Understanding the Scope of Level 2 Alterations in IEBC Section 801.1

[jar546]

Understanding the Scope of Level 2 Alterations in IEBC Section 801.1

The International Existing Building Code (IEBC) outlines specific requirements for modifications to existing buildings. Section 801.1 focuses on the scope of Level 2 alterations, which involve more significant changes than basic repairs or minor updates. Here's a detailed breakdown to help clarify these requirements.

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General Scope of Level 2 Alterations​

What Are Level 2 Alterations?

Level 2 alterations encompass:

• Reconfiguration of Space:
  
  • Changing the layout of interior spaces, such as moving walls or altering room sizes.
  • Modifying the use of spaces within the building (e.g., converting office space into a conference room).
• Changes Beyond Level 1 Alterations:
  
  • Any work that exceeds simple repairs or replacements covered under Level 1.
  • Involves modifications that can affect the building's structural integrity, safety systems, or accessibility.

Compliance Requirement:

• Chapter 8 Compliance:
  • All Level 2 alterations must comply with the provisions outlined in Chapter 8 of the IEBC.
  • This includes specific requirements related to fire protection, means of egress, accessibility, structural systems, and more.

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Exception for Accessibility-Driven Reconfigurations​

Understanding the Exception:

• Accessibility Improvements:
  • If the only reason for reconfiguring spaces is to comply with accessibility requirements, this exception applies.
  • Specifically refers to compliance with Section 306.7.1, which addresses accessibility standards.

Permitted Compliance with Chapter 7:

• Simplified Requirements:
  • Buildings undergoing reconfiguration solely for accessibility can comply with Chapter 7 instead of Chapter 8.
  • Chapter 7 covers Level 1 alterations, which have less stringent requirements compared to Level 2.

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Detailed Explanation​

1. Encouraging Accessibility Upgrades:
   
   • Lowering Barriers:
     • By allowing accessibility-focused alterations to comply with Chapter 7, the code encourages building owners to make necessary upgrades without facing the more rigorous demands of Level 2 alterations.
   • Benefits:
     • Simplifies the process and reduces potential costs associated with complying with higher-level alteration requirements.
     • Promotes wider adoption of accessibility features, enhancing inclusivity.
2. Impact on Compliance Levels:
   
   • Avoiding Unnecessary Upgrades:
     • Buildings making accessibility improvements won't trigger additional requirements that come with Level 2 alterations.
   • Focus on Safety and Accessibility:
     • Ensures that the primary goal of improving accessibility isn't burdened by unrelated code compliance issues.
3. Examples of Applicable Alterations:
   
   • Installing Ramps or Elevators:
     • Adding these features to improve access for individuals with disabilities.
   • Widening Doorways or Corridors:
     • Modifying spaces to accommodate wheelchairs or other mobility devices.
   • Adjusting Restroom Facilities:
     • Reconfiguring restrooms to meet accessibility standards.

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Key Considerations​

• Work Area Definition:
  
  • In Level 2 alterations, the work area refers to portions of the building affected by reconfiguration.
  • Not all Level 2 alterations will have a defined work area if the changes don't involve spatial modifications.
• Importance of Compliance:
  
  • Safety and Legal Obligations:
    • Adhering to the correct alteration level ensures compliance with safety codes and legal requirements.
  • Avoiding Unintended Consequences:
    • Misclassifying alterations can lead to unnecessary costs or failure to meet essential safety standards.
• Planning Ahead:
  
  • Consult Professionals:
    • Engage with architects, engineers, or code consultants early in the planning process.
  • Permitting Process:
    • Understanding the scope of alterations helps streamline permit applications and approvals.

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TBCF Summary​

IEBC Section 801.1 outlines that any significant reconfiguration of space in existing buildings falls under Level 2 alterations, requiring compliance with Chapter 8 provisions. However, there's a crucial exception for alterations made exclusively to improve accessibility per Section 306.7.1. In such cases, building owners are allowed to comply with the less stringent requirements of Chapter 7, as if performing Level 1 alterations.

This exception serves to promote accessibility enhancements by reducing regulatory burdens, thereby encouraging building owners to make necessary changes that benefit all users without facing the complexities of higher-level compliance.

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Final Thoughts

Understanding the scope and requirements of Level 2 alterations is essential for anyone involved in modifying existing buildings. By recognizing the exceptions and planning accordingly, building owners and professionals can ensure that their projects comply with the IEBC while also promoting accessibility and safety.

 

[Yankee Chronicler]

Working in a town whose history goes back to before the American Revolution, we see a LOT of projects involving existing buildings, and we have found that architects have NO idea how to use the Existing Building Code. For starters, the IEBC says the applicant has to tell the code official if they are using the Prescriptive Method, the Work Area Method (which is the only time Level 1, Level 2, or Level 3 applies), or the Performance method. When we ask them to tell us, so we'll know what part of the code to review under, they still can't get it right. I looked at a resubmittal this morning. The architect declared that they are using the Prescriptive Method, and that it's a Level 2 alteration.

:bang head:

What usually happens is the architect calls up and asks what we want them to call it. We tell them we can't make that decision for them. They have to decide which method they want to follow, and then they have to follow THAT method. Somewhere in the IEBC it says you can't mix provisions from different methods.

 

[bill1952]

Cynicism ahead. It certainly has helped the code consulting business grow. It's one of those things that make sense to a lot of experts in the room. Not sure as much sense when it's imposed on the masses.

 

[Sifu]

Working in a town whose history goes back to before the American Revolution, we see a LOT of projects involving existing buildings, and we have found that architects have NO idea how to use the Existing Building Code. For starters, the IEBC says the applicant has to tell the code official if they are using the Prescriptive Method, the Work Area Method (which is the only time Level 1, Level 2, or Level 3 applies), or the Performance method. When we ask them to tell us, so we'll know what part of the code to review under, they still can't get it right. I looked at a resubmittal this morning. The architect declared that they are using the Prescriptive Method, and that it's a Level 2 alteration.

:bang head:

What usually happens is the architect calls up and asks what we want them to call it. We tell them we can't make that decision for them. They have to decide which method they want to follow, and then they have to follow THAT method. Somewhere in the IEBC it says you can't mix provisions from different methods.

Can't agree more! To be frank, several years ago I decided that maybe I didn't know enough about how to use it either (and to be franker...maybe still don't) so I hammered down on it. It took hours, maybe even days to get enough of a handle on it that I could at least speak intelligently on it. Whole hours and days! At one point in my early IEBC journey I recall asking the question about who decides the pathway to compliance. It took minutes.....whole minutes, to find that answer for myself. I am certainly no expert in the IEBC, but I am continually amazed that it is not well used...or used at all.

 

[Yankee Chronicler]

One reason we don't see it used more here is that we had a State Building Inspector who for the entire ten years he was in office told everyone that he hated the IEBC and he couldn't understand why anyone would use it. He was an architect and an AIA member, so the architects listened to him. He retired years ago, but the effect lingers on.

The other aspect is that applying the IEBC requires reading it. In this golden age of sound bytes, nobody has time to read anything. Architects just want to get the commission, throw together something that looks sort of like a design, and they think they're done. Most of the time, what they provide as construction documents aren't any better than what we considered schematic design drawings when I was working as an architect.

As a licensed architect, I think the profession is engaged in a race to the bottom. It's like a competition to see who can provide the least amount of work and still get a building permit. When we reject their drawings and ask that they actually provide the minimum information required by the code, they scream and holler (and then complain to the mayor's office).

 

[Mr. Inspector]

Had a 3 story R2 building where they did a level 2 on each floor one at the time. If they did it all at once it would have been a level 3. I am still not sure if this was right.

I never once had an architect tell me what method they are using on my first plan review for an existing building. But it made the first plan review easy just to fail it for not stating the method they are using. We charge for each plan review.

 

[Yankee Chronicler]

Had a 3 story R2 building where they did a level 2 on each floor one at the time. If they did it all at once it would have been a level 3. I am still not sure if this was right.

I never once had an architect tell me what method they are using on my first plan review for an existing building. But it made the first plan review easy just to fail it for not stating the method they are using. We charge for each plan review.

I've been advocating for that since I started with the current department. The town administration doesn't want to hear it. The town manager literally asked why we do plan reviews. He thinks we should just rubber stamp the plans, issue the permits, and iron out any issues in the field.

 

[Sifu]

No AHJ for which I have worked charges for resubmittals based on the initial review. Theoretically, and maybe somewhere in the distant past, the resubmittals should be quick and easy. That is often not the case now. A lot of times the plans that we receive at first submittal are just a first edition, not much better than a a rough draft, which get revised way beyond the comments that are made and require new reviews. They are rushed in to meet some service level promised by the DP and are "just to get a permit started". Most AHJ's have an additional plan review fee for problem children but all heck breaks loose if we try to go down that road, and beyond the idea that it might encourage better plans up front, it has no impact. And it doesn't encourage better plans anyway. Apparently neither does a crap-ton of comments.

 

[jar546]

No AHJ for which I have worked charges for resubmittals based on the initial review. Theoretically, and maybe somewhere in the distant past, the resubmittals should be quick and easy. That is often not the case now. A lot of times the plans that we receive at first submittal are just a first edition, not much better than a a rough draft, which get revised way beyond the comments that are made and require new reviews. They are rushed in to meet some service level promised by the DP and are "just to get a permit started". Most AHJ's have an additional plan review fee for problem children but all heck breaks loose if we try to go down that road, and beyond the idea that it might encourage better plans up front, it has no impact. And it doesn't encourage better plans anyway. Apparently neither does a crap-ton of comments.

Long before I got there, the governing body approved a $50 per page re-review fee, which covers not just revisions but resubmission of initial plan reviews if necessary. In addition, many revisions are items that increase the valuation of the job, which also gets charged as it should.

 

[Sifu]

Long before I got there, the governing body approved a $50 per page re-review fee, which covers not just revisions but resubmission of initial plan reviews if necessary. In addition, many revisions are items that increase the valuation of the job, which also gets charged as it should.

Did it do anything to cut down on the amount of revisions, or improve the quality of submittals? I have found that most re-fees (inspections or reviews) are not significant enough to make any difference to anyone. The only thing I see that has any impact is time, but any more that has less of an impact because they just keep rolling, playing dumb or asking for forgiveness instead or approval (which is usually given to some extent) when they proceed with construction beyond which their reviews or inspection would allow.

For kicks, I looked at average cost to get a permit in one AHJ a last week (all fees, not just building). An average SFD, below the median price, was about 50k. An 8-unit R2, 180k, small commercial new build 120k. A few hundred in re-fees has little impact on that. Fees are ridiculous IMO, but that is a whole 'nother topic.

 

[jar546]

Did it do anything to cut down on the amount of revisions, or improve the quality of submittals? I have found that most re-fees (inspections or reviews) are not significant enough to make any difference to anyone. The only thing I see that has any impact is time, but any more that has less of an impact because they just keep rolling, playing dumb or asking for forgiveness instead or approval (which is usually given to some extent) when they proceed with construction beyond which their reviews or inspection would allow.

For kicks, I looked at average cost to get a permit in one AHJ a last week (all fees, not just building). An average SFD, below the median price, was about 50k. An 8-unit R2, 180k, small commercial new build 120k. A few hundred in re-fees has little impact on that. Fees are ridiculous IMO, but that is a whole 'nother topic.

It generates more revenue, which allows us to justify staffing levels. Does it deter screwed-up plans? No, not until we start charging them when they still can't address comments on the second try. The third submission for a new permit gets charged. Then, all of a sudden, the corrections are made.

 

[Mr. Inspector]

Yes, I think it has cut down on the number of revisions and has improve the quality of submittals from local architects that I have dealt with before. But I really don't care if it does or not. It does not change my workload, I still will work 8 hours a day, but it might make more money for my inspection company.
We charge per the ICC recommendations, second review is free, after that each review is half price.

 

[Yankee Chronicler]

No AHJ for which I have worked charges for resubmittals based on the initial review. Theoretically, and maybe somewhere in the distant past, the resubmittals should be quick and easy. That is often not the case now. A lot of times the plans that we receive at first submittal are just a first edition, not much better than a a rough draft, which get revised way beyond the comments that are made and require new reviews. They are rushed in to meet some service level promised by the DP and are "just to get a permit started". Most AHJ's have an additional plan review fee for problem children but all heck breaks loose if we try to go down that road, and beyond the idea that it might encourage better plans up front, it has no impact. And it doesn't encourage better plans anyway. Apparently neither does a crap-ton of comments.

As I have commented in other threads, the quality of construction documents" today makes me ashamed to admit that 'm an architect. What we see submitted as "construction documents" usually barely qualify as what used to be considered schematic design drawings when I was working as an architect. My plan review letters always include a notice that we can't promise to find every problem, so the design professionals should conduct a review before resubmitting. They never do, of course. They use our comments as a checklist, respond to between 50% and 75% of the comments, and get all butt hurt when we reject the resubmittal.

 

[Sifu]

As I have commented in other threads, the quality of construction documents" today makes me ashamed to admit that 'm an architect. What we see submitted as "construction documents" usually barely qualify as what used to be considered schematic design drawings when I was working as an architect. My plan review letters always include a notice that we can't promise to find every problem, so the design professionals should conduct a review before resubmitting. They never do, of course. They use our comments as a checklist, respond to between 50% and 75% of the comments, and get all butt hurt when we reject the resubmittal.

Currently 200 pages into Fountainhead by Ayn Rand. Written I believe in the 40's, it is fascinating. For those that don't know, it is about....ARCHITECTS. It may be a throwback to how things used to work, or maybe just fiction. I have read other books by her, and I love the writing, and the relevance, even though they were written in another age. NOT saying you were an architect in the 40's, but maybe understand the desire to become one. I had that desire 30 plus years ago, accepted into PSU school of architecture but somehow never found the time or money to go. Is this gig close enough?

 

[Yankee Chronicler]

Yes, I think it has cut down on the number of revisions and has improve the quality of submittals from local architects that I have dealt with before. But I really don't care if it does or not. It does not change my workload, I still will work 8 hours a day, but it might make more money for my inspection company.
We charge per the ICC recommendations, second review is free, after that each review is half price.

What ICC recommendations?

 

[Mr. Inspector]

What ICC recommendations?that

I don't know where my boss got it. But years ago, I remember I saw a list of recemented fees from the ICC.

 

[Yankee Chronicler]

I don't know where my boss got it. But years ago, I remember I saw a list of recemented fees from the ICC.

Hmmm ...

I still think I remember a BOCA book on building department management that spelled out how to determine what a department's staffing level should be. This would have been around 1995 or so. This in formation is not included in the newer ICC book. I have spoken with multiple people at the ICC to see if anyone has a copy of the book from which they can scan that chapter for me, and nobody (not even some of the old-timers who came from BOCA) remembers such a book. Maybe I imagined it, but I don't think so.

Basically, the fees are supposed to be enough to fund the operations of the department. [In theory]

 

[TheCommish]

I remember somewhere that the standard for the industry was the fees should be able to sustain the department 80% of the time over a 5-year period

 

[Yankee Chronicler]

In my state, too many municipalities look at building permit fees as a cash cow for the general fund. For fiscal year 2022-2023, in round numbers our department generated $1.5 million in permit fees, and the administration gave us $0.5 million of that for the department budget. I'm not a lawyer, but I'm pretty certain that would be found illegal is someone were to challenge it in court. The worst part is that, despite all that "excess" income, they won't let us add another full-time ABO/inspector.