S-1, Self-Storage Facility: Fire wall/Sprinkler

[ryan81]

Project Information:

Adopted Building Code: 2018 IBC
Construction Type: IIB (Pre-Engineered Metal Building)
Occupancy Classification: S-1
Number of Stories: 1
Building Area: 8,000 SF (40’x200’)
Fire Protection: Non-Sprinkled
Facility Type/Use: Exterior Access, Self-Storage Facility


Regarding the self-storage facility described above, in order to eliminate the requirement for an automatic sprinkler system, the local code official is requiring firewalls to create separate buildings with areas not exceeding 2,500 SF. This requirement is based on 903.2.9, #5 (added in the 2012 code cycle) which assumes the likelihood that the units will be used to store upholstered furniture and/or mattresses. This applicability to self-storage facilities was confirmed by IFC Interpretation 20-14 (issued on 10/6/2014). Whether or not I think the provision “makes sense”, I do believe the code official’s judgement is in alignment with the intent of the 2018 IBC.

The above said....In the 2021 edition of the IBC, this provision (903.2.9, #5) was removed and the specific provision is still absent from the 2024 edition of the code.

My question is this: Does the code provide a mechanism for the building official to waive a provision of the currently adopted building code when that requirement no longer exists in the more current editions of the code? If so, what is the appropriate course of action I must take to make my case? Could my argument, in any way, fall under the provisions of 104.11 allowing for “Alternative materials, design and methods and equipment”?

Thank you all, in advance for your thoughts on the matter.

- Ryan

 

[RLGA]

The requirement was relocated to Section 903.2.9.4 in the 2021 IBC with an exception for self-storage facilities under certain conditions. Also, the requirement was changed to a "fire area" greater than 2,500 sq. ft., which means fire barriers per IBC Section 707.3.10 can be used instead of fire walls (which seemed a bit extreme in the earlier editions, in my opinion).

 

[Sifu]

I had a similar project not long ago. I pointed out these very issues, for the CBO to make the determination. The way I have seen newer codes approved in lieu of the adopted codes was to allow them based on equivalence but only if the entire body of new codes is used. The way the CBO handled it was to ignore the provision in the '18 & the IFC interp. altogether and allow it....based on the "guidance" of the '21 code change is my assumption.

 

[ryan81]

I had a similar project not long ago. I pointed out these very issues, for the CBO to make the determination. The way I have seen newer codes approved in lieu of the adopted codes was to allow them based on equivalence but only if the entire body of new codes is used. The way the CBO handled it was to ignore the provision in the '18 & the IFC interp. altogether and allow it....based on the "guidance" of the '21 code change is my assumption.

Sifu:
I've done a cursory search online, but probably used the wrong keywords. Where might one access the "guidance" prompting this code change? I would assume it's public record....

Thanks!

 

[ryan81]

The requirement was relocated to Section 903.2.9.4 in the 2021 IBC with an exception for self-storage facilities under certain conditions. Also, the requirement was changed to a "fire area" greater than 2,500 sq. ft., which means fire barriers per IBC Section 707.3.10 can be used instead of fire walls (which seemed a bit extreme in the earlier editions, in my opinion).

Thank you for pointing out the new subsection. The way the subsection and exception are written seems to be even better (more advantageous) for my case than simply deleting the requirement....

 

[Sifu]

Sifu:
I've done a cursory search online, but probably used the wrong keywords. Where might one access the "guidance" prompting this code change? I would assume it's public record....

Thanks!

The term "guidance" was mine, by it I mean the fact that the '21 code revised the requirements and the code change proposal and significant changes document explains it. When I provided the info to the CBO, I assume he used it as "guidance" upon which he based his opinion.

 

[steveray]

Project Information:

Adopted Building Code: 2018 IBC
Construction Type: IIB (Pre-Engineered Metal Building)
Occupancy Classification: S-1
Number of Stories: 1
Building Area: 8,000 SF (40’x200’)
Fire Protection: Non-Sprinkled
Facility Type/Use: Exterior Access, Self-Storage Facility


Regarding the self-storage facility described above, in order to eliminate the requirement for an automatic sprinkler system, the local code official is requiring firewalls to create separate buildings with areas not exceeding 2,500 SF. This requirement is based on 903.2.9, #5 (added in the 2012 code cycle) which assumes the likelihood that the units will be used to store upholstered furniture and/or mattresses. This applicability to self-storage facilities was confirmed by IFC Interpretation 20-14 (issued on 10/6/2014). Whether or not I think the provision “makes sense”, I do believe the code official’s judgement is in alignment with the intent of the 2018 IBC.

The above said....In the 2021 edition of the IBC, this provision (903.2.9, #5) was removed and the specific provision is still absent from the 2024 edition of the code.

My question is this: Does the code provide a mechanism for the building official to waive a provision of the currently adopted building code when that requirement no longer exists in the more current editions of the code? If so, what is the appropriate course of action I must take to make my case? Could my argument, in any way, fall under the provisions of 104.11 allowing for “Alternative materials, design and methods and equipment”?

Thank you all, in advance for your thoughts on the matter.

- Ryan

Depends on how the jurisdiction is setup but....Generally a newer code or standard can be acceptable.....

[A] 104.10 Modifications​

Modifications, variations, or exemptions from and approval of equivalent or alternative compliance with the requirements of this code shall be in accordance with the provisions of Sections 104.10.1 to 104.10.6, inclusive.