ICC CODES - PUBLIC COMMENT FORM
FOR PUBLIC COMMENTS ON THE 2012 REPORT
OF THE PUBLIC HEARINGS ON THE 2012 EDITIONS OF:
International Building Code©
Fire Safety (FS)
General (G)
Means of Egress (E)
Structural (S)
International Fuel Gas Code© (FG)
International Mechanical Code© (M)
International Plumbing Code© (P)
International Private Sewage Disposal Code© (PSD)
CLOSING DATE: All Comments Must Be Received by: August 1, 2012
1) Please type or print clearly: Public comments will be returned if they contain unreadable information.
Name: / Jonathan Siu / Date: / 7/11/2012 /Jurisdiction/Company: / City of Seattle, Department of Planning & Development /
Submitted on Behalf of: / Washington Association of Building Officials, Technical Code Development Committee /
Address: / 700-5th Ave, Ste 2000; PO Box 34019 /
City: / Seattle / State: / WA / Zip +4: / 98124-4019 /
Phone: / 206-233-5163 / Ext: / Fax: / 206-386-4039 /
e-mail: / /
2) Copyright Release: In accordance with Council Policy #28 Code Development, all Code Change Proposals, Floor Modifications and Public Comments are required to include a copyright release. A copy of the copyright release form is included at the end of this form. Please follow the directions on the form. This form as well as an alternative release form can also be downloaded from the ICC website at www.iccsafe.org. If you have previously executed the copyright release, please check the box below:
X 2012-2014 Cycle copyright release on file
3) Code Change Proposal Number:
Indicate the Code Change Proposal Number that is being addressed by this Public Comment: _E132-12
4) Public Comment: The Final Action requested on this Code Change Proposal is: (Check Box)
Approved as Submitted (AS): / X / Approved as Modified by this Public Comment (AMPC): / Approved as Modified by the Code Committee as Published in the ROH (AM): / Approved as Modified by Assembly Floor Action as Published in the ROH (AMF): / Disapproved (D):Attached Proposed Modifications and/or Reason Statements:
See Attached Individual Consideration Form
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INDIVIDUAL CONSIDERATION FORM
E132-12 (Insert Code Change Number)
1021.2 (IFC [B] 1021.2)
Individual Consideration Agenda
This item is on the agenda for individual consideration because a public comment was submitted.
Public Comment:
Name: Jonathan Siu, City of Seattle Dept of Planning & Development, on behalf of the Washington Association of Building Officials Technical Code Development Committee
Modify the proposal as follows (Only if AMPC is desired. If no modification is requested, enter your reason statement in “Commenter’s Reason”):
Replace the proposal with the following (modify IBC 1021.2):
1021.2 Exits from stories. Two exits, or exit access stairways or ramps providing access to exits, from any story or occupied roof shall be provided where one of the following conditions exists:
1. The occupant load or number of dwelling units exceeds one of the values in Table 1021.2(1) or 1021.2(2).
2. The exit access travel distance exceeds that specified in Table 1021.2(1) or 1021.2(2) as determined in accordance with the provisions of Section 1016.1.
3. Helistop landing areas located on buildings or structures shall be provided with two exits, or exit access stairways or ramps providing access to exits.
Exceptions:
1. Rooms, areas and spaces complying with Section 1015.1 with exits that discharge directly to the exterior at the level of exit discharge, are permitted to have one exit.
2. Group R-3 occupancy buildings shall be permitted to have one exit.
2 3. Parking garages where vehicles are mechanically parked shall be permitted to have one exit.
3 4. Air traffic control towers shall be provided with the minimum number of exits specified in Section 412.3.
4 5. Individual dwelling units in compliance with Section 1021.2.3.
5 6. Group R-3 and R-4 congregate residences occupancies shall be permitted to have one exit.
6 7. Exits serving specific spaces or areas need not be accessed by the remainder of the story when all of the following are met:
6.1 7.1. The number of exits from the entire story complies with Section 1021.2.4;
6.2 7.2. The access to exits from each individual space in the story complies with Section 1015.1; and
6.3 7.3. All spaces within each portion of a story shall have access to the minimum number of approved independent exits based on the occupant load of that portion of the story, but not less than two exits.
Commenter’s Reason:
The intent of this proposal is to clean up the text that allows a single means of egress from R occupancies. While the Means of Egress Committee approved the original proposal as submitted, it has come to our attention there is a possibility the approved text is not consistent with the Fair Housing Act. Although there was no testimony to that effect in Dallas, we are submitting this public comment to head off the possibility of creating a conflict between the IBC and the Fair Housing Act.
The question of consistency with the Fair Housing Act revolves around how R-4 occupancies are treated. Our understanding of the Act is R-4 occupancies cannot be treated differently than R-3 occupancies. By deleting the exception for single exits for R-4 congregate residences, it could be construed that the code is treating the two occupancies differently. However, “congregate residences” is not a term that is used in the IBC anymore, so referring to R-4 congregate residences does not make sense. All the uses listed in Section 310.6 for an R-4 occupancy classification could be construed to be “congregate residences.” On the other hand, if the “congregate care facilities” in Section 310.6 is thought to correspond with “congregate residences,” we do not see a justification for limiting the application of this section to just congregate care facilities—all the uses listed in Section 310.6 are of similar hazard, else they would be placed in a different occupancy (most likely an I occupancy). For those reasons, we have proposed reinserting the exception for R-4’s and to allow a single exit for all R-4 occupancies, not just congregate residences (whatever those are, in the context of the IBC).
For R-3 occupancies, the intent of the original proposal was to delete redundant text that allows R-3 occupancies to have one exit—both Exceptions 2 and 6 in the 2012 IBC allows this. Apparently, the Means of Egress Committee agreed with us that Exception 2 covered Exception 6. Since this public comment changes Exception 6 (now Exception 5 in the public comment) to apply to all R-3 occupancies, the intent of the original code change is still accomplished, but in a different way. In this case, Exception 2 is covered, and can be deleted.