 24 (CA Building Standards Code) starts like that. It's intimidating even for those of us that work here. I swear, 80% of the people I've work with don't understand that whole matrix stuff despite being architects or designers or plan reviewers that only work in the state.

 

[Joe.B]

California is an odd animal. I try to avoid projects in CA if I can. Each state department seems to have its own fiefdom where it dictates which parts of the CBC apply to its own little world.

As progressive as California thinks it is, it is still stuck in the ways of the old UBC. For example, in California, you can use a sprinkler system only for an area increase or a height increase, but not both — I learned this the hard way. Ouch!

Oh, you are so correct... And it's soooooo bad. Each agency has an agenda, and they often conflict. And they all love using legislation to further their agenda. Most legislation is difficult to enforce and really doesn't amount to much change. HCD wants more housing, so they have state ADU laws which exempt them from lots of requirements, CEC wants energy efficiency, BSC has CalGREEN, DSA has accessibility, SFM and on and on...

But it's really beautiful where I live...

 

[Joe.B]

 

[Joe.B]

 

[Joe.B]

 

[arwat23]

California is an odd animal. I try to avoid projects in CA if I can. Each state department seems to have its own fiefdom where it dictates which parts of the CBC apply to its own little world.

My favorite are the definitions in the building code. Some definitions, like "workstation", have two completely different definitions, one that applies to everyone except for accessibility, and one that applies only for accessibility. Or "Walk", which has two definitions in the same paragraph that effectively describe the same thing, but one applies to multi-family private accessibility and the other to public accessibility, all while the acronyms are placed in confusing locations which just adds to our bewildering method of doing things.

Why is the DSA-AC acronym on the word but HCD 1-AC is in the definition? Why describe the same thing twice? Because each agency has their own way of doing things, and god will smite them down if they ever collaborate.

 

[Joe.B]

 

[Yikes]

My favorite are the definitions in the building code. Some definitions, like "workstation", have two completely different definitions, one that applies to everyone except for accessibility, and one that applies only for accessibility. Or "Walk", which has two definitions in the same paragraph that effectively describe the same thing, but one applies to multi-family private accessibility and the other to public accessibility, all while the acronyms are placed in confusing locations which just adds to our bewildering method of doing things.
View attachment 16640
Why is the DSA-AC acronym on the word but HCD 1-AC is in the definition? Why describe the same thing twice? Because each agency has their own way of doing things, and god will smite them down if they ever collaborate.

I can explain it, but I can't justify it:

CBC 11A was originally developed years ago through a very acrimonious process that pitted die-hard accessibility activists against the lobbyists and attorneys for the housing and hospitality (hotel) industry. Very few people want to revisit those battles, so there's a tendency to try and make its awkward phrasing work rather than to tweak it for improvement.

In this case, CBC 11B is for public accommodations and is based on ADA, and is promulgated by DSA. therefore DSA assumes that nearly every "walk" is intended for use by the public, whether of not is is adjacent to a public street.

For example, if an apartment building with a single main entrance contains no covered multifamily dwelling units (CMDs) according to CBC 11A, and its common areas are intended only for the residents, the owner, and their guests (e.g. it has no leasing office or other business enterprise) then the walk from the PROW to the main entrance does not need to be accessible under CBC 11A, as enforced by HCD.

But if that same building has CMDs, then that same entry walk now has to be accessible according to the definitions in CBC 11A.

If that building has no CMDs but has a leasing office (place of business) inside the main entrance, then the entry "walk" (and all other path-of travel elements associate with the leasing office) are subject to CBC-11B, per DSA’s definition of “walk”. However, the path to other common area amenities not used by the leasing office go under the 11A definition of "walk" and are not required to be accessible.

 

[Yankee Chronicler]

This just reinforces that, despite having been an accessibility advocate and consultant since before the ADA, I should just refrain from attempting to respond to accessibility questions about California.

 

[Joe.B]

 

[arwat23]

For example, if an apartment building with a single main entrance contains no covered multifamily dwelling units (CMDs) according to CBC 11A, and its common areas are intended only for the residents, the owner, and their guests (e.g. it has no leasing office or other business enterprise) then the walk from the PROW to the main entrance does not need to be accessible under CBC 11A, as enforced by HCD.

But if that same building has CMDs, then that same entry walk now has to be accessible according to the definitions in CBC 11A.

If that building has no CMDs but has a leasing office (place of business) inside the main entrance, then the entry "walk" (and all other path-of travel elements associate with the leasing office) are subject to CBC-11B, per DSA’s definition of “walk”. However, the path to other common area amenities not used by the leasing office go under the 11A definition of "walk" and are not required to be accessible.

This is why I just default to "make everything accessible if possible" in all my design work. The second I try to explain something like this to anyone at my office or most clients, either their eyes glaze over or they leave more confused then they were before I explained it.

 

[Joe.B]

I can explain it, but I can't justify it:

CBC 11A was originally developed years ago through a very acrimonious process that pitted die-hard accessibility activists against the lobbyists and attorneys for the housing and hospitality (hotel) industry. Very few people want to revisit those battles, so there's a tendency to try and make its awkward phrasing work rather than to tweak it for improvement.

In this case, CBC 11B is for public accommodations and is based on ADA, and is promulgated by DSA. therefore DSA assumes that nearly every "walk" is intended for use by the public, whether of not is is adjacent to a public street.

For example, if an apartment building with a single main entrance contains no covered multifamily dwelling units (CMDs) according to CBC 11A, and its common areas are intended only for the residents, the owner, and their guests (e.g. it has no leasing office or other business enterprise) then the walk from the PROW to the main entrance does not need to be accessible under CBC 11A, as enforced by HCD.

But if that same building has CMDs, then that same entry walk now has to be accessible according to the definitions in CBC 11A.

If that building has no CMDs but has a leasing office (place of business) inside the main entrance, then the entry "walk" (and all other path-of travel elements associate with the leasing office) are subject to CBC-11B, per DSA’s definition of “walk”. However, the path to other common area amenities not used by the leasing office go under the 11A definition of "walk" and are not required to be accessible.

It's like a twisted logic puzzle. If, then, but not when...

 

[Joe.B]

I'm going for my third attempt on the CASp open book Oct. 3rd. I told my boss (who wants me to get it) that I will eventually get the certificate, and I will hang it on the wall, and then I will adamantly refuse to do anything CASp related. You told me I have to get the certificate; you didn't tell me I have to use it.

Anybody ever do the Calbo Ed-Week trainings? I'll be in Burlingame next week. The other one they put on is in Costa Mesa Oct 27-30.

 

[RLGA]

It's like a twisted logic puzzle.

...but without the logic.

 

[arwat23]

Another prime example of how confusing this can get is in the Plumbing Code. CPC table 422.1 is used to determine the fixture count based on the occupant load as determined by the Building Code...

Unless you're OSHPD, then you look at table 4-2 instead...

Or its a state building or public school, then you determine the plumbing OL from Table 4-1 and then use Table 422.1 to demine the fixture count... Except not, because you can use can use the Building Code OL if you want...

Or if it's a rural HCD 1 project, then the local health department determines what's required...

Or its a project under the Department of Food and Agriculture, then you look at Table 4-3...

Or a project under the Department of Public Health, then you look at Table 4-4.


Before I started working at the firm I'm at now, the firm used Table 4-1 (formally Table A) for determining the OL, which usually resulted in a lower OL than what Building Code called for (and isn't applicable to the projects we work on). They did that for at least 6 years and were never once called out on it.

 

[Yikes]

...but without the logic.

I think economists use the terms "regulatory capture" and "rent seeking", where experts draft regulations on behalf of the administrative state that are so difficult to understand that only they can correctly interpret them, both creating and capturing the market for their skills.

 

[Joe.B]

Another prime example of how confusing this can get is in the Plumbing Code. CPC table 422.1 is used to determine the fixture count based on the occupant load as determined by the Building Code...

Unless you're OSHPD, then you look at table 4-2 instead...

Or its a state building or public school, then you determine the plumbing OL from Table 4-1 and then use Table 422.1 to demine the fixture count... Except not, because you can use can use the Building Code OL if you want...

Or if it's a rural HCD 1 project, then the local health department determines what's required...

Or its a project under the Department of Food and Agriculture, then you look at Table 4-3...

Or a project under the Department of Public Health, then you look at Table 4-4.


Before I started working at the firm I'm at now, the firm used Table 4-1 (formally Table A) for determining the OL, which usually resulted in a lower OL than what Building Code called for (and isn't applicable to the projects we work on). They did that for at least 6 years and were never once called out on it.

View attachment 16649

Many jurisdictions will take the "design occupant load" that is proposed without bothering to get too deep into the weeds with it, as long as they're stamped by an RDP. The way it was explained to me is like this: Clearly there are many different ways to design a facility to fit the needs of the intended function, and clearly, they're all valid because of the different state agencies that have adopted them. The RDP has done the work to determine what OL factor is appropriate and what fixtures will best serve the client's needs. And, if they're wrong, they stamped it.

 

[Joe.B]

If you box yourself into the strict letter of the CBC OL and Table 422.1 you could end up with way more fixtures than are actually needed, and that's just wasteful. Keep in mind, the OL factors in 1004 are all about determining means of egress. For that, don't mess around, get people out. For the number of toilets required though, meh, let them save some money if they can.

 

[arwat23]

If you box yourself into the strict letter of the CBC OL and Table 422.1 you could end up with way more fixtures than are actually needed, and that's just wasteful. Keep in mind, the OL factors in 1004 are all about determining means of egress. For that, don't mess around, get people out. For the number of toilets required though, meh, let them save some money if they can.

But code calls for using the sane OL as what's determined by CBC. The way I read code, both the Building and Plumbing OLs should match for most projects.

I won't complain about using less fixtures, but I just can't justify it based on what I see (unless, of course, the AHJ just agrees to a lower fixture count).

 

[Joe.B]

I would argue that that is the role of a building official. We are supposed to look at things logically and make judgement calls on things based on the reality of the situation. If I get a set of plans on my desk for with a different OL factor for plumbing than for egress, I'm going to understand that the designer has a good reason for that. As long as the MOE is all square, I won't blink twice at the fixture count. Others though, can be a stick in the mud. If you run into one of those, that's what 104.10 is for:

[A] 104.10 Modifications. Where there are practical difficulties
involved in carrying out the provisions of this code, the
building official shall have the authority to grant modifications
for individual cases, upon application of the owner or
the owner's authorized agent, provided that the building official
shall first find that special individual reason makes the
strict letter of this code impractical, the modification is in
compliance with the intent and purpose of this code and that
such modification does not lessen health, accessibility, life
and fire safety or structural requirements. The details of
action granting modifications shall be recorded and entered in
the files of the department of building safety.

If you as the RDP decide that the "strict letter of this code" (being the CBC OL factor) is not in the best interest of the building design, you should be able to submit for a modification to the BO. Present your case and your justifications and they now have the documentation to record and keep on file to cover them.

 

[Yankee Chronicler]

Another prime example of how confusing this can get is in the Plumbing Code. CPC table 422.1 is used to determine the fixture count based on the occupant load as determined by the Building Code...

Unless you're OSHPD, then you look at table 4-2 instead...

Or its a state building or public school, then you determine the plumbing OL from Table 4-1 and then use Table 422.1 to demine the fixture count... Except not, because you can use can use the Building Code OL if you want...

Or if it's a rural HCD 1 project, then the local health department determines what's required...

Or its a project under the Department of Food and Agriculture, then you look at Table 4-3...

Or a project under the Department of Public Health, then you look at Table 4-4.


Before I started working at the firm I'm at now, the firm used Table 4-1 (formally Table A) for determining the OL, which usually resulted in a lower OL than what Building Code called for (and isn't applicable to the projects we work on). They did that for at least 6 years and were never once called out on it.

View attachment 16649

I was licensed to practice architecture in California for twenty years (plus or minus). I surrendered my license when their continuing education requirements became too onerous. I was getting plenty of hours (needed to maintain my BO license in my home state), but California wouldn't grant credit for classes put on by my state government. I wasn't doing work in California, so I stopped renewing.

Apparently that was a good decision. IMHO, there's no point in adopting a state building code if every city and state agency can just change things around on a whim.