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IEBC Commentary

Not that I'm a fan of UpCodes, but if you buy a subscription I believe they offer some commentary. I don't subscribe, so I have no idea how helpful their supplemental material is.

What's your question? I spend a lot of time in the IEBC because my town has a lot of old buildings that rotate tenancies. We may be able to help.
 
Ultimately it would be nice to have for all future projects, but specifically I am looking to read 301.3.1. It references "in buildings complying with the IFC. I read that to mean the iFC in its entirety and not just chapter 11 requirements for existing buildings. The IEBC prescriptive method, which i have not typically used (i typically use the work area method) seems to be awful lenient on its requirements, which make me think they assume the existing building is somewhat compliant to being with. The more stringent requirements of the work area method have a fair amount of hardships as the project is an entire 3rd floor renovation and when the work area is over 50% of the floor area there are extra triggers. So was trying to dig more into the prescriptive method to see if its looking for me just to comply with chapter 11 or the entirety of the IFC.
 
2021 IEBC:

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.

 This section allows compliance in accordance with
Chapter 5 of the code, which is referred to as the prescriptive
method. These provisions are intended to
prescribe specific minimum requirements for construction
related to existing buildings, including additions,
alterations, fire escapes, window replacement, change
of occupancy and historic buildings. This method is
mainly administrative in approach. There are several
topics that have been addressed to specifically correlate
with the work area method. These topics include
structural requirements, flood hazard areas, emergency
escape and rescue openings and window fall
prevention device requirements, Historic buildings are
also addressed in this chapter.
Click to expand...

I understand that this section to mean the building must comply in all respects with the IFC for existing buildings before you can start looking at Chapter 3 of the IEBC.

The work area method doesn't rise to Level 3 when it's more than 50% of the floor area of a single story. It's over 50% of the total building area.

604.1 Scope. Level 3 alterations apply where the work area
exceeds 50 percent of the building area.
Click to expand...
 
I read it to comply with all respects of IFC also, just figured i would verify via commentary if could. would hate to include extra hardships on the client if not required. We are a level 2 alteration for sure, but with that section, there are extra requirements when the work area is over 50% of the floor area.
 
Hyrax4978 said:
I read it to comply with all respects of IFC also, just figured i would verify via commentary if could. would hate to include extra hardships on the client if not required. We are a level 2 alteration for sure, but with that section, there are extra requirements when the work area is over 50% of the floor area.
Click to expand...

Section 301.3.1? But that specifically applies to the Prescriptive Method. If you are using the Work Area Method, why are you worrying about a paragraph that does not apply to the Work Area Method?
 

I am going to assume that it means that it is legally existing and in compliance with the "existing fire code" plus the work being done meets the IEBC​

301.3.1​

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.

❖ This section allows compliance in accordance with Chapter 5 of the code, which is referred to as the prescriptive method. These provisions are intended to prescribe specific minimum requirements for construction related to existing buildings, including additions, alterations, fire escapes, window replacement, change of occupancy and historic buildings. This method is mainly administrative in approach. There are several topics that have been addressed to specifically correlate with the work area method. These topics include structural requirements, flood hazard areas, emergency escape and rescue openings and window fall prevention device requirements, Historic buildings are also addressed in this chapter.
 
Thank you Steveray, was hoping it would clarify the reference to compliance with the fire code. glad I didn't spend $102 to find out it doesn't LOL.
I am going to stick with my initial assumption that the existing building would need to comply with the IFC in whole. and since it doesn't will run with IEBC chapter 8. Much appreciated.

the prescriptive method is lacking on scope when its not a change of use which must be why they assume its already compliant with the IFC.
 
Hyrax4978 said:
I am looking to see if there are any legal EBC Commentary viewers online.
Thank you,
Click to expand...
I'm not real sure I understand your question, but I have subscribed to an ICC commentary on line at ICC for a month - $8-9 typically - just to research on issue.
 
Hyrax4978 said:
Thank you Steveray, was hoping it would clarify the reference to compliance with the fire code. glad I didn't spend $102 to find out it doesn't LOL.
I am going to stick with my initial assumption that the existing building would need to comply with the IFC in whole. and since it doesn't will run with IEBC chapter 8. Much appreciated.

the prescriptive method is lacking on scope when its not a change of use which must be why they assume its already compliant with the IFC.
Click to expand...
At least in CT...The assumption is every building that the FM has jurisdiction over meets Part IV of the fire code as they are obligated to do their "annuals" or whatever they are....Similar to what we do for MOE in Level 2 alterations...
804.2 General
The means of egress shall comply with the requirements of this section.
Exception: Where the work area and the means of egress serving it complies with the 2022 Connecticut State Fire Prevention Code.
 
Hyrax4978 said:
the prescriptive method is lacking on scope when its not a change of use which must be why they assume its already compliant with the IFC.
Click to expand...

But you said it's a level 2 alteration. If you are using the Work Area Method, why are you reading a section that specifically applies to the Prescriptive Method?
 
Hyrax4978 said:
Thank you Steveray, was hoping it would clarify the reference to compliance with the fire code. glad I didn't spend $102 to find out it doesn't LOL.
I am going to stick with my initial assumption that the existing building would need to comply with the IFC in whole. and since it doesn't will run with IEBC chapter 8. Much appreciated.

the prescriptive method is lacking on scope when its not a change of use which must be why they assume its already compliant with the IFC.
Click to expand...
when was the original building permitted? If it was permitted before CT adopted the I codes in 2005 then the existing building may fall under NPFA 101 instead of the IFC. However all new work would fall under the IBC / IFC.
 
IFC 1101.2 (2021) states;

1101.2 Intent
The intent of this chapter is to provide a minimum degree of fire and life safety to persons occupying existing buildings by providing minimum construction requirements where such existing buildings do not comply with the minimum requirements of the International Building Code.

I would agree that IEBC 301.3.1's intent would be full compliance with the IFC (in turn IBC), which is typically the compliance method used for alterations in newer buildings.

The work area method allows the RDP some flexibility based on the extent of work proposed and the existing buildings code compliance.
 
It started with a change in the 2012 IEBC if someone were so inclined to look harder at why....And research the code change history...

301.1.1 Prescriptive compliance method.
Repairs, alterations, additions and changes of occupancy complying with Chapter 4 of this code in buildings complying with the International Fire Code shall be considered in compliance with the provisions of this code.
 
Remember the IFC is more of a maintenance and operations code than a construction code. IMHO all of Chapter 11 is applicable and if there is an operation or system within the structure/use that would require an IFC permit under 105.6 or 105.7 then they would also be required to meet todays adopted IFC. Remember the IBC will send you to the IFC for specific construction requirements. I disagree with the thought that you would be required to comply with the "full" IFC under IEBC 301.3.1 language.

2018 IFC
1101.3 Permits.
Permits shall be required as set forth in Sections 105.6 and 105.7 and the International Building Code.

IFC 105.6 deals with operational permits and limits on hazardous materials may be in a structure before the fire code would be applicable.

IFC 105.7 2. Construction permit. A construction permit allows the applicant to install or modify systems and equipment for which a permit is required by Section 105.7.
The IFC list 25 systems that have specific requirements for use and installations/
 
mtlogcabin said:
Remember the IFC is more of a maintenance and operations code than a construction code. I
Click to expand...

But the project is in Connecticut. The fire marshals in Connecticut have been married to NFPA 101 since the 1950s or so. Since 2005, Connecticut has had a convoluted, confusing, 5-part fire safety code that uses the IFC as the fire code for new construction and then shifts to the existing occupancy chapters of NFPA 101 for on-going annual/bi-annual/tri-annual inspections.
 
Yankee Chronicler said:
But the project is in Connecticut. The fire marshals in Connecticut have been married to NFPA 101 since the 1950s or so. Since 2005, Connecticut has had a convoluted, confusing, 5-part fire safety code that uses the IFC as the fire code for new construction and then shifts to the existing occupancy chapters of NFPA 101 for on-going annual/bi-annual/tri-annual inspections.
Click to expand...
I thought that only buildings permitted before 2005 use NFPA 101 for the on-going annual inspections, but building permitted post 2005 under the IFC follow the IFC for those on-going annual inspections.
 
Tim Mailloux said:
I thought that only buildings permitted before 2005 use NFPA 101 for the on-going annual inspections, but building permitted post 2005 under the IFC follow the IFC for those on-going annual inspections.
Click to expand...

You are probably correct. So yet another layer of confusion on top of the basic level of chaos. I'm so accustomed to dealing with buildings constructed in the 1800s I don't pay much atention to what the fire marshals deal with for their periodic re-inspections.
 
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