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Replacement of Exterior stair - IEBC Alteration level

Dinheru

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Joined
Jun 8, 2022
Messages
13
Location
Pennsylvania
Replacement of exterior stair , pressure treated residential egress stair. )IEBC 2018)

Part of the stair collapsed so the owner start replacing the stair as it had an immediate impact on the egress of the building.
Code officials issued a stop construction order, since it was not under permit
Owners intend was do the repairs , since it causes egress hazard and apply afterwards.
Now there is stair that is not entirely finished,
Owner applied for permit. The officials call it a level 2 alteration.
My interpretation is that is a repair, or maybe level 1, definitely not a level 2 alteration

Level 1 alteration are for replacement of elements, which the stair would be

Code official says it is a reconfiguration of the space (exterior stair)

Where am I wrong or missing something? Would this be repair, level 1 or 2 alteration?
 
It is definitely not a reconfiguration of space. Unless the stairs are redesigned with a new arrangement of steps and landings, then there is no "reconfiguration."

If the stairs are being reconstructed as they were originally constructed, then there should be no issues. Under the IEBC this would be considered a repair by definition: "The reconstruction, replacement or renewal of any part of an existing building for the purpose of its maintenance or to correct damage."

If the stairs are the same configuration as the original stairs but are reconstructed using improved materials (e.g., using steel construction instead of the original wood construction), then it would be a Level 1 Alteration per IEBC Section 602.1.

Besides, per IEBC Section 301.3, the code officials do not get to decide which compliance method you use. A level 2 Alteration is for the work area compliance method. Repairs are just that, repairs, and are not associated with any specific compliance method.
 
2018 IEBC
SECTION 404
MEANS OF EGRESS

404.1 General.
Repairs shall be done in a manner that maintains the level of protection provided for the means of egress.

SECTION 405
STRUCTURAL

[BS] 405.1 General.
Structural repairs shall be in compliance with this section and Section 401.2.
 
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