32A-124 130430-CodeAnalysis-Cutler (1)Bruce,
Your request for continued review reminded me of the provisions of IBC-09 Section 1002.3 concerning fire protection in additions to
existing buildings. In my previous memorandum, I had not reviewed the applicability of that section as part of the Existing Building
Code of Massachusetts because the MA amendments of the IEBC delete Section 1002.3. That section states:
1002.3 Fire protection systems. Existing fire areas increased
by the addition shall comply with Chapter 9 of the International
Building Code.
The MSBC8 defines the term fire area as "the aggregate area of the building regardless of subdivisions by fire barriers and horizontal
assemblies". This definition is consistent with the provisions of MGL Chapter 148 Section 26G that does not recognize subdivision of
buildings by fire rated walls or floor assemblies for purposes of many code provisions.
Section 1002.3, taken together with the zero square feet threshold for sprinklering of buildings of Use Group R, would have provided
a basis for requiring sprinklers throughout the A2Z building if it has no rated subdivision or at least throughout the residential portion if
isolated from the remainder of the building by fire barrier walls and rated floor assemblies. However, the deletion of Section 1002.3 in
Massachusetts leaves only the other sections of the EBCM to generate requirements for sprinklers in the building. My analysis of
those other requirements such as the height and area limits threshold was provided in my earlier memo below.
I am uncertain about the rationale for the MA deletion of IBC-09 Section 1002.3 but it may have to do with the fact that MGL Chapter
148 Section 26G sets a lower threshold for sprinklers (7,500 sf) in many occupancies and, therefore, would take precedence over
Section 1002.3 and MSBC8 Table 903.2. That would not, however, be the case for residential buildings that are not regulated by
Section 26G.
MSBC8 Table 903.2, Note a, states in part the following:
Note a – For Use Group R and I-1 Buildings with an aggregate building area of 12,000 sq. ft. or more, and Mixed
Use Buildings, the sprinkler system shall be designed and installed throughout the structure in accordance with
NFPA 13.
Table 903.2 contains the threshold criteria for when sprinklers are to be provided in buildings. Note a is not a requirement for a
sprinkler system but rather a requirement that when sprinklers are required in large residential buildings or in mixed use buildings, the
sprinkler system shall be designed in accordance with NFPA 13. It removes the option for use of NFPA 13R in such buildings.
I continue to conclude that the EBCM does not require sprinklers in the A2Z building as a result of the the proposed project.
If you have any questions concerning my continuing analysis of this situation, please do not hesitate to contact me.
Hal
On Apr 26, 2013, at 5:32 PM, Bruce Coldham, FAIA wrote:
Hal,
Thank you for the review below.
Would please also address the Article 903.2 that Louis Hasbrouck mentions on his email to me below.
Louis is the Building Inspector that I will be dealing with.
Bruce,
I
did
get
word
from
Duane
Nichols
that
the
commercial
portion
of
the
building
does
not
need
sprinklers.
When
you
do
your
code
review,
be
sure
to
check
the
Mass
amendment
to
IBC
table
903.2,
Note
(a);
NFPA
13
system
for
residential
occupancy
in
mixed
use
buildings.
Louis Hasbrouck
hcutlercfpe <hcutlercfpe@verizon.net>
To: Bruce Coldham, FAIA <bruce@coldhamandhartman.com>
Re: A2Z Expansion Project
April 30, 2013 8:51 AM
Building Commissioner
City of Northampton
Town of Williamsburg
(413) 587-1240
Thanks Hal,
Bruce
On Apr 26, 2013, at 4:43 PM, hcutlercfpe <hcutlercfpe@verizon.net> wrote:
Bruce,
This memorandum will summarize my review of the requirements of the Existing Building Code of Massachusetts applicable to
the proposed expansion of the A2Z. I assume the work in the existing building will be minimal and primarily related to the interface
with the addition on two levels. Because of the limited work in the existing building, I have focused my review on the EBCM Work
Area Compliance Method and specifically on the requirements of Chapter 10 concerning additions.
You memo from 2001 indicates we concluded the residential portion of this building qualifies as Use Group R-3 while the
remainder of the building is of Use Group M and S-1 occupancy.
The individual requirements of the subsections of Chapter 10 are reproduced and discussed below.
1001.1 Scope. An addition to a building or structure shall comply
with the International Codes as adopted for new construction
without requiring the existing building or structure to
comply with any requirements of those codes or of these provisions,
except as required by this chapter. Where an addition
impacts the existing building or structure, that portion shall
comply with this code.
1001.2 Creation or extension of nonconformity. An addition
shall not create or extend any nonconformity in the existing
building to which the addition is being made with regard to
accessibility, structural strength, fire safety, means of egress, or
the capacity of mechanical, plumbing, or electrical systems.
The addition does not extend any non-conformity of the existing building and improves its means of egress by the addition of a
new means of egress stair.
1001.3 Other work. Any repair or alteration work within an
existing building to which an addition is being made shall comply
with the applicable requirements for the work as classified
in Chapter 4.
The minimal work in the existing portion of the building will have to be regulated as a Level 2 alteration but, based on the limited
extent of that work, should comply with those requirements. However, that aspect of the code requirements has not been
addressed in this memorandum.
SECTION 1002
HEIGHTS AND AREAS
1002.1 Height limitations. No addition shall increase the
height of an existing building beyond that permitted under the
applicable provisions of Chapter 5 of the International Building
Code for new buildings.
There will be no change of the story or dimensional height of the building as the addition is at or below the height of existing roofs.
1002.2 Area limitations. No addition shall increase the area of
an existing building beyond that permitted under the applicable
provisions of Chapter 5 of the International Building Code for
new buildings unless fire separation as required by the International
Building Code is provided.
Building Code is provided.
There will be an increase in the area of the building to a total area of approximately 8,900 sf sf as a result of the addition.
However, that area is still within the MSBC8 Table 503 are limits permitted for an unsprinklered, Type IIIB building of Use Group
M, S-1 and R-3 occupancies. Those limits are 17,500 sf, 12,500 sf and unlimited area respectively.
Exception: In-filling of floor openings and nonoccupiable
appendages such as elevator and exit stair shafts shall be
permitted beyond that permitted by the International Building
Code.
SECTION 1003
STRUCTURAL
Not reviewed
SECTION 1004
SMOKE ALARMS IN OCCUPANCY
GROUPS R-3 AND R-4
1004.1 Smoke alarms in existing portions of a building.
Whenever an addition is made to a building or structure of a
Group R-3 or R-4 occupancy, the existing building shall be provided
with smoke alarms as required by the International
Building Code or International Residential Code as applicable.
Section 1004.1 requires that smoke alarms (single or multiple station smoke detectors) shall be provided throughout the
residential portion of the building.
SECTION 1005
ACCESSIBILITY
Not applicable.
Conclusions
The proposed addition may be made without upgrading of the existing building specifically without requiring sprinkler protection in
either the existing building or the addition.
If you have any questions concerning my review of this subject, please do not hesitate to contact me.
Hal
Harold R. Cutler Consulting Fire Protection Engineer
165 Landham Road Tele. & fax: 978-443-7088
Sudbury, MA 01776-3156