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Opinion: Trying their best

lpiburn

Silver Member
Joined
Jul 30, 2013
Messages
103
Location
Albuquerque, NM
Hello All,

In your opinion, would you ever approve a permit for a restroom renovation with less than the required number of fixtures, due to the fact that it is an improvement over the existing condition?

I recently reviewed a project for a school where they have an existing stadium (overblown bleachers really) with a teeny-tiny bathroom/concessions building. The school wants to replace the little building with something code compliant, but the number of required plumbing fixtures is incredible. The calculated occ. load of the stands (both home and visitor sides) is in the 3,000s, so you would need something like 40 WCs on the female side alone. I believe the little building has a grand total of 3. :-?

I tried to qualitatively justify the numbers and give it some perspective. Given the large occupant load, even if 3 out of every 100 people (3% of 3000) need to use the restroom after a big game there would be a line of 90 people waiting to use the facilities at the same time.

While that sounds reasonable on paper, the sticker shock of adding a building with 60-70 plumbing fixtures was staggering. So the question is, if this hit your desk would you consider approving a planned renovation where they add SOME new bathrooms, even if it doesn't meet the whole requirement? The idea being that they are trying their best, but simply don't have the money/space to provide ALL the required bathrooms. Is some improvement better than no improvement at all?

I look forward to hearing your thoughts on this one. :popcorn :cheers
 
mtlogcabin said:
That is an unreasonable numberThe UPC would require 6 for males and 16 for females based on a 3,000 OL for a stadium.
So would you accept UPC as an "alternate means and methods" exception to the IPC and IBC chapter 29?
 
I am with the designers, just doing the general code review. There is no real project yet, in part because of this issue with number of fixtures. Currently using the 2009 IBC and IPC. I'm not sure how you would make it work without some kind of special variance. :|
 
If not.....

104.10 Modifications. Wherever 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 owner's representative, provided the building official shall first find that special individual reason makes the strict letter of this code impractical and 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.

Or I am sure there is a way to make it work under IEBC....Contact the AHJ and get their take....I am happy to work with people who reach out to me during design.

SECTION 710 PLUMBING

710.1 Minimum fixtures. Where the occupant load of the story is increased by more than 20 percent, plumbing fixtures for the story shall be provided in quantities specified in the International Plumbing Code based on the increased occupant load.

Not increasing OL.....no worries....
 
The IEBC reference is interesting. One potential monkey wrench is that Chapter 7 is about alterations. In this case the school is talking about demo/rebuild of the bathroom building, but not the bleachers/stadium. Would that section still apply?
 
Think of the bathrooms as a room in the stadium "building".....the bathrooms do not stand alone,they are serving the stadium, you are not building the stadium new, therefore the fixture count does not need to be as new. The work just has to comply....Or I could see it that way I think....Talk to the AHJ...
 
lpiburn said:
So would you accept UPC as an "alternate means and methods" exception to the IPC and IBC chapter 29?
I am under the UPC but I have accepted products approved under the IPC to use in my jurisdiction.

I have also allowed a reduced occupant load for plumbing fixtures when they appear to be excessive for a specific use based on historical date.

Average attendance per game. Donated bleachers that will never be used to capacity
 
I actually just spoke to them today, but I could not get a solid answer. In short they said "Send me an email with your questions and I'll look at it. No promises."

To be honest I didn't really expect a solution to this one since it really depends on the final word from the AHJ. I'm more interested / curious in what you would do if you were the AHJ in this situation.

I'll post the final results just in case anybody is interested.
 
For me the solution is simple, here in NYS the local AHJ does not have authority in public schools. That is assigned to State Ed here.

Theoretically they are enforcing the same Code with additional regs but the reality could be a different answer.

At this point, wait and see what the AHJ decides...

And we are ALWAYS interested in the final outcomes (we just don"t always get them...)
 
LPI....I (as an AHJ) would ask for some kind of proposal or "code path" in writing as well which will protect both of you. It is hard to be on the same page when there is nothing in writing. Off the cuff conversations and agreements have a way of biting back...
 
Waiting for a response... :yawnIn the meantime, here's some more information for the curious readers: 1. The bleachers were built quite some time ago. I'm not sure exactly when, but the plans were hand drawn and the architect had a registration number in the 200s. I think my state is up to 6 or 7 digits now...2. One thing the AHJ told me flat out is that they would NOT consider partial compliance at all. So adding a new smaller restroom as a supplement, even though it would be an improvement, is out of the question. If the school touches those bathrooms then they better come up to 100% of the requirements.3. One other possibility for reducing the fixture count is to make it so the bathrooms are only serving the home side bleachers. These are fairly substantial construction with a press box, and according to the school the visitors side is rarely even used. That side is made of semi-portable metal bleachers that incidentally don't meet any modern code for aisles, handrails, guards, accessibility, etc.4. I've attached the analysis I sent to the AHJ showing the comparison on occupant load and fixture counts. You can see that the IBC requires way more than the UPC. I included the 2012 UPC as well just as a frame of reference since that one changed format so much, and the plumbing counts for this occupancy dropped even further. I don't expect the AHJ to approve use of the '12 code since the state is on '09s but its interesting either way.

View attachment 1129

-LPView attachment 1129

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+ & + & +



lpiburn,

For my clarity, which code book & edition is the AHJ actually using for

the existing conditions [ the IEBC or Ch. 34 in the IBC ], or are they

planning to demolish the Restroom structure and start anew ?

Thanks ! :cool:

Also, ...I agree with **steveray** and the CYA idea of having them

produce something in writing........If they will tell you which way to go,

then you can design accordingly.



+ & + & +
 
The state uses the 09 IEBC, and strikes chapter 34. Actually their website is pretty simple so you can quickly and easily see all the amendments.

The plan would definitely be to demolish the little restroom building. One of the ideas we threw around was to retain the existing facilities and just build a new bathroom building nearby. That would help with fixture count, but the existing building is just old and tiny and it needs to go away.
 
~ & ~ & ~

Any other [ compliant ] restroom facilities located within 500 ft. ?

~ & ~ & ~
 
north star said:
Any other [ compliant ] restroom facilities located within 500 ft. ?
Yes, but not nearly enough. There is a gym nearby whose restrooms are about 400' away in actual travel distance from the furthest seat. Unfortunately it's more of the same tiny non-accessible kind of restroom. I think it's another 2-3 fixtures per M/F?? (I don't have the plans for that building) We would get to knock some fixtures off the overall count, but only a few.
 
I just argued with my father about this last night.....he thinks full compliance with full fixture count, I think something could be made to work with less....
 
( * | * )

"I just argued with my father about this last night.....he thinks full compliance with full fixture count,I think something could be made to work with less.... "
Could you provide a clear, code compliant path to arrive at anacceptable number ?.................Just sayin"... :grin:



( * | * )
 
Our California Building Code, based on the UPC, has always had an amendment / footnote in table 4 that says "the Authority Having Jurisdiction may approve alternative design criteria when determining the minimum number of plumbing fixtures."

The classic example was an all-boys or all-girls school, or a convent, or similar facility.

In your case, if you can find a similar mechanism, it may have more to do with how the field is utilized. For example, if it is primarily track-and-field events, where people are likely to not all go to the restroom at the same moment, then you may have a case for "alternative design criteria".
 
There is no similar established method for the NM codes. In fact, the whole thing is a little convoluted. The state adopted the '09 I-codes for buildings, and the '09 U-codes for plumbing & mechanical, EXCEPT for the actual fixture counts, which refer back to IBC ch 29.

We do have a process for granting variances which involves an official request form that is sent to a "Technical Advisory Committee" in the capital. We actually just got one approved on a different project and they made a decision in only a couple of days which was a pleasant surprise.

For this particular project we really can't even go down that road because there is no real project yet. We are consulting with the school pre-contract and if the local AHJ says no way then the project will stop dead before it even gets started.
 
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