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Dawes Hse Code Review 2016-04-26     Dawes House Phase III 1 April 22, 2016 Harold R. Cutler, P.E. Fire Safety, Building and Access Code Consultant 165 Landham Road Sudbury, MA 01776 -3156 Voice & fax 978-443-7088 Email hcutlercfpe@verizon.net   Summary of Building Code Requirements Existing Building Code Building Code of Massachusetts Eighth Edition Renovations, Alterations and Change of Occupancy of Dawes House, Smith College 8 Bedford Terrace, Northampton, MA This Code Summary is based upon the Eighth Edition of the Existing Building Code of Massachusetts (EBCM). The EBCM consists of the 2009 Edition of the International Building Code and the MA amendments to that code documented in Chapter 34 of the Eighth Edition of the Massachusetts State Building Code (MSBC8). References to code requirements for new construction are to the MSBC8. Basic data concerning the existing building at 8 Bedford Place and the proposed renovations and change of occupancy of that building are provided below. Existing Building Description Key characteristics of the existing building for purposes of this report may be summarized as follows: • Construction type is Type VB based on the building’s unrated, wood framed construction. • Building height is three stories with one basement. • The building area is approximately 3,720 sf based on the footprint of the building. The aggregate area on all levels is approximately 11,830 sf. • Primary occupancy classification are Use Group B (small assembly and administrative offices) on the First Floor and Use Group R-2 on the Second and Third Floors. • Means of egress is based on exit access corridors and aisles leading to doors to the exterior from the Basement and First floor and unenclosed interior stairs from the Second and Third Floors. • The building is sprinklered throughout.     Dawes House Phase III 2 April 22, 2016 • An existing fire detection and alarm system monitors the sprinkler waterflow detector and smoke detectors providing selective coverage of the building. The current Use Group B classification of the First Floor of the building resulted from processing previously of a change of occupancy from Use Group R-2 (dormitory). The Second and Third Floors continued to be Use Group R-2 in that transition. Proposed Work The primary element of the proposed project will be a change of occupancy from the existing Use Group B occupancy of the First Floor to include Use Group A-2 (dining hall) and Use Group B (entry hall and small conference room). The Use Group R-2 occupancy classification of all of the Second and Third Floors will be changed in this project to Use Group B for administrative offices of the College. However, the physical work on those two levels will be done separately from the First Floor work within the next two years. The scope of physical work in the building will include reconfiguration of less than 50% of the First Floor to expand the dining area into a second room and to create new toilet rooms and a kitchenette.     Dawes House Phase III 3 April 22, 2016 Basic Building Code Requirements for Existing Buildings   In accordance with MSBC8 Section 3401.1, the alteration, repair, addition, and change of occupancy of existing buildings shall be controlled by the provisions of the International Existing Building Code 2009 (IEBC 2009) and its appendices as modified by Massachusetts Amendments. Those documents, taken together, are identified as the Existing Building Code of Massachusetts (EBCM). The requirements of the EBCM specifically applicable to the Dawes House renovation and change of occupancy project except those related to the structural and electrical systems are summarized below. It is proposed to regulate the proposed renovations using the Work Area Compliance Method that requires that repairs, alterations, additions, changes in occupancy and relocated buildings shall comply with the applicable requirements of Chapters 4 through 12 of the code. As it is anticipated that the work area (area being reconfigured) will be less than 50 percent of the three individual floor areas and also less than 50% of the aggregate area of the building, the proposed project would normally be classified as a Level 2 alteration. In accordance with Section 404.2, the work shall comply with the provisions of EBCM Chapter 6 for Level 1 alterations and Chapter 7 for Level 2 alterations. On the other hand, as a result of the change of occupancy, EBCM Section 912.1.1 and 912.1.1 will require compliance with EBCM Chapter 8 concerning Level 3 alterations. That requirement leads in turn to the provisions of Section 802.2 that require compliance with Chapters 7 and 6 concerning Level 2 and 1 alterations respectively. The bottom line of these applicability requirements is that the Dawes House is subject to the requirements of EBCM Chapters 6, 7, 8 and 9. The technical requirements of those separate chapters as applied to the proposed office occupancy project in Dawes House are summarized in Table No. 1.     Dawes House Phase III 4 April 22, 2016 Table No. 1 Technical Requirements EBCM Chapters 6, 7, 8 and 9 Level 1 Requirements (1) An existing building or portion thereof shall not be altered such that the building becomes less safe than its existing condition Exception: Where the current level of safety or sanitation is proposed to be reduced, the portion altered shall conform to the requirements of MSBC8. (601.2) The proposed renovations will maintain the level of safety provided by the existing means of egress and fire protection features by maintaining or improving the means of egress in reconfigured areas, maintaining the existing sprinkler system and maintaining the existing fire detection and alarm system. Interior finishes (2) All newly installed interior finishes shall comply with the flame-spread requirements of the MSBC8. (602.1) (3) New carpeting used as an interior floor finish material shall comply with the radiant flux requirements of the International Building Code. (602.2) Existing and new interior wall, ceiling and floor finishes in the work area do now and will continue to comply with the new code requirements for Use Group A-2 occupancy. Those provisions include requirements for Class B, B and C wall and ceiling finishes for enclosed exits, exit access corridors and individual rooms or spaces respectively. Floor finishes in this sprinklered building are required to comply with the DOC FF-1 pill test. Materials and methods (4) All new work shall comply with materials and methods requirements in the Massachusetts Electrical Code, Massachusetts State Building Code, International Energy Conservation Code, International Mechanical Code, and Massachusetts Plumbing Code, as applicable, that specify material standards, detail of installation and connection, joints, penetrations, and continuity of any element, component, or system in the building. (602.3) New work will comply with the MSBC8 provisions for new construction. Fire Protection (5) Alterations shall be done in a manner that maintains the level of fire protection     Dawes House Phase III 5 April 22, 2016 provided. (603.1) The existing level of fire protection will be maintained by updating the existing automatic sprinkler system and the separate fire alarm system as required by the reconfiguration of the interior spaces of the building. Means of Egress (6) Repairs shall be done in a manner that maintains the level of protection provided for the means of egress. (604.1) An existing unenclosed stair from the Second to First Floors that s parallel to the existing main stair and also discharges through the entry lobby will be eliminated in the current project. The lack of separation of the two stairs and the common discharge path means they cannot be considered independent exits. Although the existing means of egress system will be minimally reconfigured by these changes, the remaining elements will provide comparable arrangement and level of protection for the means of egress. Accessibility (7) Accessibility requirements shall be in accordance with 521 CMR. Elevator and platform lift installation requirements are per 524 CMR. (605.1) The scope and cost of the current project together with the Gluten Free Dining Facility project of the summer of 2015 will require the project to be regulated by 521 CMR 3.2. That section becomes applicable when the accumulated building project costs in the building over a 36-month period exceeds 30% of the assessed value of the building. In that case, the new work being done is required to comply with 521 CMR and all features of the building regulated by 521 CMR shall be made to comply with the technical requirements of 521 CMR except those for which variances are obtained from the MA Architectural Access Board. The technical requirements of 521 CMR that will be applicable to Dawes House will include but not be limited to the following sections: • Section 11 Commercial Buildings • Section 20 Accessible Route • Section 21 Curb Cuts • Section 22 Walkways • Section 23 Parking and Passenger Loading Zones • Section 24 Ramps • Section 25 Entrances • Section 26 Doors and Doorways     Dawes House Phase III 6 April 22, 2016 • Section 27 Stairs • Section 28 Elevators • Section 29 Floor Surfaces • Section 30 Public Toilet Room • Section 35 Tables and Seating • Section 36 Drinking Fountains • Section 37 Public Telephones • Section 39 Controls • Section 40 Alarms • Section 41 Signage Among other requirements, the regulation will require that all public entrances to the buildings be accessible and that all public or common corridors be accessible including doors to all public spaces unless variances are obtained from the MA Architectural Access Board to permit specific features not to be upgraded. An application for a variance has been submitted (April 22, 2016) to permit omission of an elevator in the building to provide access to future administrative offices on the Second and Third Floors to which students or parents are entitled to access by 521 CMR. In a small existing building such as this, the reservation of a conference room on the accessible First Floor is often the basis for such a variance. That room would be available as a meeting room for administrators with offices on the Second and Third Floors and the public. In addition, an accessible unisex toilet will be constructed that is accessible from the entry lobby. The MAAAB variance application also includes a request for a two-year delay of compliance with the Access Regulations on the Second and Third Floors until work is being done there to prepare those spaces for their administrative office uses. Energy Conservation (8) Level 1 alterations to existing buildings or structures are permitted without requiring the entire building or structure to comply with the energy requirements of the International Energy Conservation Code. The alterations shall conform to the energy requirements of the International Energy Conservation Code as they relate to new construction only. (607.1) All new work including work on mechanical systems and the building envelope will be in compliance with the IECC provisions for new construction. The IECC typically only requires that building elements that are new or being altered shall comply with the IECC. For example, exterior walls and roofs are not required to be insulated unless the wall or roof cavity is exposed and then the requirement is to simply fill the cavity with insulation, not to provide a specific insulation value. Level 2 Requirements     Dawes House Phase III 7 April 22, 2016 (9) All new construction elements, components, systems, and spaces shall comply with the requirements of the Massachusetts State Building Code. Exceptions: 1. Windows may be added without requiring compliance with the light and ventilation requirements of the Massachusetts State Building Code. 2. Newly installed electrical equipment shall comply with the requirements of Section 708. 3. The length of dead-end corridors in newly constructed spaces shall only be required to comply with the provisions of Section 705.6. 4. The minimum ceiling height of the newly created habitable and occupiable spaces and corridors shall be 7 feet (2134 mm). (701.3) All new work will comply with the MSBC8 provisions for new construction. None of the exceptions in Section 701.3 will be utilized in the project. Existing vertical openings (10) All existing interior vertical openings connecting two or more floors within the work area shall be enclosed with approved assemblies having a fire-resistance rating of not less than 1 hour with approved opening protectives. Enclosure of vertical openings is a potential upgrade in this project, primarily because of dependence on the existing unenclosed main stair as the required means of egress for the Second and Third Floors. A request for acceptance of a compliance alternative will be submitted to the authorities having jurisdiction to permit that single unenclosed stair to remain as the only means of egress from the Second and Third Floors of the building. The basis for that compliance alternative would be the small population of those stories, the modest travel distances, an unrated but complete separation of most of the First Floor spaces from the egress stair and the protection of the building with both a sprinkler system and a smoke detection system. The request for acceptance of that compliance alternative will be provided in separate documentation. Supplemental shaft and floor opening enclosure requirements (11) Where the work area on any floor exceeds 50 percent of that floor area, the enclosure requirements of Section 703.2 shall apply to vertical openings other than stairways throughout the floor. (703.2.2, 912.7.2) The work areas on the individual floors are not anticipated to exceed 50% of the area of those floors. Therefore, upgrading of existing conditions related to vertical openings may not be required by the provisions of Chapter 7.     Dawes House Phase III 8 April 22, 2016 Supplemental stairway enclosure requirements (12) Where the work area on any floor exceeds 50 percent of that floor area, stairways that are part of the means of egress serving the work area shall, at a minimum, be enclosed with smoke-tight construction on the highest work area floor and all floors below. Exception: Where stairway enclosure is not required by the MSBC8 or the International Fire Code. (703.2.3, 912.7.2) The work areas on the individual floors will not exceed 50% of the area of those floors. Therefore, upgrading of existing conditions related to vertical openings is not required by the provisions of Chapter 7. Interior finish (13) The interior finish of walls and ceilings in exits and corridors in any work area shall comply with the requirements of the International Building Code. Exception: Existing interior finish materials that do not comply with the interior finish requirements of the International Building Code shall be permitted to be treated with an approved fire-retardant coating in accordance with the manufacturer’s instructions to achieve the required rating. (703.4, 912.3) (14) Where the work area on any floor exceeds 50 percent of the floor area, Section 703.4 shall also apply to the interior finish in exits and corridors serving the work area throughout the floor. Exception: Interior finish within tenant spaces that are entirely outside the work area. (703.4.1, 912.3) Interior wall, ceiling and floor finishes throughout the work area will comply with MSBC8 requirements for new construction. Those interior finish provisions in MSBC8 Table 803.9 require Class B interior finish within enclosed exits, Class B interior finish in corridors and Class C or better interior finish in rooms or enclosed spaces of this sprinklered building that includes Use Group A-2 occupancy. Guards (15) Every portion of a floor in the work area, such as a balcony or a loading dock, that is more than 30 inches (762 mm) above the floor or grade below and is not provided with guards, or those in which the existing guards are judged to be in danger of collapsing, shall be provided with guards. (703.5.1, 912.4.5) (16) Where there are no guards or where existing guards must be replaced, the     Dawes House Phase III 9 April 22, 2016 guards shall be designed and installed in accordance with the Massachusetts State Building Code. (703.5.2, 912.4.5) Existing guards are provided at locations where required by the code for new construction and existing guards are structurally adequate. No new guards will be required in the building except on the new exterior porch. Fire Protection (17) Supervise the fire sprinkler systems required by this section in accordance with Chapter 9 of the MSBC8. (704.2.5) (18) Maintain the existing fire standpipe system, if any. (704.3) (19) Maintain the existing fire detection and alarm system. (704.4) The existing sprinkler system will be maintained and modified as required by reconfiguration of the existing building. A fire standpipe system is not presently provided in the building and is not required. The existing fire alarm system provided to monitor the existing waterflow and smoke detectors and to support fire alarm devices throughout the building will be maintained. Means of Egress (20) The following conditions shall be corrected in all existing buildings: 1. Less than the number of means of egress serving every space and/or story, required by Chapter 10 of MSBC8; 2. Any required means of egress component, which is not of sufficient width to provide adequate exit capacity in accordance with section 1005.1 of the MSBC8; 3. Any means of egress which is not so arranged as to provide safe and adequate means of egress, including exit signage and emergency lighting in accordance with Chapter 10 of the MSBC8. (102.2.2.1, 912.4.1) The Second and Third Floors of this building, when converted to Use Group B occupancy, would require a minimum of two exits that are acceptable to the authority having jurisdiction. The proposed arrangement of one unenclosed stair serving the Second and Third Floors does not satisfy these minimum requirements. A request for acceptance of a compliance alternative to permit the existing single means of egress arrangements will be submitted in separate documentation. (21) In any work area, all rooms and spaces having an occupant load greater than 50 or in which the travel distance to an exit exceeds 75 feet (22 860 mm)     Dawes House Phase III 10 April 22, 2016 shall have a minimum of two egress doorways. Exceptions: 1. Storage rooms having a maximum occupant load of 10. 2. Where the work area is served by a single exit in accordance with Section 705.3.1.1. (705.4.1.1) There will be no individual rooms having occupant loads greater than 50 persons or in which the travel distance to an exit exceeds 75 feet. Therefore, this requirement is not applicable to individual rooms in the building. The combined populations of the dining rooms will exceed 50 persons. Those rooms and the adjacent kitchen and kitchenette will have access to front and rear exits. (22) In the work area and in the egress path from any work area to the exit discharge, all egress doors serving an occupant load greater than 50 shall swing in the direction of exit travel. (705.4.2) Where the work area exceeds 50 percent of the floor area, door swing shall comply with Section 705.4.2 throughout the floor. Exception: Means of egress within or serving only a tenant space that is entirely outside the work area. (705.4.2.1) There will be doors in the means of egress serving an aggregate occupant load of 50 or more persons. Therefore, those doors will be required to swing in the direction of egress travel. (23) In any work area, all doors opening onto an exit passageway at grade or an exit stair shall be self-closing or automatically closing by listed closing devices. Exceptions: 1. Where exit enclosure is not required by the MSBC8. 2. Means of egress within or serving only a tenant space that is entirely outside the work area. (705.4.3) (24) Where the work area exceeds 50 percent of the floor area, doors shall comply with Section 705.4.3 throughout the exit stair from the work area to the level of exit discharge. (705.4.3.1) There are currently no doors within the limited work area that open into an exit passageway or exit stair. Therefore, the requirements of Items 23 and 24 are not applicable in the current project based on current conditions. A requirement for enclosure of the existing stairs would require compliance with Items 23 and 24. (25) In any work area, and in the egress path from any work area to the exit discharge, in buildings or portions thereof of Group A assembly occupancies with     Dawes House Phase III 11 April 22, 2016 an occupant load greater than 100, all required exit doors equipped with latching devices shall be equipped with approved panic hardware. (705.4.4) (26) Where the work area exceeds 50 percent of the floor area, panic hardware shall comply with Section 705.4.4 throughout the floor. Exception: Means of egress within a tenant space that is entirely outside the work area. (705.4.4.1) There are and will continue to be no places of assembly with an occupant load greater than 100 persons in the building. Therefore, the requirements of Items 25 and 26 (Section 705.4.4) are not applicable to the current project. (27) Dead-end corridors in any work area shall not exceed 35 feet (10 670 mm). Exceptions: 1. Where dead-end corridors of greater length are permitted by MSBC8. 2. In other than Group A and H occupancies, the maximum length of an existing dead-end corridor shall be 70 feet (21 356 mm) in buildings equipped throughout with an automatic sprinkler system installed in accordance with MSBC8. 4. In other than Group A and H occupancies, the maximum length of an existing, newly constructed, or extended dead-end corridor shall not exceed 50 feet (15 240 mm) on floors equipped with an automatic sprinkler system installed in accordance with the MSBC8. (705.6) There will be no dead end corridors in excess of 35 feet in the building. (28) Means of egress in all work areas shall be provided with artificial lighting in accordance with the requirements of the MSBC8. (705.7.1) Artificial lighting as required by the code for new construction is provided in the means of egress of the building. (29) Where the work area on any floor exceeds 50 percent of that floor area, means of egress throughout the floor shall comply with Section 705.7.1. Exception: Means of egress within or serving only a tenant space that is entirely outside the work area. (705.7.2 ) The work areas will not exceed 50% of the individual floor areas. Therefore, the requirement of Section 705.7.2 is not applicable to the current project. (30) Means of egress in all work areas shall be provided with exit signs in accordance with the requirements of the MSBC8. (705.8.1.) (31) Where the work area on any floor exceeds 50 percent of that floor area,     Dawes House Phase III 12 April 22, 2016 means of egress throughout the floor shall comply with Section 705.8.1. Exception: Means of egress within a tenant space that is entirely outside the work area. (705.8.2) As the work areas will not exceed 50 percent of the individual floor areas, exit signs will not be required outside of the limited work area. Exit signs as required by the code for new construction will be provided in the means of egress of the First Floor. (32) Every required exit stairway that is part of the means of egress for any work area and that has three or more risers and is not provided with at least one handrail, or in which the existing handrails are judged to be in danger of collapsing, shall be provided with handrails for the full length of the run of steps on at least one side. All exit stairways with a required egress width of more than 66 inches (1676 mm) shall have handrails on both sides. (705.9.1) (33) Handrails required in accordance with Section 705.9.1 shall be designed and installed in accordance with the provisions of the MSBC8. (705.9.2) (34) The requirements of Sections 705.10.1 and 705.10.2 shall apply to guards from the work area floor to the level of exit discharge but shall be confined to the egress path of any work area. (705.10) (35) Every open portion of a stair, landing, or balcony that is more than 30 inches (762 mm) above the floor or grade below and is not provided with guards, or those portions in which existing guards are judged to be in danger of collapsing, shall be provided with guards. (705.10.1) (36) Guards required in accordance with Section 705.10.1 shall be designed and installed in accordance with the MSBC8. (705.10.2) The existing stairs and associated floor openings of the building regulated by Items 32 through 36 are subject to these requirements concerning guards and handrails. Given the requirement for full compliance with the Access regulations (521 CMR), complying handrails will ultimately be required on all existing stairs except those for which formal variance from the MAAAB are requested and granted. Existing guards at the floor openings for stairs should be considered acceptable by the cited sections of Chapter 7 and may continue in service. No action should be required under Items 34, 35 and 36. Lighting and/or Ventilation (37) In any existing building, or portion thereof, in which (a) the lighting or ventilation do not meet the applicable provisions in Chapter 12 of the EBCM, and (b) which, in the opinion of the building official, are dangerous, or hazardous, to     Dawes House Phase III 13 April 22, 2016 the health and safety of the occupants, the building official shall order the abatement of such conditions to render the building or structure occupiable or habitable as applicable for the posted use and occupant load. In enforcing the provisions of this section the building official may require or accept engineering or other evaluations of the lighting and/or ventilation systems in order to evaluate possible dangerous or hazardous conditions and acceptable solutions. Where full compliance with 780 CMR for new construction is not practical for structural and/or other technical reasons, the building official may accept compliance alternatives, or engineering or other evaluations, which adequately address the building or structure livability for the posted use and occupant load. (102.2.2.5, 911.1) Lighting and ventilation will not be dangerous or hazardous to the health and safety of building occupants. Therefore, no specific action is required under the provisions of Section 102.2.2.5. Mechanical (38) All reconfigured spaces intended for occupancy and all spaces converted to habitable or occupiable space in any work area shall be provided with natural or mechanical ventilation in accordance with the International Mechanical Code. Exception: Existing mechanical ventilation systems shall comply with the requirements of Section 709.2. (709.1, 909.1) (39) In mechanically ventilated spaces, existing mechanical ventilation systems that are altered, reconfigured, or extended shall provide not less than 5 cubic feet per minute (cfm) (0.0024m3/s) per person of outdoor air and not less than 15 cfm (0.0071 m3/s) of ventilation air per person; or not less than the amount of ventilation air determined by the Indoor Air Quality Procedure of ASHRAE 62. (709.2, 909.1) The limited work area of the current project and the fact that there will be minimal reconfiguration of the building should permit the project without modification of existing provisions for ventilation. Existing exterior wall window openings probably satisfy the Code’s requirements for natural ventilation. The proposed new kitchenette will be provided with domestic cooking equipment and used for cooking at a non-commercial level. Therefore, a commercial type and scale of exhaust ventilation should not be required. Energy Conservation (40) Level 2 alterations to existing buildings or structures are permitted without requiring the entire building or structure to comply with the energy requirements     Dawes House Phase III 14 April 22, 2016 of the International Energy Conservation Code. The alterations shall conform to the energy requirements of the International Energy Conservation Code as they relate to new construction only. (711.1) All new building systems and features including mechanical and electrical systems and new windows, exterior walls and roof assemblies will comply with the IECC requirements for new construction. Existing building systems and features that are not being altered are not required to be upgraded. Level 3 Alterations Existing shafts and vertical openings. (41) Existing stairways that are part of the means of egress shall be enclosed in accordance with Section 703.2.1 from the highest work area floor to, and including, the level of exit discharge and all floors below. (803.1, 912.7.2) There are currently no MSBC8 provisions for means of egress stairs connecting more than two stories to be unenclosed. Therefore, unless permitted to remain unenclosed by acceptance of a compliance alternative or formal variance by the authorities-having- jurisdiction, enclosure of the existing stairs will be required. A request for acceptance of that compliance alternative will be made in separate documentation. Interior finish (42) Interior finish in exits serving the work area shall comply with Section 703.4 between the highest floor on which there is a work area to the floor of exit discharge. (803.3) Interior wall, and ceiling finishes in the work area will comply with the new code requirements for Class B, B and C or better interior finish in exit enclosures, exit access corridors and rooms or enclosed spaces respectively. Automatic sprinkler systems (43) Automatic sprinkler systems shall be provided in all work areas when required by Section 704.2 or this section. In addition to the requirements in section 804, automatic sprinkler systems may be required in buildings undergoing major alterations per section 102.2.1.1. (804.1) Automatic sprinkler protection is currently provided throughout this building. That system will be maintained and upgraded as required by physical reconfiguration of the building. (44) In high-rise buildings, work areas shall be provided with automatic sprinkler     Dawes House Phase III 15 April 22, 2016 protection where the building has a sufficient water supply system to the site. Where the work area exceeds 50 percent of floor area, sprinklers shall be provided in the specified areas where sufficient water supply for design and installation of a fire sprinkler system is available at the site. (804.1.1) The building is not a high-rise building by the definition of the MSBC8. Rubbish and linen chutes (45) Rubbish and linen chutes located in the work area shall be provided with sprinkler protection or an approved fire suppression system where protection of the rubbish and linen chute would be required under the provisions of the MSBC8 for new construction. (804.1.2) There are no trash or linen chutes in the building. Fire alarm and detection systems (46) Fire alarm and detection systems complying with Sections 704.4.1 and 704.4.3 shall be provided throughout the building in accordance with the International Building Code. (804.2) (47) Where required by the International Building Code, a manual fire alarm system shall be provided throughout the work area. Alarm notification appliances shall be provided on such floors and shall be automatically activated as required by the International Building Code. Exceptions: 1. Alarm-initiating and notification appliances shall not be required to be installed in tenant spaces outside of the work area. 2. Deleted (804.2.1) (48) Where required by the International Building Code for new buildings, automatic fire detection systems shall be provided throughout the work area. (804.2.2) The existing fire detection and alarm system that includes manual pull stations, smoke detectors providing limited coverage, waterflow detectors and audible and visual alarms will be maintained. Although smoke detectors would not be required in new construction of a building of Use Group A-2 or B occupancy, the existing smoke detection system will be maintained to support arguments for acceptance of the existing or modified means of egress arrangements of the building. Means of Egress     Dawes House Phase III 16 April 22, 2016 (49) The means of egress shall comply with the requirements of Section 705 except as specifically required in Sections 805.2 and 805.3. (805.1) (50) Means of egress from the highest work area floor to the floor of exit discharge shall be provided with artificial lighting within the exit enclosure in accordance with the requirements of the International Building Code. (805.2) (51) Means of egress from the highest work area floor to the floor of exit discharge shall be provided with exit signs in accordance with the requirements of the International Building Code. (805.3) Exit signage and lighting as required by the code for new construction will be provided in the means of egress of the entire building. Accessibility (52) A building, facility or element that is altered shall comply with Sections 605 and 706. (806.1) The cited sections, in the MA Amendments to the IEBC, require compliance with the accessibility regulations of the MA Architectural Access Board (521 CMR). As discussed above under Item 7, those Regulations will require full compliance with 521 CMR except as permitted by formal variances from the Regulation. Energy Conservation (53) Level 3 alterations to existing buildings or structures are permitted without requiring the entire building or structure to comply with the energy requirements of the International Energy Conservation Code. The alterations shall conform to the energy requirements of the International Energy Conservation Code as they relate to new construction only. (808.1) All new building systems and features including mechanical and electrical systems and new replacement windows, exterior walls and roof assemblies will comply with the IECC requirements for new construction. Existing building systems and features that are not altered will not be upgraded. Chapter 9 Change of Occupancy (54) Light and ventilation shall comply with the requirements of the Massachusetts State Building Code for the new occupancy. The renovated spaces will be provided with light and ventilation as required for new construction of Use Group A-2 and B spaces. The renovated spaces will be provided with operable windows as required for natural ventilation of Use Group B spaces.     Dawes House Phase III 17 April 22, 2016 (55) An automatic fire sprinkler system shall be provided based on the new occupancy in accordance with Chapter 9 of the Massachusetts State Building Code. (912.2.1) The area threshold for a requirement for sprinkler protection in a building of Use Group A-2 is an aggregate area of 5,000 square feet on all levels of the building. Therefore, the existing automatic sprinkler protection is required by Section 912.2.1. (56) A fire alarm and detection system shall be provided based on the new occupancy in accordance with Chapter 9 of the Massachusetts State Building Code. (912.2.2) A fire alarm system is required in the building in accordance with MSBC8 Section 903.4.2 to provide occupant notification devices activated by the waterflow detector of the sprinkler system. The existing system will be maintained to monitor existing system connected manual pull stations, smoke detectors and waterflow detector. The smoke detectors of the existing fire detection and alarm system are non-required devices. The presence of the non-required smoke detection system will be used in arguments for a compliance alternative or code variance related to the means of egress of the building. (57) The interior finish of walls and ceilings shall comply with the requirements of the Massachusetts State Building Code for the new occupancy classification. (912.3) The existing interior finish materials will comply with the MSBC8 requirements for new construction. (58) When a change of occupancy classification is made to a higher hazard category (lower number) as shown in Table 912.4, the means of egress shall comply with the requirements of Chapter 10 of the Massachusetts State Building Code. (912.4.1, 912.4.1, Exception 2) (59) When a change of occupancy classification is made to an equal or lesser hazard category (higher number) as shown in Table 912.4, existing elements of the means of egress shall comply with the requirements of EBCM Section 805 for the new occupancy classification. Newly constructed or configured means of egress shall comply with the requirements of Chapter 10 of the Massachusetts State Building Code. Exception: Any stairway replacing an existing stairway within a space where the pitch or slope cannot be reduced because of existing construction shall not be required to comply with the maximum riser height and minimum tread depth requirements.     Dawes House Phase III 18 April 22, 2016 (912.4.2) On the First Floor, the change in occupancy from Use Group B (means of egress hazard category 4) to Use Group A-2 (means of egress hazard category 3) would be to a higher hazard category (lower number). On the Second and Third Floors, the change in occupancy from Use Group R-2 (means of egress hazard category 3) to Use Group B (means of egress hazard category 4) would be to a lower hazard category (higher number). In that situation, EBCM Section 912.4.1 requires that the means of egress of the First Floor shall satisfy the requirements of MSBC8 for new construction. The Phase III project will satisfy that requirement for the First Floor. (60) Egress capacity shall meet or exceed the occupant load as specified in the Massachusetts State Building Code for the new occupancy. (912.4.3) The egress capacity of the single stair from the upper floors and doors directly to the exterior from the First Floor will provide more than sufficient capacity for the small occupant loads of the individual floors and the building as a whole. (61) Existing stairways shall comply with the handrail requirements of EBCM Section 705.9 in the area of the change of occupancy classification. (912.4.4) EBCM Section 705.9 requires that every exit stairway that is part of the means of egress for any work area and that has three or more risers and is not provided with at least one handrail, or in which the existing handrails are judged to be in danger of collapsing, shall be provided with handrails for the full length of the run of steps on at least one side. Before occupancy of the Second and Third Floors, handrails will be required on both sides of the all means of egress stairs as required by 521 CMR. (62) Existing guards shall comply with the requirements in Section 705.10 in the area of the change of occupancy classification. (912.4.5) EBCM Section 705.10 requires that every open portion of a stair, landing, or balcony that is more than 30 inches (762 mm) above the floor or grade below and is not provided with guards, or those portions in which existing guards are judged to be in danger of collapsing, shall be provided with guards. Guards will be maintained, upgraded or provided as required by existing or new conditions. (63) When a change of occupancy classification is made to a higher hazard category as shown in Table 912.5, the height and area of the existing building shall be comply with the provisions of MSBC8 Chapter 5. (912.5.1) (64) When a change of occupancy classification is made to an equal or lesser hazard category as shown in Table 912.5, the height and area of the     Dawes House Phase III 19 April 22, 2016 existing building shall be deemed acceptable.(912.5.2) A change in occupancy from Use Group B (height and area hazard category 4) to Use Group A-2 (height and area hazard category 2) would be to a higher hazard category (lower number). In that situation, EBCM Section 912.5.1 requires compliance with the new construction height and area limits of the MSBC8. As there are no fire rated occupancy separations within the building, the building must be considered to be of nonseparated mixed Use Groups A-2 and B. Such a building would be restricted to two stories in height and 18,000 sf in area, the restrictions of MSBC8 Table 503 for a sprinklered building of Use Group A-2 and Type VB construction. A sprinklered building of Use Group B and Type VB construction would be permitted to have up to three stories and up to 36,000 sf. The building would comply with the height limitations of the MSBC8 if an occupancy separation were provided between the First Floor assembly spaces and the Third Floor office spaces. That separation could be provided (1) at the plane of the Second Floor, (2) the plane of the Third Floor or (3) as a combination of the wall enclosure of the Entry Hall and Conference Room and at the plane of the Second Floor above the Use Group A-2 dining rooms and kitchens. The combination of existing and new wall and floor-ceiling assemblies may be considered to provide an unrated occupancy separation between the First Floor dining facility and the First and Second Floor office areas. Such use of existing wood lath and plaster wall and ceiling assemblies is explicitly permitted by the exception in EBCM Section 912.5.3 that state: Exception: Where the fire barriers are required to have a 1-hour fire-resistance rating, existing wood lath and plaster in good condition or existing 1/2-inch-thick (12.7 mm) gypsum wallboard shall be permitted. A compliance alternative that requests acceptance of the existing or improved conditions with respect to the third of the occupancy separation options described above will be required. (65) When a change of occupancy classification is made to an equal or lesser hazard category as shown in Table 912.6, existing exterior walls, including openings, shall be accepted. (912.6.2) A change in occupancy from Use Group B (exterior wall hazard category 3) to Use Group A-2 (exterior wall hazard category 3) would be to an equal hazard category. The change on the Second and Third Floors is from Use Group R-2 (exterior wall hazard category 3) to Use Group B (exterior wall hazard category 3). In both situations, EBCM Section 912.5.2 allows the new use of the building without further compliance with the     Dawes House Phase III 20 April 22, 2016 new construction exterior wall requirements of the MSBC8. (66) Vertical shafts including stairways shall comply with the MSBC8 enclosure provisions for new construction except as permitted by specific subsections of EBCM Section 912.7. (912.7) Enclosure of the main exit stair is a potential upgrade in this project, primarily because of dependence on the existing unenclosed main stair as the required means of egress for the Second and Third Floors. That enclosure requirement will be the subject of a request for acceptance of a compliance alternative as discussed under Item 10 above. (67) Accessibility requirement shall be in accordance with 521 CMR. (912.8) The cited sections, in the MA Amendments to the IEBC, require compliance with the accessibility regulations of the MA Architectural Access Board (521 CMR) as discussed under Item 7 above. Plumbing Code (68) The building shall be provided with sufficient separate toilet fixtures for the anticipated population. (248 CMR) As there will be an increase of occupant load as a result of the current project, additional toilet facilities will be required by the current project. The toilet fixture requirements of the Plumbing Code will be satisfied by the additional toilet facilities on the First Floor and existing facilities on the Second and Third Floor. Other Work Area Compliance Method Requirements The “Work Area Compliance Method” requires that repairs, alterations, additions, changes in occupancy and relocated buildings shall comply with the applicable requirements of Chapters 4 through 12 of the code. The provisions of Chapter 4 (classification of work), Chapter 6 (Level 1 alterations), Chapter 7 (Level 2 alterations), Chapter 8 (Level 3 alterations) and Chapter 9 (change of occupancy) except those requirements related to the structural system have been summarized above. Requirements concerning the structural system for Levels 1, 2 and 3 work are provided in Sections 606, 707 and 807. Those sections are modified by the MSBC8 amendments of the IEBC. Those requirements are addressed on the project’s structural plans. The applicability of the requirements of the other chapters of the Work Area Compliance Method are summarized below: • Chapter 5 concerning repairs will be applicable to existing building features that are to be simply maintained as part of the current project. • Chapter 10 concerning additions is not applicable as the building is not to be expanded.     Dawes House Phase III 21 April 22, 2016 • Chapter 11 is not applicable as the building is not recognized as a historic building in state and federal registries. • Chapter 12 is not applicable as the building is not be moved or relocated.