INTERNATIONAL BUILDING CODE – FIRE SAFETY FS2-06/07 701.2 (New) Proposed Change as Submitted: Proponent: Bill McHugh, Firestop Contractors International Association Add new text as follows: 701.2 Modifications. No person shall remove or modify any fire-resistance-rated construction, compartmentation and structural fire resistance systems installed or maintained under the provisions of this code or the International Fire Code without approval by the building official Reason: The purpose of this code change is to give the building official an additional enforcement tool for the provisions of Chapter 7, which are now very important in buildings where it is used. Fire-resistance-rated construction, compartmentation and structural fire protection systems are critical fire and life safety items in buildings. There is no reference to the building official required involvement in removal of this critical protection in buildings. Building alterations take place during the life cycle of the building. This brings the building official into the communications when changes are made to compartmentation and structural protection, consistent with other sections of this code. Cost Impact: The code change proposal will not increase the cost of construction. Committee Action: Disapproved Committee Reason: This is an operation and maintenance issue which does not belong in a code which is intended for new construction. The IFC currently contains provisions which adequately address this issue and is the primary document for maintenance. The proposal would create a conflict with Section 3401 which permits the assembly to be maintained in accordance with the code under which it was installed. The provision is therefore not clear how it would affect Chapter 34 or the IEBC provisions. The term Astructural fire resistance systems@ is unclear. Assembly Action: None Individual Consideration Agenda This item is on the agenda for individual consideration because a public comment was submitted. Public Comment: Bill McHugh, Firestop Contractors International Association, requests Approval as Modified by this public comment. Modify proposal as follows: 701.2 Modifications. No person shall remove or decrease the fire resistance rating of modify any fire-resistance-rated construction, compartmentation and structural fire resistance systems installed or maintained under the provisions of this code or the International Fire Code without approval by the building official. Commenter=s Reason: For consistency in the code between the sprinklers, detection and alarms, and fire and smoke resistance rated compartmentation systems, it is important to approve this public comment. Effective fire and smoke resistance rated compartmentation systems should be given the same level of attention in the code as fire sprinklers, detection and alarm systems, as already exists currently in the building code in Chapter 9, Section 901.3. Properly designed, installed, inspected and maintained fire and smoke resistance rated compartmentation systems limits fire spread to the room of origin using compartmentation systems. Additionally, effective compartmentation, when operating in failure mode has some degree of protection for occupants in the building…albeit compromised. Nonetheless, there is some protection against fire spread restricting the speed of travel of fire, and oxygen loads needed for combustion. Where required by code, compartmentation needs to be properly designed, installed, inspected and maintained for effectiveness when called upon to protect people in buildings. Final Action: AS AM AMPC D 2007 ICC FINAL ACTION AGENDA 451 FS7-06/07 702.1 (IFC 902.1) Proposed Change as Submitted: Proponent: Greg Rogers, Kitsap Fire District 7, representing ICC Joint Fire Service Review Committee Revise definition as follows: FIRE AREA. The aggregate floor area enclosed and bounded by fire walls, fire barriers, exterior walls or fire- resistance-rated horizontal assemblies of a building. Areas of the building not provided with surrounding walls shall be included in the fire area if such areas are included within the horizontal projection of the roof or floor above. Reason: Sprinkler and fire alarm requirements in Chapter 9 of the IBC and IFC are based on the square footage or occupant load of a fire area. It is not clear from the definition of a fire area that building areas without surrounding walls are included in the fire area. This concept is clear in the definition of building area found in IBC 502.1, “Areas of the building not provided with surrounding walls shall be included in the building area if such areas are included within the horizontal projection of the roof or floor above”. This was confirmed by IFC Interpretation No. 25-05, dated 09-12-05. Cost Impact: The code change proposal will not increase the cost of construction. Committee Action: Disapproved Committee Reason: Although this issue is not clear in the existing code, placing this requirement within the definition is not the best solution and may be overlooked. The testimony discussed items such as picnic shelters, flea-markets and other items which don=t have walls around them that would be affected by this requirement and now need sprinklers or alarms due to exceeding the fire area. Another example given was a canopy which was 44 feet tall and open on all sides. Items which are open and unenclosed do not create the same fire hazard and should not be regulated by the same requirements that apply to enclosed buildings. Assembly Action: Approved as Submitted Individual Consideration Agenda This item is on the agenda for individual consideration because an assembly action was successful and public comments were submitted. Public Comment 1: Edmund Domian, West Valley City, Utah, requests Approval as Submitted. Commenter=s Reason: The real issue of this code change is not what meets the definition of “building” but what warrants a need for compartmentation. Many big box warehouse-type stores have a large attached open yard of combustible products for sale, which often meet the definition of high piled combustible storage. This “open yard” has a metal or fabric canopy overhead; the public are trapped in this area within a fenced perimeter. The fire load in these “open yards” can be substantial. Occupants must often re-enter the main building from this enclosed “open yard” to egress the building in an emergency. Such areas should be included in the calculations of any defined “FIRE AREA.” Public Comment 2: George Mann, representing the Code Administrators Association of Kentucky, requests Disapproval. Commenter=s Reason: Code Change FS06/07 should be denied for any one of several reasons. First and foremost, the proponent supports his position based on an interpretation issued on Sept 12, 2005; International Fire Code Interpretation #25-05 based on Section 903.2.1 of the 2003 International Fire Code. I believe this interpretation is flawed and totally inaccurate based on the printed definition of FIRE AREA. The question asked in the interpretation was: “Do the automatic sprinkler requirements in Section 903.2.1, based on the fire area of occupancy apply to buildings without surrounding exterior walls?” The answer was “Yes. The entire area of a single floor of a building or structure must be considered when determining the automatic sprinkler requirements based on fire area… Where no surrounding exterior walls are provided along the perimeter of a building, the building area is used to identify and determine applicable fire areas. Section 502.1 f the International Building Code defines BUILDING AREA as: The area included within surrounding exterior wall (or exterior walls and fire walls) exclusive of vent shafts and courts. Areas of the building not provided with surrounding walls shall be included in the building are if such areas are included within the horizontal projection of the roof or floor above” The definition of FIRE AREA in both the Fire Code and Building Code reads: “The aggregate floor area enclosed and bounded by fire walls, fire barriers, exterior walls or fire-resistance-rated horizontal assemblies of a building.” 452 2007 ICC FINAL ACTION AGENDA I ask, how does the interpretations committee arrive at the conclusion that the building area is to be used to determine the fire area if the building has no exterior walls. The definition of fire area specifically states that a fire area has to be enclosed and bounded by exterior walls. This is where I believe the interpretation is flawed and in error. The interpretation makes statements of fact that do not exist. No where in the definition of fire area does it speak to using the building area or definition of building area to determine sprinkler requirements. The definition of building area and fire area are not interchangeable. If they were meant to be then Chapter 9 would base sprinkler systems on building area bounded by fire barriers or fire walls. No where in Section 903 does it read that a sprinkler system shall be provided when the building area exceeds a specified threshold. Again, we are supposed to determine fire area based on the area of the building enclosed and bounded by exterior walls, fire wall, fire barriers or fire-resistance-rated horizontal assemblies. Therefore, if we are looking at a building without exterior walls (column and roof only) we have no fire area and never have. This proposed change is attempting to merge 2 totally different definitions into one definition. Second flaw with this proposed code change is in the application of the definition if approved. It reads that “areas not provided with surrounding walls shall be included in the fire area if such areas are included within the horizontal projection of the roof or floor above”. I read this as meaning that the area under the store front canopy, a roofed over area across the front of a retail establishment and the canopy over a loading / unloading dock would all have to be added to the area calculated within the exterior walls in order to determine sprinkler requirements.