IEBC challenges

[Sifu]

Question: Is panic hardware required in this existing building, change of occupancy?

2018 IEBC. Previous occupancy M, changed to A2, occupant load 65. No changes proposed to the two exit doors from the space.

IEBC definitions would classify this as a C of O (because it is a change of occupancy classification). IEBC 202.
IEBC 1001 indicates ch. 10 applies, further refined as a partial change of occupancy by 1001.2.2.1, which sends us directly to 1011.
IEBC 1011.1 validates that section 1011 applies to a partial change of occupancy, which compels compliance with 1002 through 1010, as well as 1011.

So now we have it. This project is subject to IEBC 1002 through 1011.

IEBC 1011.4.2 sends us to IEBC 905.
IEBC 905 sends us to IEBC 805. IEBC 805.4.4 tells us that panic is required if the A OL is >100, HOWEVER 805.1 tells us this section is limited to where an exit or corridor is shared by more than 1 tenant.

Wait, now we have it. This is subject to ch. 10, ch. 9, and ch. 8, sometimes.

Note that the IEBC general comments tells us not to confuse a change of occupancy with a change of occupancy classification but defines a change of occupancy as a change of occupancy classification. I get the nuances, but to me this is word salad.
Note that in 2 of the 3 hazard tables, an A2 is a greater hazard than an M, but not the MOE table.
Note that the commentary for 805.4.4 tells us this requirement is "much the same" as IBC 1010.1.10. IMHO it is not "much the same".
Note that IEBC 1011.1 tells us that the application of requirements for the change of occupancy shall be as set forth in 1011.1.1 through 1011.1.4. There is no 1011.1.4. (The '21 and '24 must have figured that out, or accidentally fixed it with renumbering/reconfiguration).

So a single tenant, A2 occupancy, without shared exits with an OL of 99 doesn't require panic hardware, but maybe if not sharing the exits the OL is unlimited and no panic is required.

Sorry, kind of a rant. The IEBC was intended to make existing buildings more usable without full compliance with the IBC. I get it, but is panic hardware one of the deal-breakers? If so, fine. Tell us that without all the contortions. These are challenges I have in understanding the IEBC, and making it a usable resource for DP's, owners and contractors.

 

[Yankee Chronicler]

Note that the IEBC general comments tells us not to confuse a change of occupancy with a change of occupancy classification but defines a change of occupancy as a change of occupancy classification. I get the nuances, but to me this is word salad.

It's word salad without even a decent salad dressing to make it palatable.

I have had difficulty grasping the distinction between use group, occupancy, and occupancy classification ever since we stopped using BOCA and switched to the ICC. The old way, everyone understood what everyone else was talking about. Now I don't even understand myself.

 

[jar546]

Panic hardware is not required for the existing building undergoing a change of occupancy from M to A2 with an occupant load of 65, considering the building has a single tenant and does not share exits. The occupant load is still below 100.

Thoughts?

 

[Yankee Chronicler]

Agreed.

It just takes a lot of digging to figure that out.

 

[jar546]

Agreed.

It just takes a lot of digging to figure that out.

Change of Occupancy:​

• IEBC Definitions (IEBC 202): This project involves a change of occupancy classification.
• IEBC 1001: Indicates that Chapter 10 applies to change of occupancy.
  • IEBC 1001.2.2.1: Specifies partial change of occupancy, leading us to Section 1011.
• IEBC 1011.1: Validates that Section 1011 applies to partial changes of occupancy.
  • This means compliance with Sections 1002 through 1010, and 1011 is required.

Specific Code Sections:​

• IEBC 1011.4.2: Directs us to IEBC 905.
• IEBC 905: Directs us to IEBC 805.
• IEBC 805.4.4: Requires panic hardware if the Assembly (A) Occupant Load (OL) is greater than 100.
  • IEBC 805.1: Limits this requirement to situations where an exit or corridor is shared by more than one tenant.

 

[steveray]

 

[Sifu]

Panic hardware is not required for the existing building undergoing a change of occupancy from M to A2 with an occupant load of 65, considering the building has a single tenant and does not share exits. The occupant load is still below 100.

Thoughts?

My thoughts:

Agree based on code, but not in practice. Changing from an M, very few occupants, one exit required. Now an A2, with a bar, it is an arcade, lots of noise, booze, flickering lights etc. There just doesn't seem to be valid roadblocks to changing the door hardware. The path to getting there is too convoluted, and without digging I think it likely most don't ever get there (plans examiners, inspectors, DP's). My process for existing buildings is to treat it as new, then go back on each requirements when viewed through the IEBC to either validate the comment or remove it. My initial comment on first pass was to provide the panic hardware, then an hour later scratching after scratching my head a few times did I see it would not be required. It just shouldn't be that difficult IMO.

Plus, based on 805.1, not sure there is any OL that would require panic hardware if the exits aren't shared. Makes me wonder about the intent. If they wanted the panic to apply to a non-shared exit with an OL of >100 then the pointer in 905 should send us directly to 805.4.4, thus bypassing the shared exit primer.

In a previous thread I eluded to the challenges with the IEBC, which I find to be a good idea, but with challenges. This is one I ran across after I wrote that post I can use to illustrate one of those challenges.

 

[Sifu]

View attachment 13610

I like it. That changes the scenario, and it makes sense. I stopped reading because it was in what I took to be a building separation issue. My fault, however, it still doesn't change my opinion of the convolutions of this code. Seems like we could get there a little easier.

100% guarantee that the DP does not have an IEBC (I know this because he didn't reference it, didn't provide a path, didn't tell me the previous occupancy, didn't tell me what the separations are...on and on). So when I provide a code citation I can use 805.4.4. If he buys a code book, and looks it up he will say that is in the level 2 alterations section, then I can give him the multiple sections that gets us there. Or I could write this:

Page A2: Provide panic hardware for doors A & B in accordance with IEBC 1011.1.1, IEBC 901.2, IEBC 905.1, & 805.4.4.

I know some don't provide code citations, but I do....but in this case I think it would just pi$$ people off. It has pi$$ed me off just getting there.

But, thanks for getting me there.

 

[steveray]

Do this....as painful as it might be....

Page A2: Provide panic hardware for doors A & B in accordance with IEBC 1011.1.1, IEBC 901.2, IEBC 905.1, & 805.4.4.

 

[Sifu]

While on the subject...why is an M and an A the same hazard level for MOE in the IEBC?

 

[mtlogcabin]

100% guarantee that the DP does not have an IEBC (I know this because he didn't reference it, didn't provide a path, didn't tell me the previous occupancy, didn't tell me what the separations are...on and on).

So make it easy on yourself and use Chapter 5.


SECTION 506
CHANGE OF OCCUPANCY

506.1 Compliance.
A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the International Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the building official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.

IMHO just because you correctly followed an IEBC path that requires panic hardware be installed. I believe IBC 1010.1.10 is also applicable especially the exceptions for the main doors.

1010.1.10 Panic and fire exit hardware.
Swinging doors serving a Group H occupancy and swinging doors serving rooms or spaces with an occupant load of 50 or more in a Group A or E occupancy shall not be provided with a latch or lock other than panic hardware or fire exit hardware.

Exceptions:

1. A main exit of a Group A occupancy shall be permitted to have locking devices in accordance with Section 1010.1.9.4, Item 2.

 

[Sifu]

This designer has not chosen a path from the IEBC. Your way is simpler. I have provided a comment that they must choose a path. I presume the work area in the discussion because that is the more forgiving path, but you are correct, the easier way for me is to cite prescriptive. As far as the exceptions, unless there is some indication that they are using one, I cite the main code and let them design for a possible exception.

IMO this is where the IEBC starts to struggle, since it seems to assume everyone will do this from the get-go. My first comment could be to provide the path. Only then could a review begin, so it could be the only comment on round #1, and then round #2 gets into the specifics of the path. Or, I could assume a path then cite the applicable code. Why would I assume one path over another? Why drive myself insane finding a way to approve something if they haven't done their part?

Maybe the compromise between my sanity and theirs is to cite 506.1, then move straight back to the IBC for all the comments. That might actually be easier than using the IEBC for them, since I am positive they don't have one.

I think I will adopt this as a rule. Cite this sequence and let them figure it out. I think you just saved me a lot of time in the future since so many are like this.

 

[steveray]

Never prescriptive for a change of occupancy....

 

[Sifu]

Never prescriptive for a change of occupancy....

Why? 506 seems to be a prescriptive path for change of occupancy.

 

[mtlogcabin]

​

Our state gives them a choice which is already given in the IEBC (a) The owner of an existing building may follow the requirements of either the IEBC or the IBC, but the owner may not apply some of the requirements of the IEBC and other requirements from the IBC on the same project. Never prescriptive for a change of occupancy.... Code section Please 301.3 Alteration, addition or change of occupancy. The alteration, addition or change of occupancy of all existing buildings shall comply with one of the methods listed in Section 301.3.1, 301.3.2 or 301.3.3 as selected by the applicant. Sections 301.3.1 through 301.3.3 shall not be applied in combination with each other. Exception: Subject to the approval of the code official, alterations complying with the laws in existence at the time the building or the affected portion of the building was built shall be considered in compliance with the provisions of this code. New structural members added as part of the alteration shall comply with the International Building Code. This exception shall not apply to alterations that constitute substantial improvement in flood hazard areas, which shall comply with Section 503.2, 701.3 or 1301.3.3. This exception shall not apply to the structural provisions of Chapter 5 or to the structural provisions of Sections 706, 806 and 906. 301.3.1 Prescriptive compliance method. Alterations, additions and changes of occupancy complying with Chapter 5 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code. 501.1.1 Compliance with other methods. Alterations, additions and changes of occupancy to existing buildings and structures shall comply with the provisions of this chapter or with one of the methods provided in Section 301.3.

 

[steveray]

Why? 506 seems to be a prescriptive path for change of occupancy?

Because it would have to meet all new everything/ IBC (which will then pull in the other codes) unless we say it is OK....And that just can't really happen

 

[Sifu]

Because it would have to meet all new everything/ IBC (which will then pull in the other codes) unless we say it is OK....And that just can't really happen

Yet it is an option for them, similar to the way it all worked prior to the IEBC, which, since they didn't even reference the IEBC I could assume is what they are after. The IBC requires the use of the IEBC (101.4.7) I don't get worked up if they don't and the project meets the IBC, but by not using the IEBC, not even referencing it, I could easily assume they intend to meet the provisions of the IBC, which would be fine with me.

FWIW, in this case based on what they have provided, I see no advantage to using any one method over the other except that they might know the IBC better than they know the IEBC. I know I do. My first comment is to choose the path. If they do then I can tailor my comments towards that path, but the results look to be the same.

Now, if they actually classify it correctly, add up the areas correctly and calculate the OL correctly, (they did none of this correctly, irrespective of using the IEBC) some of the comments may go away, but they would go away using any path.

 

[steveray]

Yet it is an option for them, similar to the way it all worked prior to the IEBC, which, since they didn't even reference the IEBC I could assume is what they are after. The IBC requires the use of the IEBC (101.4.7) I don't get worked up if they don't and the project meets the IBC, but by not using the IEBC, not even referencing it, I could easily assume they intend to meet the provisions of the IBC, which would be fine with me.

FWIW, in this case based on what they have provided, I see no advantage to using any one method over the other except that they might know the IBC better than they know the IEBC. I know I do. My first comment is to choose the path. If they do then I can tailor my comments towards that path, but the results look to be the same.

Now, if they actually classify it correctly, add up the areas correctly and calculate the OL correctly, (they did none of this correctly, irrespective of using the IEBC) some of the comments may go away, but they would go away using any path.

But they would have to meet ALL of the "new" codes including IMC, NEC, IPC and so on....No one is going to do that....Similar to the NFPA 13 discussion in the other thread with "todays" NFPA 13...

[A] 101.4 Referenced Codes​

The other codes specified in Sections 101.4.1 through 101.4.7 and referenced elsewhere in this code shall be considered to be part of the requirements of this code to the prescribed extent of each such reference.

 

[Sifu]

Nobody said it would be easy. They were/are free to choose a method other than prescriptive, and I would have made the comments based on that choice. I could leave the sole comment to provide the path and wait, or I could make them all to give them a head-start. Like I said, either way they need to do the same things...once they get the rest of the code analysis right. This post was specifically about the panic hardware, which you pointed out they need to do either way. I then turned it generally towards a bigger issue, but when I hit each comment I made from both pathways, they end up the same, but with a lot less contortion.

 

[mtlogcabin]

But they would have to meet ALL of the "new" codes including IMC, NEC, IPC and so on....No one is going to do that....Similar to the NFPA 13 discussion in the other thread with "todays" NFPA 13...

I respectively disagree.

506.1 Compliance.
A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the International Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the building official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.
Any other code requirements that may come up as a change of occupancy do not have to be met if the Building Official agrees that not requiring a specific code section does not make it more hazardous for life or fire.

You can only get to Chapter 10 in the IEBC is through one of the Work Compliance Levels 1,2 or 3.
301.3.2 Work area compliance method.
Alterations, additions and changes of occupancy complying with the applicable requirements of Chapters 6 through 12 of this code shall be considered in compliance with the provisions of this code.

 

[steveray]

Nobody said it would be easy. They were/are free to choose a method other than prescriptive, and I would have made the comments based on that choice. I could leave the sole comment to provide the path and wait, or I could make them all to give them a head-start. Like I said, either way they need to do the same things...once they get the rest of the code analysis right. This post was specifically about the panic hardware, which you pointed out they need to do either way. I then turned it generally towards a bigger issue, but when I hit each comment I made from both pathways, they end up the same, but with a lot less contortion.

I get it, but then how much info are you going to make then provide? Because then, anything you miss is on you....

 

[steveray]

I respectively disagree.

506.1 Compliance.
A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the International Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the building official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.
Any other code requirements that may come up as a change of occupancy do not have to be met if the Building Official agrees that not requiring a specific code section does not make it more hazardous for life or fire.

You can only get to Chapter 10 in the IEBC is through one of the Work Compliance Levels 1,2 or 3.
301.3.2 Work area compliance method.
Alterations, additions and changes of occupancy complying with the applicable requirements of Chapters 6 through 12 of this code shall be considered in compliance with the provisions of this code.

I get it...and at times, it might be a small amount of "use specific" stuff, but I know what I get for plans when people go prescriptive and the fight it is to get it right on paper and/ or the field...I just got one where the building is over height and area....(well area anyway)

506.1 Compliance.​

A change of occupancy shall not be made in any building unless that building is made to comply with the requirements of the International Building Code for the use or occupancy. Changes of occupancy in a building or portion thereof shall be such that the existing building is not less complying with the provisions of this code than the existing building or structure was prior to the change. Subject to the approval of the code official, changes of occupancy shall be permitted without complying with all of the requirements of this code for the new occupancy, provided that the new occupancy is less hazardous, based on life and fire risk, than the existing occupancy.

Exception: The building need not be made to comply with Chapter 16 of the International Building Code unless required by Section 506.5.
❖ A change of occupancy in an existing structure could change the level of inherent hazards that were initially addressed in the existing building or space. The provisions in this section intend to address the specific hazards of the new occupancy. For example, a change from a mercantile occupancy to a business occupancy renders all provisions of the code for Group B applicable to the portions of the structure where the occupancy has changed.

 

[Sifu]

I get it, but then how much info are you going to make then provide? Because then, anything you miss is on you....

As a baseline I need the IEBC pathway. As an added bonus, maybe they will buy an IEBC and try to figure this stuff out along side me. This tiny little, very simple project has 15 comments. If they provide remedies to those comments that will be good enough for me. If I miss something, so be it. I probably miss something on every single review I do. I try me best every time, all I ask is that they do the same.