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Interpretations Request Input

Original Request

  • Request ID: 8468
  • Requested By: Bradley Bowman
  • Requester E-Mail: bbowman@finfrock.com
  • Code Version: 2017
  • Code: BUILDING
  • Code Description:
  • Chapter: Chapter 2-Definition
  • Section: 202
  • Topic: Applicability of requirements for means of egress elements for an unoccupied roof.
  • Question: For an unoccupied roof, is it the intent of the FBC to require means of egress related items on the roof such as egress lighting, exit signs and fire alarm pull-stations with horns/strobes outside the stair tower roof access doors (on the roof side), and certain egress widths between walls and rooftop equipment, or between pieces of rooftop equipment? BACKGROUND: We do projects with unoccupied roofs where the roofs contain equipment related to air conditioning, plumbing vent pipes, etc. Often the projects are high-rise, and the rooftop equipment includes pressurization fans for stair shafts and elevator hoistways. Often there is also a life safety related DAS antennae on the roof (for fire dept. enhanced two-way radio communication). The FBC Section 201 definition for a “means of egress” says it’s for egress travel from an “occupied” portion of a building or structure. In my opinion, a roof as described above would not be considered an “occupied” space or area, nor would it be considered an “employee work area” under the ADA. Please refer to the attached code excerpt markup from the 2017 FBC and 2017 FBC – Accessibility codes for reference information.
  • Comment: None
  • Attachment 1: Download

Existing Interpretations and/or Declaratory Statements Related to this request

Is it the intent of FRC 5th edition definition of habitable space to include a Florida Room as a non-habitable room and therefore creating a change of use when a Florida Room is converted into a living room by virtue of removing or not removing the door that leads to the Florida room?
1. Is the definition of ""Substantial Improvement"" applicable throughout the Code or only in the section that specifically uses this term? Chapter 5, Section 505.1 it states ""Level 3 alterations apply where the work area exceeds 50 percent of the aggregate area of the building."" this appears to be different than the definition of substantial improvement. Based on this, can it be stated the 50% threshold is based on aggregate area and not dollars? 2. Additionally, please clarify the definition of ""VALUE"" as it permits replacement cost vs market value indicated within Substantial Improvement definition. Are they interchangeable or both acceptable?
If the ""north"" facing facets comprise more than 25% of the roof area, is it the intent of the Roof Section definition, to require full replacement of the roof even if only the ""north"" facing facets of a roof are damaged in a storm, and the remaining East, West, and South facing facets remain intact and in good condition?
Is it the intent of a. From definition #2, a component or group of components which supports more than 30% of the total area of the structures roof or floor i. Does total refer to the sum of all roof or floor areas throughout the entire structure, or for the roof section as defined by Chapter 2? ii. If a 20x50= 1,000SF one-story building has fire walls which section the building into five, 20 long x 10 wide office spaces, would fire damage to the roof of one office space (20 x 10 = 200 SF) be considered as 20% of the total building area and therefore would not be considered as substantial damage OR would each office space be considered its own roof area, with 100% (>30%) of the roof (200 SF) considered as damaged, and require analysis of if the roof had been reduced per the remainder of the definition? b. From definition #2, the remaining capacity of such affected elements, with respect to all dead and live loads, is less than 75 percent of that required by this code for new buildings of similar structure, purpose and location. i. If the damaged vertical component(s) have been reduced by more than 20% of its predamage condition, is it appropriate to only load Dead and Live load onto the remainder (undamaged) cross-section, and exclude wind, seismic, etc? ii. Is it acceptable for the remainder (undamaged) cross-section to have less capacity than required by the current code Live and Dead load (exclude wind, seismic, etc), as long as it has more than 75% of the required capacity? For instance, a beam with a capacity of 76 k*in is acceptable to resist an applied Moment of 100 k*in.

Input Received:

No.
No. There are other code requirements specific to equipment access.

Answer:

No

Commentary:

None.

Comments on Draft:

looks good
I agree.
I agree.
Correct - No . . .
agreed