To solve the dillema,
Read Section 201.1 and then read Section 102.1
Also remember Section 104.1.
Lets also remember Chapter 3 is titled USE AND OCCUPANCY CLASSIFICATION. Not all use areas are an occupancy because they are not an "occupiable space" as defined in Chapter 2. Those area are therefore called a "Use classification" for a cold storage room. That is what we are basically talking about. Occupiable Spaces are spaces that are considered spaces that are intended to be occupied on a perpetual basis. Cold storage rooms are not intended for perpetual occupancy of people. They are considered like any walk-in closets, bathrooms, etc. for temporary or short-term presence of human beings. Sure you physically occupy space whereever you stand. That is not the intent of code and intent of meaning of code when we talk about a space that is to be considered an "occupiable space". It is a code violation for people to be in a cold storage room the entire day. Sure, some people might be constantly in and out of such due to the nature of work.
Basically, the space we are talking about is a jumbo sized Refrigerator / Freezer. Use some basic common sense here. An occupiable space may not be kept at temperatures below a certain level for obvious health reasons... remember 101.3 and and remember 104.1 (as noted earlier).
Cold storage rooms to be considered an occupiable space shall be sub-divided into refigerators/freezer units and all portions of the space where people are expected to be occupying the space shall be heated to a level to maintain health safety standards for occupancy and also ventilated.
So basically the walk aisle and any preparation area portion of the cold storage room where people will be considered occupying the space to be deemed an occupiable space shall be a heated & ventilated space. That is how I would call it. It might defeat the purpose and nature of a cold storage room being an entire room that is chilled.... but you have to remember the intent of code is for safeguarding public health, safety and welfare and assuring that buildings and the spaces within are structurall safe, adequate means of egress, and sanitary for human occupancy and safety from fire and OTHER hazards. I would think a freezer or refrigerator is hazardous to human health under prolonged conditions without proper protective clothing and gear. Hypothermia ????
Remember the purpose and then use common sense with the defined definitions of code that is to be enforced.
