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Occupant load of a city council chamber

Tim Mailloux

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Joined
Feb 12, 2018
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922
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Hartford CT
During a recent yearly inspection, the AHJ cited several egress violations in a municipal building. The most severe citation was the lack of the required number of exits from the 2nd floor, based on the occupant load due to the city council chamber being located on this floor.

The chamber is approximately 2,100 square feet in total. The AHJ used the 1 person per 7 square feet assembly factor for the entire room, resulting in an occupant load of 300 people. However, I have some reservations about this calculation. The room is divided into two distinct areas: the front third (800 square feet) is a raised platform (about 12” above the finished floor) which includes a large fixed semi-circular council desk for the nine city council members. This raised platform is separated from the remaining two-thirds of the room (1,300 square feet) by a permanent knee wall. Behind the knee wall, there is a lectern for presentations and public comments, as well as seating for the public with loose chairs.

In my opinion, the 1,300 square feet seating area should indeed be calculated using the 1 person per 7 square feet assembly factor. However, for the 800 square feet council members' area, I believe a different, more reasonable factor should be applied since it is specifically for the nine council members at a fixed desk. Perhaps we could calculate it as 9 fixed seats?
 
Is your project In Connecticut? Did the state remove this exception from IBC 1004.5?
“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.‘
 
Is your project In Connecticut? Did the state remove this exception from IBC 1004.5?
“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.‘
The building is in CT, and CT does indeed delete that exception from the IBC. As this is a very old building, the applicable fire code is NFPA 101.
 
Is the inspector citing this old building based on the original code under which it was legally constructed?

[A] 102.6.2 Buildings Previously Occupied

The legal use and occupancy of any building existing on the date of adoption of this code shall be permitted to continue without change, except as specifically provided in this code or the 2022 Connecticut State Fire Safety Code.
 
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Before my firm got involved this went all the way up the chain to the State Fire Marshall's office, they came in and did their own assessment / report and the states findings mirrored that of the local AHJ. So its a forgone conclusion that the egress issues need to be addressed and its now a matter of how many exits need to be added. If I can get the OL of the 2nd floor under 600 people, than per NFPA 13.2.4.2 I would only need to add 2 exits instead of 3 exits.
 
Before my firm got involved this went all the way up the chain to the State Fire Marshall's office, they came in and did their own assessment / report and the states findings mirrored that of the local AHJ. So its a forgone conclusion that the egress issues need to be addressed and its now a matter of how many exits need to be added. If I can get the OL of the 2nd floor under 600 people, than per NFPA 13.2.4.2 I would only need to add 2 exits instead of 3 exits.
Before you say it is a foregone conclusion, did they base their findings on the code applicable at time of original occupancy? Did they specifically cite that code? If not, they need to document it in writing, if for no other reason than to document the due diligence for the taxpayers who would need to foot the bill for physical changes.
Someone from the public will eventually ask, why was it OK before, but not anymore?

If it complies with 102.6.2, then it complies with “current code”.
 
I would suggest using the OLF for stages and platforms for the raised area - 15 SF. I don't know if that gets you under where you'd like to be or not. 240 by my quick calculation, 60 fewer.

Those are both net, so delete area of knee wall and perhaps any stairs and ramps up and down, because that is not available for seating.
 
Is the inspector citing this old building based on the original code under which it was legally constructed?

[A] 102.6.2 Buildings Previously Occupied

The legal use and occupancy of any building existing on the date of adoption of this code shall be permitted to continue without change, except as specifically provided in this code or the 2022 Connecticut State Fire Safety Code.
102.6.2 is in reference to use and occupancy, not life safety. In CT the fire code is retro active and we must bring the egress compliance issues with in the building up to the adopted NFPA 101 code. These egress issues in this building have been cited on a yearly basis for almost 15 years and the local AHJ has finally had enough.
 
Before you say it is a foregone conclusion, did they base their findings on the code applicable at time of original occupancy? Did they specifically cite that code? If not, they need to document it in writing, if for no other reason than to document the due diligence for the taxpayers who would need to foot the bill for physical changes.
Someone from the public will eventually ask, why was it OK before, but not anymore?

If it complies with 102.6.2, then it complies with “current code”.
Hard to argue with the State...
 
I would suggest using the OLF for stages and platforms for the raised area - 15 SF. I don't know if that gets you under where you'd like to be or not. 240 by my quick calculation, 60 fewer.

Those are both net, so delete area of knee wall and perhaps any stairs and ramps up and down, because that is not available for seating.
15 for tables and chairs or maybe 150 for business....I had to do this recently for my CC....Unless they actually let people stand or put chairs there (which becomes an enforcement issue going forward) It should not be done at 7 or 5.....
 
Hard to argue with the State...
It is not hard to request that the state provide a written code citation based on applicable code. If it turns out the applicable code at time of original permit calculated total occupancy and allowable # of exits differently, then the onus is on the state to provide a very specific reason why it is now considered more unsafe than before.

At the very least, it may encourage the state to consider allowing a lower posted occupant load for the space, such as may be allowed in any other jurisdiction that did not modify IBC 1004.5.
 
15 for tables and chairs or maybe 150 for business....I had to do this recently for my CC....Unless they actually let people stand or put chairs there (which becomes an enforcement issue going forward) It should not be done at 7 or 5.....
using 1 per 15 for the elevated platform area shaves off almost 60 people from the OL of the floor. That's getting me close to the 600 OL number whioch would only require (2) exits per NFPA 101 13.2.4.2.
 

Not a fire guy but.....
7.3.1 Occupant Load


7.3.1.1 Sufficient Capacity


7.3.1.1.1


The total capacity of the means of egress for any story, balcony, tier, or other occupied space shall be sufficient for the occupant load thereof unless one of the following conditions exists:
  1. The authority having jurisdiction shall be permitted to establish the occupant load as the number of persons for which existing means of egress is adequate, provided that measures are established to prevent occupancy by a greater number of persons.
  2. The egress capacity shall have been previously approved as being adequate.
 
using 1 per 15 for the elevated platform area shaves off almost 60 people from the OL of the floor. That's getting me close to the 600 OL number whioch would only require (2) exits per NFPA 101 13.2.4.2.
Don't forget to cut out any attached millwork (for net spaces) that an ethical designer such as yourself wouldn't normally do.....And me being nice, I would give you the door swing and maneuvering if I needed to... ;)
 
The building was constructed well before January 1, 2006 and falls under the purview of Part IV of the CT fire code, which is a heavily modified version of NFPA 101, end of story.
 
Another little tidbit is that you can actually get an IBC/IEBC pass if the correction of the CFSC has a conflict:
101.7 Connecticut State Fire Safety Code Abatement


Where conflicts exist between the requirements of this code and the requirements of a 2022 Connecticut State Fire Safety Code abatement order issued in writing by the local fire marshal with respect to an existing building, the requirements of that portion of the 2022 Connecticut State Fire Safety Code that regulates existing buildings shall take precedence.
Exceptions:
  1. New fire protection systems shall meet the requirements of Chapter 9 of this code.
  2. Electrical work shall meet the requirements of NFPA 70, National Electrical Code.
  3. Structural, plumbing and mechanical work shall conform to the requirements of this code.
 
using 1 per 15 for the elevated platform area shaves off almost 60 people from the OL of the floor. That's getting me close to the 600 OL number whioch would only require (2) exits per NFPA 101 13.2.4.2.
If the table or counter or whatever is fixed, it might also cut some area.

Do they never hold other meetings or events here? These kind of spaces are usually in high demand if any good at all. I would just expect it to be used for music performances or readings or other speech events in most communities.
 
If the table or counter or whatever is fixed, it might also cut some area.

Do they never hold other meetings or events here? These kind of spaces are usually in high demand if any good at all. I would just expect it to be used for music performances or readings or other speech events in most communities.
The dais and "desk" doesn't move so it is really only set up for meetings...From what I have seen..
 
Well if the stage and platform 15 SF work, go with it. If you were going to make a case for fewer based on fixed seating, I would sure recommend telling them it's limited to that. I guess since not even close to new, they have a good idea of any other uses.

They could probably do a nice fixed seating arrangement and reduce OL even more! Usually is around 8 1l2 to 9 SF in my experience. Would seem less expensive than a stair tower, and much more appreciated.
 
Well if the stage and platform 15 SF work, go with it. If you were going to make a case for fewer based on fixed seating, I would sure recommend telling them it's limited to that. I guess since not even close to new, they have a good idea of any other uses.

They could probably do a nice fixed seating arrangement and reduce OL even more! Usually is around 8 1l2 to 9 SF in my experience. Would seem less expensive than a stair tower, and much more appreciated.
well right now the upper (3) floors of this building have no code compliant exit stairs. So at a minimum we are looking at adding (2) new rated interior exit stairs to serve as the means of egress off the upper levels. The way the occupant load for the 2nd floor was previously calculated, it had an OL of over 700 people and would require (3) exits. My exercise has been to come up with a legitimate path to get the OL under 600 people so we only require two exits and I think I am now there.
 
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