it depends

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Building code issues (wait – don’t stop reading – please)…now, I was saying, they are not my favorite subject to tackle, but I find that being conversant in them as well as navigating through them efficiently and thoroughly has brought me more work than my better ability to choose colors or develop beautiful details – ok, the jury is still out on that. Buckle up because we’re going to talk about them today.

For the record, I would rather pick paint colors or fuss with turning a corner or even stress over the intersection of two materials.

Nevertheless, when asked questions about building codes – as they apply to a person’s specific project, like clockwork I will generally answer “it depends.” Why is that? Why must we frustrate people by giving a seemingly evasive answer? Trust me, it is because many code issues, especially with existing buildings, cannot be answered decisively outside of the immediate context without the opportunity to evaluate all the parameters. Therefore, without seeing your project in person and studying a set of drawings of it, my answer will generally be “it depends.” I’m sorry, that’s just how it is; don’t hate architects because of that.

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Here is one example that comes up quite frequently. Perhaps this helps justify why architects respond as they do.

Q: “Does this building need an automatic sprinkler system?”
A: My answer – “it depends.”


In this case, we are talking about an EXISTING building so the answer for new construction might be different and easier to determine.

  1. Does the building have a Certificate of Occupancy? – We must start here, and this question deserves a post of its own (oh wait, I already did that). For now, just take my word for it that this is a very important question.
  2. What method of compliance is being used? – The IEBC (existing building code) allows multiple methods of seeking compliance – Prescriptive Compliance Method, Work Area Method and the Performance Compliance Method. There’s no room to explain all of this, other than to explain that existing buildings can be considered in multiple ways depending on the amount and type of work being proposed and especially depending on the answer to the previous question. For the record, I prefer the latter method.
  3. What is the building Use? – Is it an office or a church; is it an apartment or a retail store? Perhaps a more important question is whether it is a single use or has multiple uses (mixed use). Some building uses always require an automatic sprinkler system (in new construction); some require it when the building size or area is over a given size, height or number of stories. Sometimes an automatic sprinkler system is required when the occupancy (calculated number of people who are in the building at any given time) is over a given amount. I’m sensing your eyes have glossed over by now.
  4. What is the type of construction? – Is it all wood or is it all concrete? Are the exterior walls solid masonry and are the floor and roof framing all wood? When this isn’t readily apparent, I keep a hammer in my car to…you know…determine how it’s made.
  5. What is the area per floor and how many stories are there? – The code limits the height and area of buildings based on the use and based on the type of construction. An automatic sprinkler system can permit the building to be taller and larger when limited otherwise.
  6. Is it required by other sections – Some safety features are required for buildings as a rule; however, exceptions may exempt them when an automatic sprinkler system is included. This is complicated, and the list is endless. We will give an example below.

Let’s look at an example of how this might look for one specific instance (hint…this was an actual project that remains unbuilt). I’m using the 2009 IBC, currently in effect in Pennsylvania – that is until a week from Monday – 01 October 2018. Then it will be the 2015 version.

  • Existing building – no current automatic sprinkler system
  • No known Certificate of Occupancy.
  • Three stories and a basement
  • 4,000 square feet per floor
  • Type 3B construction (masonry, non-combustible walls + wood, combustible floor, and roof framing)
  • Two means of egress (two stairs – one in front, one in back)
  • Proposed use(s) – first floor retail (M), upper floors apartment units (R2).
  • The initial plan is to renovate the upper floors with the first floor intended for later renovation under a separate permit.

This is an approach to determine if an automatic sprinkler system is required (I’m not addressing other issues like fire separation ratings, accessibility or really anything else, so don’t make shortsighted comments below).

  1. No Certificate of Occupancy – Under the Uniform Construction Code of Pennsylvania, a C of O may be issued if the building meets the requirements of the IEBC (International Existing Building Code). An architect will evaluate this based on a method above. Without further explanation, I prefer to use the Performance Compliance Method as this is an objective scoring system. If we can demonstrate that the building features (existing and proposed) meet or exceed the requirements, thus exceed the minimum safety score, then the building official can issue a C of O.
  2. Fire Protection Systems – Under Chapter 9 of the IBC 2009, Section 903.2.8 requires this system for all Residential Uses. Game over, right? No, for an existing building using the Compliance Alternative Calculation, it may be possible to exempt this if enough points can be calculated through other categories and other safety features. I have had several small renovation projects where a sprinkler was required by the Use, but we were able to exempt the building by overcoming the negative points taken (smoke and mirrors). That may sound cryptic, but fortunately, I explained it in an earlier post. In other words, it still depends.
  3. Height and Area – Table 503 lists that for a Type R-2 use (apartments), a building may be 4 stories and 16,000 square feet per floor and 55’ tall. Therefore, in this case, an automatic sprinkler system isn’t required to meet the height and area limitations.
  4. Means of Egress – Emergency Escape and Rescue – Section 1029 requires that “[in] addition to the means of egress required by this chapter, provisions shall be made for emergency escape and rescue in Group R and I-1 occupancies. Basements and sleeping rooms below the fourth story above grade plane shall have at least one exterior emergency escape and rescue opening in accordance with this section.” This means that at least one window over a given size per sleeping room must be present that leads to a public way. In our hypothetical case, we can include a large enough window in each bedroom, but once out of the window, one would find themselves on the roof of an adjacent building – which does not lead to a public way. Uh-oh, this is a problem. Regardless of the answers to the questions above, there are no provisions to exempt the required means of egress provisions. Fortunately, there are exceptions and we can claim the first one. “Exceptions: In other than Group R-3 occupancies, buildings equipped throughout with an approved automatic sprinkler system in accordance with Section 903.3.1.1 or 903.3.1.2.”

Therefore, under the conditions above, an automatic sprinkler system is required since the provisions of Emergency Escape and Rescue cannot be fully satisfied otherwise. The only way to be exempt from this requirement is to have an automatic sprinkler system. If the building owner didn’t want to install the sprinkler system, then they could not have the R-2 apartment use. They’d have to consider an alternative use and turn the crank again to see if it works.

Hopefully, this helps one see the process we use and the questions that we must answer before we can give a definitive answer. The bad news is your building is likely different than my hypothetical example above, so if you ask me the question “do I need an automatic sprinkler system.” That’s right – you know the answer.

It depends.

it depends

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