This week, the ICC Committee Action Hearings (CAH) kicked off, where proposed code changes for the 2024 ICC Codes are heard by the various ICC committees. In yestereday's session, the IBC General committee heard several proposed changes related to occupied roofs and the classification of high-rise buildings. In recent code cycles, there have been several key changes to occupied roof requirements, but none of these have addressed whether an occupied roof over 75' would trigger classification of a high-rise building.

As a quick reminder, the 2021 IBC currently defines a high-rise building as "A building with an occupied floor located more than 75 feet above the lowest level of fire department vehicle access."

While previous code editions have remained silent on the issue, the ICC website does have two articles addressing high rise classification due to an occupied roof.

This article, authored by ICC staff member Chris Reeves, clearly states that an occupied roof is not intended to count as a floor for the purposes of evaluating the high-rise building definition. Another article, authored by ICC staff member Kimberly Paarlberg, states "What has not yet been clarified is if an occupied roof is considered an occupied floor when determining if the building does or does not have to meet the high-rise provisions in the code..."

While the two articles above are both informal opinions from ICC staff, it appears the 2024 IBC will not address this issue directly. During today's hearing, the IBC General Committee voted in favor of proposal G15-21, which is copied below:

Revise as follows:
[BG] HIGH-RISE BUILDING. A building with an occupied floor or occupied roof located more than 75 feet (22 860 mm) above the lowest level of fire department vehicle access.

This proposed change to the definition of a high-rise building would require any building with an occupied roof above 75' to meet all of the high-rise building requirements.  Several proposals, including G12-21 and G14-21, were aimed the other way, attempting to clarify that an occupied roof would not trigger a high-rise classification. Both of these were disapproved by the committee.

When a building is classified as a high-rise, there are numerous additional requirements, including:

• Hard Body Impact requirements for stairway and hoistway walls in Risk Category III and IV buildings (IBC 403.2.3)
• Minimum SFRM bond strength of 430 psf (up to 1,000 psf for buildings higher than 420') (IBC 403.2.4)
• Voice fire alarm system (IBC 403.4.4)
• Fire command center (IBC 403.4.6)
• Smoke removal (IBC 406.4.7)
• Additional standby and emergency power requirements (403.4.8)
• Smokeproof enclosures (most commonly stair pressurization) for exit stairways (IBC 403.5.4)

Do you agree with the General Committee on this issue? Should an occupied roof above 75' trigger the classification as a high rise building? Please share your thoughts in the comments section!

If you disagree with this viewpoint, there is still time to have your opinion heard before the change is codified. The ICC code development process includes a public comment period, which will be open between May 24 and July 2. Any one is free to submit a comment on this issue or any other proposed changes moved forward by ICC committees. The ICC Public Comment Hearings (PCH) will take place between September 22-29 in Pittsburgh (also open to the public).

The 2021 IBC includes several changes that impact Group I-2 occupancies. These changes build upon updates from 2018 edition and continue with the sub-grouping of occupancies into either Condition 1 or 2 that started in the 2015 edition. As a quick reminder, IBC 308.3 defines these as:

Group I-2, Condition 1: "facilities that provide nursing and medical care but do not provide emergency care, surgery, obstetrics or in-patient stabilization units for psychiatric or detoxification, including but not limited to nursing homes and foster care facilities."

Group I-2, Condition 2: "facilities that provide nursing and medical care and could provide emergency care, surgery, obstetrics or in-patient stabilization units for psychiatric or detoxification, including but not limited to hospitals."

The 2021 IBC provides two changes related to corridors doors in Group I-2 occupancies.

First, Section 407.3.1.1 has been added for corridor doors that are not required to have a fire protection rating. Generally, Group I-2 corridor walls are not required to have a fire-resistance rating unless they are part of an enclosure for an exit or vertical opening, or if they are separating an incidental use room that requires a rating per IBC 509.4.

This new section now addresses the following:

• Solid doors, which are now specifically required to have close fitting operational tolerances, head and jamb stops
• Dutch-style doors, which are now specifically allow, but must have the following features:
  • An astragal, rabbit or bevel at the meeting edge of the upper and lower sections
  • Latching hardware on both the upper and lower sections
  • Hardware that connects the upper and lower sections, allowing them to function as a single leaf
• Makeup air: when used to provide makeup air for exhaust systems (per Section 1020.6 Exception 1), doors are now specifically permitted to have either louvers OR up a 2/3" bottom gap

​Second, Section 407.6.1 has been added for automatic-closing doors on hold-opens. Previously, these doors were only required to close upon actuation of a smoke detector or loss of power to the hold-open or smoke detector. Now, these doors must also close upon activation of the fire alarm system or sprinkler system.

Section 407.4.4.3 has been revised and no longer considers the number of doors or care suites in the path of exit access. Previously, this code section limited exit access to not require passage through more than three doors before reaching the corridor. Now, the code does not provide a maximum number of doors and simply limits care suites to no more than 100' of travel to reach a corridor. When a care suite requires two exit access doors, the second exit access door must lead directly to a corridor, exit or adjacent care suite.

The 2021 IBC makes an organizational change to requirements for nursing home cooking facilities, moving the requirements for the cooking appliances into a separate section. This builds upon a change in the 2018 edition, which provided specific provisions to allow cooking facilities to be open to the corridor in Group I-2, Condition 1 occupancies.

Under the 2021 IBC, these requirements are now organized as follows:

Nursing Home Cooking Facilities (407.2.6): In Group I-2, Condition 1 occupancies, spaces containing a cooking facility with a domestic cooking appliance are permitted to be open to the corridor when all of the following criteria are met:

• No more than 30 care recipients in the smoke compartment containing the cooking facility (or served by the facility)
• No more than one cooking facility per smoke compartment
• A clearly delineated corridor space is provided
• The cooking facility can not obstruct access to the exit
• The cooking appliance must comply with 407.2.7

Domestic Cooking Appliances (407.2.7): In Group I-2 occupancies, cooking appliances in domestic cooking facilities must comply with the following:

• Appliances limited to ovens, cooktops, ranges, warmers and microwaves
• Domestic cooking hood installed in accordance with IMC 505 provided over cooktops and ranges
• Cooktops and ranges protected with Section 904.14.1, which requires either a fire extinguishing system in the hood OR a burner that is listed to prevent ignition of cooking oils. While the code does not give a specific standard for the listing, any appliances listed to the new Section 60A in UL 858 would meet this criteria. In the US, electric burners sold after April 2019 are required to meet this criteria.
  • This requirement does not apply for cooktops and ranges used for care recipient training or nutritional counseling purposes
• A fuel/electrical power shutoff for the cooking equipment is provided in a staff-only area
• A timer is provided that automatically deactivates the equipment in 120 minutes or less
• A fire extinguisher is provided within 30 feet of each domestic cooking appliance

The 2021 IBC includes several changes related to Group I-2 occupancies. These changes build upon provisions enacted during past cycles and include changes to corridor doors, care suite arrangement and nursing home cooking facility requirements.