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Interpretation #8683

Original Request

  • Date: September 07, 2022
  • Requested By: David Olivieri
  • Requester E-Mail: dolivieri@universalengineering.com
  • Code Version: 2021
  • Code: BUILDING
  • Code Description:
  • Chapter:
  • Section: 110.8 and 453.25.6
  • Topic: Penetrations of Threshold Buildings

  • Question: Is it the intent of FS 553.79 (5), FBC 453.25.6, and FBC 110.8 to require a threshold inspection plan and a threshold inspector on a bonafide existing threshold building, for a 3/4" electrical conduit penetration or any other similar drilled or cut penetration to an exterior wall for a fire alarm replacement only? Are all exterior envelope penetrations to threshold buildings, no matter how big or small, required to have a threshold inspector?

Answer on 09/07/2022 at 8:09 AM

Based on FS 553.79(5)(a), It depends if the wall being penetrated is considered part of the structural system or is a structurally load bearing component of the building. This will be determined by AHJ at permitting and either require a threshold inspection plan or not.

Commentary:

There is also a declaratory statement, DS 2014-061, which addresses this. A structural alteration to a threshold building must be evaluated on a case-by-case basis by the AHJ. Though a 3/4" hole in a wall might not be considered much of an alteration, drilling through a slab of post-tensioned construction, whether vertical or horizontal, could damage a PT cable, have impacts on fire resistance or pose other implications.