Interpretation #7226

Original Request

Code Version: 2010
Code: RESIDENT
Code Description: Residential
Chapter: 1
Section: R101.2 Exception 2
Topic: smoke alarm retrofit

Question

Is it the intent of R101.2 exception 2 to allow a designer to utilize the FEBC in lieu of the provisions of the FRC thereby making the provisions of R314.3.1 not applicable to a repair or alteration that would occur in accordance with the IEBC?

Answer Published 06/13/2014 at 1:51 PM

This seems to be a glitch in the base code.
Looking at the 2009 IRC, these
requirements were carried into the FBC-R
from the base code, with the minor
Florida changes, of course. Looking at
the Existing Buildings Volume, smoke
alarms are addressed at level 2 and
beyond as well as for additions. This
wording in both codes and sections R314
of the Residential as well as 704.4.3
and 1004 of the Existing should be
harmonized and presented as change to
ICC, probably.

Commentary

In the meantime; Chapter 1 of the Florida Building Code requires that we use the Existing Buildings volume for structures that fit the definition of existing. With this in mind, there is no allowance or reference that permits application of R314.3.1 until the FBC-EB volume refers us to it. While it is recommended an attorney be contacted for any legal opinion, the interpretation of the Building Official is the governing decision until a ruling, DEC statement, or interpretation is rendered by the Florida Building Commission on this one. Chapter 1 of the FBC-B states the most stringent rule applies, if the BO desires to apply it in that manner. This is not intended to provide legal advice!