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INTERPRETATIONS We in the Plan Review Division will frequently be asked our opinions on a particular section of a code or standard. “How do you guys treat this?”, or “Will you accept this or that material or system?”, etc. To help foster consistency and to get the word out, we have occasionally issued memos to “Interested and Affected Personnel”. In an attempt to save time (yours and ours) we will be putting those memos in this section of our website. In addition, we will use this section of the our website to publish news and update information within the Plan Review Division. Standpipe Policy: May 24, 2001 Standpipe Policy: May 24, 2001 Memo to: Sprinkler System Designers / Installers From:Donald L. Mock, Fire Protection Engineer Subject: Standpipe Design Criteria Date: May 24, 2001 The International Building Code requires standpipe systems to be installed in accordance with NFPA 14. Howard County has adopted by reference the 2000 edition of NFPA 14. Section 5-7 requires a minimum residual pressure of 100 psi at the most remote hose connection. The authority having jurisdiction can allow the residual pressure to be reduced to 65 psi at the most remote hose connection. We will allow standpipe systems to be designed to a minimum residual pressure of 65 psi at the most remote hose connection. Howard County will also allow the following exception to the minimum residual pressure of 65 psi at the top most hose connection in fully sprinkled buildings when the building does not otherwise require a fire pump to meet the minimum sprinkler system design pressure. The residual pressure of 65 psi is not required in fully sprinkled buildings where the highest floor level is not more than 75 feet above the lowest level of Fire Department vehicle access. The riser shall be sized so that the Fire Department can supply the minimum 65 psi at the most remote hose connection, based upon an FDC input pressure of 150 psi. If you have any questions, contact me at (410) 313-3948. Townhouse Sprinkler Policy: August 20, 2001 To: All Townhouse Builders, Developers, and Sprinkler Contractors From: Robert J. Frances, P.E., Chief of Plan Review and Fire Protection, Department of Inspections, Licenses, and Permits RE: Sprinkler Protection in Townhouses with Large Fourth Level Lofts Date: August 20, 2001 Background: The scope of the 2000 International Residential Code (IRC) includes single-family dwellings and townhouses up to three (3) stories high. The IRC permits such buildings to be of type V-B construction (unprotected, wood-frame). There are some townhouse designs that incorporate lofts above the third level. At some point these lofts become so large that they could be considered a separate fourth floor level. The purpose of this policy is to clarify the point at which a loft becomes a fourth level and to address the protection measures needed to ensure that townhouses can be constructed and occupied safely within the scope of the IRC. Definition: Since the current codes do not specifically address the size or arrangement of a Aloft@, this policy will use the following definition to distinguish between an occuppiable loft that is an attic and one that is an additional floor. When the usable floor space of the loft exceeds a of the interior footprint of the townhouse it shall be considered a fourth floor. AUsable floor space@ is that part of the loft with a clear ceiling height of 7a' or more. Requirements: When a loft is considered a fourth level the garage space on the lowest level shall be provided with automatic sprinkler protection. This sprinkler protection shall be protected against freezing as required. As always, the garage must be adequately separated from the remainder of the townhouse. This includes the extension of the garage separation walls up through the floor interstitial space to the underside of the floor deck above. If you have any questions regarding this policy, or any other building code issue, feel free to contact the Plan Review Division, DILP at (410) 313-2436. Townhouse Smoke Detector Policy: August 20, 2001 To: All Townhouse Builders and Developers From: Robert J. Frances, P.E., Chief of Plan Review and Fire Protection Department of Inspections, Licenses, and Permits RE: Smoke Detectors and Sprinklers in Residential Occupancies Date: August 20, 2001 Just as a reminder that under the new 2000 International Codes (International Building Code (IBC) and International Residential Code (IRC)) smoke detectors are required in all bedrooms in residential dwelling units. Also, when any interior alterations, repairs, or additions requiring a permit occur, the entire dwelling must be provided with smoke detectors as required for new construction ('R317, IRC; '907.2.10, IBC). These requirements are the same as in the previous Howard County Building Code which the IBC & IRC replace. The only difference is that the previous codes, through local interpretation excepted bedroom smoke detector requirements in sprinklered townhouses. This exception is no longer permitted. The bedroom smoke detectors must be provided in sprinklered townhouses. On a similar note, the local policy to consider sprinkler protection as equivalent to an Aemergency escape and rescue opening@ will continue to apply. Residences with an NFPA 13D sprinkler system are considered to meet the requirements of 'R310, IRC-2000, and do not need additional bedroom or basement egress. If you have any questions regarding this policy, or any other building code issue, feel free to contact the Plan Review Division, DILP at (410) 313-2436. Exterior Exit Lights: October 15, 2001 To: All Builders, Developers, Designers, Architects, and Engineers From: Robert J. Frances, P.E., Chief of Plan Review and Fire Protection Department of Inspections, Licenses, and Permits RE: Emergency Lights Adjacent to Exterior Exit Discharges Date: October 15, 2001 Background: '1003.2.11 (Means of egress illumination) of the International Building Code (IBC) states that Athe means of egress, including the exit discharge, shall be illuminated at all times the building space served by the means of egress is occupied@ (Italics added). Later in '1003.2.11.2 (4) (Illumination emergency power) the IBC states Athat emergency power shall automatically illuminate... the portion of the exterior exit discharge immediately adjacent to exit discharge doorways in buildings required to have two or more exits.@ Under previous editions of the Howard County Building Code this department had a similar requirement for exterior exit discharge illumination when the discharge was onto an elevated exterior landing and/or stair. The new IBC code requires this even for at-grade exit doors. Policy: In all buildings or spaces required to have two or more exits that discharge to the exterior of a building, the area outside and immediately adjacent to the exit discharge shall be illuminated. For the purposes of emergency power, a single light head from a two-light-head battery pack type device located outside an exterior door will be acceptable. For large glass front type areas, if it can be demonstrated that the minimum required illumination can be provided through the glass, and that the glass will not be obstructed by drapes, etc., then internal building illumination will be considered to be adequate for the purposes of '1003.2.11 and '1003.2.11.2(4). Allowances for these types of instances need to be requested, evaluated, and documented by the designer on a case-by-case basis. Finally, this lighting, when covering shell, core, and common areas shall be provided as part of the shell construction, in individual tenant spaces the lighting need not be provided until the time of tenant fit-out, and tenant use and occupancy (U&O). If you have any questions regarding this policy or any other building code issue, feel free to contact the Plan Review Division, DILP at (410) 313-2436. Guardrail and Handrail: October 15, 2001 To: All Builders, Developers, Architects, and Engineers From: Robert J. Frances, P.E., Chief of Plan Review and Fire Protection Department of Inspections, Licenses, and Permits RE: Guardrail & Handrail Requirements in Residential and Commercial Applications Date: October 15, 2001 Residential 'R315 Handrails, International Residential Code (IRC): It has been and continues to be the interpretation of this department that handrails are not required until the elevation difference between floors or floor and grade is more than 30" (763 mm). 'R316 Guards, IRC: Porches, balconies, or raised floor surfaces located not more than 30" (763 mm) above the floor or grade below may omit guards. Where the floor or grade below are not more than 48"(1220 mm), fixed barriers (e.g. planters, seats, or benches) placed around the perimeter of the open sides may be used in lieu of guards. Commercial '1003.2.12 and '1003.3.3.11: These two sections address guards and handrails respectively. If taken separately it could be interpreted that a switch-back type stair is an Aopen-sided@ stair and a 42" high guard AND a 34"-38" high handrail would both be needed. However, it is the interpretation of this department that switch-back type stairs are not considered to be open-sided if the space between the flights of stairs is 12" or less. Under those conditions a single guard 38" high, with the top-rail meeting the graspability requirements of a handrail will satisfy both sections. This code interpretation is not applicable in use E (educational) buildings. If you have any questions regarding this policy, or any other building code issue, feel free to contact the Plan Review Division, DILP at (410) 313-2436. IBC Client Update Letter: October 21, 2001 To: All Affected and Interested Parties RE: Updates and Progress with the International Codes Date: October 22, 2001 As many of you already know the latest adoption of the Howard County Building Code took effect on January 9, 2001. We were the first county in the State of Maryland to use the family of International Codes as the basis for our Howard County Building Code. This has been a learning experience for us as I=m sure it has, and continues to be for you. I am using this forum to give you an update on some of the policies, interpretations, and clarifications that we have been using to deal with the International Codes (see attachments). The topics range from residential to commercial, townhouse to highrise, from building systems to fire protection systems. Our hope is that by knowing how we view and interpret the codes those of you who do the designing and building will be able to move quickly and efficiently through the plan review process. Concerning submittal of commercial plans, we usually need two (2) sets of construction documents that include architectural, structural, mechanical, electrical, and plumbing. These plans need to be coordinated and organized as a set. They need to be signed and sealed by an architect and/or engineer as appropriate. Section 106.3.4 of the International Building Code (IBC) requires a Design Professional of Responsible Charge. Having a single responsible individual coordinating the project is a major benefit. When we make comments on a permit submittal we contact A SINGLE INDIVIDUAL. Usually the fastest turn-arounds can be made when the person contacted by us is the person who has the design authority to make corrections and revisions. Of course our policy of allowing licensed contractors to sign for their own trade work will still be permitted on a case-by-case basis. This would typically be allowed on small, non-complex type projects (e.g. no extensive HVAC or plumbing systems, no restaurants, etc.). However, on all new major construction projects and significant additions the architect and/or engineer's seals and signatures are a must. Finally, a permit submittal for a new commercial building must include two (2) copies of the approved site development plan (SDP). Except in very special cases, the practice of accepting new building plans without a completed SDP will not be permitted. We hope you find this information helpful, and as always, if you have any questions concerning this or any other aspect of the Howard County Building Code feel free to contact the Plan Review Division, DILP at (410) 313-2436, Monday through Friday, 8:00 a.m. to 5:00 p.m. Sprinkler Plans Signatures: November 1, 2001 Memo to: Sprinkler System Designers / Installers From to: Donald L. Mock, Fire Protection Engineer Subject: Signature Required on Sprinkler Drawings Date: November 1, 2001 In accordance with the Sprinkler licensing law in the State of Maryland, the signature of the designer is required on all sprinkler drawings submitted for approval. The individual whose signature appears on the plans must posses the appropriate NICET certification. All NFPA 13 designs will require a minimum of a NICET level III and NFPA 13D and 13R require a minimum of NICET level II certification. Starting December 1, 2001 all sprinkler drawings submitted for review must be signed by a individual who meets or exceeds the above requirements. If you have any questions, I can be contacted at (410) 313-3948. |
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