Code Cadre Wins 22-7

The review of the 2012 International Code Council’s family of codes has been completed.  The public hearing and administrative adjustments are all that remain between now and the anticipated implementation this fall.  Below is a summary of the proposals presented by the VSAIA Code Cadre, once again led by Kenney Payne, AIA, and supported by Jim Snowa, AIA, and Megan Shope, AIA.

VSAIA submitted:

Approved (17):

Accessory occupancies are no longer limited by their tabular height value in Table 503

• Accessory areas may now be located on upper floors, if allowed for the main occupancy
• Previously, the height was restricted  (e.g., I-3 could not be located on 3^rd floor or higher under Type 2B construction)

CO sensors will utilize the 2012 IBC language (deleted the language used in the 2009 USBC)

Combustible decorative material exceptions clarified and added[adrotate banner=”52″]

• Technically, the code did not allow any decorative combustible materials to be hung from above – it had to be applied to walls
• An exception was added that now allows such to be suspended from the ceiling

Evacuation plans (under the 2012 IBC) would have become part of the building code

• This requirement was deleted from the IBC and remains in the SFPC

Existing structural elements carrying gravity loads can now comply with IEBC

• Under the 2009 USBC/IBC, if there were any changes to the gravity loading, it could be interpreted that the entire existing building would have to conform with the IBC
• This code change clarifies that such loading would have to increase by more than 5% before affecting the existing building

Clarified that showers required on the pool deck were to be accessible hand-held spray types, and not transfer or roll-in types (as part of the ISPSC – refer below)

Lavatories are now allowed to be located within the classroom, if it meets certain criteria

• Before, a lavatory had to be located in the toilet room, even if the adjacent classroom had a lavatory
• This exception now allows you to omit the lav in the toilet room and use the one in the classroom

You no longer have to provide a Type I or II hood over electric domestic cooking appliances if they are used for domestic purposes – you can just provide a domestic-type hood

• Previously, some jurisdictions were requiring Type I or II hoods over a residential cooktop simply because it was located in a “commercial” building
• The owner must still demonstrate that the cooking appliances will be used for domestic purposes
• A church cannot say it is for domestic purposes if they intend to hold congregation functions where they feed 300 people every weekend or so

Fire-resistance assembly markings (the ratings that get painted on rated walls above the ceiling)

• Clarified locations and deleted outdated terminology

Order of precedence

• Reformatted so it would be easier to follow (use to be a run-on paragraph)
•  Deleted the term “conflicting” and clarified these would apply when you have “differing requirements”

Tenable environment and windowless buildings

• Provided a definition for “tenable environment”
• Rewrote the “windowless buildings” in its entirety and tied it to smoke control, which was its original intent
  * Should be easier to design I-3 spaces
  * Identifies those spaces requiring such smoke control
  – This prevents building officials from requiring smoke control in an office or a corridor simply because they are located in an I-3 facility

Short-term holding areas

• We created a new definition for “short-term holding areas” and added a new Section to avoid confusion with I-3 occupancies
• This includes those small lock-ups located between courtrooms, or in an airport, stadium, police station, shopping malls, etc.
• Currently, if defined as I-3, it would kick in all of the other I-3 requirements
• This code change does include some I-3 requirements, but should allow for greater flexibility in your designs

Delayed egress locks

• Clarified the intent by adding an exception (currently, there is an exception within the charging paragraph which makes interpretation difficult)

Air barriers

• Air barriers will be a requirement for the building envelope; however, it was included in the IECC and ASHRAE 90.1
• Our code change placed a “bookmark” in the IBC so architects do not miss something so critical because it was not located in the building code

Water-resistive barriers

• Deleted in its entirety
• If left in, all exterior wall assemblies (meeting the criteria) would have had to be tested per NFPA 285

Metal composite materials and NFPA 285

• Added a sprinkler exception (no NFPA 285 or full-scale testing required if your building is fully sprinkled)
• Also clarified additional NFPA 285 testing is not required for additional wall assemblies if the other changes are in non-combustible materials or combustible materials already allowed by the building code

Exterior wall assemblies and NFPA 285

• Added a sprinkler exception (no NFPA 285 or full-scale testing required if your building is fully sprinkled)
• Also clarified additional NFPA 285 testing is not required for additional wall assemblies if the other changes are in non-combustible materials or combustible materials already allowed by the building code

Denied (6):

Switch from Chapter 11 and ICC A117.1 to ADAAG 2004 as the accessibility requirements

• Building officials would not support
• Note the referenced regulation was 2004 ADAAG – not 2010 ADA Standards which includes other documents, nor was it requiring compliance with the ADA, which is a civil law
• We are not attorneys and cannot ensure our design meet ADA – we can design to meet ADAAG

The hope was that architects would only have to design to one standard – 2004 ADAAG – not three (Chapter 11 of the IBC, A117.1, and 2004 ADAAG)

Penetrations into interior stairways

• Tried to add exception allowing primary and secondary structural members
• Currently, it can be (and has been) interpreted that no structure (beam, joist, deck) can penetrate an interior stairway

Required a preliminary meeting to discuss need for fire apparatus access road requirements with fire official during design (similar to what is required for using the IEBC)

• Fire officials were against
• Currently, they do not have to comment on the requirements, or even the need for such a road, until you submit for a building permit – by then it is too late
• We were trying to codify a meeting  -during design – so we have the ability to make changes without incurring potential delays and/or change orders

In-building emergency communications coverage

• Tried to clarify some requirements (e.g., limit it to just empty conduit), add exceptions, add design and technical criteria (so we know what to design), add a preliminary meeting (so we know what the jurisdiction is going to need)
• Unless you meet the exceptions, our design must include radiating cable
• Oftentimes, coverage requirements are determined after completion of the facility – it is then too late to effect changes without incurring change orders – to which owners typically turn to the A/E to collect

Portable toilets

• Tried to allow porta-potties to be used for larger outdoor sporting events for ‘E’ uses only – to avoid providing hundreds (exaggeration) of toilets that might be used 6 times a year

NFPA 45 as an option to control areas

• Control areas limit the number of labs on upper floors – due to the limitations on the quantities allowed as buildings increase in height
• At the request of the fire officials and a number of universities, the VSAIA submitted a code change that used NFPA 45 as the template to develop a code change that would allow an alternative to control areas
• This alternative would allow greater quantities on upper floors as well as reduced fire ratings
• It should offer greater flexibility for al buildings with labs – including schools
• We first submitted as a separate code section – when that did not pass, we resubmitted as an appendix
• That did not work either
• However, it got a lot of discussion by the Codes and Standards Committee and Board of Housing and Community Development
• Many saw the benefit, but were not ready to jump in with both feet – and the fact that it was introduced late and did not go through the two-year vetting process hurt our chances
• It will be part of the agenda for the 2015 code cycle

VSAIA supported:

Approved (3): There were many – we have outlined a few here

International Swimming Pool and Spa Code (ISPSC)

• Swimming pools and spas are now regulated by the ISPSC rather than referenced standards, appendices, state amendment, or other document
• This should make it easier to design and for building officials to enforce

Delete Chapter 34 and substitute IEBC

• The ICC is going to delete Chapter 34 in the 2015 model code, so we went ahead and did it now

Increased the width of some doors in a residence to allow for 32” clear (increased accessibility)

• The National Homebuilders Association was also supportive of this code change

Denied (1):

Increased accessible parking at medical facilities

• Added types of facilities to the “list” that currently require more parking spaces (which is also required by ADAAG), as well as, two exceptions (those operating out of their home and tenant-type office buildings where you did not know who would be in it)

VSAIA opposed:  There were many – we have outlined a few here.

Denied (2): VSAIA wanted them to be denied

Restriping of existing parking lots

• We were original co-sponsors (along with accessibility advocacy groups); however, the VBCOA (building officials) started adding a number of exceptions and language which we believed could conflict with the ADA and ADAAG – so we withdrew our support and worked against its approval
• We did not believe Virginia architects should be required to design something that meets the building code, but may not meet the civil law (ADA)
• Exceeding ADAAG requirements are one thing, but conflicting requirements are something else
• The accessibility advocacy groups also withdrew their support when we withdrew our support for the same reasons

International Wildland-Urban Interface Code (IWUIC)

• Fire officials wanted to include this without any vetting
• We opposed because there was no vetting through the work groups

VSAIA submitted and then withdrew (3): We tried to “pick our battles” and did not push a difficult position unless we felt the code change was far-reaching (such as the accessibility code change proposal)

Tried to add an actual date (1973) to the definition of an “existing building”

• Currently, it states, “built prior to the initial edition of the USBC.”
• We wanted it to read, “built prior to the 1973  USBC.”  That way, you would not have to ask what year was the initial edition
• Apparently, building officials could not understand there is only one “initial”

Tried to submit an exception where stairways that are not used as an exit or provide access to an exit do not need to comply with various means of egress stair requirements (e.g., interior exit stairways and exit access stairways)

•  Building officials believe all stairways must comply – there is no such thing as a stairway that is not a part of the means of egress

Tried to get small storage rooms (100 SF or less) reclassified as “incidental uses”

• Confusion has crept up with regards to small “closets” – are we supposed to classify them as an S-1 or S-2?
• This could create unintended consequences (e.g., mixed uses, occupancy that cannot go on an upper floor)

All-in-all, I would say we had a very successful code change cycle (22 positive results and 7 negative results) and should:

• Allow architects greater flexibility in their designs
• Clarify the code to avoid misinterpretations or conflicting interpretations
• Save our clients money (e.g., NFPA 285 testing which can run as high as $40,000 per test per assembly).