Dawes Hse Complance Alternative 2016-04-26 PRELIMINARY
Harold R. Cutler, P.E.
Consulting Fire Protection Engineer
165 Landham Road
Sudbury, MA 01776 -3156
Voice & fax 978-443-7088
Email hcutlercfpe@verizon.net
April 22,2016
P/N 2526
Northampton Building Department
Puchalski Municipal Building
212 Main St. Northampton, MA 01060
Attention: Louis Hasbrouck
Building Commissioner
Dear Mr. Habrouck:
Subject: Request for Acceptance of Compliance Alternatives
Two Means of Egress Conditions and Exit Enclosure
Requriements
Dawes House at Smith College
8 Bedford Terrace, Northampton, MA
This letter is submitted on behalf of the Facilities Management Office of Smith College
and Morgan Studio, the architect for the proposed renovation project at Dawes House, 8
Bedford Terrace. It is submitted to request your department’s consideration and
acceptance of three compliance alternatives in accordance with Section 101.5.0 of the
Existing Building Code of Massachusetts (EBCM) with respect to the following
conditions in the building:
1. The single means of egress from the Second and Third Floors.
2. The lack of an enclosure of the means of egress stair from the Second and Third
Floors.
3. The lack of a complying occupancy separation between the First Floor spaces of
Use Group A-2 from the Use Group B spaces of the Second and Third Floors.
In addition to references to the EBCM, this letter will also refer to the requirements of
the Eighth Edition of the Massachusetts State Building Code (MSBC8) for new
construction.
Existing Conditions
Key characteristics of the existing building for purposes of this discussion may be
summarized as follows:
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1. Construction type is Type VB based on the building’s wood frame construction.
2. The building’s story height is three stories and basement.
3. The building area is approximately 3,720 sf based on the footprint of the building.
4. The aggregate area of all stories is 11,830 sf.
5. The primary existing occupancy classification is Use Group B (Business) for the
gluten free dining facility with kitchen on the First Floor.
6. In addition, the existing Second and Third Floors are presently classified in Use
Group R-2 but are vacant.
7. An automatic system-connected smoke detection system is provided in the
common rooms and corridors of all three levels that will activate horn-strobe
alarm notification devices throughout the building.
8. Automatic sprinkler protection is provided throughout the building.
9. Means of egress from the First Floor is provided by two doors to the exterior from
the dining facility and one door to the exterior from the entry lobby serving the
upper floors.
10. Means of egress from the Second and Third Floors is based on exit access
corridors and aisles leading to one unenclosed exit stair.
Proposed Renovations and Expansion
The proposed project will include renovations within the existing First Floor gluten free
dining facility to expand the dining area and create a new kitchenette and new toilet
facilities. As a result of the increased occupant load, the dining facility will undergo a
change in occupancy from Use Group B to Use Group A-2. The proposed renovations
and alterations on the First Floor are documented on the Phase III project plans.
At this time, the extent of renovations and alterations including upgrading of utilities
(electrical, plumbing, communications) on the Second and Third Floors are undefined
and not planned for immediate implementation. Ultimately, those spaces will be used for
“swing space” for college departments during renovations in other campus buildings.
We believe several of these existing and new characteristics and features of the
building may be recognized as compliance alternatives to strict compliance with respect
to the three issues identified above. Those separate issues are discussed below.
1. Compliance Alternative for Number of Upper Story Means of Egress
The existing means of egress stair from the Third to Second to First Floors that is to
remain terminates at the First Floor entry lobby at which level occupants leave that
lobby to the new porch on the front and side of the building. An existing second stair
from the Second to First Floors of very poor quality and requires discharge through the
entry lobby is to be demolished. There are no exterior stairs or fire escapes serving the
upper stories.
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EBCM Section 705.3.1 concerning means of egress in a building undergoing Level 2
alterations permits a single means of egress from certain buildings in accordance with
the following exception:
2. Group B, F-2, and S-2 occupancies not more than
two stories in height that are not greater than
3,500 square feet per floor (326 m2 ), when the
exit access travel distance does not exceed 75
feet (22 860 mm). The minimum fire-resistance
rating of the exit enclosure and of the opening
protection shall be 1 hour.
The Dawes House conditions do not satisfy these restrictions because (1) the building
has three stories that would have a single means of egress, (4) the existing access
travel distance including travel over the unenclosed stairs to the First Floor door to the
exterior would be 122 ft and (3) the existing stair is unenclosed.
MSBC8 Section 1021.2 and Table 1021.2 have similar restrictions for single exit stories
of buildings in new construction but specify and occupant load limit of 29 persons for a
single exit second story.
The characteristics and features of Dawes House that we believe compensate for the
lack of a second means of egress from the Second Floor include the following:
1. The complete automatic sprinkler protection of the building that is not a condition
of EBCM Section 705.3.1 or MSBC8 Table 1021.2 and provides a high level of
life safety for building occupants who are not intimately involved in an ignition
event.
2. The installation of a smoke detection system in the common areas of all three
stories would not be required under the code provisions for new construction for
this building that is not of a residential occupancy.
3. The low calculated total occupant load of the Second and Third Floors of 45
persons.
4. The modest travel distance of 122 feet from the most remote point on the Third
Floor to the front door to the exterior.
5. The isolation of the exit access stair and exit discharge lobby from the remainder
of the First Floor spaces.
The actual common path of travel distance (Item 4) may be compared to the Code’s
allowance for a maximum common path of travel distance of 100 feet within a
sprinklered, single means of egress space of Use Group B occupancy. The exit access
travel distances of Item 4 may also be compared to the Code’s allowance of 250 feet of
exist access travel distance in Table 1016.1.
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2. Compliance Alternative for Lack of Stair Enclosure
The same factors as discussed above compensate for the lack of enclosure of the three
story means of egress stair of the building. An exit stair enclosure is intended to protect
occupants when evacuating a building from fire conditions in spaces adjacent to the
means of egress path. In a sprinklered building of Use Group B occupancy, common
path of travel distances of up to 100 feet are permitted that are not required to be
protected from adjacent spaces. That distance is compared to the 122 feet of common
path of travel that will exist from the most remote point on the Third Floor of Dawes
House.
It is proposed to provide a continuous and complete (but unrated) separation of the First
Floor dining facility and kitchens from the First Floor entry lobby and conference room.
That barrier will be made up of a combination of existing and new partitions. That barrier
will prevent or delay the impact of a fire problem in the dining or kitchen areas on the
exit access path to the front door.
Approved Compliance Alternatives
EBCM Section 101.5.0 (MA amendment) references examples of compliance
alternatives found at the frequently-asked-questions (FAQ) link on the Board of Building
Regulations and Standards web site. Two of those compliance alternatives address the
conditions resulting that are the subjects of requested Compliance Alternatives 1 and 2.
The presence of the non-required common area smoke detection system will
compensate for the extra travel distance required for egress from the Third Floor with its
single means of egress and the lack of exit stair enclosure by providing an early warning
that permits early evacuation of the apartment. Such conditions are addressed in
Section 2.3 of the FAQ discussion of enclosures of exits that states the following:
2.3 Enclosure of exitways:
2.3.1 General Compliance alternatives:
1. Improve enclosure of exitway.
2. Add a partial fire suppression system.
3. Add a detection system
The travel distance issue in this case is the length of the single, unenclosed vertical exit
access path from the Third Floor offices to the First Floor entry lobby door to the
exterior. A second suggested compliance alternative with respect to travel distance, in
FAQ Section 2.2, states the following:
2.2 Travel Distance:
2.2.1 General Compliance Alternatives:
1. Add detection system.
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2. Add a partial fire suppression system.
3. Add smoke doors.
4. Increase fireresistance rating of corridor walls and doors
Occupancy Separation
A consequence of the change of occupancy to Use Group A-2 on the First Floor is a
requirement from EBCM Section 912.5.1 that the building shall comply with the height
and area limitations of the MSBC8 for new construction. If the building were arranged as
separated mixed Use Groups A-2 and B and the Use Group A-2 space were limited to
the First and Second Floors, the height limitation would be satisfied in accordance with
MSBC8 Section 508.4.3. That requirement would be satisfied if there were a one-hour
rated occupancy separation between the A-2 and B spaces.
It is proposed to consider the occupancy separation to be the combination of (1) the
walls separating the First Floor assembly and kitchen spaces from the entry lobby,
conference room and unisex toilet and (2) the Second Floor assembly above the Use
Group A-2 spaces. 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.
We request acceptance of a compliance alternative to allow the combination of existing
and new wall and floor-ceiling assemblies to be considered a comparable occupancy
separation. The conditions and characteristics of the building that are the basis for that
request include the following:
1. The Use Group A-2 occupancy will be limited to the First Floor.
2. The installation of a smoke detection system in the common areas of all three
stories would not be required under the code provisions for new construction for
this building that is not of a residential occupancy.
3. The new walls on the First Floor will be constructed to have a one-hour fire
rating.
4. The existing walls are acceptable for occupancy separation purposes in
accordance with EBCM Section 912.5.3.
5. The existing deck of the Second Floor floor-ceiling assembly will provide a smoke
barrier with some inherent fire resistance between the First and Second Floor
above the Use Group A-2 space.
The locations of the partitions and floor/ceiling assemblies described above are
indicated on the attached “Dawes House Occupancy Separation.pdf.
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Approved Compliance Alternatives
EBCM Section 101.5.0 (MA amendment) references examples of compliance
alternatives found at the frequently-asked-questions (FAQ) link on the Board of Building
Regulations and Standards web site. One of those compliance alternatives addresses
the condition that is the subject of requested Compliance Alternative 3. That
compliance alternative suggests the following with respect to building assemblies
required to be fire rated:
3.1 Fire separations and partitions;
3.1.1 General compliance alternatives:
1. Improve fire separation.
2. Add a fire suppression system.
3. Add a detection system.
In the case of Dawes House, the smoke detection system is a non-required system that
will alert building occupants long before the lack of a complete fire rating of the
occupancy separation becomes a factor in the safety of building occupants.
Conclusions
On the basis of the above analysis of the hazards and protection characteristics of
Dawes House, we request your acceptance of the above listed features and
characteristics as compliance alternatives to the code requirements related to the
indicated means of egress requirements and occupancy separation requirements of the
code for existing or new construction.
Thank you for your cooperation.
Very truly yours
Harold R. Cutler
cc: Elizabeth Morgan, MS